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Wild turkey in hardwood forest

Open for comment · closes December 2

Approve 16 miles of new trails across a Civil War battlefield without completing historic resource review

Pictured: Wild turkey in hardwood forestMore Than Just Parks
What
The plan would add approximately 16.3 miles of new trails and cost $5.8 million to build, but the agency admits Section 106 review of effects on National Register properties will not happen until after the approval decision is signed.
Where
Gettysburg National Military Park, Eisenhower National Historic Site, PA
By when
Comments to National Park Service by December 2, 2026.Date from National Park Service PEPC project page ↗, read November 3, 2026.

What to ask forAll 9 points →

The agency should complete at minimum a programmatic agreement with the SHPO and Advisory Council on Historic Preservation before signing the FONSI, not after.

Where these four lines come from
Now make it count29 days left

Two ways to be heard on this, and both count. Comment for the legal record, then call the members who answer to you.

Comment now

What to say

Make these points, in your own words

  • The EA defers all Section 106 consultation to future project-level reviews, yet the document itself acknowledges that proposed trails traverse areas of high archeological potential and that portions of several proposed trails and trailheads are within known archeological sites registered in the NPS Cultural Resources Inventory System.Read the point +

    Approving a programmatic plan without completing Section 106 assessment of effects first, then promising consultation later, does not satisfy the requirement that NEPA and Section 106 run concurrently. Section 3.2.3 states that 'further Section 106 consultation, including Section 106 assessment of effects to historic properties, would take place once the Trails Plan has been completed and the Finding of No Significant Impact (FONSI) has been signed.' That sequence is backwards: the FONSI cannot legally precede the Section 106 determination of effect on National Register properties. The agency should complete at minimum a programmatic agreement with the SHPO and Advisory Council on Historic Preservation before signing the FONSI, not after.

  • The EA dismisses wildlife from detailed analysis by asserting that 'local wildlife is habituated to human use of the landscape,' yet Section 3.5.1 documents that the least shrew, a Pennsylvania state-endangered species, may have one of its most extensive populations within Eisenhower NHS, and that a new least shrew survey is currently underway and not yet complete.Read the point +

    The agency cannot make a reasoned significance determination about a species whose population data it admittedly does not yet have. Section 3.5.3 concedes that the Camp Colt Trail may intersect least shrew habitat but defers avoidance measures to future design. The agency should wait for the ongoing least shrew survey to be completed and incorporate its findings before approving the plan, or at minimum prepare a biological assessment for the least shrew as a condition of FONSI.

  • The EA dismisses water resources and water quality from detailed analysis on the grounds that crossings would span bank to bank and that mitigation would be applied, yet Section 3.3.3 estimates approximately 0.36 acre of potential wetland disturbance from proposed trails alone, plus an additional 0.02 to 0.03 acres from the Willoughby Run pedestrian bridge.Read the point +

    The document also lists the Pennsylvania Fish and Boat Commission's concern about freshwater isopods and amphipods in Section 1.4.2 but dismisses that topic too, promising only to provide the Commission an opportunity to review erosion and sediment control plans. Neither dismissal is accompanied by any quantitative analysis of water quality effects. The agency should restore water resources and water quality as a retained impact topic and provide quantitative analysis of sedimentation and turbidity effects on the named stream segments.

  • The EA concludes that the Proposed Action would have 'No Effect' on the monarch butterfly and the green floater clam without providing any site-specific habitat analysis for either species.Read the point +

    For the green floater, a proposed threatened clam dependent on clean water and stream-bank integrity, the document simultaneously dismisses water quality from detailed analysis and dismisses the species from any effect. Section 3.5.3 states only that 'the NPS has determined that due to the nature of the work and that no critical habitat is found in the area, the Proposed Action would have No Effect on the monarch butterfly or the green floater.' Absence of designated critical habitat is not the same as absence of suitable habitat or absence of effect. The agency should provide the supporting species-specific habitat evaluation that underlies each No Effect determination, or elevate the determinations to Not Likely to Adversely Affect with formal USFWS concurrence.

  • The EA identifies grasslands as 'one of the most endangered ecosystems globally' and notes that the parks are designated Important Bird Areas, yet dismisses wildlife from detailed analysis and provides no quantitative analysis of how 13.3 miles of new mowed pedestrian trails cutting through grassland and pastoral habitats would affect grassland-dependent bird species.Read the point +

    Section 3.4.1 states that 'grassland birds require large contiguous patches of grassland habitat for successful breeding' and that fragmentation causes a decrease in breeding birds, but Section 3.4.3 does not apply this information to the proposed mowing corridors. The agency should analyze the fragmentation footprint of proposed mowed trails on Important Bird Area grassland patches and either retain grassland birds as an impact topic or explain quantitatively why fragmentation effects are non-significant.

Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.

Every point is checked against the agency’s own document ↗. 9 findings verified against the text, word for word.