The proponents of the designation change claim that the Delaware Water Gap National Recreation Area receives 4.5 million visitors per year. This figure breaks down to 12,328 visitors PER DAY, divided evenly over the entire 365 days of the year.
In this letter, Mr Robert Flatt, a Retired Certified Program Analyst for the US Army, provides an in-depth analysis of the volume of through traffic to the park.
There is a version for download at the bottom of this document.
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To the NO National Park
4/29/2022
First my apologies to the Park Service. This was created due to the Sierra Club wanting to change it to a National Park for which they had no part. If the Sierra Club had not wanted to make this change this letter would never have been created.
I am addressing my concerns of the impact of a National Park and traffic volume numbers and the collection of those numbers. I am retired from the United States Army where I served as a GS13 Certified Program Analyst. My duties included the teaching of the SAP Financial System and the teaching of how to use Work Break Down System to complete workflow to Engineers and Scientists in their jobs. I carry a green belt in Financial Analytical Studies. I served as lead Analyst to several major directorates and as Chief Financial Officer in my last job. A major part of my job was to certify funds for the propriety and ethics of funds issued.
There has been a lot of communications to various towns and counties by the Sierra Club to change the designation of the Delaware Water Gap National Recreation Area to a that of a National Park. They also have been changing their reports to reflect a favorable view after hearing what is coming out of The No National Park grass roots movement.
I have received some information thru charts showing volume of traffic thru the park. At current there are only two major roads that traverse the park and they are Route 209 in PA and Route 94 in NJ.
In PA the Route 2001 that follows above the park on the PA side; from the Dingmans light on
739 heading South, the Road is very narrow and very winding which is not built for major traffic. The northern section (between Milford and the Dingmans light) has been worked on for many years and is far from completion and also not built for major traffic.
In NJ the access thru the park is through County and town roads leading down to the Delaware River. Old Mine Road follows the river on the NJ side and has a few Historical spots and old Cemeteries. Walpack Village (old town with a few buildings left). There is also Millbrook Village with houses and buildings being maintained by volunteers who do time recreations during the warm months and the Watergate picnic area. There are also Peters Valley Artist Community and the Van Campen Inn.
Going down Route 209 from Milford PA to Bushkill there is limited access to the river. There is Milford Beach for which a fee is charged. A campground and a group campsite. There is the hiking trail from Milford to Bushkill with several pull offs to access the trail. There are a few boat launch areas for boat access. There is also PEEC which is an educational center.
I may have left off a few areas but that is the major drift of the park.
A major issue is the reporting of the number of Tourists that come through the park. This is a complex issue as it goes back to the creation of Tocks Island, the moving out of the residents by eminent domain and the Dam not being built due to a Fault line near the dam site. Route 209 on the PA side was to be flooded as was old mine road on the Jersey side. At this point there was no historic value to the area as they deemed it fit to flood the land and roads.
After this was done, it was deemed that it would be the Delaware Water Gap National Recreation Area. This is a very narrow strip of land that follows the river with many developed communities on each side that are self-containing for swimming, outdoor activities and social needs of their communities. They basically only use the park to get from point A to point B and don’t use the park lands except for Route 209 as a commuter route for shopping and work.
They only need for Rt 209 or 739 is access to and from their home. Route 209 was in use long before Tocks Island and was the major throughfare between Stroudsburg and Milford. It was a 55 MPH road at that time. The park came in and reduced the speed to 45 and played eminent domain on the road. This road has been a lot of contention between the park and the local residents for many years and is still a long-standing sore spot. People that live in this area are also landlocked from access to NJ or southern PA. The only access points are Milford Bridge, Dingmans Bridge or Eastern PA (Marshall Creek).
The federal government reports that around 4 million visitors go through the park annually. The problem that I see is their number counting. There is limited access between Pennsylvania and New Jersey. Route 206 comes across the river and leads into Milford Pa. Route 560 comes into Dingmans Bridge to Route 739 in Pa. From what I understand they are counting everyone as visitors even though daily they are traveling to their homes with no other way to get there. During the year they are also forced to use Route 209 when the Dingmans Bridge is closed for a week for yearly maintenance.
The following information was quickly gathered and is missing homes and communities that are not included in the communities listed below:
Number of houses within each community, not number of individuals in each house
Birchwood 877 Pocono Mountain 739
Wild Acres 2982 Lake Forest 525
Marcell Lake Estate 373 Fawn Lake 543
Conasaugh Lake 756 Sunrise 508
Gold Key 608
Total houses in identified communities 6911
Note: this does not include Lake Adventure, Hemlock Farms and more
If I assume that 50% are working with one car per house going over the Dingmans Bridge that would mean 3,455 one way across the bridge Monday through Friday or a total 6,911 trips daily across Dingmans Bridge 34,555 trips weekly and 1,727,750 crossings yearly. Based on 50 weeks working. This does not include the influx of travelers to place of residence in spring and fall visits or summer prolonged visits. This also does not count for local traffic during the day heading for Milford or Stroudsburg. According to the New Jersey Monthly on Feb 11, 2009 Dingmans Bridge said that there were 1.85 million cars that went over the bridge in a year. According to WIKIPEDIA it states that the Dingmans Bridge is important to local commuters to reach destinations in NJ and NY City. The location caters well to the commuter lifestyle of many area residents of Delaware and Dingmans Township and other surrounding areas.
The New Jersey Monthly stated that Milford Montague Bridge had about 3 million vehicles in 2007. According to the Delaware Joint River Toll Commission in 2019 there were 7,500 cars a day going in both directions. This would be a total of 2,667,600 vehicles going in both directions yearly. There is no indication as to the direction that they went once in PA. As a commuter it would be at least 90% of the vehicles that went through Milford and onto I 84 or to Matamoros and points east. Or headed south onto 206 South in New Jersey. Please note that the Park has stated in their reports that they have not had a counter on Rt 209 counting cars in either direction through the park. Another note is that the flow of vehicles over the river shows vehicles in both directions and the number heading north would be about 50% or 1,333,800 in each direction with about 90% or more of the vehicles heading into Milford. Please note that I am counting vehicles and they are counting people.
These commuters are not interest in the park as they are on the way to work and back. To count them is in my position fraud, waste and abuse to get funding too which it is not entitled too. I understand that all parks count numbers. A lot of the big ones are honest in that they have no one living in the control count area and have gate entry as it does not interfere with the flow of traffic in their daily commute.
I strongly suggest that an outside contractor, as designated by Leadership in Washington and not local to look into the number counting process for all parks. At this location I would question who comes in on Rt 739 to the light and to see what direction they head; straight, left or right. This also applies at the Milford Bridge and the biggest percentage will head toward town and not down thru the park and they’re only in the park for ¼ mile. Down in Bushkill those that live in Ranch Lands have no alternative but to go through the park and should not be counted. As stated previously all of the residents are land locked and the park restricts their ability to get to work or get to their homes and they must travel through the park.
Another issue with Rt 209 is the repair of it. Funds have been appropriated through Washington in the Recovery Act and issued to the park for repair of Route 209. These funds to repair the road did not come from the parks funds but came from the Recovery Act, an appropriation from congress to repair the infrastructure of this country. These are funds that the taxpayers are paying for not the park service. They need to remember that when again you try to put a charge on a public thruway from Milford to Stroudsburg.
We need to keep in mind what surrounds the river. On the New Jersey Side is High Point State Park, Stokes State Forest and Worthington State Park. On the Pennsylvania Side is mostly the park and public land. There are a lot of state hunting lands once you get a few miles into Pennsylvania.
The major issue that is going on is that the hurt from Tocks Island is not gone. I remember as a young man growing up in Sussex County the hurt that was produced by Tocks Island and how the people lost everything. What their dreams were for where they lived, the community that they loved and cherished and either moving their houses not far away or seeing it destroyed. I’ve gone out to photograph the nature in the area and I run into people still going back to where their house was and see the grief in their eyes. To now bring this up to make it a national park is more than hurting in that it will create another generation of families and their children to live the grief at the hands of people that want it to change and who do not have to live with that hurt.
Robert Flatt
Retired Certified Program Analyst GS13