IMBA's Generic Scoping Comments

The Mountain Bike Advocate's Guide to Planning and the United States Forest Service

Disclaimer: This document contains only the framework for IMBA's scoping comments. For each forest we add and/or delete information to make the letter as pertinent to the local issues and concerns. Use this document as a preliminary lens for understand the scope of topics we address at the scoping comment stage.

Dear ___________:

The International Mountain Bicycling Association (IMBA) submits the following comments and observations to assist integrating mountain biking into the new Manti-La Sal Forest Plan. In close proximity to the mountain biking mecca of Moab, the Manti-La Sal provides miles of valuable trails for mountain bikers. By the planning team's own estimation mountain biking has become one of the most popular activities on the Forest.

IMBA is a national and international education and advocacy organization with 550 member clubs, 32,000 individual members, and more than 400 corporate partners and dealer members. IMBA creates, enhances, and preserves trail opportunities for mountain bikers worldwide.

As your team noted in the Preliminary Analysis, mountain biking was a little known or nonexistent activity when the first forest plan was written in 1986. In 2005 it is one of the primary activities. Formed in 1988, IMBA has gained much experience and knowledge in mountain bike management and we offer to share and discuss it with you.

____, the _____ Trail System, and the ____ are three examples of specific areas valuable to mountain bicycling. Because IMBA is an international organization, though, most of our comments cover principles of management and policy, rather than site-specific issues. Our affiliate clubs and state representatives can often provide further information on site-specific issues, so we recommend that you contact them. We are attaching with this letter a list of those IMBA advocacy members in ____ and we are copying this letter to them.

IMBA MOU with USDA Forest Service

IMBA in 2001 signed a second Memorandum of Understanding with the USDA Forest Service. (Our first was signed in 1994.) Section III of that document outlines responsibilities to be carried out by the Forest Service, including working with IMBA and our affiliated clubs on various projects and partnerships, making IMBA information available to the public, making USFS lands available to mountain biking, managing bicycling separately from motorized recreation, and utilizing IMBA's and its affiliates' technical expertise.

IMBA in turn is committed to provide similar services to the Forest Service. A copy of this MOU is attached.

Travel Management

In the Forest Service planning framework, travel management is the central issue for managing mountain bikes. IMBA believes the following policies should generally apply on national forest lands:

1. Bicycles should be considered a form of non-motorized travel, rather than a human-powered form of off-highway-vehicle. Bicyclists are less like motorcyclists without engines; more like hikers with wheels. The IMBA-FS MOU states that the FS will "Encourage the management of mountain bike use as distinct from motorized activities when developing agency policy, forest management plans, and travel management rules."

2. Bicycles should travel only on roads and trails and should not travel cross-country. The exception to this rule is the areas of the forest zoned "open" for cross-country motorized travel. IMBA believes that "open" travel areas should be few in number and small in area and should only exist where ecosystems and social conditions can tolerate cross-country travel.

3. The _____ Forest Plan should be based upon an initial assumption that all system trails and roads are open to bicycling, as they are to other non-motorized travel forms. This means the Forest Service should not limit bicycles to designated routes only, because that is a "closed-unless-opened" policy. (In this context, the term "designated" means use-specified, not system or official trail.)

IMBA recognizes that bicycling is not permitted in designated Wilderness areas. Special circumstances, such as or a demonstrated need for a single-use trail, may warrant a prohibition of bicycling in certain places. Likewise, in some areas of high use or sensitive habitat all recreationists should be limited to travel on designated routes only. Decisions about prohibiting bicycling should only be reached with involvement of the bicycling community, preferably in collaborative forums.

4. Pedestrians, equestrians and mountain bikers should be able to share trails in a spirit of common courtesy and accommodation. When user conflict occurs, agency managers should employ or select strategies that resolve the problem while preserving high quality experiences. There are many management options short of separating or eliminating uses - such as education, peer-patrolling, or alternating days - which can work to manage diverse uses compatibly. We are attaching and highly recommend the articles, "The Minimum Tool Rule," and "A Hierarchy of Options For Managing Trail User Conflicts," by Andy Kulla, a recreation planner with the Lolo National Forest.

Another excellent resource on user conflict and trail sharing is the US DOT document, "Conflicts on Multiple-Use Trails: Synthesis of the Literature and State of the Practice," by Roger Moore; available free from the Bicycle and Pedestrian Information Center, 877-925-5245, or on IMBA's website, www.imba.com/resources/bike_management/index.html .

Also, see our attached paper, "A Trail of One's Own?"

5. When facing a situation of over-use of trails, land managers should employ management methods that do not discriminate among trail use types. Restrictions should not apply narrowly to cyclists, equestrians or hikers, and instead should apply to all non-motorized user groups.

6. It is critical that land managers understand the importance of singletrack to bicyclists. While doubletrack and gravel roads may offer excellent experiences for many cyclists, these roads do not provide the type of recreation experience that intermediate and advanced riders seek. Adding more roads does not adequately improve mountain bicycling opportunities. When planning bicycling systems, roads should be considered primarily as links to non-motorized, singletrack trails. When evaluating the number of miles of bicycling routes proposed by various Plan alternatives, the Forest Service should present separate statistics for roads versus trails. See our attached document, "The Importance of Singletrack."

IMBA approves of roads-to-trails conversions, which can enhance environmental conditions and improve recreation experiences. But please do not limit or push bicycling only to those kinds of routes. When converting roads to trails, it's important that the road not remain open to any wide vehicle travel, including agency administrative use, because wide vehicles will prevent reestablishment of the vegetation that eventually narrows a road into a trail.

7. Where the agency faces a problem of heavy erosion or other physical problems on a trail, closure to certain non-motorized groups should not be the immediate reaction. Instead, please ask, can the trail be fixed? What is the real problem, types of use, or design? Is the trail receiving heavy equestrian travel? Often, these problems can be resolved through trail re-routes, reconstruction, or maintenance, often with volunteer trailworkers. The Subaru/IMBA Trail Care Crew has worked with hundreds of land managers across the country to design and repair sustainable mountain bike and multi-use trails.

8. Obliteration of redundant and unnecessary routes to enhance ecosystem values is acceptable, if carefully planned with public involvement. The term "redundant" is subject to interpretation; what may be redundant for transportation - the process of efficiently travelling from point A to point B - may be an important additional opportunity for recreation - in which enjoyment of the travel is more important than efficiency.

9. The Recreational Opportunity Spectrum was created in the early 1980s, prior to the significant growth in mountain biking's popularity. The agency has not provided much guidance regarding the applicability of ROS to mountain bicycling. IMBA maintains that bicycles are always appropriate within the Semi-Primitive, Non-Motorized ROS areas, and usually appropriate in Primitive areas outside of Wilderness, because bicycles travel quietly with minimal impact and are human-powered.

The Travel Planning Process

The new regulations for national forest planning emphasize a high degree of collaboration of the Forest Service with the public. IMBA believes that collaboration, if properly executed, can be an exciting, positive advance in natural resource decision-making. This process involves shared decision-making, consensus agreement, and a broad range of stakeholders. Travel management presents a good opportunity for collaboration, and collaboration is usually necessary to create broad social acceptance of a travel plan. Users' involvement greatly enhances the implementation of travel plans therefore minimizing user-created trails.

Much of the controversy surrounding travel plans, such as in the White River National Forest in Colorado, seems to have resulted from inadequate involvement by user groups throughout the planning process. IMBA hopes that the new planning regulations will greatly improve the process.

Travel management collaboration should discuss not only principles, but also site-specific issues. The group should evaluate individual trails and roads. Again, we hope you utilize the local knowledge on the attached list of IMBA Utah advocacy leaders.

The organization of collaborative forums is still a relatively new approach to forest planning. An excellent guidebook for these processes is "Beyond the Hundredth Meeting: A Field Guide to Collaborative Conservation on the West's Public Lands," by Barb Cestero. It's available for $15 from the Sonoran Institute, (520) 290-0828, or www.sonoran.org.

Lastly, your Preliminary Analysis indicates that the Travel Management Plan, as a Continuous Assessment and Planning (CAP) project, will be addressed at a later time. We agree with this decision for two reasons: a) travel planning depends on the Forest Plan prescriptions and policies, so logically the prescriptions come first, and b) the issues are so complex that it's very difficult for the public to deal with all of them at once.

The Role of Science

Wildlife and ecosystem impacts

IMBA understands that trail use by all users can cause negative impacts to natural ecosystems. We seek to provide mountain biking opportunities that are environmentally responsible. While little empirical research has been conducted about the wildlife and ecosystem impacts of mountain bicycling, there is considerable research on the effects of other trails users, and some of that can help to formulate general policies.

IMBA believes that at this time there is not enough information to compare the degree of ecological impacts caused by different non-motorized recreation forms. The relative effects on wildlife of people walking, running, horseback riding, mountain bicycling, or motorcycling on a trail are often argued, but with little science to resolve those issues.

The complexity in that debate is significant. Among the many parameters of wildlife impact are duration of impact, noise, and startling. Generally, hikers have longest duration, mountain bikers startle more, and motorcycles cause more noise, but there is little evidence to support any statements regarding the relative significance of these effects. The diversity of species affected greatly compounds the complexity.

It would be an error to single out bicycling -- or, for that matter, any other non-motorized trail users -- as especially harmful compared to other users. In areas with sensitive wildlife or vegetation conditions, all recreation, not just one type, should be prohibited or seasonally restricted. Land managers should be careful in discriminating between non-motorized uses when considering the ecological impacts of trails.

The science of conservation biology indicates that a high a density of roads -- and by inference trails -- can have deleterious effects on wildlife. This is another reason to have shared-use trails: Single-use routes create a desire among user groups for "separate but equal" treatment. When an agency fulfills that request, route densities increase.

IMBA supports the principle of giving deference to protecting biological diversity and sustaining ecosystem health, but we are concerned with the implementation of this principle. We encourage the Forest Service and other agencies to support more research on the ecological impacts of recreation.

Physical Impacts on Trails

Very few studies have compared the erosion impacts of various forms of trail use, and only one has included bicycling in such comparisons. With such limited science, decisions to prohibit trail use by one user group because of their allegedly excessive trail damage may be difficult to support. Most often, the proper management response is to reconstruct or realign the trail. If funds are lacking for such projects, the Forest Service should utilize local and regional volunteer groups (see our comments on volunteerism, below).

It is important to distinguish between damage to trails and damage to ecosystems. When erosion from a trail or road causes sedimentation into streams, that may be an ecological problem that warrants corrective action. But where the route is far from a watercourse, the damage is often merely harm to the trail itself. Published in 2004, "Trail Solutions: IMBA's Guide to Building Sweet Singletrack" is a 272 page guidebook dedicated to proper methods for building sustainable trails and promoting proper riding techniques and habits. It is available for purchase on our website.

Social Impacts

With regard to the social impacts of recreation, the science is less complicated and better developed. The Roger Moore book referenced above provides solid facts and examples and offers reasonable evidence of problems and solutions.

To date, there is no information to support the claim that the presence of bicycles on shared-use trails increases the risk to other trails users' safety. The few existing studies indicate that mountain bicyclists have an excellent safety record, requiring few rescue efforts. Safety is probably less of a concern on singletrack trails compared to roads because bicycles travel at lower speeds on singletrack.

Wilderness and Roadless Areas

Roadless Areas are often the segments of national forests most valuable to mountain bicycling. Their singletrack trails and lack of motorized vehicles provide the outdoors experience that many mountain bikers value most. In addition, like hikers, horsemen and others, mountain bikers appreciate the ecological benefits of Roadless Areas, realizing the valuable habitat they provide for wildlife and vegetation.

The CFR stipulates that the Forest Service must inventory Roadless Areas for designation as wilderness and report to Congress their findings. In-depth, site-specific discussions of every proposed Wilderness and Roadless Area should be hallmarks of the planning process.

Where appropriate, IMBA supports the protection of the natural character of all existing Roadless Areas and will support the designation of more national forest lands as Wilderness. However, in areas valuable to mountain bicycling IMBA strongly encourages the use of more diverse legislative designations. The Forest Service should recommend to Congress alternatives such as National Protection Areas, National Conservation Areas, National Recreation Areas, and National Scenic Areas. These legislative designations provide wilderness-like protection for the natural environment while allowing for a wider scope of recreational activities and have been successfully implemented in national forests across the country.

To maintain the existing condition of Roadless Areas through administrative designation, IMBA recommends the use of a Primitive Backcountry Management Prescription (PBMP). The Chattahoochee National Forest used this to protect a Roadless Area with a popular singletrack trail. The PBMP protected both the trail and a local bicycle store adjacent the area that depended on customers traveling the trail. Further, implementing a PBMP is simple relative to the lengthy process and legislative mandate required to establish a wilderness area. Much like Wilderness, though, they prohibit construction of new roads, structures, or water projects. Logging is limited to stewardship projects without the use of roads. PBMPs can keep singletrack open in the ____, preserving both recreation and the environment while bringing riders to local businesses.

IMBA believes that all-terrain-vehicles should not be allowed in Roadless Areas, because the transportation system in such areas should be limited to singletrack trails. ATVs widen singletrack into roads.

When evaluating possible new Wilderness designations, the Forest Service should be careful to not use criteria and judgements appropriate for suitability decisions in the capability determination process. We encourage the Forest Service to accurately and objectively describe the landscape and then offer the public the opportunity to provide input regarding proper designations.

Timber and Vegetation Management

Timber management should always respect trails. Any trails harmed by logging should be rerouted or replaced, during or before logging, not afterward. There should be standards - not just guidelines -- that will protect trails during timber sales and other vegetation management.

Volunteerism

In many parts of the country, mountain bikers are the most active trailwork volunteers. IMBA-affiliated clubs perform more than 200,000 hours per year of volunteer trail work. Mountain bikers are increasingly viewed by land managers as committed allies who are dedicated to environmental stewardship and improving trail opportunities for all users.

For the past eight years, IMBA has employed two traveling Trail Care Crews who assist land managers and activists in the planning, design, construction, and maintenance of trails. Our crews have visited many national forests. We also hold Trailbuilding Schools that offer training in effective trail management.

Please note that IMBA does not approve of users creating trails outside of the agency planning process. User-created trails can develop into serious management problems.

The Forest Service has often supported mountain bikers' volunteerism and we hope the mutually beneficial relationship can be prominent on the ____. To encourage this cooperation, the Forest Plan should discuss opportunities for cooperative programs and projects.

Economic Impacts of Cycling

In some locales, mountain bike tourism is the fastest growing facet of local economies. Mountain bike visitors spend money on food, lodging, outdoor equipment and more. IMBA strongly encourages the ____ to consider the direct impact that mountain bike management decisions have and will continue to have on local and regional tourism.

If IMBA can provide additional information or assistance, please contact me at , or (303) 545-9011.

Sincerely,
Gary Sprung
Senior National Policy Advisor

Attachments:
IMBA - USFS MOU of 2001
List of IMBA clubs in ____
"The Minimum Tool Rule"
"A Hierarchy of Options For Managing Trail User Conflicts"
"The Importance of Singletrack," by IMBA
"A Trail of One's Own," by IMBA

cc:
IMBA clubs in ____

Help | Site Map | Copyright



	IMBA's Generic Scoping Comments The Mountain Bike Advocate's Guide to Planning and the United States Forest Service Disclaimer: This document contains only the framework for IMBA's scoping comments. For each forest we add and/or delete information to make the letter as pertinent to the local issues and concerns. Use this document as a preliminary lens for understand the scope of topics we address at the scoping comment stage. Dear ___________: The International Mountain Bicycling Association (IMBA) submits the following comments and observations to assist integrating mountain biking into the new Manti-La Sal Forest Plan. In close proximity to the mountain biking mecca of Moab, the Manti-La Sal provides miles of valuable trails for mountain bikers. By the planning team's own estimation mountain biking has become one of the most popular activities on the Forest. IMBA is a national and international education and advocacy organization with 550 member clubs, 32,000 individual members, and more than 400 corporate partners and dealer members. IMBA creates, enhances, and preserves trail opportunities for mountain bikers worldwide. As your team noted in the Preliminary Analysis, mountain biking was a little known or nonexistent activity when the first forest plan was written in 1986. In 2005 it is one of the primary activities. Formed in 1988, IMBA has gained much experience and knowledge in mountain bike management and we offer to share and discuss it with you. ____, the _____ Trail System, and the ____ are three examples of specific areas valuable to mountain bicycling. Because IMBA is an international organization, though, most of our comments cover principles of management and policy, rather than site-specific issues. Our affiliate clubs and state representatives can often provide further information on site-specific issues, so we recommend that you contact them. We are attaching with this letter a list of those IMBA advocacy members in ____ and we are copying this letter to them. IMBA MOU with USDA Forest Service IMBA in 2001 signed a second Memorandum of Understanding with the USDA Forest Service. (Our first was signed in 1994.) Section III of that document outlines responsibilities to be carried out by the Forest Service, including working with IMBA and our affiliated clubs on various projects and partnerships, making IMBA information available to the public, making USFS lands available to mountain biking, managing bicycling separately from motorized recreation, and utilizing IMBA's and its affiliates' technical expertise. IMBA in turn is committed to provide similar services to the Forest Service. A copy of this MOU is attached. Travel Management In the Forest Service planning framework, travel management is the central issue for managing mountain bikes. IMBA believes the following policies should generally apply on national forest lands: 1. Bicycles should be considered a form of non-motorized travel, rather than a human-powered form of off-highway-vehicle. Bicyclists are less like motorcyclists without engines; more like hikers with wheels. The IMBA-FS MOU states that the FS will "Encourage the management of mountain bike use as distinct from motorized activities when developing agency policy, forest management plans, and travel management rules." 2. Bicycles should travel only on roads and trails and should not travel cross-country. The exception to this rule is the areas of the forest zoned "open" for cross-country motorized travel. IMBA believes that "open" travel areas should be few in number and small in area and should only exist where ecosystems and social conditions can tolerate cross-country travel. 3. The _____ Forest Plan should be based upon an initial assumption that all system trails and roads are open to bicycling, as they are to other non-motorized travel forms. This means the Forest Service should not limit bicycles to designated routes only, because that is a "closed-unless-opened" policy. (In this context, the term "designated" means use-specified, not system or official trail.) IMBA recognizes that bicycling is not permitted in designated Wilderness areas. Special circumstances, such as or a demonstrated need for a single-use trail, may warrant a prohibition of bicycling in certain places. Likewise, in some areas of high use or sensitive habitat all recreationists should be limited to travel on designated routes only. Decisions about prohibiting bicycling should only be reached with involvement of the bicycling community, preferably in collaborative forums. 4. Pedestrians, equestrians and mountain bikers should be able to share trails in a spirit of common courtesy and accommodation. When user conflict occurs, agency managers should employ or select strategies that resolve the problem while preserving high quality experiences. There are many management options short of separating or eliminating uses - such as education, peer-patrolling, or alternating days - which can work to manage diverse uses compatibly. We are attaching and highly recommend the articles, "The Minimum Tool Rule," and "A Hierarchy of Options For Managing Trail User Conflicts," by Andy Kulla, a recreation planner with the Lolo National Forest. Another excellent resource on user conflict and trail sharing is the US DOT document, "Conflicts on Multiple-Use Trails: Synthesis of the Literature and State of the Practice," by Roger Moore; available free from the Bicycle and Pedestrian Information Center, 877-925-5245, or on IMBA's website, www.imba.com/resources/bike_management/index.html . Also, see our attached paper, "A Trail of One's Own?" 5. When facing a situation of over-use of trails, land managers should employ management methods that do not discriminate among trail use types. Restrictions should not apply narrowly to cyclists, equestrians or hikers, and instead should apply to all non-motorized user groups. 6. It is critical that land managers understand the importance of singletrack to bicyclists. While doubletrack and gravel roads may offer excellent experiences for many cyclists, these roads do not provide the type of recreation experience that intermediate and advanced riders seek. Adding more roads does not adequately improve mountain bicycling opportunities. When planning bicycling systems, roads should be considered primarily as links to non-motorized, singletrack trails. When evaluating the number of miles of bicycling routes proposed by various Plan alternatives, the Forest Service should present separate statistics for roads versus trails. See our attached document, "The Importance of Singletrack." IMBA approves of roads-to-trails conversions, which can enhance environmental conditions and improve recreation experiences. But please do not limit or push bicycling only to those kinds of routes. When converting roads to trails, it's important that the road not remain open to any wide vehicle travel, including agency administrative use, because wide vehicles will prevent reestablishment of the vegetation that eventually narrows a road into a trail. 7. Where the agency faces a problem of heavy erosion or other physical problems on a trail, closure to certain non-motorized groups should not be the immediate reaction. Instead, please ask, can the trail be fixed? What is the real problem, types of use, or design? Is the trail receiving heavy equestrian travel? Often, these problems can be resolved through trail re-routes, reconstruction, or maintenance, often with volunteer trailworkers. The Subaru/IMBA Trail Care Crew has worked with hundreds of land managers across the country to design and repair sustainable mountain bike and multi-use trails. 8. Obliteration of redundant and unnecessary routes to enhance ecosystem values is acceptable, if carefully planned with public involvement. The term "redundant" is subject to interpretation; what may be redundant for transportation - the process of efficiently travelling from point A to point B - may be an important additional opportunity for recreation - in which enjoyment of the travel is more important than efficiency. 9. The Recreational Opportunity Spectrum was created in the early 1980s, prior to the significant growth in mountain biking's popularity. The agency has not provided much guidance regarding the applicability of ROS to mountain bicycling. IMBA maintains that bicycles are always appropriate within the Semi-Primitive, Non-Motorized ROS areas, and usually appropriate in Primitive areas outside of Wilderness, because bicycles travel quietly with minimal impact and are human-powered. The Travel Planning Process The new regulations for national forest planning emphasize a high degree of collaboration of the Forest Service with the public. IMBA believes that collaboration, if properly executed, can be an exciting, positive advance in natural resource decision-making. This process involves shared decision-making, consensus agreement, and a broad range of stakeholders. Travel management presents a good opportunity for collaboration, and collaboration is usually necessary to create broad social acceptance of a travel plan. Users' involvement greatly enhances the implementation of travel plans therefore minimizing user-created trails. Much of the controversy surrounding travel plans, such as in the White River National Forest in Colorado, seems to have resulted from inadequate involvement by user groups throughout the planning process. IMBA hopes that the new planning regulations will greatly improve the process. Travel management collaboration should discuss not only principles, but also site-specific issues. The group should evaluate individual trails and roads. Again, we hope you utilize the local knowledge on the attached list of IMBA Utah advocacy leaders. The organization of collaborative forums is still a relatively new approach to forest planning. An excellent guidebook for these processes is "Beyond the Hundredth Meeting: A Field Guide to Collaborative Conservation on the West's Public Lands," by Barb Cestero. It's available for $15 from the Sonoran Institute, (520) 290-0828, or www.sonoran.org. Lastly, your Preliminary Analysis indicates that the Travel Management Plan, as a Continuous Assessment and Planning (CAP) project, will be addressed at a later time. We agree with this decision for two reasons: a) travel planning depends on the Forest Plan prescriptions and policies, so logically the prescriptions come first, and b) the issues are so complex that it's very difficult for the public to deal with all of them at once. The Role of Science Wildlife and ecosystem impacts IMBA understands that trail use by all users can cause negative impacts to natural ecosystems. We seek to provide mountain biking opportunities that are environmentally responsible. While little empirical research has been conducted about the wildlife and ecosystem impacts of mountain bicycling, there is considerable research on the effects of other trails users, and some of that can help to formulate general policies. IMBA believes that at this time there is not enough information to compare the degree of ecological impacts caused by different non-motorized recreation forms. The relative effects on wildlife of people walking, running, horseback riding, mountain bicycling, or motorcycling on a trail are often argued, but with little science to resolve those issues. The complexity in that debate is significant. Among the many parameters of wildlife impact are duration of impact, noise, and startling. Generally, hikers have longest duration, mountain bikers startle more, and motorcycles cause more noise, but there is little evidence to support any statements regarding the relative significance of these effects. The diversity of species affected greatly compounds the complexity. It would be an error to single out bicycling -- or, for that matter, any other non-motorized trail users -- as especially harmful compared to other users. In areas with sensitive wildlife or vegetation conditions, all recreation, not just one type, should be prohibited or seasonally restricted. Land managers should be careful in discriminating between non-motorized uses when considering the ecological impacts of trails. The science of conservation biology indicates that a high a density of roads -- and by inference trails -- can have deleterious effects on wildlife. This is another reason to have shared-use trails: Single-use routes create a desire among user groups for "separate but equal" treatment. When an agency fulfills that request, route densities increase. IMBA supports the principle of giving deference to protecting biological diversity and sustaining ecosystem health, but we are concerned with the implementation of this principle. We encourage the Forest Service and other agencies to support more research on the ecological impacts of recreation. Physical Impacts on Trails Very few studies have compared the erosion impacts of various forms of trail use, and only one has included bicycling in such comparisons. With such limited science, decisions to prohibit trail use by one user group because of their allegedly excessive trail damage may be difficult to support. Most often, the proper management response is to reconstruct or realign the trail. If funds are lacking for such projects, the Forest Service should utilize local and regional volunteer groups (see our comments on volunteerism, below). It is important to distinguish between damage to trails and damage to ecosystems. When erosion from a trail or road causes sedimentation into streams, that may be an ecological problem that warrants corrective action. But where the route is far from a watercourse, the damage is often merely harm to the trail itself. Published in 2004, "Trail Solutions: IMBA's Guide to Building Sweet Singletrack" is a 272 page guidebook dedicated to proper methods for building sustainable trails and promoting proper riding techniques and habits. It is available for purchase on our website. Social Impacts With regard to the social impacts of recreation, the science is less complicated and better developed. The Roger Moore book referenced above provides solid facts and examples and offers reasonable evidence of problems and solutions. To date, there is no information to support the claim that the presence of bicycles on shared-use trails increases the risk to other trails users' safety. The few existing studies indicate that mountain bicyclists have an excellent safety record, requiring few rescue efforts. Safety is probably less of a concern on singletrack trails compared to roads because bicycles travel at lower speeds on singletrack. Wilderness and Roadless Areas Roadless Areas are often the segments of national forests most valuable to mountain bicycling. Their singletrack trails and lack of motorized vehicles provide the outdoors experience that many mountain bikers value most. In addition, like hikers, horsemen and others, mountain bikers appreciate the ecological benefits of Roadless Areas, realizing the valuable habitat they provide for wildlife and vegetation. The CFR stipulates that the Forest Service must inventory Roadless Areas for designation as wilderness and report to Congress their findings. In-depth, site-specific discussions of every proposed Wilderness and Roadless Area should be hallmarks of the planning process. Where appropriate, IMBA supports the protection of the natural character of all existing Roadless Areas and will support the designation of more national forest lands as Wilderness. However, in areas valuable to mountain bicycling IMBA strongly encourages the use of more diverse legislative designations. The Forest Service should recommend to Congress alternatives such as National Protection Areas, National Conservation Areas, National Recreation Areas, and National Scenic Areas. These legislative designations provide wilderness-like protection for the natural environment while allowing for a wider scope of recreational activities and have been successfully implemented in national forests across the country. To maintain the existing condition of Roadless Areas through administrative designation, IMBA recommends the use of a Primitive Backcountry Management Prescription (PBMP). The Chattahoochee National Forest used this to protect a Roadless Area with a popular singletrack trail. The PBMP protected both the trail and a local bicycle store adjacent the area that depended on customers traveling the trail. Further, implementing a PBMP is simple relative to the lengthy process and legislative mandate required to establish a wilderness area. Much like Wilderness, though, they prohibit construction of new roads, structures, or water projects. Logging is limited to stewardship projects without the use of roads. PBMPs can keep singletrack open in the ____, preserving both recreation and the environment while bringing riders to local businesses. IMBA believes that all-terrain-vehicles should not be allowed in Roadless Areas, because the transportation system in such areas should be limited to singletrack trails. ATVs widen singletrack into roads. When evaluating possible new Wilderness designations, the Forest Service should be careful to not use criteria and judgements appropriate for suitability decisions in the capability determination process. We encourage the Forest Service to accurately and objectively describe the landscape and then offer the public the opportunity to provide input regarding proper designations. Timber and Vegetation Management Timber management should always respect trails. Any trails harmed by logging should be rerouted or replaced, during or before logging, not afterward. There should be standards - not just guidelines -- that will protect trails during timber sales and other vegetation management. Volunteerism In many parts of the country, mountain bikers are the most active trailwork volunteers. IMBA-affiliated clubs perform more than 200,000 hours per year of volunteer trail work. Mountain bikers are increasingly viewed by land managers as committed allies who are dedicated to environmental stewardship and improving trail opportunities for all users. For the past eight years, IMBA has employed two traveling Trail Care Crews who assist land managers and activists in the planning, design, construction, and maintenance of trails. Our crews have visited many national forests. We also hold Trailbuilding Schools that offer training in effective trail management. Please note that IMBA does not approve of users creating trails outside of the agency planning process. User-created trails can develop into serious management problems. The Forest Service has often supported mountain bikers' volunteerism and we hope the mutually beneficial relationship can be prominent on the ____. To encourage this cooperation, the Forest Plan should discuss opportunities for cooperative programs and projects. Economic Impacts of Cycling In some locales, mountain bike tourism is the fastest growing facet of local economies. Mountain bike visitors spend money on food, lodging, outdoor equipment and more. IMBA strongly encourages the ____ to consider the direct impact that mountain bike management decisions have and will continue to have on local and regional tourism. If IMBA can provide additional information or assistance, please contact me at , or (303) 545-9011. Sincerely, Gary Sprung Senior National Policy Advisor Attachments: IMBA - USFS MOU of 2001 List of IMBA clubs in ____ "The Minimum Tool Rule" "A Hierarchy of Options For Managing Trail User Conflicts" "The Importance of Singletrack," by IMBA "A Trail of One's Own," by IMBA cc: IMBA clubs in ____


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