Scoping comments for Manti-La Sal National Forest

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

8/9/05
Gary Sprung and Drew Vankat
International Mountain Bicycling Association
207 Canyon Blvd, Suite 301
Boulder, CO 80302

Linda Crawley
Forest Plan Revision Team
Manti-La Sal National Forest
599 W Price River Dr
Price, UT 84501

Dear Ms. Crawley:

Thank you for your interest in comments on bicycling and the Manti-La Sal Forest Plan Revision. I hope you can consider this letter IMBA's formal scoping comments. 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.

In close proximity to the mountain biking mecca of Moab, the Manti-La Sal National Forest 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.

As your team noted in the Preliminary Analysis, mountain biking was a little known 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.

Because IMBA is an international organization, 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 Utah and we are copying this letter to them. We do know that Kokopelli's Trail, the Castle Valley Ridge Trail System, and the Abajo Mountains are three examples of specific areas valuable to mountain bicycling.

Economic Impacts of Cycling

In some locales, mountain bike tourism is the fastest growing facet of local economies. Perhaps nowhere is this as true as in the mountain biking destination of Moab. But excessively hot temperatures decrease the number of mountain biking visits to Moab in the middle of summer. To take respite, many mountain bike visitors ride in the higher elevations of the Manti-La Sal. Mountain biking is therefore an important summer activity that protects the year-round economy of local towns. Mountain bike visitors spend money on food, lodging, outdoor equipment and more. IMBA strongly encourages the Manti-La Sal to consider the direct impact that mountain bike management decisions have and will continue to have on local and regional tourism.

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 - 10 principles

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. The essence of bicycling - 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."

Bicycles are also not "mechanical." This may seem an odd statement, but it has great importance to mountain biking.

Mechanical means "of or like a machine," and "machine" has two distinct definitions. The first says that a machine is a motorized device and it is in this sense that bicycles are not mechanical. The second definition is very broad: essentially, "any contraption with fixed and moving parts for performing some work." Under this definition, not only are bicycles mechanical, but so are rowboats, climbing ascenders, and skis. To explain further, in basic high school physics students have been taught that a lever is the most fundamental machine. A rowboat employs oars that are definitely levers. Skis have complex bindings and built-in camber, plus they support us above the snow, giving us a mechanical advantage. Ascenders let us climb ropes that we otherwise could not grip. Those three devices are mechanical but are allowed in Wilderness. One can even extend the definition to shoes and saddles. So it is clear to IMBA that Congress was thinking of motorized devices when it wrote a prohibition of "mechanical transport" in the 1964 Wilderness Act. Please note that the official definition of mechanized in the Code of Federal Regulations says such transport "is propelled by a non-living power source."

Bicycling in Wilderness is beyond the scope of the Forest Plan and we are not asking the agency to address that issue. Rather, we just ask you to not use the term "mechanical" or "mechanized" when speaking about and managing bicycling in non-Wilderness places. Land managers should employ two clear categories: motorized and non-motorized (which is better expressed as "muscle-powered."). Please do not invent a third category that separates bicycling from its muscle-powered brethren. This would defeat the Agency's goal of bringing people together.

2. Cross-country travel and open areas - 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. Trails open unless closed - The Manti-La Sal Forest Plan should be based upon an initial assumption that all 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.)

As noted below, science indicates that the natural resource impacts of bicycling are roughly the same as hiking. That being the case, why should bicycles be not travel cross-country? The question is perhaps asked better in reverse: What is the justification for allowing hikers to go anywhere?

In any case, very few bicyclists want to ride off of trails. But we do wish to explore game trails, canal paths, abandoned railroad grades, and ancient mining roads. Since the Forest Service allows hiking on any linear path, it should do the same for bicycling. Cross-country bicycle riding is unlikely to be a significant problem.

4. Reasons to close trails - 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. But you should apply such rules evenly to all user groups unless science demonstrates the problem is clearly related to one type of user and not the others. Decisions about prohibiting bicycling should only be reached with involvement of the bicycling community, preferably in collaborative forums.

5. Trail sharing and user conflict - 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?"

6. Too many people - 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.

7. The importance of singletrack - 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.

8. Achieving trail sustainability - 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.

9. Redundant routes - 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.

10. Recreational Opportunity Spectrum - 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 guidance regarding the applicability of ROS to mountain bicycling. IMBA maintains that bicycles are appropriate within Semi-Primitive, Non-Motorized ROS areas and 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.

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. IMBA has reviewed the available science and has found that it points to a conclusion that bicycling and hiking have roughly the same degree of impacts on wildlife. Please see our attached paper, "Natural Resource Impacts of Mountain Bicycling."

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.

So 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.

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 two have included bicycling in such comparisons. With such limited science, decisions to prohibit bicycle trail use because of its allegedly excessive trail damage are not supportable. 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). IMBA offers considerable information and training regarding solutions to trail problems. Our book "Trail Solutions: IMBA's Guide to Building Sweet Singletrack," published in 2004, 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.

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.

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.

Roadless Areas and Wilderness

Roadless Areas are often the segments of national forests most valuable to mountain bicycling. Their singletrack trails and lack of roads and development provide the outdoors experience that many mountain bikers value most. Mountain bikers also appreciate the ecological benefits of Roadless Areas, realizing the valuable habitat they provide for wildlife and vegetation.

IMBA supports the protection of the natural character of all existing Roadless Areas. The Forest Plan should stipulate or plan to prohibit the building of new roads into roadless areas.

To maintain the existing condition of Roadless Areas, IMBA recommends the use of a Remote Backcountry management prescription similar to the approach taken by the Forest Service Region 8 and the Chattahoochee National Forest (attached). The Chattahoochee's final plan used this prescription to protect a Roadless Area that has a popular singletrack trail. The prescription protected both the land and a local bicycle store adjacent the area that depended on customers traveling the trail. 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. Remote Backcountry can keep singletrack open in the Manti-La Sal, preserving both recreation and the environment while bringing riders to local businesses. This prescription is also commonly used in the Dixie and Fishlake National Forests, though they should be more affirmative of the prohibition of new road building.

When studying roadless areas for potential recommendations to Congress, the Forest Plan should take a broader approach than just considering Wilderness. The Plan should make recommendations for 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 protect the natural environment while allowing for a wider scope of recreational activities and more management flexibility. Congress has designated these kinds of areas for public lands across the country. Please see IMBA's legislative proposals at http://www.imba.com/resources/wilderness.

IMBA believes that all-terrain-vehicles (ATVs) do not belong on singletrack trails because they widen trails into roads. Thus, ATVs do not belong in Roadless Areas because the transportation system in such places is or should be limited to singletrack trails. Please note that this comment does not speak to the acceptability of motorcycles, which are narrow enough for singletrack trails. Motorcycling is a site-specific issue and beyond the scope of this letter.

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 hold Trailbuilding Schools that offer training in effective trail management. We also offer a fee-based consulting service called "Trail Solutions."

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 Manti-La Sal. To encourage this cooperation, the Forest Plan should discuss opportunities for cooperative programs and projects.

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

Sincerely,

Gary Sprung
Senior National Policy Advisor

Drew Vankat
Public Lands Intern

Attachments:
IMBA - USFS MOU of 2001
List of IMBA clubs in Utah
"Natural Resource Impacts of Mountain Biking"
"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
"Remote Backcountry Management Prescription"

cc: IMBA representatives and clubs in Utah