DEIS and Draft Plan comments for Wayne National Forest
The Mountain Bike Advocate's Guide to Planning and the United States Forest Service
July 1, 2005
Gary Sprung and Drew Vankat
International Mountain Bicycling Association
207 Canyon Blvd, Suite 301
Boulder, CO 80302
Wayne National Forest
Forest Plan Revision Team
13700 U.S. Highway 33
Nelsonville, OH 45764-9880
Dear Forest Service:
The International Mountain Bicycling Association (IMBA) submits the following comments on the Wayne National Forest Draft Environmental Impact Statement and Draft Land and Resource Management Plan.
IMBA is a national education and advocacy organization with 550 affiliate 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 coast to coast.
Based on a recent Outdoor Industry Association study, 45 million Americans rode bicycles on narrow trails ("singletrack") an average of 14 times in 2003, for a total of over 590,000,000 outings. This makes mountain biking the second largest trail user group in the country. We appreciate the agency's willingness to cooperate with our organization.
IMBA recognizes and appreciates that the Forest Service has identified bicycling as an important activity in the Wayne National Forest. We particularly appreciate that the DEIS and Draft Land and Resource Management Plan note the public's requests for increased mountain biking opportunities, plan for increased mountain bike trails and refer to bicycling as "mountain biking," rather than "mechanized" travel. (We disapprove of the tendency to call bicycling "mechanized," because the term's definition is unclear in the Code of Federal Regulations[1] [#_ftn1] ). However, we do not support the basic trails rules for bicycling proposed in the draft.
COMMENT ON PROPOSED RULES AND POLICIES
The Draft Plan for the Wayne National Forest includes proposed forest-wide management direction rules that will regulate mountain biking (sections 2-36-38, "Forest-Wide Direction: Dispersed Recreation, Trails").
IMBA partially supports the proposed rules, but suggests improvements. Our comments derive from the following interests:
- Protecting natural resources
- Providing adequate recreational opportunities for non-motorized trail users
- Applying rules equitably for user groups with comparable impacts
- Maintaining district rangers' ability to adaptively manage resources case-by-case based on actual conditions
Proposed Rule:
The Draft Plan, section 2-36, under "Dispersed Recreation," states:
SFW-REC-15: Prohibit cross-country travel by ATVs, OHMs, mountain bikes, horses, or other pack stock. These uses shall be restricted to designated trails only.
IMBA accepts the restriction to cross-country travel. Bicyclists want to ride on trails, not cross-country.
But, IMBA requests that the agency change the proposed rule regarding designated trails[2] [#_ftn2] because it is unfairly applied to bicyclists, unnecessarily restrictive, difficult for trail users to understand, difficult to enforce without significant additional resources, and does not adequately address the related issue of unplanned new routes that the Forest Service is probably concerned about.
This proposed rule as drafted is unfair and discriminatory to bicycling because it applies to bicyclists and not also to hikers. The body of empirical science that has investigated mountain biking has strongly indicated that bicycling causes about the same amount of damage to trails, about the same amount of vegetative trampling, and about the same amount of wildlife impacts as hiking. [3] [#_ftn3] Horses probably do more damage to trails than bicycling. Hikers are more numerous than cyclists and have a strong tendency to travel cross-country. If bicycling and hiking have the same natural resource impacts, and the Forest Service allows hikers to travel on all trails in the forest, then why is the agency proposing significant restrictions to bicycling?
Another way of putting that question is, "Since pedestrian travel often results in the creation of unplanned, unauthorized new routes, why is the Forest Service not restricting hikers from traveling off official, system trails?" This is especially pertinent given that studies indicate the disturbance to wildlife associated with hiking trails may be more than that from use of roads or motorized trails (White Mountains National Forest Draft EIS: Vaske et al., 1983; Jordan, 2000). Hiking causes impacts to trails, vegetation, and wildlife, yet it is almost completely unregulated by the USDA Forest Service and other agencies.
The process of human travel creating new, unauthorized, unplanned trails must end. There are now so many people enjoying outdoor recreation that trail proliferation is becoming an important management issue. But the proposed rule addresses only a portion of the people who are causing the problem and addresses it indirectly. It would be difficult to enforce.
Some mountain bikers, like many hikers and equestrians, have an adventurous spirit and enjoy traveling "off the beaten path." This is a natural instinct for humans and the Forest Service should recognize it as a good value. For this reason, abandoned roads and other travel ways are an important part of the recreational experience.
The proposed rule does not directly address the problem of unauthorized trails, nor does it provide adequate resources to enforce rules, existing or proposed, relating to unauthorized trails. The most effective way to address the issue of unplanned routes is the existing national regulation prohibiting unauthorized trail building.[4] [#_ftn4] Additionally, IMBA can assist with trail user outreach and education.
IMBA proposes the following substitute for the proposed rule:
Except for areas and routes closed to public travel by official order, trails and non-system routes will be open unless closed to mountain bike use.
Another potential formulation:
District Rangers may close areas and routes to public travel to protect significant biological or cultural resources.
Proposed Rule:
The Draft Plan, section 2-37, under "Trails," states:
SFW-REC-16: ATV/OHM, mountain bike, and horse trails are open (unless posted closed) for riding from April 15th through December 15th. Close these trails (except for foot travel) during the winter period (December 16th through April 14th) to minimize environmental impacts and maintenance costs.
IMBA and mountain bikers support trail restrictions uniformly applied to all users based on ecological concerns. However, this proposed rule incorrectly implies that hiking causes the least amount of environmental damage. As discussed above, this is inconsistent with the best available science. A fairer and more environmentally correct rule would restrict all trail users during times when trails are most sensitive to damage.
Proposed Rule:
The Draft Plan, section 2-38, under "Trails," states:
SFW-REC-26: Prohibit horses on designated hiking trails. Allow mountain bikes on hiking trails only where designated and signed.
This rule unfairly restricts mountain bike users and implies that the activity of mountain biking is not in harmony with natural communities. Mountain bikers have a strong interest in healthy natural ecosystems and respect the environment. In addition, as mentioned above, empirical science strongly suggests that environmental impacts of mountain biking are similar to that of hiking. Despite these concerns, IMBA might not object to designating certain trails as hiking-only if the reason for such designation would be potential user conflict, as opposed to incompatibility with the natural resources. However, please be aware that trails can be designed to force cyclists to go slow. Also, there are examples of interpretive trails for bicyclists. IMBA's proposal is an open-unless-closed policy as opposed to the closed-unless-open proposal in SFW-REC-26. So we recommend that the rule be reformulated as a guideline:
Hiking trails are open to mountain bikes unless closed. User conflict considerations may cause closure of trails to some types of use, but preference will be given to shared-use trails.
Proposed Policy:
The DEIS and Draft Plan indicate that mountain bicyclists will continue to be charged a fee for trail access.
IMBA strongly disagrees with the policy to charge mountain bike users a fee for trail use. If, as science indicates, mountain biking and hiking have similar effects on the natural environment, why are mountain bikers subjected to a discriminatory trail fee? A fair policy would charge both activities the same amount to help cover trail maintenance costs or make the National Forest experience free of charge for both.
The DEIS states that in 2003, 46 mountain bike permits were sold (section 3-173). Combined with the high demand for increased mountain biking opportunities, this low number is evidence that discriminatory fees are keeping prospective mountain bikers away from Wayne National Forest.
However, it also appears that Congress has banned such fees in the 2004 Federal Lands Enhancement Act:
(1) PROHIBITION ON FEES FOR CERTAIN ACTIVITIES OR SERVICES- The Secretary shall not charge any standard amenity recreation fee or expanded amenity recreation fee for Federal recreational lands and waters administered by the Bureau of Land Management, the Forest Service, or the Bureau of Reclamation under this Act for any of the following:
(B) For general access unless specifically authorized under this section.
(D) For persons who are driving through, walking through, boating through, horseback riding through, or hiking through Federal recreational lands and waters without using the facilities and services.
(D)(1)(b)(d) do not mention bicycling, but it is clear that Congress intended to not tax non-motorized uses. Already national forests are responding to this mandate: all four national forests in Southern California are eliminating fees for most day-uses. IMBA believes the Wayne's current policy is not consistent with the Recreation Enhancement Act and should be changed so that mountain biking is not taxed.
So the Plan should drop this proposal for a fee and make trails generally open to bicycling.
TRAILS COMPATIBLE WITH MOUNTAIN BIKING
IMBA applauds the inclusion of 15-30 miles of new mountain bike trails in all of the DEIS alternatives. This will help greatly to reduce one of the most important hindrances to enjoyable mountain biking in the Wayne: existing trails open to mountain bikes are often shared with OHVs. While wider routes can sometimes provide positive terrain for beginning mountain bikers or families, OHV routes suitable for these riders are difficult to find in the Wayne. OHV routes tend to have deeper ruts and loose rocks, creating trail conditions incompatible with enjoyable mountain biking. Members of the Athens Bicycle Club have recorded OHV routes in the Wayne with slopes of up to 55 percent. Even advanced mountain bikers can handle only short stretches with grades approaching half of this level. Families, beginners and even intermediate riders require trails with gentle slopes and generally smoother surfaces. In addition to the poor riding conditions OHV routes offer, mountain bikers, like other non-motorized users, greatly prefer recreation settings free of the speed, noise and exhaust that accompany OHVs.
Once comfortable with the basics of mountain biking, riders vastly prefer a singletrack experience, currently offered in very limited supply on the Wayne. Narrow trails that are properly designed, constructed and maintained can accommodate hikers, mountain bikers, and equestrians.
For cyclists, narrow trails are a favorite experience. Most other trail users similarly value this limited resource, and when they compete for it, conflict sometimes arises. Making peace on the trails requires that all trail users and land managers understand the importance and meaning of singletrack. Land managers and trails activists need to know that mountain bikers desire singletrack for very similar reasons as hikers. Every cyclist who progresses beyond a beginner level eventually seeks to ride on trails.
Since the singletrack resource is highly valued for similar or identical reasons by many kinds of trail users, the Wayne should try to offer ample singletrack experiences. The policy for managing singletrack should start with shared-use. Shared-use builds the family of trail users, causing a need for cooperation. Shared-use reduces the pressure to build additional trails for each type of user, thereby reducing the ecological impacts of trails. This means that the Wayne should start with the assumption that a singletrack can and will be used by a wide variety of trail users. There may be legitimate reasons to close some singletrack to user classes (for example, Wilderness), but managers should begin with the presumption that these routes are open to every narrow travel method. OHV routes are not enough.
IMBA has recommendations for opening singletrack in the Wayne in our section on "Travel Management Planning." We support several specific mountain bike trail openings that will greatly enhance mountain biking on the Wayne while minimizing environmental degradation and user conflict.
BUILDING RELATIONSHIPS AND MAKING PLANS
Mountain bicyclists and the USDA Forest Service are benefiting from increasingly positive and productive relationships on national forests nationwide. The Forest Service has generally regarded bicycling and all outdoor recreation as good, but it also sees the need for limits and is addressing that through both regulations and cooperative projects.
IMBA provides highly trained volunteers and crew leaders to assist the Forest Service with needs stemming from the expansion of mountain biking and other recreational trail use. Through cooperation, bicyclists and the Forest Service can address the real social and ecological problems that are arising through the growth of mountain biking and expansion of all outdoor recreation. There is much potential to expand volunteer trailwork and volunteer ecosystem restoration projects.
IMBA worries that the approach to bicycling expressed in the proposed rules of the Draft LRMP and policies in the DEIS could lead to a general deterioration in land manager-bicyclist relationships. A closed-unless-opened policy can work well only if combined with diligent travel management planning, public outreach, trail user education, and reasonable regulation and enforcement. Without those elements, a closed-unless-opened policy creates confusion, user conflict, and often backlash from the public. These feelings result in unauthorized trail construction, environmental impacts, and erosion of the public-private partnership. That can lead to a decrease in bicycle tourism in the communities surrounding the forest, which would affect the communities' relationships with the Forest Service.
We believe that an area-by-area, site-specific approach will generate the public support that is necessary for effective recreation management.
TRAVEL MANAGEMENT PLANNING
We ask the Forest Service to initiate a series of travel management planning processes for particular sections of the National Forest.
In each planning process, the agency can, with ongoing public participation, thoroughly inventory all travel routes and make decisions about each path. Some should be obliterated, some should be shared-use trails and others may occasionally be appropriate for a single type of user. The community of people involved can probably come close to consensus on a reasonable system of trails and rules for each place.
But a needed key to this process is recognition that bicycling is not especially or particularly damaging to natural resources compared to other users. If there is a need to restrict bicycling more than hiking it stems only from social issues. Some hikers wish to have hiking-only areas, and that may be appropriate in certain instances, but many national forests and other areas have implemented successful mountain bike or shared-use trail systems with great success.
Specifically, IMBA requests the Wayne National Forest consider opening the figure eight trail in Wild Cat Hollow to mountain bikes. Doing so would accomplish several objectives. Because Wild Cat Hollow receives little traffic, the narrow trail would keep mountain bikes at a slower speed and minimize user conflict. By using an existing 15-mile trail, Wayne National Forest can go a long ways towards opening the 15-30 miles of trail stated in the DEIS. Finally, as progress continues towards opening existing singletrack trails to mountain bikers in Burr Oak State Park, connecting that network with Wild Cat Hollow would provide the largest mountain biking trail network in Ohio, drawing visitors from the entire state and beyond. The Buckeye Trail Council is supportive of connecting Wild Cat Hollow with Burr Oak and a partnership with local mountain bike clubs would help construct a connector trail between the two systems and provide volunteer trail maintenance labor.
Another valuable mountain biking area is the Marietta Unit. Many trails, including the North Country National Scenic Trail (NCNST), are of great value to mountain bikers. Thanks to numerous hours of volunteer labor by members of the Marietta Cycling Club and other local cyclists, the NCNST and adjoining trails have become a favorite riding location. The Wayne National Forest should keep these trails open to mountain bikes and continue to partner with cyclists on trail construction and maintenance, not discourage their generous efforts by closing the trails.
You will probably receive comments that maintain the North County National Scenic Trail should be closed to bicycling. These people tend to argue that national trails should be managed in the pattern of the Appalachian Trail, which Congress declared is "primarily" for hiking. However, that is the only national trail where Congress made such a statement. In 1983 Congress amended the National Trails Act to support diverse trail uses, including bicycling. 16USC1246(j) states:
(j) Types of trail use allowed
Potential trail uses allowed on designated components of the national trails system may include, but are not limited to, the following: bicycling, cross-country skiing, day hiking, equestrian activities, jogging or similar fitness activities, trail biking, overnight and long-distance backpacking, snowmobiling, and surface water and underwater activities. Vehicles which may be permitted on certain trails may include, but need not be limited to, motorcycles, bicycles, four-wheel drive or all-terrain off-road vehicles.
We are aware of a "desired future condition" statement that says the agencies will eliminate bicycling and equestrian travel from the NCNST. We consider this document illegitimate because its creation had absolutely no public comment or involvement, other than the input of the private North Country Trail Association. The Wayne National Forest is free to act as it wishes since there is no regional order stating the NCNST is closed to biking and horseback riding. Please do not close the NCNST in the Wayne NF to these uses.
SUMMARY
IMBA requests that the Forest Service:
- Adopt an open-unless-closed policy for mountain bikes.
- Uniformly apply trail restrictions for environmental concerns to all users.
- Follow the lead of other national forests in complying with the 2004 Recreation Enhancement Act by dropping fees for mountain bike use.
- Open Wild Cat Hollow to mountain bikes.
- Retain mountain bike access to the trail system in the Marietta Unit, including the North Country National Scenic Trail.
Thank you for consideration of these comments.
Sincerely,
Gary Sprung
IMBA senior national policy advisor
Drew Vankat
Public lands intern
Attached:
"The Importance of Singletrack"
"Natural Resource Impacts of Mountain Biking"
Endnote 1: The Forest Service's definition of "mechanical transport" in the Code of Federal Regulations refers to "any contrivance...propelled by a non-living power source." 36CFR-293.6a
Endnote 2: We are assuming the Wayne is using the term "designated" to mean use-designated rather than an official or system trail.
Endnote 3: See, Sprung, Gary, "Natural Resource Impacts of Mountain Biking," International Mountain Bicycling Association, attached.
Endnote 4: 36CFR-261.10 Occupancy and use.
The following are prohibited:
(a) Constructing, placing, or maintaining any kind of road, trail, structure, fence, enclosure, communication equipment, or other improvement on National Forest system land or facilities without a special-use authorization, contract, or approved operating plan.
