Bringing Access to the People at Berryessa Snow Mountain National Monument
The following is a letter sent to the United States Forest Service by California chapter presidents on the wilderness inventory and evaluation plan. Please use this letter and subhead topics to guide your comments. It is important to personalize your feedback slightly so each submission is counted as a unique comment. Submit comments by Feb. 1, 2016.
You can submit comments via the webform at the bottom of this link: http://tinyurl.com/earlyadoptersfpr, or follow instructions on the same page to submit comments on the specific areas of concern listed.
- About IMBA
- On Wilderness
- Wilderness Inventory and Assessment; Mapping Concerns
- Further Comments for Specific Forests and Areas
Authored by [INSERT INSERT RELEVANT NAMES/TITLES]
January 30, 2016
Dear Forest Service Representative,
Thank you for the opportunity to comment on management strategies for the Sequoia, Inyo and Sierra National Forests.
We represent the International Mountain Bicycling Association (IMBA), a non-profit membership association. In the United States, IMBA is composed of more than 200 local chapters and more than 35,000 individual members who are dedicated to the conservation and stewardship of our nation’s natural resources, and to promoting healthy outdoor recreation for all citizens. We believe that growth in active lifestyles will make outdoor recreation the dominant use of public lands in the next 30 years. Natural surface recreational trails will increasingly be a key component of community and economic development to attract both visitors and quality of life recruits, whether employees or employers. As sustainable technologies are further developed, recreation on public lands will become an increasingly mainstream economic driver for communities.
IMBA members in over 200 chapters nationwide, plus affiliates, are the biggest single provider of trail stewardship volunteers, trail maintenance partnerships, and trail design and construction services on public lands of all types. IMBA is committed to supporting and evolving public land policy to meet 21st century needs for access to recreation assets in natural settings.
IMBA members highly value land conservation, clean water and clean air. The vast majority of mountain bicyclists enjoy riding in natural areas on singletrack trails, away from roads and development. Our activity brings us closer to nature and fosters a desire for environmental protection. Backcountry travel by bicycle is demanding, yet highly rewarding, and cyclists wish to protect these experiences.
Turning to the Sequoia, Inyo and Sierra National Forests, we would like to begin our comments with the firm belief that Wilderness designations, which prohibit bicycle access, should not be the only form of land protection considered for these forests. There are a variety of other protection designations, from Roadless Areas to a suite of Special Management Areas to National Recreation Areas and National Monuments that may be suitable and would not prohibit bicycling. These established designations can be used to protect special places. Therefore, IMBA frequently recommends employing these bike-friendly designations to achieve high-value conservation protection coupled with flexible and accessible management. The mountain biking community highly values protected lands with Wilderness-like qualities as they preserve the wildness that offers outstanding opportunities for enjoying and appreciating nature via the bicycle. These experiences should be provided and promoted on these three national forests for a wide variety of recreationists where they are compatible and manageable. We firmly contend that current science supports the premise that landscapes with wilderness quality characteristics can support continued and managed mountain bike trail access while maintaining those characteristics.
Unfortunately, formal Wilderness designation thwarts all future options for new and properly designed, sustainable trails. The protection technique known as “cherry stemming” (preserving access via narrow trail corridors) does not work well for these forests due to a variety of factors, including burnt forest in need of restoration, steep terrain, and flash flooding. Trails often need major re-routes and improvements to be truly sustainable and passable. Therefore, moving Wilderness boundaries too close to existing trails does not adequately account for how land and trails change, and how modern, sustainable trail building techniques have evolved.
Wilderness suitability does not automatically justify or warrant a Wilderness recommendation nor should it preclude current or future bicycle access. Bicycles and wild characteristics are not mutually exclusive. We acknowledge that the US Forest Service generally agrees with this sentiment. However, we know that typically there is great pressure exerted by special interest wilderness groups to expand wilderness and restrict “non-conforming” uses. Thoughtful and active management can and should maintain the character and values of a landscape for the long term without unnecessarily denying access by a diversity of recreational modes and uses. This can be achieved through creative and tailored agency management prescriptions and alternative land protection designations.
Wilderness Inventory and Assessment; Mapping Concerns
An important observation we would like to share is that the quality of the maps included with the current Forest Service Wilderness evaluation is poor—we found many discrepancies between downloadable GPS polygon data, polygon descriptions and published maps. Also, we cannot zoom in enough to sufficiently examine current mountain biking/multi-use/motorized trails, routes, roads, and potential opportunities for future trails/routes. We look forward to this issue being resolved by the next comment period, when the Draft EIS is released.
Having qualifying characteristics of wilderness suitability is not the only metric that should be accounted for in an inventory and assessment. In order to be fair, balanced and well informed, an inventory and assessment must include a risk/value analysis. This analysis must account for the value of other existing and potential uses of an area and weigh the values and risks of those uses against the wilderness suitability in order to identify how best to balance and maintain both options without unnecessarily curtailing one or the other. Wild and remote areas are popular for long-distance backcountry bike trails, multi-day bike-packing tours, and other appropriate recreational activities.
IMBA understands that the inventory procedure is an exercise to inventory wilderness character. However, if sufficient data is not carefully collected, analyzed and presented, or other qualities and values fully accounted for, this process could lead to the failure to fully account for the value of other uses; therefore precluding appropriate activities such as mountain biking on the false premise that recreational mountain biking and wilderness character are incompatible. Often, wilderness characteristics exist alongside other uses in the same geography. Therefore, the Forest Service should seek to continue to maintain the preexisting character along with the current uses. Careful consideration must be taken to weigh the value of a spectrum of uses with the wilderness characteristics identified.
We recommend that the USFS balance any positive identification of suitability with a value assessment to identify what the pros and cons are to managing an area in any specific manner. At all opportunities, alternative protective forest planning prescriptions and administrative designations that would achieve the same end result of protection and maintenance without unnecessarily curtailing appropriate and sustainable recreation opportunities, both current and yet to be fully realized, should be fully considered, reviewed, and pursued to avoid further restricting or confining public access.
Further Comments for Specific Forests and Areas:
Sequoia National Forest
In the Sequoia National Forest, there are recommendations for seven potential additions to two existing Wilderness areas:
2 potential additions to the west side of the Domeland Wilderness
1 potential addition to the north side (Fish Creek area) of the Domeland Wilderness
4 potential additions to the western and southern sides of the South Sierra Wilderness
Regrettably, this would result in the loss of several high quality mountain biking opportunities. In a time when mountain biking is growing exponentially in the Sequoia NF, wilderness recommendation would concentrate bikers on the highest use trails and force them into hot, dry, lower elevation climates. Instead of wilderness recommendations, IMBA recommends the use alternate land protection designations that can be used to protect these special places and allow for lawful and sustainable bike access.
The Sequoia NF’s motto is “The Land of Many Uses,” yet 41% of the Sequoia NF is already Wilderness (322,314 acres of Wilderness in the 772,231-acre Sequoia National Forest). Only 1.4% of Sequoia NF visitors even enter Wilderness lands according to the Sequoia NVUM.
Optimizing access of mountain bikes to trails will increase the number of visitors to national forests, increase the diversity of visitors and increase volunteer stewardship for maintaining quality trails.
South Sierra Wilderness Western Addition
This area has become very popular with mountain bikers from the Eastern Sierra, Big Bear, Kern River Valley and Central Valley, etc. It provides a rare opportunity to ride mountain bikes on alpine singletrack above the heat of the summer.
We cannot support this wilderness addition that would close the recently cleared and reopened Bitter Creek Trail (34E03) to mountain bikes near the popular Kennedy Meadows area. The changes would move the Wilderness boundary only a very small distance up to the paved Sherman Pass Road (22S05), which would sacrifice this valued recreational resource with very little additional wilderness protection.
Dropping approximately 1,500 feet from Rodeo Flat, Bitter Creek Trail is one of the only non-motorized options in the entire region, and is a very suitable and sustainable mountain bike trail. It can be utilized as an “out and back” route, or be ridden as a loop (or shuttled) with Sherman Pass Road. It is also the closest legal singletrack trail to the Eastern Sierra in this region. With a significant increase in the number of mountain bikers riding this trail this year, we cannot support any measure that would eliminate this valued recreational resource.
The proposed wilderness addition also moves the boundary to within 70 feet of the Jackass National Scenic Trail (35313), which leaves very little room for more sustainable re-routes or improvements to this very popular trail. It would also eliminate the opportunity to connect this trail with the lower Hooker Meadow Trail (35E05), which would be lost with the new Wilderness addition. Hooker Meadow Trail also currently provides a beautiful “out and back” riding experience in the midst of a giant stand of Aspen trees. As a result, mountain bikers would lose this recreational resource. We cannot support any measure that would eliminate this valued recreational resource.
To the north, the new Wilderness would eliminate the non-motorized trail through Broder Meadow that links to the Jackass Peak Trail and Granite-Broder Trail, a popular mountain bike loop. We cannot support any measure that would eliminate this valued recreational resource.
Fish Creek Wilderness Addition
The Fish Creek Wilderness addition does not seem to affect any trails directly, but it would extend wilderness right up to Sherman Pass Road (22S05) across from the Bitter Creek Trail, one of the only non-motorized trails in the area and a popular trail for mountain biking. We cannot support any measure that would eliminate bicycle access to the Bitter Creek Trail, a valued recreational resource.
Domelands Wilderness Addition
The area and trails affected by the Domeland Wilderness addition are on the southern Kern Plateau, and link to the Cannell Trail, an IMBA Epic trail. Directly above Kernville, this area is seeing a notable increase in mountain bike use. This landscape offers a rare and increasingly limited area for epic cross-country mountain bike riding and bikepacking at higher elevations. We cannot support any measure that would eliminate access to these mountain bike trails, all valued recreational resources.
The Domelands Wilderness Addition extends the existing Wilderness right up to the Sirretta Trail (34E12). This trail is in mountainous terrain and climbs to over 9,500 feet in elevation. It is the main trail section of a large alpine backcountry loop that connects to Cannell Meadow Trail. It currently is being considered for a re-route that would feature sustainable grades, which would improve both the environmental and mountain biking quality. However the Wilderness proposal seeks to move the boundary to within feet of this trail, which would eliminate most of the possible re-route area. We cannot support moving the wilderness boundary so close to this important trail due to the loss of the ability to create environmental improvements.
Just south near Taylor Meadow, there is another excellent area for various mountain biking options. The proposed wilderness addition would completely eliminate the Big Meadow Trail (34E15) to mountain bikes. Currently, only a small section of the trail is in the Domeland Wilderness. Mountain bikers have wanted to propose a contouring re-route that would skirt the edge of the existing Wilderness and connect to the other trails in the area. All mountain bikers would lose this amazing opportunity with the new Wilderness addition. We cannot support any measure that would eliminate this valued recreational resource.
This same section of proposed Wilderness also extends up to Upper Dry Lake Trail (34E17), leaving no room for re-routes or environmental improvements to the trail in the future. This excellent trail creates an important link in several mountain bike loop options.
Another major problem with this addition is that it moves the wilderness boundary down the ridge on the Woodpecker Trail (34E08). Currently mountain bikers can ride up to the existing Domelands Wilderness boundary and enjoy the views of Domelands at the base of Church Dome. It is a unique “out and back” ride that links to the other trails in the area. The new Wilderness proposal would forever take this experience away from mountain bikers. We cannot support any measure that would eliminate this valued recreational resource.
South Sierra Wilderness Eastern Addition
The proposed section of wilderness near Haiwee Pass eliminates a huge section of the Southern and Eastern Sierra’s mountain bike potential. In a time when the demand for sustainable outdoor recreation is increasing, the opportunity for new trails should not be eliminated in such a huge area of higher elevation land. Mountain bikers should not be limited to riding the desert floor in the southern Eastern Sierra. There is excellent potential for high quality mountain bike trails in the area, and they should be proposed.
Sierra National Forest
At this time we cannot support any of the recommended wilderness polygons on the Sierra NF, due to the poor quality of the maps included with the current Forest Service Wilderness evaluation. We found many discrepancies between downloadable GPS polygon data, polygon descriptions and published maps. Also, we cannot zoom in enough to sufficiently examine current mountain biking/multi-use/motorized trails, routes, roads, and potential opportunities for future trails/routes. We look forward to this issue being resolved by the next comment period, when the Draft EIS is released. No further comments on the Sierra NF at this time.
Inyo National Forest
At this time we cannot support any of the recommended wilderness polygons on the Inyo NF, due to the poor quality of the maps included with the current Forest Service Wilderness evaluation. We found many discrepancies between downloadable GPS polygon data, polygon descriptions and published maps. Also, we cannot zoom in enough to sufficiently examine current mountain biking/multi-use/motorized trails, routes, roads, and potential opportunities for future trails/routes. We look forward to this issue being resolved by the next comment period, when the Draft EIS is released. No further comments on the Inyo NF at this time.
We thank you for the opportunity to comment on the management plans for these three national forests and their important recreational resources.
[INSERT RELEVANT NAMES/TITLES]