Comments Needed on Southern California Draft Forest Plans - Deadline, Aug. 11

Action Alert

ACTION ALERT: For Immediate Release
07-22-04
Contact: Gary Sprung

IMBA is calling on all California mountain bikers to comment on the draft plans for the four national forests of Southern California: the Cleveland, San Bernardino, Angeles and Los Padres national forests. Your comments now will affect the next 15 years of mountain biking in these forests. Please help protect and improve bicycling opportunities by getting involved today.

IMBA representatives and other mountain bicyclists have been involved at every step of the process and the U.S. Forest Service is treating cyclists fairly. But, anti-bike advocates are asking for extensive trail closures. You need to write to help the Forest Service provide balance.

THE COMMENT DEADLINE IS AUGUST 11, 2004.

Each forest has its own plan. You need to comment on the plan for each Forest where you ride. You may comment either online, by mail, or by fax:

ONLINE: http://www.fs.fed.us/r5/scfpr
Use the Forest Service web site to place your comments "in" the text of the plan or "on" the maps.

MAIL:
Southern California Forest Planning
Re: (Specific forests you're commenting on: Cleveland, San Bernardino, Angeles, and/or Los Padres)
USDA Forest Service Content Analysis Center
PO Box 22777
Salt Lake City, UT 84122

FAX:
You may also fax your comments to: (801) 517-1015

You should tell them who you are, where you ride, what your concerns are. In your own words, please comment on the following issues (which we explain at length below):

1. The plan is welcome and well done. We generally support the Forest Service's preferred alternatives (except as explained in points 2-4, below).
2. We support the agency's proposed Wilderness areas in the Los Padres and Angeles national forests. But in the San Bernardino, the Forest Service should recommend a protection plan other than Wilderness for the Sugarloaf area near Big Bear and the San Gorgonio Southwest area east of Redlands. In the Cleveland National Forest, the agency should protect Cutca Valley with a Protection Area instead of Wilderness. Those places offer critical singletrack riding opportunities.
3. The plans should NOT restrict bicycling to official, system trails until and unless a thorough inventory and travel planning process occurs with public involvement. Until then, the plan should only require bikes to stay on existing trails.
4. The plans should allow bicycling in Critical Biological Areas and should address recreation/ecosystem conflicts with constructive management measures. The impact of bicycling on natural resources is about the same as the impact of hiking, which the plans would allow in Critical Biological Areas.
5. You can add other comments, such as:
• Bicycling is human-powered, low-impact recreation.
• Shared-use trail systems are best.
• The plan should protect all the roadless areas. Roadless areas allow bicycling while preserving the land.
• The plan should also resurrect the California Riding and Hiking Trail, and it should consider where bicycling is appropriate on the Pacific Crest National Scenic Trail.

Finally, please forward this notice to every cyclist you know in California. We need to make sure the Forest Service hears IMBA's message and protects and improves cycling in these four forests for the next 15 years.

Thank you for getting involved in this critical matter.

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Detailed Information On IMBA's Position

1. The plan is welcome and well done. We generally support the Forest Service's preferred alternatives (except as explained in points 2-4, below).

Mountain bicyclists have enjoyed recreation on the Southern California Forests since the very invention of the modern mountain bike in the 1970's. In urban Southern California, where escape into nature nourishes our bodies, minds and spirits, the forests are extraordinarily important to mountain bicyclists. We value the terrain, the flora and fauna, and the rich variety of trail experiences available to us. There are many, many mountain bicyclists enjoying the forests of Southern California.

Mountain bicycle groups, many of which affiliate with IMBA, have developed active volunteer programs to assist the National Forests in trail maintenance, volunteer patrols and a number of other significant joint endeavors.

The National Forest planning process was excellent. The workshop formats provided for adequate opportunities for the exchange of information while avoiding and defusing public grandstanding and inter-group conflict.

The Forest Service has identified "preferred" alternatives, which IMBA generally supports. In those alternatives the Forest Service recognizes that recreation is a top priority on these National Forests. The plans will both encourage and manage recreation. The challenge is how to serve such a huge population base while protecting the resources of the Forests.

For the Los Padres, the Angeles and the San Bernardino national forests, IMBA generally supports "Alternative #4" and for the Cleveland National Forest we support "Alternative #2," with the exceptions of points two through four, explained below.

2. The plans' recommendations for Wilderness need adjustment.

Wilderness designation presents a thorny problem for the mountain bike community. On the one hand, we are environmentally minded and generally support high levels of resource protection. On the other, current regulations prohibit bicycle use in Wilderness. U.S. Senator Barbara Boxer has proposed many new Wilderness areas in the Southern California Forests (alternative number six includes most of them). Congress trumps Forest Plans on Wilderness designations, but the analysis the agency provided supports our view that many of these areas can be best protected in ways other than Wilderness. For many of the areas proposed as Wilderness in the Boxer bill, the Forests have chosen to identify and manage them as "Back Country Non-Motorized," which allows biking.

One problem is in the San Bernardino National Forest, northwest of Los Angeles. The Forest Service has proposed recommending Wilderness designations for the Sugarloaf and San Gorgonio Southwest areas. The Sugarloaf area is south of Big Bear and in an area where legal singletrack is in short supply. The preferred plan would close to bicycling the Green Canyon and Sugarloaf National Recreational Trails, whereas the 2003 Boxer bill would leave them open. Also at stake is the Wildhorse Trail. All are on the eastern side of the area and a boundary adjustment to exclude them would gain IMBA's support.

The San Gorgonio Southwest proposed Wilderness, which lies about 15 miles east of the city of Redlands, near San Bernardino, is a group of seven sections of "checkerboard" public land connected only by their corners, with private lands interspersed. This proposal would close to bicycling a ride that has appeared in a mountain bicycling map since 1994, the trail to Little San Gorgonio Peak. This is not an appropriate place for Wilderness.

In the Cleveland National Forest, the draft management plan calls for new Wilderness at Cutca Valley. While IMBA believes that this area does warrant a high level of resource protection, the proposed Wilderness would eliminate bicycle access to the Cutca Valley Trail and would prevent bicyclists from making the connection from High Point Road in the east (8S05) to Cutca Road in the west (8S08). The trail is well established and provides some of the only non-fire road trail experience in the area. IMBA believes that the Cutca Trail should be excluded from any new Wilderness boundary, or that the entire area be protected using an alternative designation. (The USFS web site maps do not show the Cutca Valley Trail, but it appears on other USFS printed maps and in most outdoor guidebooks.)

IMBA can support the remainder of the plans' proposed Wilderness areas because they do not conflict with significant bicycling opportunities.

3. The plans should not restrict bicycling to official, system trails until and unless a thorough inventory and travel planning process occurs with public involvement. Until then, the plan should require bikes to stay on existing trails.

One aspect of the plan threatens to close an unknown, but potentially high number of bicycling routes. The plan would limit bicycling to official, "designated" trails. But some areas actually include many more trails that the agency has not yet made official. Many of these unofficial trails are popular, well built trails and are significant improvements to the recreational resource.

Tell the Forest Service to please hold off on the limitation. A separate, travel management planning process is necessary before the agency restricts bicycling to designated routes. The agency needs to thoroughly inventory ALL trails, and then make decisions about each route. They must involve the public in that decision-making. Until then, bicyclists should be able to use any trail, except those already officially closed. (IMBA does not support riding off of trails, and we especially disdain the unauthorized building of new trails. Cyclists should work with the agency to create new routes.)

4. The plans should allow bicycling in Critical Biological Areas and should address recreation/ecosystem conflicts with constructive management measures.

The four Southern California national forests have identified several "Critical Biological Areas" where they intend to ban bicycle use. In a few cases, trails now open to bicycling pass through these zones.

It's unfortunate that the Forest Service is thinking that they must ban bikes - while leaving trails open to hikers and equestrians - in order to protect species. They do not have solid evidence that bikes are more harmful to wildlife and ecosystems than other users. The impacts of bicycling on natural resources are about the same as the impacts of hiking.

IMBA is committed to preserving species, but we think the Forest Service can protect theses areas without a blanket ban on bikes. For example, in Part 3 "Design Criteria for the Southern California Forests", Appendix D-3 "Adaptive Mitigation Protocol for Recreation Sites" a number of actions are indicated which would protect these areas, but still allow bike use. We encourage the Forest to adopt those strategies.

5. Other potential comments

A. Bike use is human-powered, low impact recreation

There is ample scientific literature that indicates that responsible mountain bicycling is an appropriate, sustainable, low impact and quiet form of trail recreation. It is muscle-powered recreation, and both the motives and impacts of cyclists are much like those of hikers and equestrians. Bicyclists seek urban escape, nature appreciation, wildlife observation, exercise and a variety of other enriching outcomes when we visit the Forests. It is important to us that our needs are considered and our motives and impacts are not confused in this planning.

Bicycling is NOT a non-motorized form of Off-Highway Vehicle. Management should consider bicycling in the same class a hiking and horseback riding.

Note: In the Los Padres, the Forest Service map indicates that the Madulce-Buckhorn recommended Wilderness crosses the Buckhorn Trail, which is a designated IMBA Epic. This was a drafting error. As described in the text description, the recommended Wilderness stops north of the Buckhorn Trail.

B. Roadless Areas and road-to-trail conversions

IMBA supports protection of all Roadless Areas. The original Roadless Initiative would have protected those areas while allowing bicycling. These plans should maintain that protection. We also support road-to-trail conversions when old roads no longer serve their purpose. Trails are far less problematic to ecosystems than roads.

C. Shared-use trail systems are best

Mountain bicycling is a trail-based activity. We value trail diversity and connectivity. Especially in urban interface areas, the Forest Service should provide for a number of dispersed entrance points to the trail system and should look for opportunities to connect trails to one another. Shared-use trails give users the greatest variety of experiences to choose from. They accommodate the largest number of users, minimize impacts, are cost efficient in terms of maintenance and monitoring, and build a community of trail users.

While IMBA recognizes that some trails might exclude bicyclists or some other uses, single-use trails should be the exception. Reasons for single-use trails include: ADA accessible trails, Braille trails, trails that separate users at crowded trail heads, horse trails that lead to stables and specific horse facilities, competition trails, and nature interpretation trails which might receive high use from children. But most trails should be shared-use.

D. Pacific Crest Trail and California Riding and Hiking Trail

Two significant trails worth mentioning in your comments are the Pacific Crest Trail (PCT) and the California Riding and Hiking Trail (CRHT). In each case, good forest planning could enhance opportunities for trail visitors. The PCT currently bans bikes, but IMBA does not believe this ban should apply to the entire trail. There are many places in Southern California where allowing bikes on the PCT would enhance the value of the trail as a recreational resource. In addition, bike use would also make a great deal of volunteer labor available for PCT trail maintenance. We ask that the Forest Service consider where opening the PCT to bicycles would make good planning sense.

The California Riding and Hiking Trail is an historic trail project that was never completed. The goal was a multi-use, non-motorized recreational trail that circumnavigates the state. While much of the trail is "on the ground," many of the original easements have been lost or abandoned. Many in the California trail community are working to revive the CRHT. The Southern California Forests have the potential to be a very important resource in that effort. Please consider the CRHT as the planning process continues.

E. Perceptions of User Conflict Are Higher than Reality

Several studies, some conducted in Southern California, have indicated that perceptions of user conflict are often magnified by the multiple complaints of a small number of people. People often have a hard time getting along with those they consider to be different. This is normal human behavior, but not an acceptable way to build public policy. There is an abundance of evidence to suggest that the key to reducing user conflict is cooperation and communication between trail users.