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Marin County Parks
CVP comment letter on proposal to open the Bob Middagh Trail to mountain biking
The following comment letter has been submitted to Carl Somers, Chief, Planning and Acquisition of the Marin County Parks / Open Space District.
Some context may be important to preface the purpose of this letter. It is in response to the MCOSD’s prescribed public comment period deadline. The issues surrounding the Middagh Trail go back several decades. This letter is not about whether mountain biking should be banned in general (it should not be banned, indiscriminately), but is rather about whether or not it should be allowed on particular single track trails and what the impacts of that would be. This letter is asking a public agency to carefully consider all facts and circumstances before making a decision. It is more narrowly about the legal requirements to make a "change of use" decision and precedents that would be set for all Marin Open Space if the Middagh Trail were changed to multi-use allowing mountain biking.
The public process for this proposal, the history of the Middagh Trail, the quality of the MCOSD workshops, the proper evaluation of environmental and public safety impacts, and a variety of other legal requirements are all at issue here. The environmental and preservation movement in our county, and in fact, the world has always been about the fate of a small animal or parcel of land, which has led things like the Endangered Species Act and the Clean Air and water laws.
Standing up for principle and what is lawful is ultimately beneficial to us all.
Dear Mr. Somers:
We are submitting this comment regarding your recent recommendation to change the allowable uses on certain trails in the Alto Bowl Preserve, and in particular the Bob Middagh Trail. The Middagh Trail is currently designated for limited use by hikers and equestrians. Your proposal is to expand that to multi-use by allowing mountain biking. We are opposed to this change and do not support your recommendation for the reasons that are enumerated below.
Community Venture Partners (“CVP”) is a 501(c)(3) nonprofit organization that supports community-based projects, programs and initiatives that demonstrate the highest principles of economic, social and environmental sustainability. CVP is headquartered in Mill Valley and its officers, board members, collaborators and advisors use and enjoy the hiking trails in Southern Marin, regularly, including the Bob Middagh Trail.
The Bob Middagh Trail remains a unique hiking and equestrian experience in Southern Marin, where hikers can experience the peacefulness and magnificence of our local foothills against the backdrop of Mt. Tamalpais. I want to remind you of its significance by quoting from your own website, which notes:
This is a small preserve (37 acres), but its story is a perfect example of how many areas that are now open space were spared from development. As the town of Mill Valley grew in the late ‘60’s, the citizens realized that the surrounding ridges would soon be covered with buildings. Grassroots activism squelched the plans of several developers, and eventually the County was able to acquire the first 50 acres, which form the eastern half of the preserve.
The southern half of the Alto Bowl Preserve is known as “Horse Hill” and is leased for horse pasturing by the Alto Bowl Horseowners Association. The sight of horses grazing peacefully on this grassy hillside has been a landmark for decades. Slated for development in the 1980s, the credit for its preservation goes to the horse owners, their supporters, the Marin County Open Space District, the Marin Community Foundation, and the City of Mill Valley who together raised 2.4 million dollars.
Dedicated volunteers have restored many acres of this preserve’s native habitats by waging an ongoing battle against French broom and other invasive, exotic plants.
All this considered, we strongly oppose the change of use to allow mountain biking on the Bob Middagh Trail for the following reasons:
1 - ENVIRONMENTAL IMPACTS
Cumulative Environmental Impacts:
All available research and data suggests that the addition of mountain biking, as an allowable use, on the Middagh Trail would result in increased and significant, cumulative environmental impacts. To put this in the simplest terms; if a trail is currently being used by “X” number of hikers and “Y” number of equestrians, their impacts are quantifiable. If we add “Z” number of mountain bikers, the overall cumulative environmental impacts of all these users increase by “Z.” The addition of a new user group does not displace the existing users but is additive to the total number of users and the resultant environmental impacts.
These cumulative impacts would include but not be limited to increased erosion, rutting and topsoil loss, increased damage and destruction of vegetation and plant root systems, and increased negative impacts on wildlife, wildlife habitat and habitat sustainability (noise, trash and other pollution, decrease in nesting area, etc.).
In addition, new environmental cumulative impacts are created by adding mountain bikers as a third user group. As will be further noted in the section on “Conflicts” below, it is impossible for current trail users (hikers and equestrians) to meet mountain bikers going in the opposite direction without one or the other stepping off the trail in order to pass each other. This increases the number of times users will go off trail and therefore increases the environmental impacts. Further, since all evidence indicates that the number of potential mountain bikers using the trail will be considerable, those additional cumulative environmental impacts will be equally considerable.
Scientific literature and research are replete with data on the environmental impacts of mountain biking. Some references that we ask you to carefully consider are:
Mountain Biking: A review of the ecological effects – A Literature Review of Parks of Canada – National Office (Visitor Experience Branch); February 2010 by Michael Quinn and Greg Chernoff at the Miistakis Institute; University of Calgary:
http://www.lib.washington.edu/msd/norestriction/b67566091.pdf
More Bikes on Marin County Open Space Trails? - Marin Audubon Society: comment on species and habitat destruction; The Clapper Rail; December 2009:
http://www.marinaudubon.org/pdf/ClapperRailDec09c.pdf
ARPN Journal of Science and Technology - The impacts of Mountain Biking on Wildlife and People - A review of the Literature; Michael J. Vandeman, Ph.D.
http://www.ejournalofscience.org/archive/vol4no7/vol4no7_5.pdf
Trail damage by mountain bikers and illegal riding:
Evidence of resultant trail damage specifically related to the introduction of mountain biking as an allowable use is well documented both in Marin County and around the country. Some references that we ask you to carefully consider are:
Supervisors tackle Marin trail conflicts – Marin IJ
http://www.marinij.com/general-news/20091103/supervisors-tackle-marin-trail-conflicts
Bicyclist in trouble again over illegal trail at China Camp – Marin IJ
http://www.marinij.com/ci_9127375
Mountain Biking Too Costly For Marin Taxpayers – Coastal Post
http://www.coastalpost.com/00/11/02.htm
Froome illegal Mountain Bike Trail Construction Destroys Forest Ecosystem
http://www.clubtread.com/sforum/topic.asp?TOPIC_ID=9736
Pogonipwatch: reports of illegal bike riding Santa Cruz
http://www.pogonipwatch.org/illegal/
Arboretum trails restored after bikers tear them up.
http://westernfrontonline.net/news/13473-arboretum-trails-restored-after-bikers-tear-some-up
Illegal bike jumps irk trail users, Granite Bay, CA
http://granitebaypt.com/detail/168318.html
More Illegal Mountain Biking Trail-Building (BC) Escarpment Trails damaged
http://www.nugget.ca/ArticleDisplay.aspx?e=3357138
Trail use issues create canyon concerns Auburn area Cyclists’ illegal jumps, riding in undesignated areas pose safety risks, ranger says
http://auburnjournal.com/detail/168742.html
U.C. Santa Cruz Natural Reserves: illegal bicycle trail, located in the Seven Springs area of the reserve, has caused major destruction of habitat, erosion, and shows a major lack of respect for the mission of the CNR
http://ucsantacruz.ucnrs.org/?page_id=613
Bicyclist in trouble again over Illegal trail at China Camp. Michael More (Marin Bike Council) again caught building illegal trail; cost to repair approx $20,000
http://www.marinij.com/ci_9127375
Fairfax man convicted of illegal mountain biking at Point Reyes. Steven Gravenites, 45, was found guilty of a misdemeanor and has been convicted of riding on an illegal trail;
http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/2007/11/15/BANJTD9J7.DTL
Tahoe Bikers Blaze Illegal Trails - Las Vegas
http://www.lvrj.com/news/53397297.html
Boulder discovers illegal, ‘extreme’ mountain bike trail on Flagstaff - Boulder CO
http://www.dailycamera.com/ci_17721077
New York-New Jersey Trail Conference - Report: tracking illegal mountain bike, dirt bike and ATV usage
http://www.nynjtc.org/webform/illegal-usage-problem-report
Crane Mountain Illegal Mountain Biking out of control
http://www.swanview.org/home/articles/blog/crane_mountain_biking_out_of_control/70
Union Pacific levels illegal Auburn Mountain Bike Course
BLM, Trail Mix cite concerns over illegal mountain bike trails
DEC Imposes New Fines for Illegal Trail Building (The New York State Department of Environmental Conservation Adirondack Forest Preserve)
http://forums.mtbr.com/new-york/dec-imposes-new-fines-illegal-trail-building-557512.html
No such thing as a Free Ride--Illegal trail building
http://www.flatheadbeacon.com/articles/article/no_such_thing_as_a_freeride/24213
Rogue trail builders clear mile-long off-road bike path in Portland’s Forest Park
http://www.oregonlive.com/portland/index.ssf/2010/02/rogue_trail_builders_clear_mil.html
Illegal bike trail area razed by council!
http://www.thisissouthwales.co.uk/Bike-trail-area-razed-council/story-15919755-detail/story.html
Forest Service might close illegal mountain bike trail near Aspen
http://www.aspentimes.com/article/20100922/NEWS/100929950
Forestry Commission Wales removes illegal bike jumps
http://dirt.mpora.com/news/forestry-commission-wales-removes-illegal-bike-jumps.html
2 - TRAIL CONFLICTS, RESULTING SIGNIFICANT IMPACTS, AND PUBLIC SAFETY CONCERNS
It is unarguable that hikers and equestrians and mountain bikers on the same single track trail will experience significant conflicts, which can result in increased environmental damage and personal injury. They are not only using the trail in different ways but use it at different speeds and intensity. Whereas, hiking and equestrian use is predominately leisurely, contemplative and pastoral, mountain biking is inherently about strength, endurance, challenges and tests of skill, as well as thrill seeking and high speeds (which is fine where it's appropriate, but the Alto Bowl is not one of those places).
As much as hiking is about “man (or woman) in nature,” mountain biking is much more about “man versus nature.”
This contradiction of purposes forms the basis of the incompatibility, and the basis of significant conflicts and public safety issues that have consistently arisen on multi-use trails that combine hiking, equestrians and mountain bikers. What is telling regarding reports of trail conflicts is that the record is almost devoid of reports of significant conflicts between hikers and equestrians. Almost all conflict, injury and public safety reports involve mountain bikers. This may be due to the fact that both hikers and equestrian use is, as noted, leisurely, whereas mountain biking is a high speed, high risk sport. That mountain biking is a high risk sport is indisputable and fully supported even by all major mountain biking organizations.
The published record of research, parks manager studies, news accounts and a myriad of other sources fully support this common sense conclusion. Some references that we ask you to carefully consider are:
Conflicts on Multi Use Trails: Synthesis of the Literature and State of the Practice - Federal Highway Administration
http://www.fs.fed.us/cdt/carrying_capacity/conflicts_trails_synthesis_1994.pdf
Board of directors of the Medical Society of Metropolitan Portland: In Forest Park, biking and hiking don’t belong together;
http://www.oregonlive.com/opinion/index.ssf/2010/06/in_forest_park_biking_and_hiki.html
Marin Voice: Making Public Lands Safe For All Users: by Nona Dennis, president of the Marin Conservation League, Joel Bartlett, president of the Marin Horse Council, and Steven Schoonover, president of Tamalpais Conservation Club
http://www.marinij.com/opinion/ci_15875309
California Recreational Trails Committee; User conflicts and accidents from bikes on multi-use trails
http://www.parks.ca.gov/pages/1324/files/crtc%20minutes%2011-13-08.pdf
Chronology of growth of User Conflicts on Santa Barbara Front Country Trails System; USDA
http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5097666.pdf
Supervisors tackle Marin Trail conflicts, by Mark Prado
http://www.marinij.com/general-news/20091103/supervisors-tackle-marin-trail-conflicts
NBC Bay Area News; Little Enforcement for Dangerous Behavior on Mount Tamalpais.
Marin: Bikers Damage Trails, Bully Hikers, Horses – San Francisco Chronicle Opinion
http://www.sfgate.com/cgi-bin/article.cgi?f=/c/a/1999/07/02/NB49806.DTL
Bicycle Trails Council Pushing for Unsafe Trails - Pedestrians and Equestrians will suffer; The Coastal Post
http://www.coastalpost.com/00/7/09.htm
Local Accounts of hiker / biker conflicts and accidents
Novato Horse riders thrown, injured, after run-in with illegal mountain bikers on trail; Marin IJ
http://www.marinij.com/article/ZZ/20130624/NEWS/130629091
Novato biking violation that injured riders and horse ignites online debate on trails, culture.
http://www.marinij.com/article/ZZ/20130627/NEWS/130628993
Conflict on Marin County Trails Returns to the Spotlight – SF Chronicle
http://www.sfgate.com/bayarea/article/Conflict-on-Marin-County-trails-returns-to-6119944.php
Pedestrian Struck by Cyclist Dies – SF Chronicle
Marin IJ; Wake Up Marin: by Connie Berto (Marin Horse Council)
http://www.marinij.com/opinion/ci_14447296
More Illegal Trail Building and Bike Riding in Sensitive Off-Limits Bike Trail in Marin County Open Space
Santa Venetia’s Illegal Bike Problems.
Personal Encounter with biker riders and horse
http://horseandman.com/handy-tips/bicycles-and-green-horses-on-the-trail-together-oh-my/
History of Biker / Hiker Conflicts in Marin County, CA History Frank Lurz,
http://fellsforever.org/articles_on_mountain_biking/mtbhiker-conflicts-in-marin-county-ca/
Injured rider comes home to family
http://changemy--life.blogspot.com/2012/10/hurt-rider-comes-home-to-her-family.html
Altadena: Karin Bugge, Biker vs. Hiker On the Way to Echo Mountain
http://altadena.patch.com/articles/biker-vs-hiker-on-the-way-to-echo-mountain
Bikers and green horses don’t mix on trails.
http://horseandman.com/handy-tips/bicycles-and-green-horses-on-the-trail-together-oh-my/
Letter to Marin Independent Journal from Marina Eisemzimmer on illegal trail riding.
http://www.marinij.com/letters/ci_14862837
Bikers put Horses at Risk; Marin IJ; by Connie Berto
http://www.marinij.com/letters/ci_5859719
Husband and wife thrown from horses caused by speeding mountain biker
http://www.paloaltoonline.com/weekly/morgue/cover/2000_Jun_28.BIKERCOV.html
Other accounts of hiking and mountain biking incompatibility
Mountain Bikes and Wilderness Don’t Mix - High Country Times
https://www.hcn.org/wotr/mountain-bikes-and-wilderness-dont-mix
Whistler Mountain Bike Park: a risky, injury-prone experience, study finds. What to do about that? - Vancouver Sun
Concerns about lawsuits have prompted the state to rip apart a number of illegal mountain bike trails and jumps in Whatcom County. - Seattle Times
Arizona BCH requests National Forests to separate bikes from horses
Headwaters, Montana Mountain Bike user conflicts
http://www.headwatersmontana.org/news/mountain-biking-its-fun-trail-user-conflicts-rise
Hiker v Biker: Altadena: Karin Bugge, Biker vs. Hiker On the Way to Echo Mountain Altadena, CA 2012 User conflicts and safety issues
http://altadena.patch.com/articles/biker-vs-hiker-on-the-way-to-echo-mountain
Bikers and equestrians say neigh to sharing trails at Fort Custer MLive.com
Outlaw Bikers In Rock Creek Park, Illegal Mountain Biking Spooks Hikers and Horses
http://www.washingtoncitypaper.com/articles/9353/outlaw-bikers/
3 - BIKE BANS DUE TO PUBLIC SAFETY DANGERS
The increasing body of evidence of the significant environmental and public safety impacts of allowing mountain biking on hiking and equestrian trails, other than on dedicated fire roads, has led numerous public agencies and municipalities to ban mountain biking on all hiking trails. These uses are simply incompatible on single track trails.
Some references that we ask you to carefully consider are:
Battle of wheels: A mountain bike ban in a Santa Cruz Park could be a signal of more to come; LA Times
http://articles.latimes.com/2005/jan/25/news/os-bike25
Boulder bars mountain bikes from new Anemone Hill loop trail; Daily Camera
http://www.dailycamera.com/boulder-county-news/ci_19194615?source=most_viewed
Dogs can stay; bike ban continues in West Trail Study Area; Daily Camera
http://www.dailycamera.com/ci_17739472
MROSD district lands: Trail tension: Battle brews between bikers and hikers in the foothills; Palo Alto Online
http://www.paloaltoonline.com/weekly/morgue/cover/2000_Jun_28.BIKERCOV.html
Los Angeles Parks ban on biking holds in City action to ban biking on hiking trails
http://theequestriannews.com/2011/04/19/l-a-city-ban-on-trail-biking-holds/
List of California agencies that have bans on mountain biking on hiking trails
• Big Basin State Park (bikes permitted on fire roads only), CSP, Santa Cruz County
• Bolinas Lagoon Preserve, Audubon Canyon Ranch, Marin County (no bikes on trails)
• Butano State Park (bikes permitted on fire roads only), CSP, San Mateo County
• Calero County Park (no bikes permitted on any trails), SCCP, Santa Clara County
• Castle Rock State Park (no bikes permitted on any trails), CSP, Santa Cruz County
• Cataract Trail (no bikes on the trail), Mount Tamalpais (Marin Municipal Water District), Marin County
• Coal Mine Ridge, Portola Ranch Homeowner's Association, San Mateo County
• Fall Creek Unit, Henry Cowell State Park (no bikes permitted on any trails), CSP, Santa Cruz County
• Hidden Villa, Santa Clara County
• Huckleberry Botanic Regional Preserve (no bikes permitted on any trails), EBRPD, Contra Costa County
• Indian Tree Open Space Preserve (bikes are permitted only one trail; others restricted), MCOSD, Marin County
• Junipero Serra County Park (bikes only permitted on park roads; no bikes on trails), SMCPD, San Mateo County
• La Honda Open Space Preserve, MROSD, San Mateo County
• Loch Lomond Recreation Area, City of Santa Cruz, Santa Cruz County
• Los Trancos Open Space Preserve, MROSD, San Mateo County
• Los Vaqueros Watershed (no bikes permitted at the County Line Staging Area, south end of the watershed), CCWD, Contra Costa County
• Maurice Thorner Memorial Open Space Preserve (no bikes permitted on the preserve's trail), MCOSD, Marin County
• Miller/Knox Regional Shoreline (no bikes permitted on the trails in the park's eastern section), EBRPD, Contra Costa County
• Mount Madonna County Park (no bikes on park trails), SCCP, Santa Clara County
• Muir Woods National Monument (no bikes permitted on any trails), MWNM, Marin County
• Napa River Ecological Reserve (no bikes permitted), California Department of Fish and Game, Napa County
• Olompali State Historic Park (no bikes permitted on any trails), CSP, Marin County
• Palomarin Trailhead (no bikes south of Wildcat Camp), PRNS, Marin County
• Pichetti Ranch Open Space Preserve, MROSD, Santa Clara County
• Pulgas Ridge Open Space Preserve, MRSOD, San Mateo County
• Portola Redwoods State Park (allowed on paved roads only), CSP, San Mateo County
• Rush Ranch Open Space Preserve (no bikes permitted on any trails), Solano Land Trust, Solano County
• Sanborn-Skyline County Park (no bikes permitted on any trails), SCCP, Santa Clara County
• Sonoma Coast State Beach (includes Kortum Trail and Bodega Head), CSP, Sonoma County
• Thornewood Open Space Preserve (no bikes permitted on the one trail), MROSD, San Mateo County
• Tomales Bay State Park, CSP, Marin County (no bikes on trails, bikes ok on paved park road)
• Tomales Point Trailhead, Point Reyes National Seashore (no bikes on the trail).
• Uvas Canyon County Park (no bikes permitted on any trails), SCCP, Santa Clara County
• Villa Montalvo County Park (no bikes permitted on any trails), SCCP, Santa Clara County
• Westwood Hills Park (no bikes permitted on any trails), City of Napa Parks and Recreation
• Wilbur's Watch (no bikes permitted), Peninsula Open Space Trust
• Wunderlich County Park (no bikes permitted on any trails), SMCPD, San Mateo County
Legend:
CCWD=Contra Costa Water District
CSP=California State Parks
EBRPD=East Bay Regional Park District
MCOSD=Marin County Open Space District
MROSD=Midpeninsula Regional Open Space District
MWNM=Muir Woods National Monument
PRNS=Point Reyes National Seashore
SCCP=Santa Clara County Parks
SMCPD=San Mateo County Parks Department
Other State Agencies that ban mountain biking on hiking trails
Hidden Villa Farm and Wilderness Preserve
http://www.bahiker.com/southbayhikes/hiddenvilla.html
Nevada County, CA Emigrant Trail Conservancy: Hiking and Equestrian only
http://www.emigranttrailconservancy.org/index.html
Hellman Park Puente Hills Habitat Preservation Authority
http://www.lamountains.com/parks.asp?parkid=633
Lake Camanche Recreation, Ione, California
http://www.camancherecreation.com/recreation/index.php
Ohlone regional wilderness, CA
http://www.ebparks.org/parks/ohlone
L.A. City Parks:
Arches National Park
http://www.utah.com/bike/trails/arches.htm
Canyonlands National Park
http://www.utah.com/bike/trails/canyonlands.htm
Great Smoky Mountain National Parks
http://www.hikinginthesmokys.com/bicycling_smoky_mountains.htm
Mt. Rainer
Green Belt Park NPS
http://www.rundc.com/Doc/MD/PG/GreenbeltPark.htm
State of California Department of Parks and Rec. Goldfields District, Folsom Sector
http://www.garlic.com/~lbha/Pioneer%20Express%20Trail%20Use%20Designation%20Order.pdf
Oahu State Park: ‘Aiea Loop Trail;
http://www.hawaiistateparks.org/hiking/oahu/index.cfm?hike_id=10
Pilot Mountain State Park, North Carolina:
http://www.ohranger.com/nc/pilot-mountain
Michigan Shore-to-Shore Trail:
http://en.wikipedia.org/wiki/Michigan_Shore-to-Shore_Trail
TN State Parks: Cove Lake State Park
http://tn.gov/environment/parks/CoveLake/
Hinckley Reservation, Ohio
http://www.trails.com/tcatalog_trail.aspx?trailid=BGM010-005
Headwaters Montana
http://headwatersmontana.org/news/mountain-biking-its-fun-trail-user-conflicts-rise
4 - MULTI-USE SINGLE TRACK TRAIL STANDARDS
Significant environmental and hazardous impacts result from adding mountain biking as an allowable use on trails, which were previously designated only for hikers and equestrians. This is a well-documented problem. For that reason numerous respected local, regional, state and federal agencies have created extensive guidelines about what must be considered when any change of use is contemplated. They are almost in unanimous agreement that only trails that are at least the width of a service road or fire road should be considered for multi-use that includes mountain biking. This makes the Middagh single track trail totally unsuitable for the proposed change of use.
Some references that we ask you to carefully consider are:
Documents listed here are found at the website addresses, noted below, for the California Parks Department Trails Change of Use: Program EIR Standard Procedures
Change in Use Process
https://www.parks.ca.gov/?page_id=28461
Change in Use Process – List of Documents
https://www.parks.ca.gov/?page_id=28462
Road and Trail Change in Use Evaluation Process Program Environmental Impact Report – Findings of Fact
https://www.parks.ca.gov/pages/795/files/ciu_findings_csp%20change-in-use%20process_04%2029%2013.pdf
Roads and Trails Program
https://www.parks.ca.gov/?page_id=1324
Rails to Trails Conservency: American Association of State Highway and Transportation Officials’ (AASHTO) design guidelines as the standard for multi-use trail widths.
http://www.railstotrails.org/ourwork/trailbuilding/toolbox/informationsummaries/design_for_user.html
Mountain Biking: Issues and Actions for USDA Forest Service
http://www.fs.fed.us/psw/publications/documents/psw_rp226/psw_rp226.pdf
National Parks Service: Report of the Multiple Use Trail Guidelines
http://www.nps.gov/samo/parkmgmt/upload/SmmartMultiUse.pdf
California Equestrian Trails and Lands Coalition: Safety Considerations for Multi-use trails:
https://www.parks.ca.gov/pages/1324/files/trailsguidelines.pdf
U.S. Department of Agriculture with the U.S. Department of Transportation: Equestrian Design Guidebook for Trails, Trailheads, and Campgrounds.
East Bay Parks Summary Report on Multi-Use of Narrow Trails
http://www.ebparks.org/assets/files/narrow_trail_study_final_03_24_11.pdf
Saratoga County NY plan Recreational Trail Standards and Guidelines.
http://nysparks.com/recreation/trails/documents/TrailsTechnicalStandardsandGuidelines.pdf
5 - ENVIRONMENTAL REVIEW AND FINAL DETERMINATION ON PROJECT
We have yet to receive any explanation from the Marin County Open Space District of how the types of environmental impacts and safety issues discussed above, will be addressed in a public process compliant with CEQA or other applicable laws.
The documents cited in the section above illustrate the kind of comprehensive environmental review process that normally occurs for federal and state agencies when proposing to change a trail use, where there is a potential that such change will cause environmental impacts and/or safety issues vis a vis other existing users.
In addition, from what we have heard from members of the public attending the meeting in August, the District appears not to be considering the option of maintaining the status quo for trail use in this area. We urge the District to consider this option as a way to avoid or lessen the substantial environmental and safety impacts that will occur from allowing bikes in this area. In fact, we believe the MCOSD District Road and Trail Management Plan may require retaining the status quo of existing uses, unless it can be shown that impacts will be avoided and existing users not displaced.
See Plan, Policies SW.16-17.
Finally, at this point in time, the public appears to have no information from the District on how it will make a decision on either allowing or not allowing biking on these trails. When and how and by whom will the final decision be made? How will the public be informed of that decision? Will there be an opportunity to appeal any decision made? In our view, the fact that the public has not been informed of the District's procedure in this regard undermines transparent decision-making and public process.
6 - ADDENDUM: ATTACHED EXHIBITS, which are made part of this comment letter by reference.
All of the documents noted in the Addendum were hand-delivered to the Marin County Parks and Open Space District Offices at the Marin County Civic Center on September 23, 2016.
Thank you in advance for your consideration.
Sincerely,
Bob Silvestri
President
Addendum - Attached Exhibits
Exhibit 1 - Mountain Biking: A review of the ecological effects – A Literature Review of Parks of Canada – National Office (Visitor Experience Branch); February 2010 by Michael Quinn and Greg Chernoff at the Miistakis Institute; University of Calgary.
Exhibit 2 -- More Bikes on Marin County Open Space Trails? - Marin Audubon Society: comment on species and habitat destruction; The Clapper Rail; December 2009
Exhibit 3 - ARPN Journal of Science and Technology - The impacts of Mountain Biking on Wildlife and People - A review of the Literature; Michael J. Vandeman, Ph.D.
Exhibit 4 - Conflicts on Multi Use Trails: Synthesis of the Literature and State of the Practice - United States Forest Service
Exhibit 5 - Board of directors of the Medical Society of Metropolitan Portland: In Forest Park, biking and hiking don’t belong together
Exhibit 6 - Marin Voice: Making Public Lands Safe For All Users: by Nona Dennis, president of the Marin Conservation League, Joel Bartlett, president of the Marin Horse Council, and Steven Schoonover, president of Tamalpais Conservation Club
Exhibit 7 - California Recreational Trails Committee; User conflicts and accidents from bikes on multi-use trails
Exhibit 8 - Chronology of growth of User Conflicts on Santa Barbara Front Country Trails System; USDA
Exhibit 9 - NBC Bay Area News; Little Enforcement for Dangerous Behavior on Mount Tamalpais
Exhibit 10 - "Two wheeled trouble on Mt. TAM MARIN" & List of parks that do not allow bikes."
Exhibit 11 - Novato Horse riders thrown, injured, after run-in with illegal mountain bikers on trail;
Exhibit 12 - History of Biker / Hiker Conflicts in Marin County, CA History Frank Lurz,
Exhibit 13 - Resolution Mountain Bicycles On The Prescott National Forest Non-Motorized Trails
Exhibit 14 - Petition: Protect Pogonip: Keep it Bike-free.
Exhibit 15 - Trail Change-In-Use Process at a Glance California State Parks
Exhibit 16 - Change in Trail Use Evaluation Form, California State Parks
Exhibit 17 - Road and Trail Change-In-Use Evaluation Process Program Environmental Impact Report
California Environmental Quality Act Findings of Fact, California State Parks
Exhibit 18 - Road and Trail Change of Use Evaluation Process - Final EIR -- California State Parks
Exhibit 19- Road and Trail Change of Use Evaluation Process - Final EIR - Appendices - comment letters, California State Parks
Exhibit 20 - Designing for User Type - Rails to - Trails Conservancy
Exhibit 21 - United States Department of Agriculture Forest Service Pacific Southwest Research Station Research Paper PSW-RP-226- -Mountain Biking: Issues and Actions for USDA Forest Service Managers
Exhibit 22 - Calif. Equestrian Trails & Lands Coalition June 2005 Safety Considerations for Multi-use Trails
Exhibit 23 - Report of the Multiple Use Trail Guidelines Team
Exhibit 24 - Narrow Natural Surface Trails - Managing Multiple Use
Exhibit 25 - Bicycle Trails Council v. Babbitt; United States District Court for the Northern District of California September 1, 1994