Marin County Parks
The following letter has been submitted to the Marin County Open Space District (MCOSD) to comment on the County staff’s presentation and the resultant discussion at the May meeting of the Open Space Commissioners. This letter raises several concerns that staff failed to thoroughly present, among which is perhaps the core issue for the public: if biking can or cannot be safely integrated into Alto Bowl single-track, hiking, and equestrian trails that have been historically restricted that use.
CVP has long held that the County is approaching the issue of allowing biking in open space incorrectly and in a way that increases the potential for conflicts and public hazards. We believe that bikers and hikers and equestrians cannot all be safely integrated on narrow, single-track trails and that the best way to accommodate biking is to provide bikers with their own dedicated trails.
As shown in several of the Alternative Trail proposals that have been submitted to MCSOD in recent years, propose new ways to best accommodate biking in the Alto Bowl Preserve by separating user types. It is imperative that MCOSD carefully consider and disclose to the public that such options exist and warrant careful consideration.
CVP invites and encourages the local biking organizations to join us in this approach of separating hikers and equestrians from bikers, while integrating biking into Marin County’s open space with their own dedicated trails.
CLICK HERE to view the Alternative Proposals referenced in this letter.
To Mr. Korten, Marin County Open Space District, and Open Space Commissioners,
I’m writing to you as President of Community Venture Partners, Inc. (CVP) and on behalf of local residents and community groups regarding statements made by presenters and staff members at the recent Marin County Open Space Commission meeting held on May 19, 2022. (Video available at: https://marin.granicus.com/player/clip/11355?view_id=49&redirect=true).
At that hearing, the presentation by staff reviewed the physical improvements that have been made to the Bob Middagh Trail and the Horse Hill Trail in the Alto Bowl Preserve, by the Marin County Open Space District (the MCOSD”). Staff also provided a much abbreviated “recap” of events and circumstances surrounding the improvements to and allowable uses of those trails since 2015, which included stating that MCOSD intends to reopen the Bob Middagh Trails to biking at an unspecified future date, even though as it stands today, MCOSD has acknowledged (the signage on the trails was recently changed) that bikes are not allowed on the Middagh.
With regards to any future decision by MCOSD to allow bikes on the Bob Middagh Trail, we request that the District provide adequate public notice of any proposed decision and adequate opportunity for the public to provide comment and input on the District’s proposed decision. In addition, please consider the following comments and incorporated references.
Recent Submissions by the Public and Alternative Proposals
In their presentation of proposals submitted by the public, County staff characterized the list of trail proposals presented to the Commissioners as a “comprehensive list.” However, the presenters failed to inform the Commission and the general public that since 2019, many comments have been submitted by the public, regarding trail use and trail safety, and several new alternative proposals have been submitted to MCOSD by CVP and other community organizations, (“Submissions”) some of which demonstrate very reasonable and cost-effective ways to allow bikes to traverse the Alto Bowl Preserve without opening the Bob Middagh Trails to biking or creating public safety conflicts with existing Alto Bowl trails users.
These recent submissions from concerned citizens demonstrate and disclose new conditions on the trail system in the Alto Bowl Preserve, including a substantial increase in illegal mountain bike riding on these trails since the Middagh Trail was “opened” to bikers in June of 2021. In particular, these submissions show that illegal bike riders are using the Horse Hill hiking/equestrian only trail running north/south just west of Meadowcrest Drive, or illegally coming south on the Fairview Avenue social trail, and then riding down the Horse Hill Trail, which then connects to the Coach/Alto Bowl Fire Road, from which bikers can access the Middagh Trail.
As a result, opening up the Middagh to mountain biking has proven to promote more illegal, off-road riding on the Horse Hill Trail, even though this trail has always been off-limits to bikers. This is an inevitable result of opening the Middagh Trail to biking because it creates an east-west connector route, preferred by off-road bikers, using the Horse Hill Trail to access Middagh heading west.
The Submissions by the community also show that biking on the Middagh Trail has been ongoing, aggressive, and hazardous. (The Marin County Bicycle Coalition still promotes the Bob Middagh Trail as “open to biking” on their website.) Trail damage and erosion are increasing and hikers continue to be regularly forced off-trail to avoid collisions. This is particularly dangerous for seniors, children, and the disabled.
Two of the Alternative proposals submitted, in particular, one by Community Venture Partners, Inc. and one by John Palmer, president of the Scott Valley Homeowners Association, provided options that created new, east/west connector trails, exclusively for mountain bikers, offering bike access across the southern portion of the Alto Bowl Preserve, where off-road bikers coming north from Mill Valley, Tiburon, or Strawberry, Alto Sutton neighborhoods, and north on the Mill Valley Sausalito Multiuse Path, from San Francisco, into the Alto Bowl Preserve, gain improved access to the Camino Alto Preserve trails, to the west.
MCBC and other biking groups have always acknowledged that a convenient east/west connector trail is their top priority and these proposed connector trails would accomplish that and increase connectivity to Region 1 Open Space, to the west.
The new proposed trails are both fully contained with MCOSD-owned land, will have minimal environmental impacts, and meets all RTMP trails guidelines and standards. In addition, at the western end of the new proposed trails by Community Venture Partners, Inc. and the Scott Valley Homeowners Association the County has the option to seek permission from the City of Mill Valley to connect directly to the Mill Valley Sausalito Multi-Use Path (which runs all the way to Sausalito and beyond), at Vasco Ct.
Please note that the creation of an east/west connector route for bikers has been the highest priority for the biking community and the number one argument for opening the Middagh Trail to biking since the beginning. Both of these alternative proposals address this more sustainably without creating any conflicts with other types of existing Alto Bowl users.
For example, the CVP alternative (copy attached) proposes to,
“Create a new, east/west connector trail offering bike access across the southern portion of the Alto Bowl Preserve, where off-road bikers coming north from Mill Valley, Tiburon, or Strawberry, Alto Sutton neighborhoods, and north on the Mill Valley Sausalito Multiuse Path, from San Francisco, into the Alto Bowl Preserve, gain improved access to the Camino Alto Preserve trails, to the west. Biking groups acknowledge that a convenient east/west connector trail is desirable.
This new connector trail will improve connectivity to Region 1 Open Space, and provide off-road bikers with an exciting, low-conflict east/west bike route to the west, with varying grades and clear sight lines.
“The new trail is fully contained with MCOSD-owned land, will have minimal environmental impacts, and meets all RTMP trails guidelines and standards. NOTE: In 2016, a new bike lane was installed along the north/south route of Camino Alto, providing more biking options in the Alto Bowl area.”
Concerning meeting RTMP goals, it notes,
“This proposal for a new east/west connector trail in the southern Alto Bowl Preserve meets all RTMP goals and design, sustainability, and management standards. It will reduce maintenance and decrease environmental degradation, illegal off-trail riding, trail hazards, and user conflicts. It will increase trail safety, enhance the experience for all Alto Bowl Preserve users, and better serve bikers’ needs.
“MCOSD’s attempt to open the Middagh Trail to biking failed, not just because the courts "set aside" its illegitimate approval, but because it violated the RTMP's goals and policies, noted above. It also failed to create a legitimate “east/west connector,” as promised, and it did not “improve connectivity to Region 1 Open Space preserves,” as it stated, because the Middagh Trail can only serve as an east/west "connector" if bikers get to it by illegally riding on the Horse Hill Trail to the east.
“As a result, illegal biking on the Middagh increased illegal biking on the Horse Hill Trail, increased trail hazards, user conflicts, and trail and environmental degradation.Finally, the MCOSD Middagh proposal failed to address bikers' real need for a logistically effective Alto Bowl east/west connector, which is best served by a southern route.”
Regarding the proposal’s “consistency” with RTMP policies, standards, and Guidelines, it notes,
“It is a matter of record that biking on single-track hiking/equestrian trails displaces existing users, increases user conflicts, and reduces public safety. A new biking trail will separate users, to the benefit of both.
“This proposal aligns with goals and policies of the RTMP: Policy SW.12, “strive to increase road and trail connectivity.” It conforms to BIO-4.k, to “protect habitat and wildlife corridors,” and BIO-5.f “clearly marked” access, and supports GOALS TRL-1 (“expand trail network”), TRL-1.2 (“expand trail system”), TRL.1.d (“complete trail systems”), TRL-2.3 and TRL-2.e, (“user” and “public safety”), TRL-2.6 and P3 (“multiple access points”), TRL-2.8 and T2c (provide “signage”), and Policy T.1 and SW.12 (“loop connectors”).
“A southern connector is superior to any northern route (e.g., The Middagh), per Policy SW.16, "The MCOSD may prohibit certain trail uses or apply increased trail use restrictions within certain areas to enhance safety, minimize conflicts between trail users and protect natural resources." And Policy SW.17, “strive to prevent displacement of equestrians and pedestrians when accommodating trail access and trail connections for mountain bikers” and “take care to maintain connectivity between destinations for user groups historically using those trails.”
Similarly, the Scott Valley Homeowners Association Alternative Proposal (copy attached) proposes to,
“Create a new east/west connector trail, starting where the Highway 101 multi-use path meets the end of Lomita Rd., across the southern Alto Bowl Preserve border to Vasco Court (See map, attached). Install 5 ft. bench cut following existing topography, having varying but gradual slopes, good natural drainage, and largely unobstructed sight lines. Habitat disruption and vegetation removal are minimal. No streams or registered species are impacted. The new trail is within MCOSD lands. The trail will meet or exceed all RTMP trails guidelines and construction and maintenance standards.”
And notes that,
“Keeping bikes off the Middagh is a superior solution for all, because it encourages legal biking, and is supported by Policy SW.16, "The MCOSD may prohibit certain trail uses or apply increased trail use restrictions within certain areas to enhance safety, minimize conflicts between trail users and protect natural resources." And is supported by Policy SW.17, “strive to prevent displacement of equestrians and pedestrians when accommodating trail access and trail connections for mountain bikers” and “take care to maintain connectivity between destinations for user groups historically using those trails.”
“The illegal east/west route via Horse Hill Trail and onto the Middagh Trail is much longer than the new trail we show in our RTMP Trails Proposal. Our new, southern, east/west connector offers a much shorter route and less surface street riding than the illegal path bikers are now using. It offers a more immediate, safe, and legal east/west connector route for bikers coming from the south to access the fire roads in the Camino Alto preserve, which is the primary, stated goal of biking advocates.”
As we have argued before the courts, allowing bikes on the Middagh Trail violates policies set forth in the RTMP to "prevent displacement of equestrians and pedestrians when accommodating trail access and trail connections for mountain bikers." (Policy SW.17) and to ban bike riding in instances where it "compromises public safety." (Policy SW.3).
The RTMP Trail Plan policies strive to "improve the visitor experience and visitor safety," and to "prohibit certain trail uses or apply increased trail use restrictions within certain areas to enhance safety, minimize conflicts between trail users and protect natural resources" (Policy SW 16)
The Trail Plan requires the District to "protect sensitive habitat and natural resources" (TRL‑2.1); "maintain trails to protect the safety of trail users" (TRL‑2.3); "Promote Harmony Among Trail Users" (TRL‑2.g), and "monitor the type and frequency of violations," (TRL2.p).
Given that feasible alternatives for off-road connections for bikes, exist, and that new facts showing that allowing bikes on the Middagh Trail will result in illegal riding on the Horse Hill Trail, facts that have not previously been considered by the District, the District cannot open the Middagh Trail to bike use and at the same time be consistent with these RTMP policies.
In support of these comments, please also consider and evaluate the facts presented by the August 2020 submissions for future projects in the Horse Hill Preserve by Mari Robinson, Marla Orth, Suzanne Gooch, and the Marin Horse Council concerning alternative routes for bikes, the impacts of recent bike riding on the Middagh Trail and the new information that the opening of bikes caused a new major biking loop to be created, leading directly to illegal riding on the nearby Horse Hill trail.
Please also consider the facts in the form of letters, comments, and incident reports included in the administrative record of CVP v. Marin County Open Space District, (Marin Superior Court Case No. CIV 1701913) showing adverse impacts and conflicts between bikers and hikers and equestrians that are foreseeable if bikes are allowed on the Middagh Trail.
Respectfully, Bob Silvestri
President, Community Venture Partners, Inc.
Bob Silvestri is a Marin County resident, the Editor of the Marin Post, and the founder and president of Community Venture Partners, a 501(c)(3) nonprofit community organization funded by individuals and nonprofit donors. Please consider DONATING TO THE MARIN POST AND CVP to enable us to continue to work on behalf of California residents.