Sequoia and Sierra Forest Plan Revision

Re: Comments on Sierra and Sequoia National Forest Revised Draft Land Management Plan

September 18, 2019

To the Attention of the USFS – Planning Team,

The Yosemite South Gate Trail Cooperative (YSGTC) appreciates the opportunity to comment on the revised draft management plan for the Sierra and Sequoia National Forest. Founded in 2017, YSGTC is a 501c3 non-profit, volunteer group of dedicated mountain bikers working in the Sierra National Forest in Central California.  YSGTC actively encourages responsible riding, volunteer trail work, and cooperation among trail user-groups and land managers. Our mission is to promote sustainable non-motorized use in our Sierra National Forest and its environs. To this end we also support and encourage youth involvement in maintaining and learning about our National Forest resources. In our first two years we cut out over 300 hundred trees from our multi-user-group trails in the Southern Yosemite/Bass Lake region.  Our efforts have been recognized by the Forest Service with the Restoration Award, and the President's Volunteer Award for 2018. Our public comment follows.

Many of the specific areas addressed by the RDLMP are encouraging for the mountain bike community, and we are glad the USFS has included these in the plan. Specifically, we are encouraged by:

1.       Forest Service’s emphasis on sustainable recreation in the draft plan. We appreciate the stated desire to provide “a range of year-round developed and dispersed recreation settings that offer a variety of motorized and nonmotorized opportunities and recreation experiences that provide satisfying experiences for the variety of visitor preferences.”

2.       Forest Service recognition as a Desired Condition “[a] sustainable system of trails [that] provides for opportunities that connect to a larger trail system, provides linkages from local communities to the national forest, and is planned, designed and managed to be compatible with other resources.”

3.       Specific language throughout the draft plans that aims to improve collaboration and productive partnerships between the Forest Service and local communities and user groups for the appropriate—and in many cases long overdue—enhancement, maintenance, and long-term stewardship of sustainable recreation infrastructure and facilities. There is an army of volunteers ready and willing to adopt these trails, to become the stewards of every trail in the inventory that is suitable for mountain biking (both bike-packing and general trail riding). Individual, groups and organizations want to take leadership on this, and we appreciate any plan component that takes this into account and utilizes it to the best potential for forest management.

4.       Alternative B and the limited amount of Recommended Wilderness areas to be included.

5.       Backcountry Management Areas as a means to preserve the wild characteristics of certain places, while providing for continued recreational access.

We are also concerned with some areas of the plan, as it is our opinion that they do not provide the necessary framework to maintain, improve, and expand non-motorized recreation access where appropriate and sustainable. We would like to see plan components more adequately address a process by which existing mountain bike access is not threatened and ensures that increased access is possible within the context of sustainability as defined by the Guidelines for a Quality Trail Experience developed by the Bureau of Land Management:

Environmental Sustainability — Will the trail provide for resource protection? This is the definition that is commonly used when referring to what does or does not provide for a sustainable trail.

Social Sustainability — This is frequently overlooked in the trail development process. Evidence of the failure to meet desired user outcomes (experiences and associated benefits) are everywhere: overcrowded trails, trails with little use, trail users who feel “pushed out” by other users, and unauthorized routes.

Economic Sustainability — Can the land manager and the community bear the long-term costs of maintaining a trail? If it provides a valuable experience, it is likely worth the investment, but it must be weighed against shrinking maintenance budgets.

Additionally, we would like the plan to address the lack of purpose-built mountain bike trails in our National Forest. YSGTC, being a strong advocate for all types of non-motorized travel in our national forests, nevertheless remains a group of mountain bikers dedicated to preserving and acquiring access to trails for mountain biking, be they shared use (viz. all trails in current inventory), or trails specific to mountain bike use (viz. future trails that would allow mountain bike specific/preferred access).  It is our hope that our dedication to the maintenance of the shared-use trails we vigilantly and diligently keep free from fallen trees and in generally good repair will be given consideration by the USFS in the new Plan for managing our forests. 

The agency’s own information currently distributed at the High Sierra Visitors Center states that: “Mountain Bikes can be ridden on trails designed for hikers, equestrians, motorized bikes, and four-wheel drive vehicles.” That statement is very telling of the current situation facing mountain bikers in the Sierra National Forest, and it is a real problem that must be addressed in order to “provide a high level of visitor satisfaction” for those of us who choose to ride mountain bikes in the forest. Again, the GQTE from the BLM can offer some guidance:

Quality is defined as excellence. In the context of mountain bike trails, excellence is realized when a trail design merges the desired outcomes and difficulty that a rider seeks with the setting in which the outcomes are realized. These variables ultimately equate to an overall level of sustainability that protects resources while simultaneously providing a rider with the outcomes they seek.

To this end, areas of concern that we seek to highlight in this process are based on current trail access, past access, and future access, both maintaining access to current trails and expanding and improving the network through access to new trails. These concerns are:

1.       The Forest Service should further recognize the important social and economic benefit of such a trail system to local communities and to the broader public, and also to acknowledge that a comprehensive and sustainable trail system must include a balanced range of motorized and nonmotorized recreation opportunities, including, specifically, mountain biking opportunities within appropriate Sustainable Recreation Management Areas and Backcountry Management Areas.

2.       We would like to see specific language that promotes the development of purpose built mountain bike trails. Most trails that are open to mountain bikes on these public lands were designed with other trail users in mind; OHV, hikers, and equestrians all have access to purpose-built trails in these forests, but in the Sierra National Forest, and especially in the High Sierra Ranger District, there are very few purpose-built mountain bike trails (indeed, only the trails at the privately managed ski resort, China Peak, can be said to fit this rubric). We are left to ride (and maintain) trails that were built with other users’ needs in mind. The need to expand the network with purpose-built, multi-use single-track is critical to ensuring access to the type of experience that will “provide a high level of visitor satisfaction.”

3.       Areas designated as Recommended Wilderness in Alternative C are problematic, as many of the areas have existing mountain bike access that would be lost through designation as RW, and other areas are suitable locations for expansion of mountain bike access. We cannot support the designation of these areas as RW, specifically:

a.       Shuteye RW conflicts with current trails and with future desired trail projects.

b.       Ansel Adams Wilderness San Joaquin Addition is the location of the French Trail, and this is an area where future mountain bike access is desirable and expansion and realignments are needed to improve the user experience (both bike-packing and general trail riding).

c.       Dinkey Lakes Wilderness Bear Mountain Addition is an area that should be considered for the future development of a purpose-built mountain bike trail.

d.       Dinkey Lakes Wilderness Addition 1 is an area that would provide trail connectivity between Kaiser Peak and Red Mountain via Badger Flats. Existing trails should be considered to allow access to mountain bikes.

4.       Some areas designated as Recommended Wilderness in Alternative E are problematic because they are in areas with existing trails or identified as potential new trail projects.

a.       Dinkey Lakes Wilderness Bear Mountain Addition should be changed to BMA

b.       Ansel Adams Wilderness San Joaquin Addition should be modified to allow access to the French Trail and allow for improvements and development of better trails here.

5.       Backcountry Management Areas are, at first glance, a suitable alternative to RW, as current access would continue under BMA status, but we would like to see specific language that defines BMA to allow for development, improvement and maintenance of mountain biking trails. Without better language to define BMA as such, problems with BMA designations in Alternative E are:

a.       Shuteye BMA – not only adjacent to Shuteye trail but also encompassing the network to the south and west (inside the loop).

b.       Other BMA near Bass Lake overlap with Willow Creek and Central Camp trail.

6.       Some areas of concern specific to Sequoia National Forest are as follows:

a.       Slate Mountain RW – There are numerous conflicts with existing mountain biking in this area: Summit Trail, Bear Creek, Nelson Trail. We are opposed to this RW and suggest BMA as long as the appropriate changes are made to BMA definition to allow for development, improvement and maintenance of mountain biking trails.

b.       Stormy Canyon/Cannell Peak RW - numerous conflicts: Whisky Flat, Tobias Creek, Cannell Meadow, Sherman Pass, Kern River Trail, Cedar Canyon (near boundary), Portuguese Pass (near boundary).

7.       Existing mechanized transport, and motorized travel and uses, for example use of mountain bikes, should be allowed to continue in any new RW if such uses do not prevent the protection and maintenance of the social and ecological characteristics that provide the basis for wilderness designation.

8.       We understand the need for a PCT management area to be defined, but existing trails that are available for public mechanized travel within the PCT management area, including trails that cross the PCT, should remain open for public mechanized travel.

These specific areas of concern listed above are of core importance, but we also believe that incorporating more specific language—along with particular goals, standards, guidelines and potential management approaches—regarding appropriate mountain biking opportunities and trails infrastructure is the best way to address the needs of a large and growing recreational user group. Furthermore, integrating such language into other relevant forest-wide plan components, including watershed conditions, riparian and meadow restoration, and vegetation/fuels management is the approach that we suggest. For example, we suggest that the following plan components be added to final draft plans:

Under Forestwide Components for Watershed Conditions:

Standard: Where historic and current use trails exist with potential adverse impacts to watershed quality and aquatic and riparian conditions, seek to engage partners and recreation user groups to assist in re-routing trails around sensitive areas such that they can thereafter be sustainably maintained to standard.

Under Forestwide Components for Terrestrial Ecosystems:

Guideline: Mechanical vegetation treatment projects should consider recreation facilities, infrastructure and opportunities, including trails, roads, signage, camping, climbing and parking areas as appropriate to the context of the landscape, watershed, wildlife, and forest health management scenarios.

Potential Management Approach: Work with partners to re-route, re-align or restore existing system trails as necessary during vegetation management projects to provide for better fire management solutions, to improve maintenance and connectivity of existing recreation infrastructure and trail systems, and to support sustainable recreation opportunities.

Under Complex Early Seral Habitats:

Guideline: Post-disturbance restoration projects should be designed to optimize and enhance appropriate recreation opportunities and trail system infrastructure.

Under Fire:

Potential Management Approach: Where feasible and suitable, consider all available tools and methods to reduce vegetation buildup to lower the risk of unwanted wildfire, including grazing, mechanical treatment, system trail maintenance, prescribed fire, or wildfires managed to meet resource objectives.

Potential Management Approach: Consider re-routing or re-aligning existing system trails to provide for better fire management solutions, to improve maintenance of existing recreation infrastructure, and to support sustainable recreation opportunities.

Under Sustainable Recreation:

Goal: Collaborate with local mountain bike user groups and volunteers to improve and maintain to standard a connected and accessible network of sustainable purpose-built nonmotorized mountain bike trails within appropriate Sustainable Recreation and Backcountry Management Areas.

Guideline: Work with local and national partners to educate users on best practices for reducing conflict and to sign shared-use trails with information on trail etiquette and to promote responsible behavior.  Additionally, collaborate with local user groups (including mountain bike groups) to sign trails clearly where motorized traffic is not currently allowed by law to discourage illegal use and abuse of trails and resources.

Potential Management Approach: Collaborate with local mountain bike user groups and volunteers to improve and maintain to standard a connected and accessible network of sustainable purpose-built nonmotorized mountain bike trails within appropriate Sustainable Recreation and Backcountry Management Areas.

Potential Management Approach: Conduct nonmotorized recreation activity planning where and when needed, looking for opportunities to connect single-track loops, provide accessible options for mountain biking from communities, and complete routes in areas with high visitation.

Potential Management Approach: Use trailhead and camp hosts or volunteer patrollers, including volunteer mountain bike patrollers, to educate and interact with the public to promote responsible and sustainable public use practices.

Under Cultural Resources:

Guideline: Where existing or historic use trails are determined to impact cultural resources, engage partners to help implement appropriate re-routing or mitigation measures in order to maintain access and trail system connectivity.

Under Infrastructure:

Desired Condition: Sustainable motorized and nonmotorized trail networks allow for a wide variety of recreation opportunities and access with minimal adverse effects to wildlife, riparian and aquatic resources, or other forest uses.

Under Management Areas > Sustainable Recreation:

Incorporate specific Desired Conditions, Objectives, Standards, Guidelines and Potential Management Approaches for development and maintenance of sustainable mountain bike system trails within each recreation management area (Destination Recreation Area, General Recreation Areas and Challenging Backroad Areas).

Define specific Desired Conditions, Objectives, Standards, Guidelines and Potential Management Approaches for mountain bike trails in Backcountry Management Area designations.


We thank the Forest Service and the individual members of the planning team for the opportunity to voice our comments on this critically important process to determine the management of our public lands, and we look forward to continuing our involvement in this process as the next steps are undertaken. Our primary concern is ensuring that mountain bikers have a voice in this process, and we thank you for taking the time to listen.





List of desired projects for Sierra National Forest

         I.            Lakeshore trail at Bass Lake

       II.            Stacked loop at Jose Basin

     III.            Alpine sightline trail at Bear Mountain

    IV.            San Joaquin trail connectivity from Skaggs Bridge to Mammoth Pools

      V.            Trail connectivity from Kaiser Pass to Shaver Lake

    VI.            Trail connectivity from Tamarack Ridge to Bald Mountain trailhead

   VII.            Trail connectivity spanning Sierra and Sequoia National Forests to become a section of a proposed statewide, north to south, alternative route to the PCT. Mountain bikes should have access to the PCT, at least in part, in our opinion. But rather than fight that losing battle we would like to see all national, state, and local agencies cooperate on this long overdue trail plan. Several routes from the southern end of Sequoia NF to the northern end of Sierra could be suggested, but the overall concept needs to be a part of the USFS plan.