YSGTC Statement on 007 MRP
Yosemite South Gate Trail Cooperative (YSGTC) would like to express provisional support for Alternative 3 (Alt. 3) of the USFS’ recently published Environmental Assessment (EA) of the Motorized Recreation Plan (MRP). Our reasons for supporting this alternative are outlined below.
It is our understanding that “Existing Conditions: No Action” of the MRP’s EA are off the table, though we are perplexed as to why it is included in the published EA without an explicit declaration that “Existing Conditions: No Action” is not up for consideration (see Appendix I for more on this).
Alternative 2 (Alt. 2) of the MRP’s EA would present a grave conflict between a newly legalized motorized user group and the mountain bikers, who have been using the trail for nearly four decades (see Appendix II). Mountain bikers travel down the trail at speeds up to 35 MPH, and motorcyclists travel up the trail at similar, if not greater speeds. Given the stopping capability of each vehicle, collisions are inevitable. Collisions have already occurred, and have already resulted in injuries to mountain bikers, though not yet to motorcyclists, as they are much better protected, both by the weight of their vehicle and the nature of their protective gear. Such collisions are likely increase considerably if Alt. 2 is implemented. The implementation of legalized two-way traffic on “007” with the increase in users over the past decades would legalize and institutionalize a dangerous user conflict.
Therefore, we support the compromise agreement worked out between YSGTC and the Stewards of the Sierra National Forest (SOTSNF) during the scoping phase of the MRP, which appears in in the recently published EA as Alt. 3., albeit in a form not entirely as agreed by the two volunteer groups representing the interests of both user groups. We support Alt 3. provisionally because some minor changes are needed to bring the compromise back into accord with the concessions each group made in our June 18, 2019 meeting. The following changes (so long as they comport with USFS Design Criteria [DC] regulations) are necessary to avoid the user conflicts stated above:
(A) directional downhill (DH) designation for BP 82, together with appropriate reinforcements, (drainage, hardening, and armoring), and constriction of earthen water bars constructed so as to serve as mountain bike features to maintain the historic user enjoyment of the trail and its namesake.
(B) Appropriate reinforcements, (drainage, hardening, and armoring), and realignment on BP 81.
(C) An adjustment to the realignment (as agreed between the SOTSNF and YSGTC at our June 18, 2019 meeting) on BP 80. All of these changes will be necessary to maintain a safe and quality trail for mountain bike use.
All of these changes to the trail should comport with the USFS Trails Management Handbook both for motorcycles and for bicycles (i.e., mountain bikes).1
Notes:
1. https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5403615.pdf
The appendices below contain statements that may or may not pertain to the MRP AE as written but express sentiments that we believe the USFS should consider in making a decision, and we would like them to stand as part of the public record.
Appendix I:
A majority in the mountain bike community feel like we have been somewhat left out and misled on the earliest developments of the MRP and how 007 would be incorporated into the MRP. — i.e., that this was a fait accompli, and that we would only be able to give an up or down opinion on Alt. 3 which is a compromise solution to ensure mountain biker safety vis-à-vis motorized users and so is our only choice. Whereas the motorized user community (though much smaller) has two choices: one wherein they get everything, and another wherein they get almost everything. From our perspective, the only other option, viz. Alt. 2, which is anathema to mountain biker interests, is a big loss for mountain bikers. It is worth remembering that all of this debate is concerning but a scant 3 miles of trail that we’re advocating to maintain for mountain biker enjoyment — this of nearly 27 miles under consideration in the BLRD, and many, many more miles in the HSRD. But there is no option that allows these trails that have special concern for mountain bikers to be left out of the MRP altogether. This continues to perplex us. (Put simply, it is either Alt. 2 or Alt 3, whereupon we are forced to make the better of two poor choices with no option for what is best for human powered users.). For motorized users it is good vs. best, whereas for mountain bikers it is good/not so good vs. bad.
Had we known that this was the pre-ordained choice, we might have sought legal advice on how to preserve these trails in our best interests, but the whole process has been rather arcane to those of us on the outside, while those on the inside (representatives of the SOTSNF) , several of whom are retired USFS employees, have had a special relationship — a standing monthly meeting with the USFS Forest Supervisor, no less(!), wherein the architecture for the plan seems to have been largely worked out until it became public and mountain bikers got involved.
Pending the USFS Decision, we presume that we will have standing to contest whatever inequities might arise in the MRP Decision, and we are meeting with legal counsel to see what our options might be.
Appendix II:
We understand that prior to the Travel Management (TM) reforms of 2011, which explicitly prohibited motorized users (OHV) — to include motorcycles —from operating on BP 82, BP 81, and BP 80 (the so-called 007 trails), motorcycles had been in the habit of using these trails legally. We also understand that the top one mile of BP 82 (viz. 6S42G) is and has always been legal for motorized use, as it is inventoried as a road in the USFS inventory. We further recognize that BP 82 and BP 81(the original 007) was a service road in the early 20th Century, and that a motorcyclist was the first to cut back the brush to begin riding up the road in the late 1970s. A small group of motorcyclists began to use the trail. Mountain bikers began using the trail shortly after in the early 1980s, and as mountain bikes have gained in popularity, mountain bikers have become the largest user group by an order of magnitude.
With all this history in mind, we would like to underscore that mountain bikers have been using the 007 trails since the early/mid-1980s, and as usership has increased over the years there was a long period wherein conflicts were rather inconsequential, as there were relatively few users in each user group (motorcyclists and mountain bikers). However, as both user groups grew, and with the general lack of maintenance on BP 82, compounded by the implementation of restrictions on motorized use with TM II (which closed the forest to cross country motorized travel) in 2011, the 007 trail underwent severe erosive damage to the soil integrity with continued motorized use under a USFS policy of benign neglect. With the extremely heavy rainfall of 2017 the trail experienced considerable damage. With the convergence of these contingencies 007 has become a bone of contention between mountain bikers and motorcyclists, as the increased number of motorcyclists present a clear and present danger to the much more largely increased mountain bike user group. The growth of the mountain bike industry has exceeded that of the motorcycle industry considerably (see notes Appendix IV with notes). Indeed, growth in the OHV industry has come mostly from the sale of UTVs (see idem), which present a conflict with non-motorized users (to include mountain bikes) in this immediate region on Central Camp Road, because of the greater speed at which UTVs travel. (Note: this conflict is not present between motorcyclists and UTV drivers, if each abides by lawful USFS speed limits).
The Stewards claim that these trails hold particular historical importance to them, which other than the sense of entitlement stemming from having had access to these trails for some 25 years preceding the closure of these particular trails (together with numerous other trails) when Travel Management 2 was decided and “implemented” back in 2011, we struggle to see what “history” they are referring to. However, mountain bikers do have a somewhat long, historical connection to the 007 trail(s): e.g., there were cross country mountain bike races as far back as the late 1980s, and a downhill race that ran from the mid-1990s through the early 2000s, all with the approval of and permitted by the USFS. We have a memorial, which is still maintained, to a mountain biker (Eric Mendez), who passed away due to a heart attack back in 2009. And we have had a steadily increasing presence on these trails over the past several decades resulting in our being by far the most frequent users of the BP 82, 81, and 80 trails (what we call 007).
Appendix III:
First and foremost, the proposed MRP as it relates to the Bass Lake Ranger District (BLRD) appears to violate the language explicated in the MRP Draft EA, specifically in 1.0 Introduction, wherein of the seven bullet points listed below the paragraph outlining the purpose of the MRP, no fewer than four of the bullet points contradict both Alt. 2, and Alt. 3 of the planed MRP (especially Alt 2):
"The SNF has committed to the motorized recreation community to examine routes and areas that were not previously analyzed and decided in the 2010 Travel Management Environmental Impact Statement (EIS) or the 2012 Travel Management 2 Environmental Assessment (EA) for potential addition to the NFTS. After two public meetings and numerous comments received, the Motorized Recreation Project (Project) incorporates roads, motorized trails, and areas that meet the following criteria into the development of the alternatives:"
1. Recreation opportunities are enhanced by creating loop options and/or connect to motorized trails, roads, and areas/destinations.
It is debatable whether the inclusion of BP 82, BP 81, and BP 80 actually enhance opportunities, as there are already sufficient and more sustainable routes (e.g., Central Camp Road) to connect motorized users to their destinations. By their own admission (in our meeting with the SOTSNF we were reminded repeatedly that motorcylicsts use the 007 trails to access their destinations in the Shuteye and Whiskey Falls areas), and as can be observed in their consistent use of the trails, motorcyclists travel up BP 82, up BP 81, and up BP80 (and BP 100), but never make loops on the 3 miles of trail in question. They generally travel up to their preferred riding, and then back down the road, only seldom riding back down the trails they had illegally come up, which is by definition not a loop.
It is highly probable that increased danger due to user conflict resulting certainly from Alt 2, (with increased likelihood even in Alt 3) and the likely degradation of trail conditions will actually reduce recreation opportunities for mountain bike users, who are among the fastest growing and assiduous of recreational user groups.
2. Route is unique (parallel trail/road that does not go to the same location or overlap with trail/road that already exists).
BP 82, BP 81, and BP 80 are not unique for the purposes of motorized use, as they serve as options parallel to an existing trail/road, viz. Central Camp Rd., which crisscrosses BP 82 and BP 81, with BP 80 being accessible from nearby Francis Junction Rd. Central Camp Rd. goes to the same location(s) as BP 82, BP 81, and PB 80 via Francis Junction. Should BP 82 be re-graded to its original width and contour as proposed in the MRP, it would serve as little more than a parallel option with much the same character as Central Camp road itself and would therefore be redundant.
6. Areas and routes located in highly used Off Highway Vehicles (OHV) geographic areas are priority.
Seeing as there are already abundant routes and areas dedicated to OHV recreation (e.g., the nearby Miami Creek OHV Trails, and the many miles of trails in the Whiskey Falls and Cascadel areas very near BP 82, BP 81, and BP 80), it seems that classifying the BP 82-80 trails as "priority", especially given their proximity to Central Camp Road (as noted above,) is without sufficient justification.
7. User conflict is addressed.
Since the meeting with the SOTSNF on June 18, 2019, mountain bikers and trail runners have had numerous confrontations and even several collisions resulting in injury to the non-motorized user. Some of these encounters, even when not physical, have been acrimonious to say the least. Motorcyclists will often "roost" dirt onto non-motorized users after having been forced to slow down. Many verbal altercations have occurred, and threats to run over non-motorized users have been made. Suffice it to say that as non-motorized users we cannot say confidently that these conflicts will be addressed by the proposed changes to the current prohibition of motorized users on BP 82, 81, and 80. From our perspective, SOTSNF has not encouraged their members and constituents to refrain from illegally using the trails under discussion.
Moreover, with the stark increase in motorized traffic on Central Camp Road, both by motorcycles and especially by the recently introduced technology of so-called side-x-side vehicles (Utility Task Vehicles, or UTVs), and more performance oriented so-called Razor OHVs, which together have seen a 96% growth since 2006 and an anticipated 32% growth over the next five years according to an article in Specialty Equipment Market 2 (and yet these figures are belied by what seems to be a nigh one-thousand percent increase in presence in the BLRD area over the past year alone, as we experience multiple groups — often 5 to 10 in number — of side-x-side/UTV type vehicles several times daily blasting up the road). Mountain Bikers have experienced still further threat of physical harm by such vehicles traveling far in excess of the legal speed limits on USFS roads, drifting through turns, passing without giving safe berth, and dusting (sometimes clearly intentionally) non-motorized users out as they pedal up, or run up the road. These behaviors are verging on terrorizing non-motorized users. Hence, we maintain that non-motorized users ought not be forced to travel up Central Camp Road in such conditions.
Appendix IV:
In an ideal world where we might have an equitable choice YSGTC would likely endorse ‘Existing Conditions: No Action’, if that were on the table, which would mean continued prohibition of motorized use of BP 82, BP 81, and PB 80 (as well as BP 100, which appears to be off the table now due to the additional user conflict between a cattle rancher and OHV users), but with the added measure(s) of clear signage, improved communication among and between user groups, both OHV and human powered, and — when needed — enforcement. We would hope and champion the SNF seeing fit to allow and encourage motorized users to improve and maintain their existing OHV areas and the entirety of the MRP with the exception of 007 in the BLRD, and we would hope that the SNF would allow mountain bikers and other non-motorized users to continue to use, and also in the future be allowed to maintain the trails in question (BP 82, BP 81, and BP 80). As there are no mountain bike specific trails in the SNF, even while there are many OHV recreation opportunities in both the BLRD, and the High Sierra Ranger District (HSRD).
Since Travel Management 2 in 2011, advancements in mountain bike technology and capabilities have attracted many more people to the sport, an increase in this particular user group that sees no sign of slowing. (See the links below for industry growth.)3, 4 & 5 The literature on the economic and social benefits of mountain bike tourism and local usage to mountain communities is clear, as study after study indicates. Mountain bikers as a community are eager to spend money locally and enhance the prospects of otherwise remote towns and areas (see links below)6, 7 & 8. Still more, mountain bikers are an extremely conscientious group and are excellent stewards of the forest, more often packing out the trash and debris of other users than leaving their own behind. We think it is in the interests of the USFS to encourage mountain biking and responsible mountain bike access, as studies show that it has a low environmental impact, far lower than other user groups — e.g., equestrian and especially motorsport and OHV users.
We are happy and grateful to have the USFS enforcing the motorized vehicle restrictions at the bottom of 007 (BP 82), as it has made a big impact on human powered user enjoyment. And as the officers (Cori Hayth and Franny Adams), who have been demonstrating a presence and giving guidance to motorcyclists, can testify, we mountain bikers far outnumber motorcyclists, and as they can likewise attest, we have a wide range of ages (8 years old and younger through adults of all ages), which means generations of eager volunteers for the forest.
Yet, as we embark on this “compromise” we are also discouraged in this eleventh hour that the SOTSNF have not taken us up on our request to walk the trail and share our mutual concerns in a constructive way, and we are somewhat troubled at the prospects that the trail will not be kept mountain biker friendly and will end up like Miami Creek OHV area, which would be disastrous for us. The local communities likewise would suffer, as they would feel the impact of mountain biker absence from the area.9 We hope all of this will be taken into consideration as the MRP Decision moves forward.
Notes (2-8):
2.) https://www.sema.org/sema-news/2019/07/upward-trend-in-powersports
It is notable that the majority of growth in the motorsport industry is in UTV sales rather than motorcycle sales.
4.) https://www.polarismarketresearch.com/press-releases/global-mountain-bike-market
5.)
6.) https://www.imba.com/resource/impacts-mountain-bike-tourism-oakridge-or
Oakridge OR was a dying former lumber mill town, much like North Fork. Mountain biking has added a much-needed boost to its economy, as several of our members who have visited can testify.
Key findings in the conclusion of this study include:
In the case of the Marquette area mountain biking trails system, several local organizations have worked together to develop an ecotourism model that has added to the quality of the economy and the culture of the area.
In order to develop a successful mountain biking ecotourism economy, a community must develop and maintain quality trails that provide riding opportunities for riders of all skill levels.
8.) https://www.youtube.com/watch?v=lFAuFH9V5mc