Archive for the ‘Trail Access’ Category

LA County: Santa Susana Mountains Trails Master Plan Update

Wednesday, March 12th, 2014
Santa Susana Mountains Trail Master Plan Meeting

Kathline King introduces the SSMTMP

At last weeks second public meeting on the Santa Susana Mountains Trails Master Plan, the County presented a comprehensive map showing their planned trails, the existing trails, and the relevant delineations of private, public and utility lands. While public comments were made, they weren’t being recorded.

CORBA would like to express our sincere thanks and gratitude to L.A. County Parks and Recreation Planning Division staff for moving this trail plan forward, and to Supervisor Antonovich for his support of the process. CORBA whole-heartedly supports project, the process, and the deliverables (maps) presented at the meeting last week.

In looking at the final draft map, we were pleased to see that the agency had listened to the prior comments asking to expand the study area so that true connectivity between disparate open spaces and existing trails could be explored more thoroughly and with a more regional view.

From our cursory review of the maps presented at the meeting, we can say that the work that has gone into this planning effort has been very much worthwhile. We feel the document is a great step towards achieving the stated goals of identifying missing links, providing connectivity between existing trails, open spaces and jurisdictions, and recognizing the value of some of the existing non-system trails. We feel the eventual implementation of the plan will increase both the quality, quantity, and variety of recreational experiences the community so badly needs.

We are also sensitive to the concerns of private property owners who expressed feelings that they hadn’t been heard. However, we also feel that many of their concerns arose from an incomplete understanding of the goals of this planning process. In some cases, it seemed their negative experiences with other neighboring public land managers have elevated their concerns about dealing with the County. We hope that as the plan is implemented and negotiations take place with private land owners (and the neighboring public land managers), their fears can be allayed and mutually beneficial compromises reached for the benefit of the entire trail user community and the public-at-large.

The County’s policy favoring shared-use trails including bicycles is very important to us as a trail advocacy group comprised of bicyclists. We know that there are several places where proposed County trails will connect to trails in City of Los Angeles parks such as O’Melveny and Limekiln Canyon. On these City trails bicycles are presently prohibited. It is our hope that the County and City can come to a compromise that would allow bicycles to connect legally to the proposed County trails/trailheads that are only accessible through City property and trails.

Since this Trail Master Plan will be incorporated into the County General Plan, we feel it would also be worth coordinating proposed trailheads with the 2012 L.A. County Bicycle Master Plan. Having trailheads accessible by bicycle-friendly infrastructure such as Class II Bike lanes is good for encouragement, makes them more accessible to non-drivers, and helps reduce vehicular traffic to trailheads.

CORBA is at present in full support of the plan. It will be presented to the County Rec and Parks Commission later in the year, and subsequently to the L.A. County Board of Supervisors for adoption.

Update March 16, 2014: The plan will be presented to the Planning Commission on March 26, 2014. Meeting starts at 9 am at the Hall of Records Room 150, 320 W. Temple Street, Los Angeles, California 90012. The Parks and Recreation element is agenda item #6.i.

The Trail Master Plan map and powerpoint presentation are available on the County’s web site.

Update, March 26, 2014: The LA County Regional Planning Commission held their hearing on the draft plan today. Steve Messer, Jim Hasenauer, Ken Raleigh and Tony Arnold all testified in support of the plan. One private landowner, and five equestrian representatives also testified in support of the plan, all of them mentioning multi-use trails. Nobody spoke against the plan. Other elements of the County General Plan were also presented to the Commission, who held the matter over until their next meeting in April. We are confident the Planning Commission will approve the plan, which will then go before the Board Of Supervisors later in the year.

LA County’s Draft Santa Susana Mountains Trail Plan

Wednesday, February 12th, 2014


In 2012, CORBA attended public meetings to give input on L.A. County’s Santa Susana Mountains trails master plan. The County has taken the input we and many others gave, and will present their draft Trail Master Plan at a public meeting on March 6 in Granada Hills. They will also seek additional feedback from the trail user community.

The area under consideration for this trails master plan included the unincorporated open space north of Chatsworth, up to the crest of the Santa Susana Mountains. In our comments, and many others submitted by the public, we urged that the project area be expanded north to the LA County border, and east to incorporate the entire northern range of the San Fernando Valley.

The County will present the draft trail master plan at:

Thursday, March 6, 2014, 6:00 p.m. – 8:00 p.m. 
Knollwood Country Club,
Granada Room
12024 Balboa Blvd, 
Granada Hills, CA 91344
Parking is free. 


Santa Monica Mountains Draft Trail Management Plan Released

Friday, January 31st, 2014


smmtmp-coverOn Friday, January 31, 2014, CORBA was notified that the long-awaited Santa Monica Mountains Draft Trail Management Plan (TMP) had been released in draft form for review. In developing the plan, NPS supposedly inventoried all existing trails, including “unofficial” or “volunteer” trails, and lays out a vision for how the entire trail system will be managed going forward. The plan has been in development for more than ten years, with several false starts and periods of uncertainty due to dwindling budgets, lack of staff and other limitations. The NPS last year received a grant to complete the plan.

Now that the draft has been released, we will be going over it in detail over the coming weeks  to see whether our concerns have been given due consideration. We’d encourage everyone familiar with the trails of the Santa Monica Mountains to see if there are any trails they know of that will be affected by the proposed plan.

CORBA has a long-standing request for bicycle access to particular trails that are currently closed to bikes. Our list goes back more than two decades, but our formal requests were, at least in part, the impetus for State Parks to develop their formal Change In Use (CIU) process. So far, two trails for which we requested a change in use have been evaluated using the CIU methodology. One of those, the Canyon trail in Placerita Canyon (a State Park unit managed by L.A. County) was reviewed and opened to bikes after trail modifications were made. The other trails that were approved for a change in use have been on hold due to a lack of funds, a need for major re-routes, and pending the final release of the TMP.

We’re hoping to see the trails for which CORBA has formally requested a Change In Use, a list that goes back more than a decade, have been given due consideration in the TMP. We’re also hoping to see plans for new trails to provide better through-connectivity, including a multi-use bypass trail around the Boney Mountain State Wilderness, among other things. We’d also like to see the Backbone trail opened in its entirety, or viable multi-use singletrack alternate routes for sections that can’t or won’t be opened to bikes.

The TMP document is complex. Since the Santa Monica Mountains National Recreation Area includes land owned by multiple agencies, it was quite an undertaking to coordinate the effort between the affected agencies: State Parks, National Park Service, Mountains Recreation Conservation Authority, Santa Monica Mountains Conservancy, LA County, private landowners and others.

The plans can be downloaded for viewing at:  The public comment period ends on April 1st. We aim to have reviewed the documents in detail and offer our assessment and comment suggestions by the end of February.

Two Public hearings are scheduled, and we encourage anyone with an interest in the trails of the Santa Monica Mountains to attend:

February 20, 2014, 6:30 – 8:30 p.m. 
King Gillette Ranch 
Dining Hall 
26800 Mulholland Highway 
Calabasas, CA 91302  
February 22, 2014, 10:00 a.m. – 12:00 p.m.
Temescal Gateway Park 
Woodland Hall 
15601 Sunset Blvd. 
Pacific Palisades, CA 90272 

Sullivan Canyon Pipeline Work Begins January 6

Friday, December 20th, 2013

From the Public Affairs Office of Southern California Gas:

Since 1960, Southern California Gas Company (“SoCaIGas”) has owned much of the land that comprises Sullivan Canyon (more than 4 miles in length). This property is used as a corridor for two transmission pipelines that provide Los Angeles residents with a safe and reliable supply of natural gas. Periodically, SoCalGas must perform maintenance on these pipelines. The purpose of this letter is to provide information on pipeline maintenance and repair work that will occur in 2014.

Purpose of this Work

We recently internally inspected our pipeline. By code, we have areas we are required to perform a visual inspection of the pipeline as part of a validation process. This work is required to maintain the pipeline’s safety and integrity.

Location and Logistics

There are two work areas along the access road within the canyon that will require excavation.

Location 1: 0.7 (seven tenths) of a mile south from fire road #26 at the Mulholland entrance

Location 2: 2.8 miles in from fire road #26, or 1.4 miles from the Queensferry entrance

Partial Canyon Closures

The Canyon path will be closed from the Mulholland entrance at fire road #26 to location 1.

There is no change to the Queensferry entrance. Signs will be posted along the path indicating construction status.

The following impacts are to be expected in the canyon and surrounding neighborhood. I will keep you apprised of any changes.

-Work will commence on or about January 6, 2014.

-Work is estimated to be completed in 8 weeks.

-Information signs will be posted in advance at the beginning of each entrance.

-Work hours are sun up to sun down, Monday through Friday. No work will be performed on Saturday and Sunday.

-Intermittent loud noise in the immediate work areas.

-Increased dust in the immediate work areas.

-Increased traffic at the Mulholland entrance from work crews and equipment.

SoCalGas appreciates your understanding and apologizes for any inconveniences caused by this necessary work. It is our goal to minimize disruptions. We value our relationship with the community and will communicate with you when our work has the potential of impacting our neighbors. Again, there are two high-pressure transmission pipelines located in the canyon and we will continue to periodically perform maintenance work to them as-needed to ensure safety.

Safety is our first priority. Should you have any questions, please call me 213 244-4633 or email me at


Mike Harriel

Public Affairs Manager

Angeles National Forest Recreation Fee Proposed Changes

Saturday, December 7th, 2013

Adventure PassThe Forest Service has proposed major revisions to the Angeles National Forest recreational fees. Similar revisions are proposed for the San Bernardino National Forest, Cleveland National Forest and Los Padres National Forest.

The proposed changes will result in fees being required only at concentrated, developed sites, while larger areas of the forest will become free for public use. Fee amounts will remain the same, at $5 for a day pass, or $30 for an annual adventure pass.

Under the new fee structure, fees are to be charged only where there are services and developed facilities including bathrooms, kiosks/interpretive signs, trash collection, picnic tables and security patrols. Sites lacking one or more of the above will be free.

In the Angeles Front Country, for example, fees  would continue to be required at Millard Day Use Area, Switzers Picnic Area, Red Box, Skyline Park (Mount Wilson), and Chantry Flats. All other front country areas would become free for public use. Note that the forest service has already stopped enforcement of passes at the areas where fees will be dropped under the new fee structure. Full details of front country changes are available here.

While CORBA supports this more reasonable and appropriate fee structure, we do have concerns that it may result in reduced levels of service across the National Forest as a whole. The financial impacts of the proposed changes are as yet undetermined. National Forest budgets have faced continued reductions over the past decade, and staff levels are at an all-time low. Recreational Fees have helped fill the budget shortfalls, funding numerous improvements to facilities within the National Forest.

The California Recreational Resource Advisory Committee (R-RAC), a citizen’s Federal Advisory Committee, is charged with representing the public interest in matters of recreational fees and other issues. The proposed changes are on the R-RAC agenda for for January 15-16, 2014. Public comments to the committee must be made by January 6, 2014, emailed to:

Area maps and detailed descriptions of the affected areas of the Angeles National Forest can be found at:

For our other Southern California National Forests, visit their respective pages at:




Tell Los Angeles Recreation and Parks What You Want

Wednesday, November 27th, 2013

rec and parks logoThe City of of Los Angeles Recreation and Parks Department (RAP) is seeking public input on the future and funding of our City parks. This is being conducted through a series of public meetings, and an online Community Budget Discussion survey

We are taking this opportunity to remind RAP of their obligations and duties as identified in the 2010 Los Angeles City Bike Plan. CORBA worked diligently to keep the meager provisions for off-road cycling in the 2010 Bike Plan, while the powerful equestrian lobby fought hard to have them removed. We submitted over 1000 letters and petition signatures calling on the City to include strategies for accommodating mountain bikes on at least some City trails. We also asked that a recommendation for Bike Parks be included in the Bike Plan, but a Bike Park provision was not included in the final plan.

Havemeyer Park, a pop-up bike park facility in Brooklyn

Havemeyer Park, a pop-up bike park facility in Brooklyn

The City has made remarkable progress on the implementation of the Bike Plan, at least where the Department of Transport is the lead agency. The five-year implementation strategy is ahead of schedule with regards to new bike lanes and other infrastructure supporting cycling on the City’s streets.

To our knowledge, nothing has yet been done to implement the off-road cycling provisions identified in Chapter 4, Sections 3.3.5, 3.3.6, and 3.3.7 of the 2010 Bike Plan. The lead agency identified for those provisions is RAP.  The Bike Plan calls for these provisions to be completed by 2015.

We therefore urge all of CORBA’s members who live within the City of Los Angeles to complete the survey. The survey is available at, where a popup window will direct you to the survey. The survey can also be accessed directly at, but please read on before doing so.

The RAP survey will ask how often you visit City parks, what activities you participate in, how far would you travel for specific activities, and what amenities you would like to see. Nowhere within the survey is there any mention of bicycles, trails for bicycles or bike parks. You must write those in where appropriate.

While “equestrian trails” and “hiking/walking” trails are referred to in the survey, there is not a single mention of bicycle trails or multiple-use trails. Also missing is any mention of Bike Parks. Therefore the only opportunity within the survey to request park facilities for bicycles, such as trails, pump tracks or bike parks, is in the “Additional Comments,” section 9.

We encourage our members and readers to take the survey, and in the “Additional Comments section,” urge the RAP department to:

The Recreation and Parks Department needs to allocate the necessary resources to complete the programs for which it is the lead agency as identified in Chapter 4, Sections 3.3.6 and 3.3.7 of the 2010 Bike Plan. Numerous funding sources in the form of bike industry grants, community health and wellness grants, and youth initiative grants are available to fund and support bike skills parks and multiple-use trails, as well as sponsorships and public-private partnerships. RAP needs to provide natural-surface trails for bicycles, and should consider developing urban bike skills parks, with a range of skills development features that are suitable for all ages and skill levels. 

You may copy and paste the above paragraph to post under “additional comments”, but feel free to provide your own input for the survey. Additionally, section 6 asks surveyees to rank or prioritize desired facilities. Bike parks are not mentioned, but can be written in under option W: “Other, Please Specify.”

Core to the survey is the identification of sources of revenue to fund the City’s parks. There are many funding options in the form of bike industry grants available for the construction of bike parks and multi-use trails. There is also a ready and willing army of volunteers who would gladly help build and maintain bike parks. However, the City must first undergo a change in attitude towards off-road bicyclists, just as it has seen a change in attitude towards road cyclists and bike commuters.

A series of public meetings are being held, some of which have already taken place. A full list of them is available at Meetings are from 6:30 – 8 p.m. For more information, contact Theresa Walker,, at (213) 202-3205.

CD1 – December 4: Ramona Hall Community Center, 4580 North Figueroa Street
CD3 – December 3: Woodland Hills Recreation Center, 5858 Shoup Avenue
CD4 – December 9: Griffith Park Visitor’s Center, 4730 Crystal Springs Dr.
CD7 – December 10: Ritchie Valens Recreation Center, 10736 Laurel Canyon Boulevard (Pacoima)
CD8 – December 3: Algin Sutton Recreation Center, 8800 South Hoover Street
CD9 – December 12: EXPO Center, 3980 South Bill Robertson Lane
CD10 – December 4: Rancho Cienega Sports Complex, 5001 Rodeo Road
CD14 – December 2: City Hall, 200 N. Spring St. Public Works Board Room
CD14 – December 3: Evergreen Recreation Center, 2844 East 2nd Street
CD15 – December 5: 109th St. Rec Center, 1464 E. 109th St.

Edit: CORBA’s response letter to Rec and Parks can be read at: 2013-12-02-Los Angeles Rec and Parks Letter.

What CORBA Does

Wednesday, October 30th, 2013

By Mark Langton

Bikes, horses, hikers and runners

Bikes, horses, hikers and runners. We all love trails.

Recently a bicycle club-team representative  contacted CORBA wanting to see what more they could do to get more of the trails that are currently closed to bicycles opened up to shared use. A couple of comments from the correspondence were that they thought that showing up in larger numbers to public meetings would help, and that they thought the main reason that trails were closed were because of an influential public anti-bicycle lobby.

I wrote back to the person who contacted me, and in doing so came up with what I think is a good overview of what CORBA has been doing for the past 26 years, and continues to do on behalf of all public backcountry trail users (see below). Yes, CORBA is a mountain bike organization, but we are more than that, and here’s why: We believe that shared use works better because it disperses use, rather than concentrating it. When you disperse use, you reduce congestion, and when you reduce congestion, you reduce confrontation. Moreover, it has been shown that where shared use trails exist, it works. Maybe not perfectly, but certainly better than where there are restrictions to bicycles, because shared use also fosters cooperation. Bicycles do mix when operated considerately and with the safety and serenity of other trail users in mind. And that’s the crux of the issue: If bicyclists would simply slow down around others, including other bicyclists, they would be solving the problem of both dangerous speed, and the “startle factor,” or the disruption of another’s peaceful enjoyment of the backcountry.

Here’s what I wrote to that bicycle club team member:

This year CORBA celebrated its 26th anniversary. In that time we have made many strides to opening trails to shared use (hiking, equestrian, bicycle) in the Santa Monica Mountains National Recreation Area, Angeles National Forest, Los Angeles County, and Eastern Ventura County. We have participated in hundreds of public meetings with land managers over the years. Land managers recognize and continue to adapt to the growing bicycle population and changing demographic profile of the trail user community. They are certainly aware of the needs and desires of the mountain biking community through CORBA’s efforts, which include quarterly meetings with principal agency managers (National Park Service, State Parks, Mountains Recreation and Conservation Authority). We are also in constant communication with these agencies and/or when the need arises to address a specific issue. CORBA also works closely with the Mountain Bike Unit which aids the rangers and community with safety and education. CORBA also schedules and organizes regular trail maintenance work days s in conjunction with the Santa Monica Mountains Trails Council and Conejo Open Space Conservation Agency. CORBA is also heavily involved with the Angeles National Forest with trail maintenance and volunteer patrol participation. Due to CORBA’s efforts, most of the singletrack trails built in the last 25 years are shared use (not to mention a lot of the singletrack that already existed not getting shut down).

 As you can see, there is more to getting involved than just showing up at meetings in large numbers. The issue of bikes not being allowed on trails is more than just politically active opponents to bicycles; it is mired in an outdated management policy of restriction that is predicated to a large degree on ignorance and a status quo mentality. Within the last few years there has been a systemic change for adopting shared use as the overriding management strategy. It is a slow moving process but we do see a very strong indication that within the next few years we will see many more trails opening to shared use on a statewide basis than currently exists. This change comes from consistent efforts not only by CORBA, but mountain bike advocates all over the state, with assistance from the International Mountain Bicycle Association (of which CORBA was a founding club in 1988).

 The one concern that is always at the forefront of managers’ minds is safety. It is agreed by everyone that bicycles are an acceptable form of public open space trail recreation. However, it is when riders go too fast around other users as to make it an unsafe or even just an unpleasant experience that gets mountain bikers a bad reputation, and gets the managers to thinking about restricting bicycles. If everyone would just slow down when passing others, and slow down into corners so they don’t scare others on the other side, we would pretty much solve the problem. I am not saying you shouldn’t go fast, I’m just saying do it when conditions are safe. 

Backbone Trail blocked at the west end of Etz Meloy Mtwy

Monday, October 28th, 2013

A locked gate has been blocking the Backbone Trail (BBT) at the west end of Etz Meloy Motorway since mid-October. This interupts a very popular ride from the parking area on Encinal Canyon Road to the Mishe Mokwa Trailhead, covering the two newest singletrack sections of the Backbone Trail.

There has been a standard fireroad gate there for years, but apparently some months ago a side gate appeared that completely blocks passage along the road. This side gate was usually open or unlocked, but was permanently locked at about the time of the federal governement shutdown in October. This led to speculation that it was the National Park Service (NPS), owner of most of the land around this section of the BBT, who closed off the trail to keep people off of federal property during the government shutdown.

However, the locked gate was a surprise to the NPS as much as to the rest of us. Apparently one of the private landowners in the area has locked the gate. One rumor is that it is to keep noisy and littering partiers out.

Etz Meloy Access

Some of the land crossed by Etz Meloy Mtwy at the west end is still in private hands. The NPS is actively trying to acquire this propery or make some other arrangements with the landowners to allow public access. Until that happens, the west end of Etz Meloy has been and continutes to be closed to public access (see map above). The NPS asks that members of the public stay off of this section to help engender his cooperation in discussions to allow everyone to use this trail.

CORBA will provide more information as it becomes available.

Show Us Your Smile

Tuesday, August 27th, 2013

smileSometimes a picture is worth a thousand words. We have created this message tag with the help of BikeTags ( so that we can spread the message of goodwill, peace, and harmony throughout the world. Or maybe just the message “don’t worry, be happy.” The idea is to show other trail users that we belong, we care, and we can coexist. Similar to the SoCal High School Cycling League’s “spirit of howdy”, it’s a way to remember to slow down and smell the sage brush.

We’ll be making the CORBA Smile Tags available to anyone who wants one, just send an email request to We’ll be giving away prizes for the best photos of the tags on your bikes while on the trail. Photos will be judged on originality, creativity, and overall quality. (Details to follow in the coming weeks). The grand prize will be a Niner full suspension frameset, donated by Niner.

OK, so maybe putting the Smile Tag on your bike* won’t save the world. But a lot of times a little smile can go a long way.

*The Smile Tag is a high quality plastic laminated product and comes with all hardware necessary to mount on a handlebar or under the seat. If mounting to the handlebar, a hole may need to be punched at the bottom of the tag to help secure the tag to a brake or derailleur cable (see photo).



CORBA’s Comments on State Parks’ Rulemaking Process

Thursday, August 15th, 2013

California State ParksLast year, a disconcerting fact came to light. The California Public Resources Code, under which State Parks operate, contained a rule that essentially allowed bicycles on State Parks trails unless specifically closed to them. It also contained a rule that trails were closed to equestrians unless specifically opened to them.

State Parks’ practice and policy for these past 25 years has been the exact opposite.

While considerable progress has been made by State Parks in acknowledging the legitimacy of bicycle use in State Parks at the policy level, in practice little has changed. CORBA has fought long and hard to gain more equitable access to trails in State Parks, and in fact, virtually all of the singletrack trails in the Santa Monica Mountains that are open to bicycles, are open either directly or indirectly, because of CORBA’s efforts.

Yet there is a rule currently on the books that, if followed, would have helped give us access to trails two decades ago.

State Parks held two private focus group meetings in October 2012, at which both CORBA and IMBA were represented, along with equestrians, hikers, and environmentalists. Those focus groups almost unanimously called for more inclusive rules that allowed both equestrians and cyclists access to trails unless specifically closed to them, despite the policy and practice in place.

Also discussed were rules regarding “minimum tool use” with the goal of only allowing use of only the minimum tools required to complete a task, in State Preserves (natural and cultural).

Fast forward nine months, and the proposed draft rules were released and public meetings were scheduled. One of the public meetings was scheduled AFTER the public comment period closed. The draft rules were the exact opposite of the consensus of the focus group meetings in which we participated.

We understand that due to the seriously flawed nature of this public rulemaking process, and the confusion resulting from these poorly drafted rules, that there will be another chance to comment on them. Details of the current drafts are available at

While this was not an issue that required a show of numbers by the public, even the limited public process involving stakeholder groups such as CORBA and IMBA was flawed. Our comments follow, and we’ll keep you informed when there are any further developments in the process.




August 15, 2013
Alexandra Stehl, Statewide Trails Program Manager
California Department of Parks and Recreation
PO Box, 942896
Sacramento, CA 94296

Re: State Parks Proposed Rule Making Comments

Dear Ms. Stehl,

I am submitting these comments on behalf of the Concerned Off-Road Bicyclists Association (CORBA), a chapter of the International Mountain Bicycling Association (IMBA). We are a 501(c)(3) non-profit representing off-road cyclists in the Los Angeles and Ventura County region. We have been working closely with State Parks on trail-related issues since our founding in 1987. Our volunteer trail crews have contributed many thousands of hours of labor to trail maintenance efforts in State Parks. We serve as a bridge between land managers and the mountain biking community, educating and encouraging trail users on proper trail etiquette and responsible trail use, while at the same time advocating for protection of public lands and equitable access to the trails by which the public enjoys those resources for all trail users.

Having participated in the initial invitation-only focus group meetings conducted by Charlie Willard, we were initially dismayed to learn that State Parks policy of trails being “closed to bicycles unless specifically opened“ had been implemented in direct contradiction to the language of Title 14, division 3 of the Natural Resources Code. The policy of equestrians being permitted on trails unless specifically closed to them was also in direct contradiction to the code. We welcomed the opportunity to be a part of the process of rectifying this situation. The outcome of those focus group meetings appeared to be overwhelmingly in support of language that welcomes and includes equestrians, hikers and cyclists as trail users on State Parks trails. The proposed draft rules fail to meet that goal shared by the focus groups in both Southern California and Northern California, and appears to have completely ignored our input.

We therefore fully support and agree with the position taken by IMBA. We encourage State Parks to adopt the language submitted by IMBA for Title 14, Division 3 of the Natural Resources Code as follows:

§ 4360 – Trail Use

State park trails are open to non-motorized users including hikers, bicyclists, and equestrians unless otherwise designated. Trail use designations are established based upon user needs, visitor safety and environmental sustainability. This includes access to trails in Reserves and Preserves, as defined in PRC Sections 5019.65, 5019.71 and 5019.74, where particular emphasis will be placed upon importance of public access to the area, or desirability of providing important connections to other trails, provided impacts to special resources for which the area was established will be less than significant.

We put forward this language to replace existing provisions in the Natural Resources Code (§4359 and §4360).  It will also include the provisions of proposed §4360.1, which we, and IMBA, urge be eliminated.

IMBA’s and others’ comments also include a background of State Parks policy and the policy’s contradiction to the existing code. CORBA has been at the forefront of these issues and we have played an ongoing part in that history and background. Despite more than two decades of gradual State Park policy changes to be more inclusive of cyclists, the rate of actual progress towards increasing trail access and opportunities for cyclists has been painstakingly slow and frustrating. This is an opportunity for State Parks to follow through on their stated goals of providing increased access for bicycles. The language proposed by State Parks would be a step backwards in this process.

There are many reasons for adoption of the above language, or even to retain the existing language of §4360, and change §4359 to include similar language to that for bicycles in §4360, allowing equestrian access to trails unless specifically closed to them. As a group we advocate for shared-use trails, and feel that the message sent by the proposed exclusionary and negative language sends the wrong message to State Park unit superintendents and managers, and sets the wrong example for other land management agencies who may be influenced by State Park rules and policy.

It also sends the wrong message to the public. The proposed language has the potential to further and compound perceived user conflict by giving one user group a sense of “superiority” over other user groups; it legitimizes and reinforces this perceived conflict, and discourages the sharing of multi-use trails. As outlined in the State Parks Trail Change In Use PEIR, Appendix A, even perceived conflict is rare, and actual incidents are rarer still. The language we are proposing will help promote a sense of community, sharing of trails, and is in line with State Parks’ stated goals of providing more trail opportunities to off-road cyclists.

Management practices exist to close specific trails to particular user groups where legitimate, objectively-determined concerns or environmental impacts are demonstrated. Therefore, adopting this more welcoming language will not have any immediate impact on existing trails, and where impacts are demonstrated, the means to close them is already in place. This should place no additional burden on State Parks, above that of the now-adopted Change-In-Use process. Further, a more uniform shared-use policy will be easier to manage and police than the current status quo.

Our proposed language is also in keeping with current research on trail and resource impacts by different “muscle-powered” user groups. It treats each user group equally, just as overall impacts to resources and trails by each of the major muscle-powered user groups have been demonstrated to be similar. It is now well-understood that the greatest impacts to trail and resource sustainability are the result of poor trail design, rather than any particular user group. The proposed language appears to ignore this fact.

With regards to the proposed changes to the “Minimal Tool Use” sections of Division 3 of Title 14, we are deeply troubled by the proposed lumping together of Preserves and State Wilderness. These are two distinct land-use designations (actually three if you include ‘cultural’; and ‘natural’ preserves) that require distinct, but at times overlapping, approaches to management. The term “mechanical transport” as it applies to State Wilderness is NOT applicable to Preserves as proposed. The unintended consequences could be daunting, with significant impacts to cyclists and the mobility-impaired as user groups. While the concept and goal of “minimum tool use” is appropriate for both natural preserves and state wilderness, the proposed language can too easily be misinterpreted. We have been informed that State Parks does not wish to summarily exclude cyclists from Preserves, yet the proposed language does just that. We urge State Parks to either retain the existing sections §4351 and §4351.1, or to prepare language that avoids misinterpretation and unintended consequences.

Given the haphazardly drafted proposed rules, and numerous problems with the process–including scheduling public meetings AFTER the public comment period closes–we can only surmise that the draft rules were preordained prior to any public process and were put together with complete disregard to public input. The public and private meetings seem to have been held only to placate the public, not to seek actual input. We therefore urge State Parks to continue the public process appropriately and professionally, and allow for another round of public comments on the revisions that come out of this comment period.

Thank you for consideration of our comments. If you have any questions, feel free to contact us.