CORBA’s State Parks Change in Use PEIR Comments

CORBA has submitted comments on California State Parks Change In Use Programmatic Environmental Impact Report. Our comments are included below.

Currently, the Yearling trail has been approved for a change in use, pending the implementation of “Project Specific Requirements” which include a re-route and other trail modifications, for which the State does not presently have the resources to complete. Recently Bill’s Trail in Marin was also approved for multi-use, after more than a five-year process. Our comments reflect our desire to see the process streamlined and sped up.

While this is a step forward for gaining access to trails for bicycles in California State Parks, we see the process as overly burdensome and resource intensive. Given the State’s track record of meeting its stated goals and completing tasks, we have to question whether this additional process will slow down or speed up the process of opening trails to bicycles. However, the PEIR does in fact include some important documentation and acknowledgements of the legitimacy and appropriateness of allowing bicycles on trails, though it risks homogenizing State Parks trails to a “standard” that we feel will reduce the diversity of trail experiences for bicyclists. We’ll be reporting on the Change in Use process as the final version is released.

December 4, 2012

Environmental Coordinator
California Department of Parks & Recreation
Northern Service Center
One Capitol Mall- Suite 410
Sacramento, CA 95814
Via email:

Re:  Programmatic EIR for State Parks Roads and Trails Change In Use

The Concerned Off-Road Bicyclists Association (CORBA) is a 501(c)(3) non-profit, representing off-road cyclists in the Los Angeles and Ventura County areas. We are a local chapter of IMBA, the International Mountain Bicyclists Association. Our membership comes from a vast diversity of backgrounds, skill and fitness levels, bicycle riding styles and desired experiences on trails both in State Parks and other open space areas. CORBA’s mission includes the preservation of our open spaces, informing the public about trail and open space issues, education of bicyclists about proper trail etiquette and educating non-cyclists about off-road cycling in all its diverse genres.

First and foremost, we would like to point out that the comments submitted by CORBA on November 30, 2010 do not appear in the current draft document appendices. A copy of those comments is attached to this email.

We appreciate the opportunity to submit comments on the Draft PEIR. While we commend State Parks for putting together such a comprehensive document that is a step in the right direction towards implementing the State’s stated multi-use policies and objectives for trails, we find that it is based on some glaringly inaccurate assumptions.

The PEIR fails to recognize that bicycles and hikers have similar capabilities for traversing rough, steep, narrow or otherwise technically challenging terrain, whether the skill level of the bicyclist necessitates him or her to “hike-a-bike” (walking the bike through a section that is beyond their skill or fitness level), or whether they are able to ride through a section. The criteria used to determine the suitability of a trail for the addition of bicyclists as a user group wrongly assumes a level of skill and fitness of that of a beginner or novice cyclist. In fact, many trails within the State Park system and other jurisdictions that are currently open to bicycles are much more technically and physically challenging than many which remain closed to bicycles, including for the baseline recommendations of tread width, surface textures and maximum grades. We recommend that the addition of signage to indicate a technically or physically challenging trail, alerting trail users to the potential trail hazards and challenges ahead, be offered as an approach to open trails where such conditions exist. Many such trails lead to significant points of interest, views or overlooks or other destinations of interest to all trail users, or provide connectivity to trails that do. The PEIR also fails to recognize in this section that travel speeds on technically challenging terrain are generally much lower than speeds on wider, smoother trails, where “artificial” treatments such as pinch points are then required to reduce speeds.

Given this fact, it is apparent that many more trails could be opened to bikes without going through a cumbersome, lengthy, and extensive change-in-use process. In fact, the State’s limited resources leave us questioning whether, after 25 years of being excluded from many, many trails in State Parks that could easily accommodate bicycles, the State will in fact be able to work through the two-decade long backlog of hundreds, if not thousands of miles of trails that have been requested to be opened to bicycles by CORBA and other organizations around the State. This Change In Use process as outlined is labor-, time- and resource-intensive.  Based on State Parks’ track record of failing to fulfill its own objectives for trails over the past 25 years, we find it hard to believe that the PEIR and change in use process in its current form will in fact result in significant near-term opening of trails to bicycles.

State Park districts have a history of being unable to complete the tasks directed of them from Sacramento. In 1994 districts were instructed to assess trails in order to develop a list of those suitable for multiple use by 1996. Most districts failed to do this. In 2004, a trail use policy provided a process for districts to create multi-use trails, and again most districts failed to implement the process. The current Change In Use process, which has been a “work in progress” since 2008, has proven too expensive for many districts to implement. In fact the Change in Use process assessment and recommended mitigations have been applied to a trail that was already designated multi-use, which we feel was a misapplication of available resources. For these reasons, we are concerned that the Change in Use process, as it is currently outlined, will have little near-term affect in increasing trail access opportunities for bicycles in State Park.

Instead, and given the aforementioned concerns and inaccurate assumptions about bicyclists, we would prefer to see trails opened to bicycles “as is” with Adaptive Management principles used to monitor and report on the results. The Change In Use process could then applied if that monitoring provided hard evidence of a need for further study or mitigations. If after monitoring the objective evidence points to a need, it is much easier to close a trail to a user group than it is, under this process, to open one. This is a fundamental change in the CIU “flow chart” organization, but would result in more opportunities for bicycles, less cost to the State and taxpayers, fewer trail unnecessary trail modifications, and more dispersed use of trails by bicycles. The funds saved in this approach could be applied to better enforcement and education, both of which have far-reaching positive impacts beyond just a single trail.

In fact, this is the approach inferred by the Public Resources Code (CCR sections 4359 and 4360), which specifically states that trails should be opened to bicycles unless specifically closed. These codes also state that trails should be closed to horses unless specifically opened, a stance with which we disagree. We feel all trails should be opened to all users, unless specifically closed. We strongly feel that these codes should be referenced in section 3.3, the “Policy and Planning Context” and that their omission fails to provide the complete context of the regulations under which bicycles should have been managed for the past twenty five years.

Another incorrect assumption about bicyclists is the repeated use of the term trails as “attractions in themselves” and the stated position that it is not the State’s mission to provide trails as “attractions in themselves” for bicycles. We find it hard to fathom that the code limiting “attractions in themselves” in State Parks was intended for natural surface trails. Trails are the primary means by which a majority of park visitors experience and appreciate a park unit. It is nearly impossible to dissociate the “trail experience” from the “park experience.” Trails are an integral part of the park experience, and in many natural area and open space park units, trails are the only way to fully “enjoy and appreciate the resource.”

Just as there are many and varied types of parks, types of terrain, bioregions, habitats, cultural and natural resources, there are many type of trails. Trail users expect and look forward to a variety of trail experiences within State Parks. All trail user groups have within their ranks a range of abilities and expectations from novices to experts, and it is the natural inclination of humans to seek to improve their fitness, skill and comfort on a variety of terrain over time, whether on horseback, on foot or on a bicycle.

To state that all trails must meet a certain set of standards to be considered viable for multiple use, is to misinterpret the range of desired park experiences of all park visitors including bicyclists. Trail users do not look forward to a homogenized look-alike set of paths through parks any more than they expect to see exactly the same terrain along each trail or in each park unit. To apply rigorous “standards” to these trails is to deny the diversity of experience that all trail users seek and expect. Trail “standards” are difficult if not impossible to apply consistently given the variety of terrain and geology through which trails pass. These should be referred to as “guidelines” where mentioned in the PEIR.

These Standards are referenced in the CSP Trail Manual, however this manual has not, to our knowledge, been made available for public or peer review, nor is the complete document included in the appendices. We would like to see the CSP Trail Manual made public, put through a peer and public review process, and updated at a minimum every five years to incorporate the most current research, technologies and trail user group trends.

When a Project Specific Requirement for a mitigation is identified that is necessary to address a trail’s already-existing environmental impact, where the user group being added to the allowed uses has less impact than the currently allowed users (eg. bicycles having less impact than horses, as acknowledged in Table 4.10-3) the addition of that user group to the trail should not be postponed until after the PSR is implemented. The environmental impacts are already taking place. To delay the addition of a group until after mitigating measures for these impacts are installed or implemented is unfair when no other issues are identified. This is especially true in the current economic climate where the implementation of the mitigating measures might take a significant amount of financial resources that may be unavailable at the time. Those mitigating measures can be scheduled for later implementation when financial and other constraining resources are available. Alternatively, the trail should be closed to all users if the ongoing impacts are significant.

The appendices of the PEIR provide plenty of evidence showing that multiple use trails can be safe, sustainable and successful. The PEIR does a good job of calling out where personal opinions and claims deriding mountain bicyclists lack any documentation or supporting evidence. Some of the “evidence” submitted is correctly refuted as hearsay or unsubstantiated. The PEIR correctly identifies the general scarcity of incidents and accidents, and acknowledges that perceived conflict is subjective and infrequent, while incidents and accidents are much rarer. We commend State Parks for correctly addressing these claims.

Finally, regardless of whether the change in use process is adopted as described or modified to prioritize Adaptive Use Management before the CIU process as we have expressed, the State needs to assign staff specifically responsible for overseeing the change in use process statewide, with a budget sufficient to move through the backlog of change in use requests expeditiously and in good faith.

Below are some specific observations on the content of the PEIR itself.

Sections 3-14  and 4.4-41: directs CSP staff to inspect a route semi-annually after a change-in-use for the first three years after implementation. The inability of a CSP unit to fulfill this requirement due to shortfalls in staffing, financial resources or other hindrances should never be grounds for reversal of the Change In Use ruling. We find that this is one more example of the resource-intensive nature of this process, and wonder whether it will be implemented.

4.1-10 – Refers to linear rut development, but fails to cite research or evidence for such a claim. In our experience, soil displacement by all users, followed by hydrologic erosion are the predominant causes of ruts. Cyclists tend to avoid ruts, riding along their edges which helps break down the sides of the rut. If there is evidence for this claim, we’d like to see it referenced.

4.6-1 needs to explicitly state that multi-use including bikes may be appropriate on trails in cultural preserves. While this is our understanding after conversations with CSP staff, explicitly stating the same would remove any ambiguity in the matter, and make it clear to district superintendents.

4.7-29 – Refers to user conflict as contributing to geological impacts. We fail to see how user conflicts could contribute to geologic impacts and would like further references or clarifications.

Table 4.10-3 makes it clear that horses have significantly greater impacts to hydrology, water quality and sedimentation than either hikers or bicycles. Yet resource protection is often cited as a reason for prohibiting bicycles on trails. It is apparent from this table that, barring other considerations, many more trails that are currently open to equestrians should either be closed to equestrian use to protect the resource, or should be opened to bicycles who have less impacts than the currently allowed users.

Table 4.14-1 outlines five categories of trails by their designated use and trail type.  It doesn’t separate out trails within State or Federally designated Wilderness areas, which are by definition and law, closed to bicycles and therefore will never be candidates for a change-in-use to include bicycles. We would like to see this table break down trails inside and outside of wilderness areas. We’d also like to see the State’s inventory of trails from which this table was compiled, as the data provided seems to imply that bicycles have more access than our experience would indicate.

Section 4.14.1 (page 4.14-2) fails to recognize that many trails which are highly technical lead to significant points of interest, or provide connectivity to other trails, park units or otherwise desired destinations. While it may not be CSP policy to provide for such trails, it is CSP policy to allow users to enjoy and experience the park’s natural features. Where a trail that leads to a point of interest or provides through-connectivity to other trails is considered technically challenging, due consideration to this connectivity or access to points of interest must be given.

Section 8.3, paragraph 2, refers to mountain biking as “active recreation” which lies outside the mission of CSP. In this situation it is referring to high-speed or highly technical travel by bicycles. However, mountain biking is not an “active recreation” as defined in the literature. Trail conditions may induce or require highly technical travel or higher speed, but do not require the construction of specialized facilities. Active recreation is generally defined in the literature as a recreation that requires specific construction or facility such as a football field or basketball court.

In the appendices, section 2.6.1 States that Singletrack is the most popular or sought after type of mountain bike trail.  This is not necessarily true, as there is a wide range of desired park experiences. Some prefer the ease and openness of fire roads, while others prefer singletrack. However, narrow singletrack trails is where the greatest disparity of trail miles available to bicyclists exists, and is therefore the primary subject of the change-in-use process. It also fails to recognized that travel speeds on fire roads are inherently faster than on narrow trails.

2.6.1 States that Backcountry trails must have a minimum 18” width for the accommodation of bicycles, but not equestrians, However “backcountry” is not clearly defined. In our experience the greatest concentration of hikers is within the first two miles of a trail, or on trails that lead to a point of interest less than two miles distance. With increasing distance there is decreasing use by hikers.

2.6.6 Elements should be placed so that they provide more of a visual “pinch point” than a literal narrowing (see Figure 2-3)  Some of the pinch points demonstrated on Tapia Spur trail in Malibu Creek State Park have been constructed as a literal narrowing of the trail. While skilled riders are able to easily negotiate these pinch points, average riders have expressed difficulty at navigating them in the uphill direction, where traction is less than desirable, and slow-speed balance, a more advanced skill, is required to negotiate them. The design criteria for pinch points needs to take into consideration grade and surface condition (traction) to comply with the desired objective to be “easy for the average user to negotiate.”  In steeper, looser conditions, the minimum physical distance between the obstacles forming the pinch point must be greater than that recommended on lesser grades or high-traction trail tread surfaces. These guidelines should be included in the State Parks’ trails manual, which has not been made available publicly.

Under measures, 2-16 The speed control features are substantial enough in volume that users can easily see them and will not accidentally or deliberately run over them (e.g., 3 to 4 feet high and 4 to 6 feet wide). These specifications will be unrealistic on many trails, and we’d prefer to see the example measurements removed. The fact that they should be easily visible should be specific enough.

Thank you for your time and consideration of our position.

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