State Parks Rulemaking Comments

Today was the deadline for comments on the draft State Parks Rules concerning trail use. The proposed rule would hinder the process of gaining access to more trails for bicycles in State Parks.

We understand that hundreds of letters were written by our IMBA Alert recipients, for which we thank you.

Below are comments submitted by CORBA.


April 3, 2014

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

Re: State Parks Proposed RuleMaking 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) non­profit representing off­road cyclists in the Los Angeles and Ventura County region. We have been working closely with State Parks on trail­related 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.

Despite comments from CORBA and many others calling for language of inclusion for § 4360 ­ Trail Use in both the first round of private discussions and the subsequent round of public comments, we were once again dismayed to read the same policies of inequality and exclusion, favoring one group (Hikers) over two others (Equestrians and Cyclists).

We still stand by the language suggested by IMBA in the last round of comments as follows:

§ 4360 ­ Trail Use

State park trails are open to non­motorized 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.

Such a policy of inclusion would give the most welcoming signals to the broadest population; it would allow policies regarding all non-motorized trail users to be developed from an equal starting point. It would help change the perceived tone of State Parks where “NO…. “ signs sometimes seem to outnumber signs with a more positive message.  

Gross inequities still exist in the allocation of singletrack trails to shared use including bicycles vs. trails open to equestrians and hikers. It has been clearly stated that whatever the outcome of this rulemaking, nothing on the ground will change without going through the already approved formal Change in Use process. It would, however, help guide us into a more equitable future.

If fact, the CIU-PEIR Appendices have the most clear and current research on user conflict, finding that perceived conflict is relatively rare, and actual confict rarer still. Other research shows that the trail impacts of bicycles is similar to that of hikers, and less than that of equestrians. If protection of the resources are a priority, it makes little sense to allow a user group that has a greater impact on trails than one with a lesser impact.

The former director of State Parks once stated that “we need to engage our youth and get them excited about our parks.” Consider the phenomenal growth of the High School Mountain Bike League. There are now well over 1000 high school students, and now Middle School students (pilot program), who are participating in competitive cross country mountain bike races on school-based teams in California. The Southern California League started 6 years ago with about 70 high school students racing. This year there are over 500 students registered in the league from more than 40 teams. A very large proportion of these student-athletes are mountain biking for the first time when they start riding with their school team. These students have taken to mountain biking, and many will continue to enjoy the great outdoors by bicycle far beyond their school years. The high school league promotes stewardship, encouraging their student-athletes to give back to the trails in the form of volunteer trailwork. Most teams have done so. The proposed rule sends the wrong message to these kids, that they are not welcome at State Parks with their bicycles. Is this policy of exclusion how the agency can best engage a new generation of State Park visitors, our upcoming stewards of the land?

As a group we advocate for shared­use 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. It sets the wrong example for other land management agencies who may be influenced by State Park rules and policies.

State Parks now has a policy favoring multi-use trails over single or dual-use. The mission of State Parks includes “creating opportunities for high-quality outdoor recreation.” This policy is not supported by the proposed rule.

This policy is also in direct opposition to the findings and efforts of the Parks Forward Committee. Responsiveness to community needs is one of the goals of that committee. Clearly, when cyclists comprise a large proportion of trail users (on the trails they are permitted), and the gross inequities in trails open to bicycles still exist, that is not meeting community needs.

While some user groups have complained about the “excessive” number of bicycles on some trails, increasing perceived conflict, a rule and policy allowing access to a greater range of trails will help disperse cyclists across more trails, reducing the social impacts on any particular trail.

Those who would rather use trails where bicycles are prohibited still have many trails to choose from, including all of those in designated State wildernesses, the Pacific Crest trail, and many other City trails (here in Los Angeles).

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 multi­use 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 off­road cyclists.

Again, we encourage you to consider the language proposed by IMBA, or some variation that indicates trails are open to all users, unless they have been ordered closed.

Minimum Tool Use

We understand the intent of the term “non-mechanized” as used in the Minimum Tool use for Preserves and Reeserves is to apply to tool use only, and not to trail users. However, the perception by anyone familiar with the Wilderness Act is that bicycles are not permitted. The context in which it is used fails to clearly indicate that this does not mean bicycles are prohibited from preserves and reserves. A cursory reading by a State Park employee might lead to that wrong conclusion. It certainly does that to the public, again creating an unwelcoming message to bicyclists.

Language from the Wilderness Act is specific to the management of wilderness. Park units that are managed under a different desgination and for different purpose to Wilderness should have language specific to that designation. How can a cultural preserve, whose mission is to preserve and protect man-made historically significant artifacts or structures, be managed in the same way as Wilderness, whose mission is to preserve and protect pristine habitats? So once again, we would like to see language other than “non-mechanized” used in this context for Preserves and Reserves.

For Minimum Tool use we might suggest the following language, or something similar: “using the tools and methods with the least resource impacts possible to get the task done, and excluding motorized or mechanized equipment.”

If you have any questions about the above suggestions and comments, please feel free to contact me. I urge and look forward to another round of drafts for public review.


Steve Messer
President, Concerned Off-Road Bicyclists Association

CC: Major General Anthony Jackson, Director, California State Parks
John Laird, Secretary, Natural Resources Agency
Lousi Nastro, Assistant to the California State Park and Recreation Commission
Fran Pavley, District 27 State Senator
Matthew Dababneh, District 45 Assembly Member

About CORBA:  The Concerned Off-Road Bicyclists Association (CORBA) is an all-volunteer 501(c)(3) nonprofit, and a chapter of the International Mountain Bicyclists Association (IMBA). Formed in 1987, CORBA works with land managers and the off-road cycling community at large to foster off-road cycling as a healthy, sustainable outdoor recreation in Los Angeles and Ventura Counties. CORBA is dedicated to preserving open space, maintaining public access to public lands, and creating more trail opportunities for all to enjoy. CORBA works with California State Parks, National Park Service, National Forest Service, Mountains Recreation Conservation Authority, Conejo Open Space Agency, as well as other local City and County government agencies. Our Volunteer Trail Crew, Youth Adventures, Free Skills Clinics, CORBA Kids Club and other programs promote off-road cycling recreation, and the responsible use and stewardship of our trails and open spaces.  

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