Sun, 24 Jun 2001
Board of Directors
85 Second Street
San Francisco, CA 94105-5799
Dear Members of the Board of Directors,
I'm a Sierra Club member and would like to provide some information that
may help in a possible review of the 1994 Park City Agreement between
the Sierra Club and the International Mountain Bicycling Association
My family does a great deal of hiking on the trails of San Francisco Bay
Area parks and I've become familiar with the controversy surrounding
off-road mountain biking. In my view, IMBA and its affiliated
organizations have consistently fought against reasonable environmental
and safety regulations for off-road biking. In the Bay Area the primary
IMBA-affiliated organizations are the Bicycle Trails Council of the East
Bay and the Bicycle Trails Council of Marin.
The most obvious example of the attacks on environmental and safety
regulations is the lawsuit that IMBA and the above Bay Area organizations
brought against the National Park Service (NPS) in their attempt to
overturn the 1992 mountain biking regulations of the Golden Gate National
Recreation Area. The U.S. District Court upheld the reasonable NPS policy
that prohibited mountain bikes on narrow trails, and the mountain bikers
lost their appeal to the U.S. Court of Appeals in 1996 ("Bicycle Trails
Council of Marin v. Babbitt", 82 F.3d 1445 (9th Cir. 1996)).
The Sierra Club was an important Defendant-Intervenor in the case, which
today stands as a landmark ruling in environmental law. Note that the
mountain bikers continued their litigation against the NPS into 1996,
two years after the Park City Agreement was signed.
I don't believe that anything has changed since 1996. In the Oakland
area in which I live, the IMBA-affiliated groups continue to press for
park management agencies to open most trails to off-road mountain biking,
regardless of the safety and environmental consequences. Mountain bikers
training for off-road racing or engaging in aggressive sport riding have
displaced families with small children and senior citizens from many of
the local trails, as park walkers, hikers and bird watchers are concerned
about the possibility of a high-speed collision.
In the 425 acre Oakland city park (Joaquin Miller) next to our house,
recent trail injuries range from a 1998 mountain biker fatality that
resulted from the biker flying headfirst over his handlebars when braking
too hard while going over tree roots (the biker was wearing his helmet),
to the extensive internal bleeding suffered by a senior citizen who
required emergency medical treatment after he took a hard fall trying to
avoid a speeding biker in 2000. In the East Bay Regional Park District
(greater Oakland area) in 2000, seven mountain bikers required helicopter
airlifts to hospitals after accidents, and a total of 36 people were
sent to hospitals after bike accidents.
The Park City Agreement does not make clear the Sierra Club's view of the
use of park trails for high speed off-road racing training or aggressive
sport riding, or to what extent trails should be opened to mountain bikes.
The agreement simply refers to using trails in a "socially responsible
manner" and says that "not all non-Wilderness trails should be opened
to bicycle use". I'm afraid that this can be interpreted as permitting
riding on most narrow trails, and many mountain bikers consider this
socially responsible, even at high speeds.
Because the Park City Agreement specifically mentions that biking
on "single track" trails is a "legitimate form of recreation and
transportation", I'd like point out that this is not consistent with
standard engineering practice in the State of California for the
construction of stand-alone bike paths.
The State's Department of Transportation has detailed engineering
specifications for how wide bike paths need to be, how sharp turns
can be, the required clearances on the side of trails and allowable
grades [reference: CALTRANS Design Criteria 1003.1 Class I Bikeways
(bike paths)]. The specified minimum width for two-way paths is 3.6
meters if "significant pedestrian traffic is expected". Clearly, the
State of California has a serious concern about bicyclist and pedestrian
safety on narrow paths, and I don't believe that a licensed civil or
transportation engineer in California could recommend allowing biking on
single-track trails (typically 2-4 ft. wide) without violating provisions
of the State's "Professional Engineers Act", which provides for strong
penalties for negligence or incompetence.
I recommend that the Sierra Club defer to licensed professional engineers
and appropriate engineering regulations on the issue of what sorts of
trails are appropriate for bicycles.
For those of you who have not spent much time walking or hiking on trails
popular with off-road mountain bikers -- which in my City is essentially
every trail -- I'd like provide a glimpse of what the trail experience
is like by quoting from a leading off-road mountain bike magazine,
"Mountain Bike Action", from the 8/2000 issue.
The issue was brought to my attention as it featured an extensive article
with color photos about a new trail in Oakland. The trail was built by
mountain bikers from IMBA-affiliated groups in City open space parkland
without appropriate environmental or safety review or the required
"Creek Protection" permit. The article, "The Battle for Dimond Canyon --
Why Oakland, California's new urban singletrack raises the ante for
mountain bikers everywhere", gives good insight as to how the trails
near my family's home and in the Bay Area in general are being used by
many mountain bikers. The first paragraph on page 103 states:
Most people traveling through Oakland, California do so
reluctantly -- it's like Beirut or Bosnia, only on the West Coast.
To be fair, Oakland has improved somewhat during the tenure
of Mayor Jerry Brown, but still has its fair share of problems.
There are those nasty imploding ghettos, random carjackings and,
of course, full-clip full-auto shootouts. But wait, what's that
off of Fruitvale Avenue, right behind the city's public pool?
It's some local hammerhead dropping in on a 25-percent vertical
grade singletrack, then railing a dozen root ledges as he
glissades all the way down to the rocky creek. Whoa, Dorothy,
you and the Munchkins aren't in the ghetto anymore! Grab your
bike and put on your sparkly red bikin' shoes, 'cuz we're going
to bag some of the slinky stuff. Be sure to check your brakes,
though -- rumor has it the Oakland coroner has been seen handing
out complimentary toe tags at the precipitous bottom!
The Sierra Club needs to decide if it wants to be associated with
mountain biking organizations such as IMBA that value parks primarily as
locations for high-speed, thrill-seeking recreation, or if traditional
park activities such as a walking, hiking, bird watching and nature
study should be given higher priority. The Sierra Club's "Off Road
Use of Bicycles" policy dated May 1994 is consistent with traditional
use and protection of parks. The Park City Agreement undermines the
above policy and should be rescinded.
Please do not hesitate to contact me if you would like to review
documentation supporting my comments above or if you have any questions.
[name withheld to protect them from threats, harassment, and vandalism by mountain bikers]