Date: Wed, 11 Sep 2002

Subject: BLM draft National Mountain Bicycling Strategic Action Plan

Board of Directors

Sierra Club

85 Second Street

San Francisco, CA 94105-5799

Dear Members of the Board of Directors:

As a Sierra Club member, I would like to request that the Sierra Club

provide appropriate input to the Bureau of Land Management (BLM) on

the BLM's proposed National Mountain Bicycling Strategic Action Plan.

The public comment period ends 9/25/02. The Plan is described at:

A primary objective of the Plan is to provide a United States Government

endorsement for mountain biking on narrow trails. Such an endorsement

is completely at odds with the position taken by the Department of the

Interior in the previous federal litigation "Bicycle Trails Council of

Marin v. Babbitt", 82 F.3d 1445 (9th Cir. 1996). In that case, the

Sierra Club was one of several Defendants-Intervenors-Appellants and

the International Mountain Bicycling Association (IMBA) was one of the

Plaintiffs-Appellants; the Defendants' arguments in favor of prohibiting

mountain bicycling on narrow trails, which included descriptions of

environmental damage and the danger to park visitors, were upheld by

the United States Court of Appeals for the Ninth Circuit.

Please note that the above litigation extended two years past the 1994

signing of the Park City agreement between the Sierra Club and IMBA.

IMBA's name is mentioned 22 times in the proposed BLM Plan, which appears

considerably influenced by IMBA's positions that directly benefit

IMBA's commercial sponsors.

Such influence is unfortunate at a time when IMBA has emerged as a

leading threat to Wilderness in the United States. In California,

IMBA worked behind the scenes to substantially weaken Senator Boxer's

proposed Wilderness Bill before it was introduced. Now IMBA is leading

the fight to have large areas removed from the bill (S. 2535). See:

Additionally, IMBA has has started a campaign to prevent Wilderness

designation of two key areas in Idaho. See:

The influence of IMBA on the BLM Plan, and the focus on permitting

mountain biking on narrow trails which should only be used by hikers, is

made clear in the Plan's Issue 5 of topic "Planning and Environmental

Considerations" (page 11 of the non-graphics version of the draft):

Issue 5: How best to provide and preserve single-track trails.

Rationale: Single-track trails exemplify the highest quality riding

experience for most mountain bicyclists. ...

A BLM official is quoted in the 8/31/02 Deseret News (Utah -,1249,405027639,00.html) article

"Smoother pedaling for bikers" as confirming a major reason for the plan:

"I really love that it finally legitimizes single track,"

said Cimarron Chacon, landscape architect for the (BLM) in St.

George. Chacon is putting together a countywide non-motorized

trail system, and trying to discern how best to provide and

preserve single-track trails is a major part of the plan.

As you are probably aware, responsible agencies such as the National Park

Service nearly always restrict mountain bicycles to wider paths such as

fire roads and very often only to designated paved surfaces (such is the

rule in Yosemite N.P.). These restrictions are to protect the safety

of pedestrians, minimize trail erosion and damage to trailside plants,

and reduce the impact of humans on wildlife (mountain bikers can travel

over a much greater area in a day than hikers). Once mountain bicycles

are permitted on an trail, activities such as wildlife viewing,


and flora identification become very difficult to participate in because

the focus of pedestrians must shift to avoiding collisions with mountain


Some of the primary mountain biking destinations on BLM land are around

Moab, Utah (BLM info at

A quick review of the visitor experiences in that popular area leads me

to believe that off-road mountain biking is just as hazardous in Utah

as it is in the parks closer to my family's Oakland, California home.

For example, in the article "Mountain biking: Minimize your risk of

getting hurt on the trail", by Edmund R. Burke, Ph.D.,,

1/4/2002 (, the author


Hospital emergency rooms near major mountain bike trails and centers

of activity confirm that mountain bike injuries are on the rise in

proportions matching the rapid growth of the sport. For example, the

emergency room in Moab, Utah, treats 10 to 30 mountain bikers on a

typical spring or fall weekend.

"Dirt rash" is the most often treated injury. Broken collarbones --


frequent result of an unscheduled trip over the handlebar -- are


followed by wrist fractures and ankle injuries. Hip and pelvic


are more rare, but hospitals have treated a few.

When my family takes a hike, we listen for birds, look for butterflies,

lizards, snakes, and squirrels, and our 2-year-old likes to stop

every minute or two to examine a leaf, twig, or small insect. This

sort of hike is now almost impossible in the parks near our home as

at any moment a pack of bikers with up to 15 riders can appear

in an instant and shower us with dirt/dust thrown up by their knobby

tires as they pass within inches, often without slowing down

in the least.

Fortunately, our desired style of hiking and nature study is still

possible on some federal land -- even in some BLM areas. But it appears

that given IMBA's funding from commercial sponsors and its corresponding

influence, that the list of areas where off-road mountain biking is

subject to reasonable restrictions will quickly be reduced further.

It seems very likely that a U.S. Government policy that promotes

mountain biking on narrow trails, even if it is only a BLM policy at

first, will be cited by those fighting for mountain bike access to

contested trails within NPS and Forest Service boundaries, and within

State and District/County/City parks.

I hate to consider what will happen in 20-30 years, but at the rate that

IMBA is influencing decision making, it seems probable that in a few

decades or possibly less we will see packs of bikers racing the length

of the Pacific Crest Trail, and there will be few trails on public land

free from mountain bike traffic.

I don't think this is the vision that most Sierra Club members have

for our public lands, and I hope that the Club will strongly object to

the draft BLM National Mountain Bicycling Strategic Action Plan, and

recommend instead that the BLM aim for consistency with National Park

Service practice as described in the 1996 federal litigation that

the Club participated in. I recommend that the Sierra Club advise

the BLM against the use of mountain bicycles on narrow trails, for

both the reasons discussed in this letter and consistency with

the Court's 1996 ruling in "Bicycle Trails Council of Marin v. Babbitt."

I would appreciate receiving a copy of any input that the Sierra

Club sends to the BLM, or if the Sierra Club takes no position on

the Plan, an explanation for why that approach was chosen.

I'm sending a copy of this letter to organizations that have often held

views consistent with those expressed by the Sierra Club in the past,

and I encourage them to provide input to the BLM similar to that I've

suggested above.


Steve Luzmoor

Oakland, California

cc: Sierra Club Wild Planet Strategy Team

Sierra Club S.F. Bay Chapter Leadership

Audubon Society representatives

Public Employees for Environmental Responsibility

The Wilderness Society