The Sierra Club might want to reconsider its Park City Agreement with IMBA, in the light of this development!:
To: imBA@cycling.org
From: Jennifer Lamb <jen@imba.com>
Subject: IMBA's Comments to the Forest Service on President Clinton's
Roadless Initiat
Date: Tue, 21 Dec 1999 16:00:07 -0800
Reply-To: imba@topica.com
The following is IMBA's letter commenting on the Forest Service's Notice of
Intent to prepare an Environmental Impact Statement in response to
President Clinton's Roadless Initiative. If you'd like more information
about IMBA's perspective on the Roadless Initiative, please see the
December issue of IMBA Trail News (p.1) or visit our website at www.imba.com.
Have a peaceful holiday,
jen
for IMBA
============================
Dec. 20, 1999
Via email and mail
USDA Forest Service-CAET
Attention Roadless Areas NOI
P O Box 221090
Salt Lake City, UT 84122
Dear Forest Service,
The International Mountain Bicycling Association (IMBA) supports the
President's Initiative to preserve America's roadless areas. We believe
that no roads should be built into Roadless Areas within America's national
forests. Mountain bicyclists generally prefer to ride on trails in areas
where there are few (or no) roads, as long as reasonable road access to
trailheads is available.
IMBA is an international education and advocacy organization with 325
member clubs, more than 80 corporate partners, and a network of more than
50,000 individual mountain bikers. IMBA's mission is to promote mountain
bicycling opportunities that are environmentally sound and socially
responsible.
Summary
The following is a summary of IMBA's comments on the President's
Initiative. More detailed analysis follows.
1. Roadless areas are important to mountain bicyclists because they are
undisturbed and natural.
2. Roadless areas are ideal for bicycling because they contain singletrack
trails that provide the types of experiences mountain bicyclists prefer.
3. Roads and road use make forests less natural and more noisy, which can
detract from the quality of the mountain biking experience.
4. IMBA sees the Roadless Initiative as an opportunity to create and
implement a new, effective method of protecting land, while allowing
mountain biking.
5. IMBA will oppose roadless area designations if the Forest Service
requires or recommends that roadless areas be managed as if they are
Wilderness, or according to the same (or similar) travel restrictions that
pertain to Wilderness.
6. Local land managers and the public must continue to play a role in
recreation management of roadless areas.
7. Mountain bicycling should not be restricted in roadless areas unless
scientific research demonstrates that the ecological impact of cycling is
greater than that of other allowable recreation uses.
8. IMBA believes that bicycle use -- a form of non-motorized recreation and
transportation -- is appropriate in, and consistent with, the purposes of
roadless areas.
Effects Of Banning Road-Building
The Notice of Intent states that the environmental impact statement will
examine two main issues. The first is the effects of eliminating road
construction in roadless areas. IMBA asks the Forest Service to consider
the outcome of the opposite action: the effects of constructing roads on
the opportunities for mountain bicycling. Forest roads are typically built
to support logging, mining and other industrial activities, or to access
inholdings. These activities can degrade the quality of mountain bicycling
experiences, discouraging visitation and hurting tourism.
Ecological Values
The second issue under examination relates to social and ecological values
that make roadless areas important. IMBA requests that the Forest Service
examine how mountain biking relates to those values.
IMBA recognizes that all types of forest uses, including recreation, have
ecological impacts. IMBA agrees with the Forest Service statement that
roads and activities associated with roads can cause ecological problems.
But we do not believe that the agency, or any scientist, can at this time
reasonably distinguish the ecological impacts of different non-motorized
recreation forms. While the effects on wildlife of people walking, running,
horseback riding, or mountain bicycling are often argued, no science is
available to compare these impacts. The complexity of this debate is
significant. Among the many parameters of impact are duration, startling,
and noise. Generally, hikers stay in areas the longest, mountain bikers may
startle more, and motorcycles create more noise, but there is little
evidence to support any statements regarding the relative significance of
these effects. The diversity of species affected makes the analysis more
complex.
In the absence of scientific data, it would be an error to single out
bicycling -- or, for that matter, any other non-motorized trail use -- as
more harmful than another. Therefore, all four of the proposed alternatives
for part one of the EIS ought to allow bicycling within roadless areas.
Social Values
The social values issue relates to diverse perceptions, opinions, and
philosophies held by Americans. Some may believe that roadless areas are
not proper places for bicycling because bicycles are "mechanical." This is
the reason bikes are banned in Wilderness under current interpretation of
the Wilderness Act. IMBA maintains that "mechanical" transport is
consistent with the values of roadless areas. The tenets of Wilderness
management should not be applied to roadless areas.
Mountain bicycling is human powered, silent recreation. It helps people
appreciate and respect nature, motivating them to protect it. Nature needs
a human constituency that includes mountain bicyclists.
Smaller, Uninventoried Roadless Areas
IMBA recommends that the agency adopt a rule or policy that encourages
individual national forests to examine smaller roadless areas on a
site-specific basis, with thorough public participation. A prohibition on
road building in these areas could benefit bicyclists.
Tongass National Forest
The Notice of Intent specifically requested comment on the Tongass National
Forest in Alaska. IMBA believes that the proposed rule should apply to the
Tongass, and the EIS should examine the effects of the rule in both parts
one and two.
Motorized Recreation
IMBA requests that the Forest Service not lump bicycling into the motorized
recreation category, both in terms of analysis and management actions.
Bicycling is non-motorized and properly belongs within analysis and
management of non-motorized recreation.
IMBA is concerned about the widening of singletrack trails by the travel of
all-terrain-vehicles. ATVs are too wide for singletrack trails. Their
wheelbase is typically 50 inches, whereas the tread width of most Forest
Service singletrack is 12 to 36 inches. Bicyclists value the narrow
character of singletrack and strongly object when ATVs cause such routes to
widen. The wide routes created by ATV use are essentially roads. ATVs are
not appropriate on narrow trails and should be prohibited within roadless
areas.
Burden Of Proof
Among the four alternatives outlined in the Notice of Intent, the third may
create an impossible standard for recreation by requiring that activities
"contribute" to ecological values of roadless areas. What about allowing
those activities that do not harm or interfere with ecological values?
Vegetation management, trail maintenance, or stream restoration may enhance
ecological values. But it is difficult to see how any human recreation can
contribute to ecological values.
Protecting the Land with Cyclists' Support
IMBA supports the Roadless Initiative because we believe it can protect
natural, undisturbed areas and maintain bicycling opportunities. In
addition, IMBA sees this Initiative as an opportunity to create and
implement a new, effective method of protecting Forest Service land. While
IMBA can support the designation of some new Wilderness areas within
national forests, we seek to protect land with legal tools that allow
mountain bicycling. An official Roadless Area designation can be exactly that.
However, we will oppose Roadless Area designations if the Forest Service
requires or recommends that roadless areas be managed as if they are
Wilderness, or according to the same (or similar) travel restrictions that
pertain to Wilderness. Such a requirement would eliminate the appeal of
this designation as a supplement or alternative to Wilderness.
We hope that the Forest Service will recognize the value of creating
something different than Wilderness. This would increase bicyclists'
support for the agency's process and intent.
Thanks for your consideration of these comments,
Best wishes,
Tim Blumenthal
IMBA Executive Director
--
Jennifer Lamb-Advocacy Director
International Mountain Bicycling Association
ph: (303)545-9011 x 103, FAX: (303)545-9026
e-mail: jen@imba.com website: <http://www.imba.com>http://www.imba.com