The Sierra Club might want to reconsider its Park City Agreement with IMBA, in the light of this development!:


From: Jennifer Lamb <>

Subject: IMBA's Comments to the Forest Service on President Clinton's

Roadless Initiat

Date: Tue, 21 Dec 1999 16:00:07 -0800


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

Have a peaceful holiday,


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



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


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


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: website: <>