Sun, 24 Jun 2001

Board of Directors

Sierra Club

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]

Oakland, California