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  1. #1
    A guy on a bike Moderator
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    Colorado Trail Access Issues

    If you love the Colorado Trail, check out this thread: Colorado Trail Access Issues

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    Toby - you should make this a sticky until the public comment period has expired. For reference, the final day is Dec 17th.

    Link to the actual Forest Service information: USDA Forest Service - Saguache Ranger District NEPA Projects - Continental Divide National Scenic Trail Addition
    Link to IMBAs support page: Support Bike Access on the Continental Divide Trail | International Mountain Bicycling Association
    Link to Denver Post article: A rerouting of Continental Divide Trail in southern Colorado could ban bikes - The Denver Post
    Link to analyses of *scientific* studies of trail-user impacts: WildBike - Advocacy
    Last edited by SkaredShtles; 11-29-2012 at 09:46 AM.

  3. #3
    A guy on a bike Moderator
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    I'd like to sticky it, but I'm only a moderator for the bikepacking forum. I'll see if one of the other mods can do it,

    Thanks for the extra links. Very nice!

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    Comments to the FS sent.

  5. #5
    A guy on a bike Moderator
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    Quote Originally Posted by ingluis View Post
    Comments to the FS sent.
    Thank you!

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    Quote Originally Posted by TobyGadd View Post
    If you love the Colorado Trail, check out this thread: Colorado Trail Access Issues
    Thanks for posting.

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    I find the language in the EA under the "Hikers/horseback riders" section starting on page 27 very troubling. It states that MTBs have more environmental impact than equestrians and hikers, yet it fails to cite any evidence or scientific proof of this damage. Further, the EA mentions nothing of the environmental impacts caused by hikers/equestrians.

    The report then states the trail will have "tread width of 24 inches and clearing width of 6 feet" on either side of the trail. It seems to imply an 8 foot wide swath cut through the forest for a "primitive" trail.

    It's clear the EA was written in support of "Alternative 2" and the language used in the EA shows obvious bias toward hikers/equestrians while demonizing MTB and motorized access.

  8. #8
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    Quote Originally Posted by rogbie View Post
    I find the language in the EA under the "Hikers/horseback riders" section starting on page 27 very troubling. It states that MTBs have more environmental impact than equestrians and hikers, yet it fails to cite any evidence or scientific proof of this damage. Further, the EA mentions nothing of the environmental impacts caused by hikers/equestrians.
    In my correspondence with the FS contact email I cited that *exact* section. The thought that someone might argue that equestrians have *less* impact than bikes is pretty ludicrous given the studies I've reviewed.

    It's clear the EA was written in support of "Alternative 2" and the language used in the EA shows obvious bias toward hikers/equestrians while demonizing MTB and motorized access.
    Yep. I would encourage everyone to read the EA themselves and register their support *specifically* for Alternative 3 which allows bicyclists.

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    I addressed the bias in my letters to Mary Nelson, and the email provided in the EA:

    "Further, I find the language of the EA biased toward Alternative 2. More troubling language occurs in the statements regarding environmental impacts of mountain bikes on trail tread (paragraph 4 on page 28) with no supporting evidence of such impacts. Most troubling though, is the lack of comment on the environmental impacts of "hikers/horseback riders" on trail tread.

    Lastly, closing trails to users limits the volunteer base that is the foundation of trail maintenance."

  10. #10
    A guy on a bike Moderator
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    More! We need MORE!

    That is, we need more people to submit comments. We have two more weeks to make a positive contribution to this important issue. Don't let your voice be unheard...

    Thanks!

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    Done... Thanks for the heads up, TobyGadd!

  12. #12
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    Submit Your Comments!

    Thanks! Don't forget to submit your comments: Submit your CDT Comments | International Mountain Bicycling Association

    Please join COMBA and IMBA in recommending a more bike-friendly solution. We are gathering comments in support of "Alternative 3" an option that the Forest Service is considering and which would allow bicycles on the new singletrack.

    Take Action! Support Bike Access on the Continental Divide Trail | Colorado Mountain Bike Association

    Thanks for you support!

  13. #13
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    I am going to singlehandedly make this a sticky!

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    I sent in a comment on this a few weeks ago. My text is below. Feel free to incorporate whatever points you feel you agree with. Also, I included a link to this recent research paper which refutes the misguided opinions in the FS document. "Following our mountain bike research in the Southwest, we feel confident in asserting that mountain biking does not appear to be any more damaging to the environment than other trail-based recreation activities."


    After reading the CDNST proposed reroute for the Lujan to La Garita I was disappointed to learn that the prefered alternative would exclude mountain bikers. The justifications given were counter to what I have learned and observed in my trail experiences as a trained and experienced trail designer. That is, the purported cupping of the trail and the potential user conflicts. First of all, cupping from bike riders is not nearly as common as the justification suggests, and it has been my experience that when a trail is properly designed and built, with low to moderate bike traffic, there is no signficant difference in trail wear between a biker and a hiker. If anything, the non-motorized user that needs to be excluded are equestrians, which contribute an order of magnitude more wear per user than hikers and bikers. Second of all, as the document explains, this portion of the CDNST has few users of any type, thus the entire argument about tread wear is moot -- no user group should contribute any significant amount of wear as compared to basic weathering. As far as user conflict goes, a proper design that includes good sight-lines, curvilinear design, and appropriate grades will eliminate situations where bikers impact the trail experience of other users. Finally, as described in the document, one of the major users of this area of the trail, and in some sections the biggest users by far, are mountain bikers, yet, somehow the writers of this document justify excluding them using what amounts to invalid conclusions based on traffic and wear assumptions that don't apply to this area. I hope that you will reconsider your proposed alternative to take into account current studies of mountain bike impact versus other users. Human powered travel should be the prefered mode, and bikers should be allowed to traverse this section along with others.

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    Manual stickyfication.

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    FWIW, here's what I submitted via the IMBA website:

    Thank you for the opportunity to comment on the Continental Divide National Scenic Trail Reroute Environmental Assessment (EA). I’m an avid hiker and cyclist. I believe management decisions in the proposed trail reroute located on public land should be based on science, best available land management practices, and should be inclusive to as many user groups as is practical. I am submitting these comments in support of Alternative 3.

    The Forest Service has not complied with either the National Environmental Policy Act (NEPA) or the Federal Land Policy and Management Act (FLPMA) in the EA. It has failed to fairly assess and disclose impacts hikers, equestrians, mountain bikes would have on the proposed trail. The Forest Service also has not provided the public with all the information necessary to make an informed decision, pursuant to NEPA. The following comments detail the Forest Service's overt bias and prejudice against mountain bike use on the proposed trail, without considering best available land management practices or providing the public a scientific basis for its conclusions.

    There are 1000's of miles of trails in backcountry settings that support mechanized and non-mechanized use. The EA makes no mention of these examples of successful user group management or how they could be applied to the proposed trail.

    Page 28 of the EA discusses the alleged effects of mountain bikes on trail tread. The statements in this section are baseless and without merit. In the absence of peer reviewed research or other scientific based assessment, the assertions that mountain bike impacts on tread should not be part of the EA analysis as they prejudice the conclusions and provide a baseless justification for excluding mountain bikes. In addition, the EA makes no mention of tread impacts from hiker or equestrian use. There is research (see below) that demonstrates that impacts from hikers and equestrians are on par with those of bicycles.

    I refer you to the following studies that invalidate the tread impact assertions in the EA:

    Chiu, Luke and Kriwoken, Lorne, “Managing Recreational Mountain Biking in Wellington Park, Tasmania, Australia,” Annals of Leisure Research

    Crockett, Christopher S., “Survey of Ecological Impact Considerations Related to Mountain Bicycle Use on the Edwards Field Trail at Joseph D. Grant County Park, 1986, Santa Clara County (CA) Parks Dept. (1986)

    Goeft, Ute and Alder, Jackie, “Sustainable Mountain Biking: A Case Study from the Southwest of Western Australia,” Journal of Sustainable Tourism, (2001), 9(3):193-211

    Wilson, John P. and Seney, Joseph P., “Erosional Impacts of Hikers, Horses, Motorcycles and Off-Road Bicycles on Mountain Trails in Montana,” Mountain Research and Development, (1994), 47(1):77-88.

    Another example of incomplete disclosure and baseless prejudice against mountain bikes is found in the statement on page 29, "Some riders may actually prefer the use of roads and more developed surfaces and less of a feeling of isolation, while others seek that experience." This is another speculative statement without any basis in fact. The idea that some user groups might prefer “roads and more developed surfaces and less of a feeling of isolation” is not limited to mountain bikers. This idea applies equally to horseback riders and hikers, however it is only used as additional justification to exclude bicycles from the proposed trail.

    Chapter 5 of the EA lists William Apple (Trail Angel) as one of the individuals included in the EA consultation process. I don’t know Mr. Apple or what his bias’s might be, however as the only non-governmental individual listed in the consultation process, his role and influence on the EA should be disclosed. In the event that Mr. Apple has any degree of bias against mountain bikes on the proposed trail, a mountain biking proponent should be added to the consultation process to assure a balanced and fair process.

    In conclusion, the EA’s Preferred Alternative (2) isn’t based on best available land management practices or science. Alternative 3 should be selected so that our public lands are inclusive to all low impact user groups, which includes mountain bikes.

  17. #17
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    Stick!

  18. #18
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    Quote Originally Posted by jradin View Post
    fwiw, here's what i submitted via the imba website:

    Thank you for the opportunity to comment on the continental divide national scenic trail reroute environmental assessment (ea). I’m an avid hiker and cyclist. I believe management decisions in the proposed trail reroute located on public land should be based on science, best available land management practices, and should be inclusive to as many user groups as is practical. I am submitting these comments in support of alternative 3.

    The forest service has not complied with either the national environmental policy act (nepa) or the federal land policy and management act (flpma) in the ea. It has failed to fairly assess and disclose impacts hikers, equestrians, mountain bikes would have on the proposed trail. The forest service also has not provided the public with all the information necessary to make an informed decision, pursuant to nepa. The following comments detail the forest service's overt bias and prejudice against mountain bike use on the proposed trail, without considering best available land management practices or providing the public a scientific basis for its conclusions.

    There are 1000's of miles of trails in backcountry settings that support mechanized and non-mechanized use. The ea makes no mention of these examples of successful user group management or how they could be applied to the proposed trail.

    Page 28 of the ea discusses the alleged effects of mountain bikes on trail tread. The statements in this section are baseless and without merit. In the absence of peer reviewed research or other scientific based assessment, the assertions that mountain bike impacts on tread should not be part of the ea analysis as they prejudice the conclusions and provide a baseless justification for excluding mountain bikes. In addition, the ea makes no mention of tread impacts from hiker or equestrian use. There is research (see below) that demonstrates that impacts from hikers and equestrians are on par with those of bicycles.

    I refer you to the following studies that invalidate the tread impact assertions in the ea:

    Chiu, luke and kriwoken, lorne, “managing recreational mountain biking in wellington park, tasmania, australia,” annals of leisure research

    crockett, christopher s., “survey of ecological impact considerations related to mountain bicycle use on the edwards field trail at joseph d. Grant county park, 1986, santa clara county (ca) parks dept. (1986)

    goeft, ute and alder, jackie, “sustainable mountain biking: A case study from the southwest of western australia,” journal of sustainable tourism, (2001), 9(3):193-211

    wilson, john p. And seney, joseph p., “erosional impacts of hikers, horses, motorcycles and off-road bicycles on mountain trails in montana,” mountain research and development, (1994), 47(1):77-88.

    Another example of incomplete disclosure and baseless prejudice against mountain bikes is found in the statement on page 29, "some riders may actually prefer the use of roads and more developed surfaces and less of a feeling of isolation, while others seek that experience." this is another speculative statement without any basis in fact. The idea that some user groups might prefer “roads and more developed surfaces and less of a feeling of isolation” is not limited to mountain bikers. This idea applies equally to horseback riders and hikers, however it is only used as additional justification to exclude bicycles from the proposed trail.

    Chapter 5 of the ea lists william apple (trail angel) as one of the individuals included in the ea consultation process. I don’t know mr. Apple or what his bias’s might be, however as the only non-governmental individual listed in the consultation process, his role and influence on the ea should be disclosed. In the event that mr. Apple has any degree of bias against mountain bikes on the proposed trail, a mountain biking proponent should be added to the consultation process to assure a balanced and fair process.

    In conclusion, the ea’s preferred alternative (2) isn’t based on best available land management practices or science. Alternative 3 should be selected so that our public lands are inclusive to all low impact user groups, which includes mountain bikes.
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    Does anyone know when the 30 day comment period ends? The EA is dated October, so I have a feeling it may already be over.

  20. #20
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    Quote Originally Posted by jradin View Post
    Does anyone know when the 30 day comment period ends? The EA is dated October, so I have a feeling it may already be over.
    The comment deadline was extended until Dec 17th.

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    I've been thinking a lot about this issue since submitting comments yesterday (probably thinking about it too much as my distracted state had me nearly swerving off the trail today).

    First of all, submitting comments that say, "I prefer Alternative 3 because..." won't influence the process. You have to challenge the validity of the Environmental Assessment. You have to demonstrate that the EA is fundamentally flawed and violates the intent of the National Environmental Policy Act (NEPA). Fortunately, as experienced mountain bikers and trail volunteers, we have the knowledge to do that without being NEPA process experts. For example, here's an exceprt from page 28 of the EA:

    "Also, where the trail created by hiker and horse use is more likely to have relatively flat walking surface, the “cross section profile” of the tread of a trail used by mountain bike traffic is often rounded, or open horseshoe shaped. The consequence of this to the hiker and horse is that with each step, the foot is placed on an inward slope, turning the ankle and knee, and even hip, in an unnatural fashion. Long hikes on this kind of trail can result in unusual soreness in hikers or horses, and simply be uncomfortable."
    (emphasis mine)

    I have no training in trail design. I've know very little about the long term impacts on trail from mountain bikes. Perhaps this is a true statement and belongs in the EA. Perhaps this is a valid reason for excluding mountain bikers from the proposed 31 miles of (potentially epic) single track. Maybe the "discomfort" hikers experience is real. However there are no references in the EA to support this statement. In fact, the EA doesn't have a reference or bibliography section at all. The purpose of an EA is to disclose environmental impacts. In the absence of science-based references, the basis for excluding mountain bikes is in question. THIS IS HOW YOU CHALLENGE THE EA.

    Open the document and read Page 28. If it gets you fired up, submit comments. Or donate to the IMBA or COMBA legal funds.

    There have been many threads on these forums *****ing about the Wilderness designation and it's resultant exclusion of mountain bikes. Well, as I see it, the Continental Divide Trail is where the Wilderness Act was before they replaced the "motorized" prohibition with the "mechanized" prohibition.

    Mechanized travel is accepted per the 2009 Continental Divide National Scenic Trail Comprehensive Plan. The EA references the Plan many times, but skews it's intent and uses it as a basis for excluding mechanized travel (sound familiar...motorized vs mechanized in Wilderness?).

    See page 15 of The Continental Divide National Scenic Trail Comprehensive Plan:
    http://www.fs.fed.us/cdt/main/cdnst_...nal_092809.pdf

    In the Recreation Resource policy section, It says:

    (1) Manage the CDNST to provide high-quality scenic, primitive hiking and pack and saddle stock opportunities. Backpacking, nature walking, day hiking, horseback riding, nature photography, mountain climbing, cross-country skiing, and snowshoeing are compatible with the nature and purposes of the CDNST.
    (2) Bicycle use may be allowed on the CDNST (16 U.S.C. 1246(c)) if the use is consistent with the applicable land and resource management plan and will not substantially interfere with the nature and purposes of the CDNST.

    I'm going to submit some additional comments challenging the EA's assertion that mechanized travel isn't consistent with the "applicable land and resource management plant". I just don't think the EA has made a substantive case.

    The truth is, I may never ride this section of trail even if it is open to bikes, but I hate the thought that the unsubstantiated statements in this EA could be used to keep bikes off other new or existing CDNST trails (perhaps they already have?), so it's worth submitting my 2 cents. I hope you feel the same.

  22. #22
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    Submit Your Comments until December 17th!

    Quote Originally Posted by jradin View Post
    FWIW, here's what I submitted via the IMBA website:

    Thank you for the opportunity to comment on the Continental Divide National Scenic Trail Reroute Environmental Assessment (EA). I’m an avid hiker and cyclist. I believe management decisions in the proposed trail reroute located on public land should be based on science, best available land management practices, and should be inclusive to as many user groups as is practical. I am submitting these comments in support of Alternative 3.

    The Forest Service has not complied with either the National Environmental Policy Act (NEPA) or the Federal Land Policy and Management Act (FLPMA) in the EA. It has failed to fairly assess and disclose impacts hikers, equestrians, mountain bikes would have on the proposed trail. The Forest Service also has not provided the public with all the information necessary to make an informed decision, pursuant to NEPA. The following comments detail the Forest Service's overt bias and prejudice against mountain bike use on the proposed trail, without considering best available land management practices or providing the public a scientific basis for its conclusions.

    There are 1000's of miles of trails in backcountry settings that support mechanized and non-mechanized use. The EA makes no mention of these examples of successful user group management or how they could be applied to the proposed trail.

    Page 28 of the EA discusses the alleged effects of mountain bikes on trail tread. The statements in this section are baseless and without merit. In the absence of peer reviewed research or other scientific based assessment, the assertions that mountain bike impacts on tread should not be part of the EA analysis as they prejudice the conclusions and provide a baseless justification for excluding mountain bikes. In addition, the EA makes no mention of tread impacts from hiker or equestrian use. There is research (see below) that demonstrates that impacts from hikers and equestrians are on par with those of bicycles.

    I refer you to the following studies that invalidate the tread impact assertions in the EA:

    Chiu, Luke and Kriwoken, Lorne, “Managing Recreational Mountain Biking in Wellington Park, Tasmania, Australia,” Annals of Leisure Research

    Crockett, Christopher S., “Survey of Ecological Impact Considerations Related to Mountain Bicycle Use on the Edwards Field Trail at Joseph D. Grant County Park, 1986, Santa Clara County (CA) Parks Dept. (1986)

    Goeft, Ute and Alder, Jackie, “Sustainable Mountain Biking: A Case Study from the Southwest of Western Australia,” Journal of Sustainable Tourism, (2001), 9(3):193-211

    Wilson, John P. and Seney, Joseph P., “Erosional Impacts of Hikers, Horses, Motorcycles and Off-Road Bicycles on Mountain Trails in Montana,” Mountain Research and Development, (1994), 47(1):77-88.

    Another example of incomplete disclosure and baseless prejudice against mountain bikes is found in the statement on page 29, "Some riders may actually prefer the use of roads and more developed surfaces and less of a feeling of isolation, while others seek that experience." This is another speculative statement without any basis in fact. The idea that some user groups might prefer “roads and more developed surfaces and less of a feeling of isolation” is not limited to mountain bikers. This idea applies equally to horseback riders and hikers, however it is only used as additional justification to exclude bicycles from the proposed trail.

    Chapter 5 of the EA lists William Apple (Trail Angel) as one of the individuals included in the EA consultation process. I don’t know Mr. Apple or what his bias’s might be, however as the only non-governmental individual listed in the consultation process, his role and influence on the EA should be disclosed. In the event that Mr. Apple has any degree of bias against mountain bikes on the proposed trail, a mountain biking proponent should be added to the consultation process to assure a balanced and fair process.

    In conclusion, the EA’s Preferred Alternative (2) isn’t based on best available land management practices or science. Alternative 3 should be selected so that our public lands are inclusive to all low impact user groups, which includes mountain bikes.
    This is fantastic, thank-you for sharing, references and all!

  23. #23
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    Bumpity bump bump.

    Less than a week left to comment!

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    Bump.
    Last day to comment!

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    Comment sent.
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