USFS Call for Public Comment!

USFS Revisions for the Inyo, Sequoia, and Sierra National Forests

“The conservation of the Pacific Crest Trail (PCT) is very important to me. For this reason, I take great interest in the current proposal to establish special management areas such as what might be created along the PCT corridor so as to better care for the trail. However, I am loath to support any proposal that may perpetuate the unfair, inappropriate and unnecessary exclusion from the PCT of trail users who would like to experience parts of the trail by bicycle.

The 1988 temporary Closure Order that is the basis for the bicycle exclusion is badly outdated; reflects 25-year-old management practice; never involved significant public input; does not serve the long-term conservation goals for the PCT; and unfairly prevents a significant segment of the public from accessing any part of the public trail in a safe and sustainable manner. Preserving a 2,650-mile public trail for the exclusive use of a relatively tiny segment of the public is bad policy and it erodes public support for the trail.

Until USFS agrees to a transparent, public review of the 1988 Closure Order, it is very difficult to support efforts that may perpetuate the plainly outdated ban on bicycle access.”

“To the Decision Makers addressing the Inyo, Sierra, and Sequoia National Forests Land Management Plans:

As an avid outdoorsman and a lover of the gorgeous Sierras, I am pleased to see efforts to sustainably manage this magnificent natural resource. However, I must strenuously object to the codifying of the ill-advised ban on bicycle across these portions of the PCT (as well as non-Wilderness areas across the PCT as a whole)

The 1988 temporary Closure Order that initiated the bicycle ban is outdated; reflects an incomplete management practice, failed to include significant public input, and most importantly does not serve the long-term conservation goals for the PCT. Preserving a 2,650-mile public trail for the exclusive use of one or two user groups at the expense of an equally low-impact user group bad policy and it erodes public support for the trail. Until USFS agrees to a transparent, public review of the 1988 Closure Order, it is very difficult to support efforts that may perpetuate the plainly outdated ban on bicycle access.

I have hiked portions of the PCT and cycled adjacent trails which cross the PCT. The portions I hiked were perfectly suitable and sustainable as cycling routes. Moreover, the wording in the plan that implies the possible further removal of cycling access to key trails which cross the PCT is particularly disturbing.

Hikers often cite bad behavior by cyclists as a reason to perpetuate the ban. However, hikers and backpackers are more likely to build illegal fire rings, smoke in high fire danger areas, relieve themselves within close proximity of water sources, and cut switchbacks, thus creating new avenues for erosion. The point is that no one user group has exclusive claim to either vice or virtue and it makes no sense to ban one but not the other. Where trails are sustainably built, multiple studies, including those commissioned by the USFS, demonstrate the impact of cycling and hiking to be roughly equivalent and both to be far less impactful than equestrian use, which is given top billing in the plan. Cyclists impact hikers, but hikers also impact cyclists; there is no basis for placing one above the other. If you’re still concerned about protecting the hiking experience at the expense of cyclists, please consider that 1,000 miles of the PCT’s 2,600 mile length passes through designated Wilderness, thus still providing hikers and equestrians with tremendous opportunity for a bike-free experience.

Bottom line: Cycling should be allowed where it can be done suitably and sustainably, which includes some portions of the PCT. There is simply no rational justification for a blanket exclusion on all portions of the PCT to preserve the elitist experiences of a highly vocal, but no more equally valid user group. Please reconsider the perpetuation of the unfair blanket ban against this low-impact, conservation minded user group.”

“Dear Sir or Madam:

“I cannot support any proposal that may perpetuate the unfair, unenforceable, and probably unlawful putative exclusion of bicycle riders on the Pacific Crest Trail (PCT). It’s unclear to me whether this plan does this, but if it does, count me against it.

The August 31, 1988 closure order that is the basis for the bicycle exclusion is properly deemed temporary under the Forest Service’s own rules and regulations, and it expired long ago. It was promulgated by three Forest Service field personnel who typed up the closure order after the Forest Service headquarters rejected a request for a bicycle ban in 1987. Thereafter, in violation of the Administrative Procedure Act that the Forest Service is required by law to abide by, local Forest Service personnel let it become a permanent plan with no public notice or comment. And since the public wasn’t aware that the plan was implemented with no opportunity for public input, it accepted it for the most part, until the Pacific Crest Trail Reassessment Initiative challenged it in 2010. (See Sharing the Pacific Crest Trail.) That Catch-22 (no notice, therefore no complaints until 2010) has been bad: bad for the law, bad for the PCT, and bad for public support for wildland conservation.

Additionally, the PCT bicycle ban is antiquated, reflects the minimal understanding of how to manage nonmotorized trails for multiuse of a quarter-century ago, does not serve the PCT’s interests (the trail cannot be maintained with the small cadre of hiker volunteers who currently make themselves available), and unfairly prevents a significant segment of the public from accessing any part of the public trail in a safe and sustainable manner. Granting exclusive use of a 2,650-mile publicly funded trail mainly for the use of a few hundred through-hikers has resulted in public indifference about the trail, and its hundreds of miles of overgrown and poorly maintained sections are the proof of the pudding.

Until the Forest Service agrees to a thorough-going review of the 1988 closure order, one that complies with the Administrative Procedure Act by allowing public participation, attempts to put patches on the inadequate existing management scheme are a waste of time.

Certainly in the interim the Forest Service should direct its current and retired employees not to harangue mountain bikers who are on non-Wilderness PCT sections. Their presence there may be entirely lawful.”