December
24, 2002
Patti
Du Mont
Environmental
Coordinator
California
Department of Parks and Recreation
Acquisition
and Development
One
Capitol Mall - Suite 500
Sacramento,
CA 95814
43 page fax including this page: 916 445-9100
The Board of Directors of the Tamalpais Conservation Club,
founded in 1912 on the principals of “preserving the natural features of Marin
County and particularly Mount Tamalpais” state for the record that the project
as presented through various forms of communications between first receipt of
the Application by a third party on October 5, 2002 through the events leading
up to today is factually incorrect, contradictory, completely lacking in
scientific citation to back up any of the several key assertions and incomplete
as outlined below.
Furthermore, we believe the Mitigated Negative Declaration
(MND) as proposed is an unnecessary waste of money and resources at a time when
the State of California is facing a serious budgetary shortfall. We assert
there are several common sense cost-saving steps that should be instituted to
reduce the overall cost of the project while simultaneously protecting the
environment, substantially reducing erosion, improving safety, improving aesthetic
appeal and increasing visitor diversity.
Based on the facts at hand, the TCC believes this project in
its current form will create more environmental damage to Mount Tamalpais State
Park then it will solve. Certainly it will create negative environmental and
social impacts well beyond any of the estimations purported by the Mitigated
Negative Declaration. Based upon the following facts, the TCC requests that a
complete EIR be performed.
The Board of Directors of the Tamalpais Conservation Club
request the minimum acceptable width of the proposed Coastal Fire Trail is not
less than 72”. With regard to the Lone Tree Fire Road, we request it be
decommissioned and no trail is built to replace it.
The following are the major points and deficiencies of the
MND:
1. Creation of an
Attraction and Use Level Deficiencies
Critical to the proposal, the MND claims no impact and no
additional “attractions” would be created. The MND also claims that it would
not substantially increase visitation or demands to this or any other park or
recreational facility in the area.
(p 54, Section XIV, a)
The TCC maintains there is ample and compelling evidence
that the creation of a trail of less than 72” in width will in and of itself
set a precedent on MTSP and by DPR’s own admission will create a major
“international” “attraction” as outlined below.
a. The MND is inconsistent, in direct conflict and direct
contradiction with its own Application, entitled “Final EEM application10-02.”
The MND does not address DPR’s own anticipated increased environmental impact,
increases in traffic congestion and parking, and the need for additional
staffing.
The MND specifically and substantially conflicts with the
Application in the following two critical areas:
None of the project elements would contribute to a
significant increase of visitation and the level of required services is
expected to remain relatively static.
(p. 52 Section XIII, a: Discussion)
A significant increase in overall visitation to Mt.
Tamalpais SP is not anticipated as a result of the proposed project although there
may be some increase in use of the new trails.
(p. 56, Section XV, a: Discussion)
Utilizing DPR’s own repeated assertions in the Application,
it is clearly anticipated that DPR fully expects and virtually is encouraging a
significant increase in recreational use in MTSP. The Application asserts there
is a need to increase recreational opportunities and increase visitation to the
area, as follows:
MTSP has yet to realize its full recreational
potential.
It is anticipated that the new trails will attract
greater visitation as park users seek more aesthetically pleasing pathways that provide
the intimate experience of meandering through the countryside, following the
natural contours of the hills, while taking in the world class views of the San
Francisco Bay Area.
This project has additional environmental benefits
that augment the natural character of Mount Tamalpais State Park, but also
increase its recreational use.
Experience gained by State Park staff during the implementation
of similar projects located within Annadel State Park, demonstrate that
visitation of all user groups is greatly increased […]
Road to trail conversion work accomplished in l998,
2000 and 2001 in Annadel demonstrate that […] visitation is increased […]
This state park (MTSP) receives very high use and is visited by one of
the most diverse populations in the state.
The proposed trails will be visible and
accessible to anyone traveling on Highway 1. MTSP is literally the backyard of the 14,000
residents of Mill Valley with another estimated 6.8 million people living
nearby in the Bay Area. Local use of
the park is quite high. International
visitor attendance is substantial at MWNM.
These individuals will also be attracted to the project site area
[...]
“Road removal and road to trail conversion projects
completed in Sonoma County, just to the north, have been an incredible success demonstrated
by increased and diversified park use […]
b. The TCC asserts that the creation of narrow “multi-use”
trails on MTSP will create a huge increase in traffic and visitation not
anticipated by the MND. It can be anticipated, based on previous well-documented
experience, that narrow multi-use trails of widths less than 72” will receive a
great deal of press attention from both online resources and in MTB (mountain
bike) magazines. Evidence of this pattern is directly available through
industry leading Bike Magazine, www.bike.com, consisting of numerous
depictions in various issues of the Magazine of destructive use and illegal use
throughout the world, in and around Marin, and specifically in close proximity
to the proposed project. These depictions encourage and seek to glorify illegal
activities and, specifically, riding on traditional hiking trails. Several
years worth of these depictions are available upon request.
It is a virtual certainty Bike Magazine and other
publication and a variety of mountain bike-based websites would publish photos
and written commentary with the intent of advertising the creation of two
trails of less than 72”in width in what is well known as the birthplace of the
mountain bike, MTSP and adjacent property. Completion of this project in its
current form virtually will assure a significant increase in anticipated
worldwide mountain bike use thereby creating a major new international
attraction to the property.
b. Additional evidence of its potential popularity was
demonstrated when 100-200 mountain bike supporters, with significant numbers
identifying themselves as from outside the county, attended the November 4,
2002 Public Input Meeting at DPR's Marin Headquarters in Novato. This is the
largest turnout of mountain bikers for a proposed multi-use trail project in
the last decade in Marin County.
c. The MND fails to address that while total MTSP levels
might remain static, creation of this “attraction” will place an imbalanced
user load on these proposed new trails
d. The MND does not adequately address MTSP's unique
international status within the mountain bike community as home and birthplace
of the mountain bike and the impact this will have if trails of less than 72”
are open to mountain biking. Mount Tamalpais is often referred to as “Mecca”
for mountain bikers. The importance of this symbol as encouraging use must be
recognized in an EIR.
2. Lack of Comparative
Local Data
a. There is no scientific evidence or citations to research
addressing the environmental and social impacts of narrow trails, since their
creation, to local State Parks, specifically China Camp S.P. (CCSP) and Annadel
S.P. Furthermore, China Camp S.P. which lies in close proximity to MTSP and
serves as a model for this proposal, where for several years multi-use trail of
widths narrower than 72” have existed, is never cited or mentioned either in
the MND or the Application.
b. There is clear and compelling evidence of high levels of
damaging bicycling activities at CCSP. Furthermore, there is clear and
compelling evidence that serious displacement of other user groups has occurred
in CCSP and San Pedro Ridge since the opening of narrow trails to mountain
bicyclists on CCSP several years ago.
c. During TCC's onsite November 21, 2002 visit, David Boyd
offered that CCSP should be closed to vehicular traffic, specifically mountain
bicycling, during the wettest, most environmentally sensitive periods of the
year when environmental damage, a direct result of mountain biking activity, is
clearly evident. Mr. Boyd stated this issue had been discussed but claimed
there was no viable way to enforce closure of CCSP while simultaneously
acknowledging its necessity. The identical problem would face MTSP should this
project be allowed to go forward in its current form.
d. There is ample physical evidence at CCSP to demonstrate
that the concept of opening narrow multi-use trails in this State Park has
failed on numerous levels. The same would occur on MTSP lands. Specifically:
- It has
resulted in tremendous environmental damage in the neighboring
jurisdictions of the City of San Rafael Open Space and MCOSD lands on San
Pedro Ridge where a web of illegal, highly erosive trails has been created
by mountain bicyclists.
- Every existing hiking trail on San Pedro
Ridge has been deeply eroded through illegal bicycling.
We maintain the same can be anticipated for MTSP and
neighboring jurisdictions. Included is documentation dated February 11, 2000 to
Fran Brigmann, General Manager, MCOSD regarding San Pedro Ridge and CCSP
concerns. These are many of the same concerns we have in regard to this
project.
3. Trail Width
Deficiencies within the MND
a. The so-called 48” trail width that DPR considers the
minimum acceptable standard lacks any scientific reference or citations to back
up these assertions. Furthermore, there is no available comparison to
demonstrate that DPR’s minimum acceptable trail width is viable or
environmentally sustainable in “very high traffic” areas which DPR acknowledges
exist on MTSP.
b. The MND claims this project does not conflict with the
Marin Countywide Plan, Trails Element. (p44. IX, b).
We assert it is in direct conflict with the Countywide Plan
and inconsistent with the policies of neighboring jurisdictions. No where in
the Plan, or in any other jurisdiction including but not limited to MCOSD,
MMWD, GGNR, and Muir Woods is there any mention of creating multi-use trails of
less than 72”.
c. David Boyd claimed the environmental and visual impact of
a 72” trail will be greater than that of narrower width.
While acknowledging the concern regarding views, we note
that the proposed trails are being built to follow contours rather than across
them. This is a change from the trails current locations, often cutting across
contours. Given this proposed change of location, the reasonable width TCC
proposes will not be detrimental to views. We maintain a well designed trail of
any reasonable width will have minimal long-term environmental impact and in
fact will require far less maintenance than the attraction DPR proposes to
create. We maintain the impact of anything less than a 72” multi-use trail will
be far greater over the long term.
d. DPR claims narrower trails are safer, more accessible and
will decrease the threat to park resources. Section 2.4, p7.
There is ample documentation proving the opposite will occur. There is are no citations provided nor any outside peer reviewed scientific evidence to support the assertion that mountain bikers will go more slowly on narrower trails.
Additionally, the reliance on outdated usage studies, i.e., those done in the early 1980's when mountain biking was just beginning and not up to its present, typical intensity, prevents an accurate study of safety given the subsequent use of mountain bikes, used at varying rates of speed, on trails previously wide enough for hikers only.
Reference is made here to sections of documentation
entitled: “CONFLICTS ON MULTIPLE-USE TRAILS: Synthesis of the Literature and
State of the Practice” Sponsored by The Federal Highway Administration and The
National Recreational Trails Advisory Committee.
e. We request that DPR provide all statistical evidence at
its disposal that narrower trails are safer and also to provide bases for these
assertions.
f. The MND does not address user displacement issues.
Displacement of users is a major concern and inconsistent with DPR’s primary
mission. There is ample evidence that a major change in usage patterns have
occurred at CCSP since it installed narrow multi-use trails. The park has been
largely abandoned by equestrians, runners and hikers. Reference “CONFLICTS ON
MULTIPLE-USE TRAILS: Synthesis of the Literature and State of the Practice” for
more complete information in regard to this issue.
g. David Boyd stated during the onsite visit on November 21,
2002 that mitigation for hikers and bikers meeting on proposed 48” trails are
for hikers to step up or down off the trails. This meeting can occur anywhere
on a trail, causing hikers to step off in areas that can be dangerous. He
acknowledged that it is not likely that a biker will get off a bike and wheel
the bike off the trail to let the hiker or equestrian go by. When bikers and
horses meet, there is increased danger because the room needed for a horse to
move or sidestep is significant.
h. The turnout proposal discussed by David Boyd with the TCC
and more recently with MMWD staff is unworkable and impractical as mountain
bikers generally will not look far enough down the trail to see others, nor
stop to allow others to pass specifically at these designated turnouts. Often
mountain bikers are looking at the ground ahead of them in order to avoid
roadbed problems. At these times, they are not looking down the trail for
upcoming passersby.
i. The MND lacks a seasonal provision to reduce or eliminate
vehicular use during wettest months. Nor does it address the viability of
keeping these trails open to vehicular use during the wettest months nor the
impact varying levels of vehicular use will have during these months. DPR has
not studied the long-term environmental impact and associated maintenance costs
of allowing vehicular use during these periods.
4. Failure to Address
Safety Concerns
a. There is no discussion or evidence presented regarding
the relative safety to various user groups on 48” multi-use trails in
comparison with minimum 72” multi-use trails.
b. There is no evidence presented on the safety of narrow
48” multi-use trails in high traffic of areas as is anticipated by the
Application.
c. At the Nov. 4, 2002 meeting we asked for the scientific
basis in writing, or any rationale whatsoever, for learning how the 48" minimum
width was chosen. We were told by DPR that no such documents are in existence.
DPR also stated at this meeting that it relied on usage
studies that were from the early 1980's. This was prior to the first years of
commercial mountain biking, so the studies could not take into account the
subsequent exploding use of mountain bikes in general and on MTSP. Thus the
studies are outdated and do not provide accurate or adequate data to support
the use projections included in the MND.
d. The MND implicitly excludes mountain biking from these
trails by its supporting rationale. It describes the historic uses of these
MTSP footpaths, prior to the construction of the to-be-converted fire roads, as
a reason for converting these roads back to trails. It describes these trails
as
"historically important within the context of
use of Mt. Tamalpais as a regional destination for hiking and other outdoor
recreational activities during the late nineteenth and early 20th centuries.
[...] [T]he historic significance of the area is based on the retention of the
original alignment of the trail and the continued use of the trail system in a
manner constant [sic] with its historic use. This allows visitors to enjoy the
views and use the resources in much the same way visitors have for over a
century.
However, mountain bicycling is approximately only 20 years
old. Therefore it is not an historic use but a relatively recently introduced
use. Therefore, there is no rationale for including it when these trails are
returned to their historic use.
e. The TCC requests access to any and all studies currently
at the disposal of DPR and its personnel demonstrating safety on narrower
trails.
f. There are no citations providing evidence that narrow
trails will cause mountain bikers to ride in a socially responsible,
environmentally sensitive manner. All assertions in both the MND and the
Application are based on opinion rather than fact and are therefore invalid.
g. We request a complete EIR be preformed and the issues of
safety are fully addressed. We ask that statistical and environmental evidence
be collected throughout the State Parks system where narrow multi-use trails of
widths less than 72” to demonstrate the relative success or failure of these
policies.
5. Coastal Fire Road
Issues
a. The MND proposes trail alignment primarily on downhill
slope. The reason David Boyd offered for proposing construction on the more
environmentally sensitive, higher visual impact downhill slope is to provide
users with “views.” Reference: Sierra Club/IMBA Policy On Off Road Bicycle Use,
January 31, 1998
We propose flatter, uphill side which shall minimize visual
impact of trail when viewed from the proximity of places such as the Dipsea
Trail. Views and aesthetics are minimally impacted. Furthermore, it will be
then relatively easy to incorporate those sections of the current fire road
that are not damaged or in need of replacement into the new alignment.
b. DPR proposes to decommission all but 0.3 miles of the
current road.
We propose to replace those specific sections that are
heavily damaged due to poor alignment and too steep by current standards. The
public’s approach will save substantial state funds. We believe it is
unnecessary to decommission a majority of the current road.
c. DPR proposes that the Parts that 0.3miles of the current
road that will be utilized are to be narrowed by infilling the existing fire
road with dirt.
We maintain this is unnecessary as the current fire road is
an average seven feet in width and perfectly suited as a multi-use trail. This
approach will save substantial state funds.
d. The MND does not address potential impact of anticipated
illegal bicycling use to Heather Cutoff Trail.
e. The MND does not address the fact that Heather Cutoff
leading to Coastal is the only exit from the horse camp at Franks Valley for
equestrians. Nor does it discuss the potential for displacement of equestrians,
equestrian safety and the anticipated safety and user conflict issues of riding
horses on the narrow multi-use alignment.
5. Lone Tree Fire
Road Issues
a. The MND does not address a return route nor discuss
safety of dumping users onto a narrow and very dangerous section of Highway 1
with no return loop.
b. At the December 9, 2002 meeting of the majority of major environmental
conservation and equestrian groups at MCL headquarters attended by David Boyd
and Denali Beard, after careful consideration of the proposal, when asked for
our opinion, the nearly unanimous consensus was to decommission Lone Tree
allowing the land to return to its natural state. The public’s approach will
save substantial sums of state funds minimally impacting user enjoyment and
increasing safety.
We request return to what we have been told was the original
plan to decommission Lone Tree as it is unnecessary, is historically
insignificant to the public and only serves to repeat a past mistake in the
name of questionable historical significance.
c. The MND does not address potential impact of illegal bicycling use that can and should be anticipated to occur on Dipsea Trail.
Not building an essentially parallel trail to the Dipsea
Trail will protect the Dipsea from illegal biking and protect a trail of true
great historical significance to the public.
There is ample evidence illegal bicycling occurs to trails
adjacent to legal narrow width bicycling trails in China Camp SP, Annadel SP
and in Mid-Peninsula Regional Open Space District. (Reference February 11, 2000
to Fran Brigmann, General Manager, MCOSD regarding San Pedro Ridge and CCSP
concerns).
6. Public Input
a. DPR did not properly notice the public.
- None of the three so called notices is legally sufficient. Only one letter, the one in the front of the MND. states where copies are available.
- It does not give the beginning and ending dates of the comment period as required by law.
- The other two letters, DuMont and Boyd's, fail to give the locations where the MND is supposedly located.
This information needs to be in the notice for it to be legal. Therefore, there has been NO notice given. We request to start the process over.
b. Many groups and several public entities on the mailing
list provided to us by David Boyd never received word of the November 4 meeting
and therefore were denied an opportunity to be present. The original
Application lacks initial equestrian, environmentalist and conservationist
input and presents a biased and inaccurate portrayal of public support of this
project. (Reference TCC Position Statement to David Boyd, November 4, 2002).
The release of the MND to the interested public no sooner
than December 2, 2002 along with the December timing factor right in between
the three most major holidays of the year puts the public at a tremendous
disadvantage to properly address it within the window provided. The public has
every reason to be highly suspicious of the motivations and apparent
manipulations of any government entity and its personnel that attempts to push
a project past the public during this time period and specifically in the
manner in which DPR has approached this project from its inception.
As outlined in the letter from the TCC to Shaelyn Raab
Strattan on
December 23, 2002 and copied to Ms. Du Mont. The community received conflicting
dates and conflicting contacts adding to the confusion. There is clear evidence
of unfair foreknowledge of the plan in the mountain bike community resulting in
imbalance of viewpoints throughout the MND and Application.
The mountain biking community, represented by the following:
Marin BTC, East Bay BTC, IMBA, Access4Bikes and the Sonoma County Trails
Council (a mountain biking organization) were included in the original list of
organizations contacted by DPR as it prepared the Application. No
environmental, conservation or equestrian group was contacted and there is no
conservation group included in this list, although many including the TCC are
well known to DPR.
7. Enforcement
a. The MND states that there will be "no impact"
on police protection, stating:
None of the project elements would contribute to a
significant increase of visitation and the level of required services is
expected to remain relatively static.
However, the MND ignores known needs for increased patrols.
At the Nov. 4, 2002 public meeting, all present recognized the potential for
increased contacts on the proposed trails. In response the DPR stated that it
would need greater signage asking users to be courteous to each other.
In addition on a site visit on November 21, 2002 DPR staff
stated that one element of determining the new trail alignments was to avoid
areas where mountain bikers would go off-trail, down slopes, and create new,
illegal trails. Since this occurs all-too-often, increased patrolling will be
necessary, in contradiction to the MND. (Reference February 11, 2000 to Fran
Brigmann, General Manager, MCOSD regarding San Pedro Ridge and CCSP concerns).
As an example of the seriousness of this problem, the
ex-vice president of the Marin Bicycle Trails Council was found guilty in US
District Court of Northern California, with two others, of destruction of
federal property by cutting an illegal four mile trail in highly sensitive,
endangered Coho and Spotted Owl habitat across State, Federal, and County
lands, when they were discovered in the act. This individual was in attendance
at the November 4 meeting.
b. The MND lacks an enforcement element. This must be
adequately addressed.
c. The MND does not address inherent and well documented
user conflicts.
(Reference February 11, 2000 to Fran Brigmann, General
Manager, MCOSD, “CONFLICTS ON MULTIPLE-USE TRAILS: Synthesis of the Literature
and State of the Practice”)
d. The MND does not address inherent and well documented
evidence of increase in injuries and how emergency personnel will respond.
Sincerely yours,
Larry Minikes
Corresponding Secretary Tamalpais Conservation Club
Member, Board of Directors, Bay Area Trails Preservation Council
References
We
request the following documents are included in our request for a complete EIR.
February
11, 2000 to Fran Brigmann, General Manager, MCOSD regarding San Pedro Ridge and
CCSP concerns
November
4, 2002 TCC Position Statement to California Department of Parks and
Recreation, Planning and Local Services Section
“CONFLICTS ON MULTIPLE-USE TRAILS: Synthesis of the Literature and State of the Practice” Sponsored by The Federal Highway Administration and The National Recreational Trails Advisory Committee.
Sierra
Club/IMBA Policy On Off Road Bicycle Use, January 31, 1998
TAMALPIAS CONSERVATION CLUB
3030 Bridgeway Suite 117
Sausalito, CA 94965
February 11, 2000
Fran Brigmann, General Manager, MCOSD
3501 Civic Center Drive, Room 415
San Rafael, CA 94903
Re: San Pedro Ridge BTC Proposal
Dear Fran,
On behalf of the Tamalpais Conservation Club, in regard to
our meeting in your office with you and Ron Miska on 1/21/00, we request this
correspondence be included in the packet you are delivering to members of the
Parks and Open Space Committee prior to the February 23 meeting.
All involved parties should understand we environmentalists
and conservationists of the TCC are very much in support of bicycling, when and
where it is practiced in an environmentally sound and socially responsible
manner. Furthermore, we fully support the current rules and regulations
designed to protect our lands and its users from abuse, conflicts, potential
injury, and lawsuits.
For the record, based on our combined years of previous and
ongoing experiences as involved members of our community, we are quite
concerned as to the likelihood for success for a project of this type. We
believe it is premature to consider such an undertaking until a number of
important issues are resolved prior to start of this study. At this time we
believe District resources and personnel time can be put to better use dealing
with these other issues first.
However, if our reasonable concerns can be satisfactorily
addressed, we are willing to work in cooperation with all participants, and
will support a proposal to study the building of a trail on San Pedro Ridge
from Woodoaks Drive to Scetrini Fire Road.
The position of the Board of the TCC is that the Open Space
District and the Marin BTC should fully address these concerns prior to any
consideration of the building of new trails. In essence, we are asking that a
number of sensible, proactive steps be taken to reduce user conflicts and protect
sensitive habitats from further damage, degradation, and permanent destruction.
Our concerns are complementary to those presented by the Bay Area Trails Preservation
Council. We would like to reiterate the points covered during the meeting, and
add related comments as well.
Our concerns cover five major areas and are outlined, as
follows:
I.
District Policy
II.
Trail Construction and Environmental Impacts
III.
Traffic and Parking
IV.
Enforcement
V.
Proactive Bicycling Community Involvement
District Policy Concerns
- As
acknowledged by all participants in the meeting, if and when such a trail
is built, the vast majority of users will be bicyclists. Though this is
presented as a proposal to study building a "multiple-use"
trail, it is understood and acknowledged this is a proposal primarily for
a mountain bicycle trail with expectations of very low use by other user
groups.
- While
other recreational trails have been constructed under the current policy,
this is the first to be considered with the explicit understanding it is
primarily for the benefit of a single-user group.
As Nancy Sandy of the TPC stated, just the mere discussion of such a proposal represents a major change in District mission. Prior to moving forward on any proposal, Open Space policy needs to acknowledge and reflect its shift in mission to one that properly addresses:
– First, the continuation of building trails purely for recreational purposes.
– Second, building trails primarily for use by single-user recreational groups.
– Third, establishment of a master plan for recreation.
As a public agency, it is essential all in the community be provided a formal opportunity to review and approve of this change, which we view as significant departure from previous policy.
- Furthermore,
based on experiences at Tamarancho and China Camp S.P., all participants
should recognize, and the public be made aware that there is a clear and
reasonable expectation that user group displacement will occur on the
Ridge.
We are asking this be acknowledged for the purposes of moving forward within that context. It is then for the community to decide if this is a reasonable use of the Ridge and adjacent lands.
Construction and Environmental Concerns
- We ask
for written assurance that all active participants in the process agree
that best practices will be utilized in the event this process reaches the
construction phase. Work must be based upon the recommendations of MCOSD
staff regarding proper trail alignment, grade, and trail width.
Additionally, CEQA guidelines should be followed, where applicable. Other
concerns we have are:
- What
criteria is the BTC using for suggesting a standard of 75 pound per square
foot live load, and what citations are they referencing this to?
- What
the expected environmental impact to the current hiking trail? And should
higher levels of illegal use be anticipated to the hiking trail because of
its proximity to the proposed trail?
- As of
now policy is clear; District signs on the Ridge state only fire roads are
open to bicycling. Will creation of this multi-use trail serve to confuse
bicyclers as to types of trails open for the activity?
- Is
consideration being given to the seasonal traffic expectations on the
proposed trail?
- Is the
anticipated regional growth rate in the coming years being considered?
- Assuming
it is agreed the proposed trail will receive a fair amount of use, we ask
that the District identify the carrying capacity the proposed trail will
be able to withstand under varying weather conditions.
- What
impact upon flora and fauna in the area is anticipated?
For Example:
– Impact to nesting animals during trail construction, and after completion
– Impact to identified rare species residing in the vicinity
– Number of cubic yards of soil that will be displaced
- Should
this trail be constructed, we request a comprehensive minimum two-year
study period, to include baseline measurements after the trail is
constructed.
In our opinion, the District must be able to fully assess impacts to the immediate trail and the Ridge before any further trail building proposals by the BTC or associated bicycling groups may be considered on MCOSD lands. This is to ensure we move forward in the future with a clear knowledge of long and short-term recreational and environmental impacts to District lands through this kind of project.
Traffic and Parking Concerns
- As was
acknowledged in the meeting, the vast majority of the mountain bicycling
traffic entering at a Woodoaks trailhead will climb the Ridge and ride to
the State Park, or conversely, exit through Woodoaks. This effectively
creates a western portal to the Park.
As the location is approximately one-half mile off Highway 101 in a fairly densely populated section of Marin, in our opinion it is reasonable to expect a sizable percentage of China Camp S.P. traffic will be diverted to this optional western entry point.
Furthermore, because of its proximity to a major highway interchange, if history is an indicator, it potentially will become a convenient regional destination point for those coming from outside the county, thereby increasing total use. Because of the convenience of parking in the area, the potential exists of funneling far more traffic to the Woodoaks area than either Tamarancho or China Camp S.P. currently receive.
- We
understand, as part of the process that the affected neighborhood will be
made aware of the project prior to any construction.
We are going on record to predict high use levels will prevail. We wish to ensure that the affected neighborhood understands this and is allowed to become full partners in the process to avoid unpleasant surprises and later conflicts. We respectfully ask:
– Awareness of our opinion, as stated here, of possible traffic impacts.
– The neighborhood be made aware of issues affecting other neighborhoods with similar trailheads or similar use patterns, specifically in the Cascade Canyon and Tamarancho areas.
– The neighborhood be made aware of current traffic patterns around China Camp S.P.
Enforcement Concerns
- Today
there exists a myriad of illegal trails on the Ridge. There are clear
signs of heavy, ongoing bicycle traffic appearing on nearly every hiking
trail and illegal bike path; this includes paths clearly marked as closed
to all forms of traffic. Old trails that have been stable for many years
are now showing signs of degradation, directly attributable to this
illegal use.
Social bicycling trails have appeared in the last few years where previously there were none. A virtual spider web of cross country trails and shortcuts has developed in China Camp, the areas immediately adjacent to it, and the Ridge in general. Additionally, there is comprehensive evidence of off-trail cross-country bicycle riding occurring in very sensitive redwood habitat on District lands.
We respectfully request the following of the District:
A. Before any proposal for trail building goes forward, a plan is executed to fully inventory these unauthorized trails and closely monitor present use patterns on these and established hiking paths.
B. Once the scope is understood, a plan is prepared, funded, and implemented to ensure this pattern is substantially reduced or eliminated.
C. The District establishes and funds a formal mechanism to periodically report on the relative success of this program.
- During
the 1/21 meeting, all agreed this would undoubtedly bring more recreation
to the Ridge. We ask for a commitment to, and a demonstrated ability of
the District rangers to enforce rules and regulations in the San Pedro
Ridge area. We ask for a determination of the future forecast impact on
staff time, the impact on enforcement in other areas, whether extra staff
will be required, and the projected additional costs to be borne by the
community.
- As the
Open Space District is moving towards a more active recreational policy,
we ask it to review the format of its current rules and regulations and
develop a more complete and comprehensive set for all users to follow.
Furthermore, we ask it be made readily available to the public so all
users may better understand what is expected of them and why.
- We ask
the District prepare a comprehensive plan in the event that problems
continue and the Committee does not deem the proposed trails building
program a success. We ask what benchmarks will be established for the
Committee and the District to determine relative success or failure.
Bicycling Community Concerns
- We ask
that as part of the plan, the Marin BTC makes a long-term commitment
towards:
- Acknowledgement
that there are illegally developed trails on San Pedro Ridge and
elsewhere on MCOSD lands, used primarily by off-road bicyclers; and that
these activities constitute improper use of our resources and must cease
if any plan to build additional trails is to succeed over the long term.
- We
feel the bicycling community leadership has been far too uninvolved and
silent in this particular area for much too long. We ask for a strong
public commitment against illegal bicycling activities of all kinds.
- Agreement
to use BTC trail building volunteers to mitigate and repair any and all
illegal bicycling trails present on San Pedro Ridge, under the auspices
and direction of the District, before discussion of new trail
construction continues.
- Agreement
to repair legal hiking paths on the Ridge showing conclusive evidence of
damage due to mountain bicycling use.
- Agreement
to exert meaningful peer pressure to keep bikes off all hiking paths.
- Acknowledgement
that while it is a minority of users causing the majority of problems
this still represents a sizable number of individuals negatively
impacting the environment and the experience of all user groups on a
consistent, historical, and ongoing basis.
- Subsequent
to the foregoing, to then present a comprehensive plan to the Committee
consisting of a proactive education campaign via peer networks,
newsletters, Internet, mountain bicycling events, etc. to curtail illegal
use in all forms throughout the county, including, but not limited to:
·
Explaining the reasons behind the rules and
regulations.
·
Providing a better understanding for the need to
live within those rules and regulations.
·
Consistent reinforcement of the rules and
regulations by members of the BTC to the bicycling community at large.
·
Sensitivity Training – teaching the need to
understand and respect the rights of others within and outside their user
group.
·
Agreement to report any and all illegal trails
and trail activity throughout the county, and take a proactive role in working
towards prevention of this type of activity in the future. Acting as a set of
eyes and ears for the District.
·
Provide a specific, concrete plan as to how each
of these aspects will be implemented.
The Board of Directors of the Tamalpais Conservation Club
asks the District to request of the Marin Bicycle Trails Committee that it
aspire to a much higher level of leadership, resource protection and
proactivity in our community in regards to the above issues. If and when these
conditions are instituted in good faith, only
then should the county consider devoting resources to a project of this
nature.
In closing, we ask the bicycling community to show by
action, rather than words alone, that they are willing to fully embrace and
work within policies set by our community. At this time we feel an independent
study will support our contention of high levels of flagrant abuse of policy,
as it relates to San Pedro Ridge specifically, and generally to other District
lands throughout our county.
We ask that any proposal to study the building of new trails
be postponed until these larger, more vexing issues are properly addressed, and
until the District and the Committee has a full grasp of the problems already
facing the Ridge and surrounding areas.
Sincerely yours,
Larry Minikes
TCC, Bicycling Committee Chair
Cc: Ron Miska
Marin Board
of Supervisors
Bay Area Trails Preservation
Council
Marin
Conservation League
Sierra
Club, North Bay Chapter
Audubon
Society, Marin Chapter
Native
Plant Society, Marin Chapter
November
4, 2002
California
Department of Parks and Recreation
Planning
and Local Services Section
P.O.
Box 942896
Sacramento,
CA 94296-0001
Re:
Conversion of Coastal and Lone Tree Fire Roads
Position
Statement
The
Tamalpais Conservation Club has been recognized as Guardian of the Mountain
since 1912. Our organization has consistently been at the forefront of
preserving and protecting what is now Mount Tamalpais State Park, founded in
1930, and neighboring jurisdictions. Over the last ninety years, the Club has
been actively working to preserve and protect the slopes and spurs of Mount
Tamalpais through financial contributions and the direct involvement of its
membership to build, maintain and restore trails, bridges and other manmade and
natural features.
The
directors of the Tamalpais Conservation Club object to the Application in its
current form. The Application is biased in its views and observations,
incomplete, misleading, inconsistent with the Trails Element of the Marin
Countywide Plan, which it cites, and inconsistent with the California
Department of Parks and Recreation’s mission statement.
Specifically,
the Tamalpais Conservation Club states the following claims are false:
"This
project is widely supported by visitors and trail groups of all kinds.”
“This
project is widely accepted as an important breakthrough for multi-use trail
access."
“This
project is consistent with all local and state plans.”
The
organizations asked to provide letters of support during the development
process of the Application excluded virtually all local, traditional,
environmental and recreation groups. The overwhelming majority of recreational
groups initially invited to participate with written comment were mountain
biking groups, one of which is headquartered outside of Marin County and
another headquartered in Colorado. When asked why the TCC was not provided with
an opportunity to comment, the written response received from Assistant State
Park Resource Ecologist Denali Beard claims it was an “oversight,” further
stating that “recreation-oriented groups” were contacted first. This explanation
raises several questions of credibility.
It is
wholly unacceptable that the Department of Parks and Recreation when seeking
comment overlooked, unintentionally or otherwise, the TCC and affiliated groups
including, but not limited to, the Sierra Club Marin Chapter, the Mount
Tamalpais Interpretive Association, the Alpine Club, the Marin Audubon Society,
the Marin Conservation League, the Marin Horse Council and the Bay Area Trails
Preservation Council. The DPR is well aware several of the named groups have
been at the local, state and national forefront of recreational use issues for
well over a decade.
Furthermore
the Board of Directors of the Tamalpais Conservation Club finds that the
following statements are an inaccurate portrayal of the majority of
stakeholders:
1.
“MTSP has yet to realize its full recreational potential.” We believe the
majority of the public desires a primarily low-key, pastoral recreational
experience as opposed to converting Mount Tam into a primarily mechanical venue
as suggested in this Application.
2.
“This project will provide a more diverse, enhanced visitor trail experience.”
We believe, as is demonstrated in the case of China Camp S.P., that in reality
the suggested four-foot multi-use width will not enhance overall user
experience. Instead it will result in increases in bicycling traffic and
displacement of other user groups due to well-documented incompatibility
issues.
3.
“More narrow (multi-use) pathways are needed.” What has occurred on
San Pedro Ridge when more narrow pathways were added to China Camp S.P. is a
tremendous increase in serious erosion, the direct result of illegal bicycling
use on trails closed to bikes, and the surreptitious creation of an illegal
bicycling trails network throughout the neighboring jurisdictions.
4.
“Roads to more narrowly constructed pathways will increase the opportunity for
users to have a more aesthetically pleasing, safer and environmentally
friendly, multi-use trail experience.” Narrow pathways, rather than slowing
some mountain bikers down, serve to encourage tests of speed and technical
skill for a small but very significant group of riders that has before, and
will now, negatively impact the experience of the vast majority of all user
groups.
5.
“Steep slopes far exceed limits for safe travel, and encourage excessive
mountain bike speed.” This is false. Steepness of slope and trail width are
minor characteristics in determining speed and safety. Excessive mountain bike
speed is a direct function of the attitude, demeanor, equipment quality and
expertise of the user.
Safety
is an issue when there is no regard for the rules and regulations, when riding
beyond capabilities and when there is a lack of consideration for other users.
Another important factor affecting safety is the mixing of vehicles capable of
high speeds in a narrow space with slower modes of transport. A narrower
trail increases the margin for error. It allows for fewer options and increases
the risk to all users.
Key
to this is that DPR makes no mention that MTSP’s maintenance and enforcement
staffs are at historically all-time lows thereby rendering enforcement of
illegal uses difficult to impossible. It makes no mention how it intends to
deal with the negative impact increased use will have on the rest of the
facility and neighboring jurisdictions, nor how it intends to deal with
additional traffic and the increased need for additional parking that it will
create.
The
Tamalpais Conservation Club requests that the process be suspended until all
stakeholders are given an equal opportunity to comment on the Application and
specifically requests that:
1.
Additional input is sought from all interested stakeholders with an adequate
time and opportunity to respond.
2.
The misrepresentations in the Application are corrected.
Until
these conditions are satisfied the issuance of a negative declaration would be
improper.
While
the TCC strongly supports public restoration projects and restoration of these
two historic routes, we believe the Application in its current form is not in
the best interests of Mount Tamalpais, its slopes and spurs, and the majority
of its users.
Many
of our organizations share a long and productive relationship with DPR. The
Tamalpais Conservation Club expects that in the future the Department of Parks
and Recreation, as steward, will make every effort to ensure all stakeholders
are provided an equal opportunity to participate in projects of this kind.
Sincerely
yours,
Larry
Minikes, Corresponding Secretary
cc:
State of California, Department of Parks and Recreation, Marin District
Headquarters