The Tamalpais Conservation Club has been recognized as Guardian of the Mountain since 1912

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