The premises do not  Justify the Recommendations

The Draft Recreational Plan is very comprehensive and consistently arranged. In the "Recreational Needs Assessment and Actions" section (Section IX), 19 recreational activities are evaluated. For each activity, the following topics were addressed:
 

  1. Description
  2. Public Input
  3. Current Opportunities
  4. Environmental Impacts, Constraints, and User Conflicts
  5. Analysis
  6. Decisions with Actions


In this process, The first three steps provide a concise summary of the activity as practiced in Region 7. Steps 4 and 5 then lay the basis for the recommendations in Step 6. The recommendations in Step 6 include a change in the current DEC policy from "open unless designated closed" to "closed unless designated open". Despite the plan's recommendation of four "new" mountain bike trails, this change in management will result in reductions in available trails, especially considering that the "new" trails systems consist in large part of roads and/or existing trails.

The evaluation in steps 4 and 5 do not support the restrictions that are recommended in step 6. Below, the entire text of steps 4 and 5 are reprinted with IMBA/NYMBC comments:

Environmental Impacts, Constraints, and User Conflicts

The combined weight of the bike and rider, how the bike is ridden, and the relatively narrow tires of the wheels cause soil compaction and rutting. 
This sentence addresses several unrelated topics. The predicate of the sentence is "cause soil compaction and rutting". Trail design and construction manuals and courses routinely stress the importance of compacting the trail tread during trail construction. A well compacted trail tread combined with the proper outslope prevents erosion of tread material. Compaction of trail tread is a good thing. Rutting, on the other hand is bad. However, with properly designed and constructed trails, including adequate compaction, rutting does not occur. Rutting only occurs in wet conditions, and this is addressed below. The subject of the sentence addresses the pressure density of cyclists on trails. Gordon Cessford, in his comprehensive review of the literature (published by the New Zealand Department of Conservation, 1995) summarized studies on this and found that "Mountain bikes will exert downward force through their tires, although the "mean ground contact pressure", which comprises the wheel load divided by the contact area (Soane et al. 1981, Smith and Dickson 1990) is likely to be less than that of heavier motorized vehicles, horses and heavily laden hikers." Bicycle pressure distributions would fall somewhere between a day hiker and a backpacker. Thus this is not a factor on which to regulate bicycles differently from hiking.
 
Continued use of the same paths of travel creates trails which lead to environmental concerns. 
This point seems to suggest that Region 7 believes that bike travel off trail is a problem in state forests. This is not supported in any of the public meeting summaries, nor in the technical literature. In fact, in comparison to other trail users including hiking, horseback riding, or motorized use, bicycles are by far the least likely to leave the trail. Simply put, bicycles don't work off trail in densely wooded areas as found in Region 7 forests, and would be the least likely to cause environmental concerns from off-trail travel.
The most common types of impacts from mountain biking are trail impacts, soil impacts, water related impacts and aesthetic impacts. 
Soil impacts include: 
Widening of the trails to avoid problems in the trail such as water and downed trees. Trail braiding is associated with trail widening. Braiding occurs when there are several paths in close proximity which avoid the same obstacle.



This is a real problem on some trails. The primary cause of widening and braiding is wet conditions, and this is addressed in the next topic. However, this is a function of trail design and construction, and not bicycle use. In fact, on page 42 of the draft plan, under the section for hiking, the plan says "Most of these [long distance hiking] trails are in suitable locations. However, some portions are located in wet, poorly drained areas or on steep slopes that are highly erodible. This leads to wider and multiple trails around wet areas. Trails located on unsuitable locations can result in muddy or eroded trail conditions." Thus, this plan itself recognizes what has been documented in the scientific literature: Impacts from hiking and cycling are equivalent in most circumstances, and are much less than impacts from non-human-powered recreation. The best studies of these comparative impact, although they are narrow in scope, are Seney (1990) and Thurston and Reader (2001). 
 

Rutting occurs when the ground is too soft to support the weight of the vehicle and rider. This usually occurs in the autumn and spring when the ground is wet and soft and during wet periods during the rest of the year. Ruts collect rain water and runoff, keeping the trail wet. Ruts channel water, leading to erosion of the trail. 
This statement is true for some trails in the spring or after heavy rains (though many trails are adequately drained and rarely develop ruts even in the wettest conditions). Cyclists dislike these conditions as much as any other trail user. This is why we support seasonal closures of trails, although not for the duration, and with the inflexibility, recommended in the plan. Please note that this is not unique to cyclist use. For example, in the Adirondack High Peaks region, which is closed to bikes, and very popular with hikers, the Adirondack Mountain Club regularly issues warnings for hikers to stay off the trails in spring time because the wet conditions present at that time accelerate trail damage from hiking.  The draft plan provides no similar restrictions on trail use by hikers. 

This statement supports the need for limitations on trail use in the spring. It does not, however, support a policy of blanket closure of trails throughout Region 7, unless signed.  This statement refers only to trails where the topography does not allow adequate drainage.  Trails that are inherently wet, such as those routed through wetlands or are on flat areas that can not be made to drain adequately, should be closed, not just to cyclists, but to all users. Trails that are built or repaired to provide adequate drainage do not lead to trail erosion from bicycle use.
 

Switchbacks are sometimes designed into a trail to allow a trail to zig zag up or down a hill to lessen the slope of trail and to minimize erosion. Shortcutting the switchbacks defeats the purpose of the switchback and leads to erosion.
If the turn radius of the switchback is too small, then it is difficult for novice to intermediate riders to successfully negotiate.   However, it would be surprising if this is at all a common problem on Region 7 trails. The vast majority of trails do not include such switchbacks. This is not a valid justification for adoption of a general closure of trails to bicycles. For the few situations where this problem exists, there are two options. The first is to reconstruct the switchback to the proper specifications that allow bicycle use.  Cyclists are available and willing to help with this. Switchbacks constructed to the proper specifications regularly handle large volumes of bicycle traffic on trails in Region 9 without impact. If this approach is not possible (due to other priorities), then the particular section of trail that contains the switchback could be closed to bicycle use until the switchback is reconstructed.
 
On unsuitable soils, trails need constant maintenance to control erosion. Where erosion cannot be controlled, the trails need relocation or closure. 
This statement is true, but is unrelated to bicycle use. Unsuitable soils should not be used for trails, regardless of who would otherwise be using these trails. We fully support closure of unsustainable trails. These trails should be obstructed at intersections with other trails, and removed from the forest through placement of branches and other forest debris on the former tread. Signs placed at the former intersections explaining the reasons for trail removal help in deterring users from trying to reopen these trails.
 
Trees are often cut or damaged when trails are established by users without authorization. No consideration is given to other management actions that might occur on the site. This often results in conflicts with other activities. Unauthorized trails, when constructed in poor locations, increase the potential for erosion.
Again, this statement is true, but is unrelated to bicycle use. Unauthorized trail construction is illegal and is universally condemned by trail advocates. Region 7 has indicated that they believe that many unauthorized trails have been constructed by cyclists. If this is true, then it is unclear how restricting cycling opportunities through a closed-unless-open approach would discourage these lawbreakers, since their misguided efforts presumably stem from their perception of inadequate trail opportunities under present management policy. If illegal trail building is currently a problem, this problem would likely be exacerbated by the recommendations of this draft report.

It is also not clear how Region 7 has determined or otherwise documented that illegal trail construction by cyclists is a significant problem.  If this is a serious enough problem to justify closing all trails to bicycles unless designated open, it is incumbent upon Region 7 to document and quantify the amount of trails that it believes have been illegally constructed by cyclists.  Not only is such documentation/justification not presented in the draft plan, the draft plan gives reason to believe that Region 7 may be overestimating the amount of such trails.  For example, the draft plan deems all trails in Shindagin Hollow, except the Finger Lakes Trail, as unauthorized (p.  56, also Appendix 6).  In communications last April, Region 7 implied these trails were illegally made by cyclists.  The fact is the vast majority of these trails were not created by cyclists.  Most were present before cycling became a popular activity in state forests.  Any conclusions made by the plan based on the assumption that these and other trails were made by cyclists is not based on an accurate understanding of existing trails. 
 

Braking on steep Intentional skidding  [sic] mainly to brake the vehicle on steep hills will lead to trail erosion. 
Skidding is perhaps the only unique impact that bicycles have on trails in comparison to hiking. That is why bicycle advocates have been active in discouraging this behavior with the "skids are for kids" message. However, to a large extent, this again is a function of trail design rather than usage patterns. Quoting again from Cessford's literature review (1995), "Skidding can loosen track surfaces and move material downslope, and most significantly, promote the development of ruts which channel water-flow. The development of such ruts which can promote erosive water-flows to a greater extent than by foot-step puddling, is the most distinctly unique 'wheeling' impact.". But in the review of literature regarding hiking impacts, "Studies of human trampling have been extensive and diverse. For example, the trampling motions of feet were described in Holmes (1979), the effects of different types of boot sole were compared by Kuss (1983), and the forces exerted on surfaces by walking were investigated by Quinn et al. (1980). Quinn et al . (1980) noted that damage from feet was caused first by the downward compaction forces from the heel early in the step, and then from rotational shearing forces from the toe at the end. The shearing action was found to be most important, particularly through soil deformation and "smearing" in wet conditions, and was found to be greatest on up-slope travel. Downhill walking was not investigated in the analysis by Quinn et al. (1980), but separate work by Weaver and Dale (1978) and Weaver et al . (1979), found that downhill stepping (by foot and hoof) was more erosive than downhill motorbiking. This was due to the greater downward forces exerted through the heels in down-stepping. The importance of this distinction between downhill and uphill stepping was emphasized by Bayfield (1973), who found that although 20 percent fewer steps were taken on downhills than uphills, the erosive impacts of downhill stepping was still higher." Cessford's conclusion regarding impact on steep slopes was "However, where skidding does not occur, impacts from the normal rolling effects of wheels would likely be less than those of foot steps."  The emphasis on skidding in the cycling section of the plan without commensurate discussion of the impacts of steep trail design and construction on trail sustainability under hiking use suggests a bias against cycling use of trails.  

Additionally, this sentence refers to bicycles as vehicles.  Since New York State Law specifically excludes bicycles from its definition of vehicles (Title 1, Article 1, Chapter 71 of NYS Consolidated Laws), referring to bicycles as vehicles in this sentence consciously or unconsciously associates cyclists with motorized trail users, which is inappropriate.

Water quality impacts include: 

Siltation of nearby water resources from riding on wet and muddy trails. 
Erosion of stream banks where the trail crosses a stream. 
Erosion of trail surface. 
Sediment suspension in streams can impact fish survivability, and thus trail management must take this into account.  However, once again, this issue is mainly governed by trail design, and is not unique to trail use by bicycles.  We support the use of rock fords and other hardened crossings where trails cross permanent streams.  Aligning the stream crossing at right angles is the most effective way of reducing sedimentation at trail crossings.  In any event, this is not an issue that would call for management of bicycles differently from hiking.

Aesthetic impacts: 

Muddy, rutted, poorly designed and maintained trails are all aesthetically unpleasant to other users of the forests. 
As mentioned above, these aesthetic impacts as unpleasant to cyclists as to other forest users. We support efforts to eliminate "muddy, rutted, poorly designed and maintained trails". 
 
Some of the physical and environmental constraints on mountain bike trail development are steep slopes, poorly drained soils, limited public access, actual and potential user conflicts, the lack for parking areas, and impacts on rare and endangered species. Competitive/organized trail rides require a temporary revocable permit (TRP) from the Department. See page 13 for discussion on TRPs. 


All of these are constraints on trail development and usage in general, and do not support implementation of stricter controls on bicycles. Of these constraints, one, "rare and endangered species" is actually applicable to all trail use  except cycling at least with respoect to plant species. As noted above, bicycles do not work off trail, and thus cycling, as opposed to most other trail uses, is not expected to impact rare and endangered plant species, except in the case of development of new trails.
 
 

The following are conflicts which have been identified; 
Mountain bikes and mountain bikers make little noise when riding the trails. Conflicts may occur when horseback riders and horses are startled when they are approached from behind and taken by surprise. 
Right of way is a usual conflict occurring between mountain bikers and hikers on the same trail. 
Mountain bikers sometimes feel threatened by the presence of hunters on or nearby the trails.
The plan does not document how these conflicts were identified. Presumably they were identified either through public input, Region 7 review of literature, or Region 7 personal experience. The only summary of public input in this planning process is Appendix 1 of the draft plan, which comes with the disclaimer that this is not an accurate count of actual public comments. Notwithstanding this disclaimer, the meeting summaries do not support that these conflicts are significant enough to warrant the drastic changes in bicycle management proposed by this plan. Out of 54 counted comments about "conflicts with other recreationalists", the summary counts only 6 comments from hikers about mountain bikes (in general), and 1 from an equestrian that may be interpreted as possible complaints about startling or right-of-way contention. It is not surprising that there are so few comments on this. Cycling advocates have heavily promoted the message of yielding the trail to hikers and horses. Yielding involves slowing down, and allowing the other trail user to acknowledge your presence before passing.  Right of way conflicts were more prevalent, perhaps, in the earlier days of mountain biking. However, today all but the most novice cyclist today understands the importance of being polite on the trails.  The proposed trailhead kiosks will also provide a means to better educate users on the rules of the trail, and will further reduce user conflicts.
 

Disproportionate impacts are also attributed to mountain bicycles elsewhere in the plan. For example, on page 42 in the hiking activity section, the plan states "Horseback riding and mountain bike riding on foot trails also conflict with pedestrian foot trail users. These two activities also require wider trails and have more environmental impact on the foot trail than pedestrians do." First, bicycles do not require greater trail widths for suitable use. Second, bicycle impacts on trails are similar to hiking impacts, whereas limited scientific evidence indicates that horses cause more damage to the physical stucture of trails than do hiking and bicycling. Combining horses and bicycles into a single sentence gives the false impression that impacts from these trail users are similar.