1. Retain the current open-unless-designated-closed bicycle management policy. This is the most important issue to us. There is no documented justification presented in the draft plan for abandoning the current management approach. The current management strategy, open-unless-designated-closed is the mode of management used throughout the rest of the state, and it works. Environmental and aesthetic impacts are managed by the closure of unsustainable trails.  Unsustainable trails should be closed to all users, and removed from the forest.

We strongly urge that this change in management approach be removed from the plan because the premises provided do not justify such dramatic measures. Beyond that, however, we have real concerns over its impact on bicycle access in Region 7 and throughout the state. On the face of it, the draft plan's intention to open sustainable trails to bicycles and our recommendation to close unsustainable trails should result in the same trail designation pattern. However, the Region 7 staff manages 117 state forests totaling 195,000 acres. Because of staff and time constraints, Region 7 is in many cases not as familiar with all the forests as are its users. While the draft plan does provide for Region 7 to designate sustainable trails open to bicycles, we are not convinced that Region 7 has a comprehensive enough inventory of the existing trails on these 195,000 acres to efficiently and timely designate which trails are to open to bicycles.  The result would be a much greater reduction in cycling opportunities than are otherwise justified. Many trails that are important to cyclists -- sustainable trails -- would be closed. This concern was amplified this past spring during meetings between cyclists and Region 7 regarding a planned timber sale. Most cyclists are not opposed to timber sales and did not ask for a halt of the sale. However, we met to voice our concerns about the impact of the sale on some trails; trails that were not constructed by cyclists. The Region 7 representatives were not aware of these trails and were not taking them into account during the timber sale plans. If Region 7 is unaware of the presence of trails, it can not designate them open.

Of course, the converse of this argument could be made, that the amount of area to cover makes it difficult to designate all trails that need to be closed in a timely manner. However, the majority of trails are sustainable (even without minor maintenance), and probably would remain open. There are fewer trails that need to be closed than will remain open. A blanket closure would result in more trails being closed than justified. Cycling organizations would be willing to work with Region 7 to identify which trails need to be designated closed. It is in our best interest that only sustainable trails be available. 

2. Reduce the duration of the wet season closure, but extend it to include Shindagin. The six month closure of all trails is excessive and not justified. Fall and spring typically produce wet conditions even on the most sustainable trails. However, the impacts on trails arise disproportionately from spring time usage. Fall usage is generally much reduced due to lack of daylight, deer hunting season, and the fact that many cyclists have just finished a great summer of cycling, and don't feel as inclined to hit the trails in these wetter and colder conditions. Any impacts from the few riders in the late fall are minor in scope and are generally erased by frost heaves and the weight of snow cover during the winter. In contrast, in spring, there is a pent-up demand for cycling, resulting in some people going out earlier than they should. It is during this period that seasonal restrictions are required. 

The seasonal closure period should be flexible.  Granted, it is difficult to survey the condition of the trails through the Region 7 forests.  However, authority to review trail conditions could be delegated to volunteer organizations.  Where it is not practical to evaluate the trails or designate organizations, a default closure period of February 15 - April 15 is all that is appropriate.. As discussed above, fall impacts are not significant. During winter, it is important to keep bicycles off trails suitable for skiing. However, this is simply addressed by designating trails closed when snow sufficient for skiing is present on the trails. This is a simple solution to what I suspect is a small or or very localized problem. Few, if any, cyclists ride when there is that much snow on the trails. It doesn't work.  The limited amount of cycling that takes place in mid winter is on packed snowmobile trails, where usage would not conflict with skiing.

There is no justification provided in the plan for excluding Shindagin Hollow from a (two-month) seasonal closure. Excluding this forest sends the wrong message to forest users - that is OK to ride in wet conditions. Funneling riders from the whole region to one forest will result in too high usage rates during this period. It only encourages damage of otherwise sustainable trails. This could cause problems for usage for the rest of the year, and would artificially create conditions that others could misconstrue as reasons why bicycles could be banned everywhere, when in fact it is due to policies funneling rides onto few trails when inappropriate.

3. The plan should stipulate that all trail closure plans be submitted to organized cycling groups prior to implementation. As stated above, trails should be managed as open unless designated closed. For each state forest, DEC should work with a local cycling organization to review planned closures before they are implemented. Some trails may need permanent closure due to soil conditions. Others may need reroutes, drainage work, or other maintenance work. For these latter trails, the DEC and local cycling group should agree upon what needs to be done, set a schedule for the changes to be satisfactorily completed (whether by volunteer labor or by DEC), and only closed if this schedule is not met.
 

4.  The draft plan should not seek to codify many of the recommendations of the draft or final plan into 6NYCRR Part 190 to make them apply state-wide.  First, while there are many aspects of the draft plan to which we agree, the two most important issues that we see needing revision before this plan goes final (plans to reverse the bicycle management approach to closed-unless-open, and the six-month closure of all trails) are the only two bicycle-related elements that the draft plan recommends to be codified in statewide regulations.  These restrictions should neither be applied in Region 7, nor be applied statewide.  Secondly, it is wrong to apply recommendations developed in one regional office, based on input and comment solicited and received primarily from one region only, to regulations that would apply state wide.  On this basis, the entire Section XII should be removed from the final plan.


5. The Recreation Plan should not make the distinction between foot trails and multipurpose trails. Rather it should distinguish between human-powered and non-human-powered activities. Our recommended distinction more adequately reflects the difference between impacts of the various user groups.  The plan's foot/multipurpose distinction incorrectly suggests that hiking activity deserves special attention and unique attention among the human-powered activities in the recreation plan. The designation of "multipurpose" may, in some people's minds cause cycling to be associated with motorized use or horseback riding. Motorized and horse trails require specialized construction, whereas the requirements for all human-powered trail uses are the same. Trail width specifications provided on page 60 for bicycles are too wide, and should be the same as given for hiking trail on page 47.