Responding to the Region 7 Draft Recreation Plan


Guidelines for Responding to the Draft Recreational Plan Recommendations for Mountain Bikes
 

Because of the significant restrictions that the draft plan would impose on Mountain Biking, it is imperative that every cyclist in the state respond with comments before February 28. Response info is at the end of this page.  This page goes over the general aspects on responding to the draft plan.  More specifics are available from the the following in-depth pages:


It is not clear how the DEC will handle, or take action upon, letters received. However, it is not likely that they are simply going to count "fors" and "againsts" and see who "won", although certainly, the more letters sent in hte better. As far as the DEC is concerned, they have researched the issues as they see them, and have put together an acceptable compromise plan that addresses all competing concerns. We think that many aspects of their plan are unacceptable, and if we want to get the plan revised, then we need to provide convincing, persuasive arguments as to why their conclusions are in some cases wrong. Letters that simply say "I don't want restrictions" aren't going to get anywhere. The DEC told me they "didn't expect mountain bikers to like the recommendations", so just telling them you don't like it won't be bringing anything new to the table. Here are some guidelines on how to prepare you letter.  Our responses may be more effective if a similar message is received from lots of respondents.  Of course, the final form of your response is up to you.

To facilitate your response, we have put together a "skeleton" of a letter that you could use as a starting point.  However, please do not use this skeleton as a substitute for reviewing the guidelines we have presented here.


 

Read the whole Plan, and comment on what it says
 

Comment letters that do not respond to what the plan actually recommends will be discarded as uninformed or otherwise clueless. The plan does not say "mountain bikes suck and should be kicked off everywhere". Read the whole plan. The DEC has included provisions that strive to accommodate cyclists. However, we don't think these mitigate the proposed dramatic change in management approach. We need to respond to exactly what is in the plan that we don't like. The primary objections are the switch to "closed-unless-signed-open" policy, and the duration of the wet season closure.
 

Present your ideas constructively
 

The DEC has spent two years preparing this document. The authors of the plan, who will also be those revising the plan, will take any comments you make personally because of the time and effort they have invested in this work. If you want to influence their revision of the document, you must provide constructive comments backup with sound reason. Angry or insulting comments will work against us.
 

Recognize the parts of the plan you agree with
 

Comment letters that are entirely negative send the message that you are just a complainer or an obstructionist. Aspects of the plan to which the official NYMBC/IMBA response will agree with are discussed here . For example, we support closure of inherently unsustainable trails (to all users), and a limited wet season closure period (though with flexibility in some cases and certainly not 6 months!). Please review these and consider incorporating similar comments in your letter. Your scope of agreement may differ from this, so feel free to say what you think.
 

Show why the premises of their justification are unsupported
 

The "Environmental Impacts, Constraints, and User Conflicts" and "Analysis" sections developed for each of the 19 activities addressed in the plan lay out the justification for the recommendations made for each activity. For mountain bicycling, these sections are on pages 56 through 58 (remember, though,read the whole plan!). These sections are based on anecdotal experience at best, and are not supported by studies of trail use and impact. A more detailed review of these issues, part of the official NYMBC/IMBA response, is presented here . There is no question that poor trail design and high levels of use can cause bad trails. However, for the most part, there has been no distinction made as to why bicycles are being singled out as the cause of the impact.
 

An important thing  not to do: Do not base any of you arguments on "horses/ATVs/whatever do much more damage to trails". This is not a persuasive argument. As you see in the plan, it does not like horses much better, and ATVs are still banned everywhere. It is true that horses and ATVs impact the trail more than anything else, and sometimes cyclists get blamed for the damage they caused. However, this is not an effective argument for more bicycle access. Similarly, arguments like "I'm a taxpayer, too", don't work, since nobody is telling you that you can't go in the forest. What the DEC is trying to say is that you can't ride your bicycle there in many places, which is entirely different.
 

Provide a summary of exactly what you want to change in the plan
 

After you have discussed what is right and wrong with the plan (and why), provide a summary of just what exactly you want to see kept in the plan, and what you want changed. We want some things to change. There should be no confusion about what it is we should change. The NYMBC/IMBA summary is here .
 

Provide your vision of mountain biking in state forests
 

Responding to exactly what the plan says is the most important goal of your letter. However, in closing, consider discussing mountain biking in state forests in more general terms. Even without considering the recommendations, the draft plan appears to be subtly biased against bicycle usage and this colors the conclusions they reach. For example, some of the items addressed by the NYMBC/IMBA response are here . Of particular concern, the plan has a default of approach of discussing trails in terms of either "footpaths" or "multipurpose". This presents a built in bias before evaluation even begins. This is an inappropriate distinction, that consciously or unconsciously lumps cycling in with higher impact forms or recreation such as horses and motorized users. A much more appropriate distinction is between human powered and non-human powered recreation. This distinction more accurately describes the range of users of the trail and their impacts.
 

SEND YOUR LETTERS IN!!
 

Deadline is February 28. The official designated addresses to sent them to is:
 

NYSDEC 
Division of Lands and Forests 
Re: Recreation Master Plan
2715 State Hwy. 
Sherburne, NY 13460
(tel. 607-674-4036) 

or

NYSDEC 
Division of Lands and Forests
Re: Recreation Master Plan
1285 Fisher Ave.
Cortland, NY 13045
(tel. 607-753-3095)

Please copy your letters, especially the really good ones, to the higher ups in the DEC. These would include:
 

Thomas Wolfe
Chief, Bureau of Public Lands

Robert Davies
Director, Division of Lands and Forests

Peter Duncan
Executive Deputy Commissioner

these three official are at:

New York State Department of Environmental Conservation
625 Broadway
Albany, NY 12233

also consider:

Kenneth Lynch 
Director, Region 7
New York State Department of Environmental Conservation
615 Erie Blvd. West 
Syracuse, NY 13204-2400 
 

The public meetings ar enow over.  But for the record, the meeting dates and locations were:
 

Jan. 7, Homer High School, 80 West Road, Homer
Jan. 8, BOCES, Butterfly Road, Mexico
Jan. 9, SUNY Forestry school, Syracuse, Baker Lab
Jan 15, Johnson City High, 666 Reynolds Road, Johnson City
Jan 17, Norwich High, Midland Drive, Norwich.



 

Here are a couple more links to check for staying up to date on advocacy issues. The FLCC has a newsletter you can join here: http://www.topica.com/lists/flcc/ The New York Mountain Biking Coalition (NYMBC) has a lot of useful information and an email newsletter you can join here: http://www.nymbc.com

Of course: if you are serious about Mountain Biking then join the IMBA:
International Mountain Bicycling Association