HomeMy WebLinkAbout10/19/2021 Item 7a, Christie
From:Santa Lucia Sierra Club <sierraclub8@gmail.com>
Sent:Monday, October 18, 2021
To:E-mail Council Website
Subject:RE: 10/19/21 meeting, Item 7a: Open Space Winter Evening Hours of Use At Cerro
San Luis Natural Reserve Two-Year Pilot Program
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Dear Mayor Stewart and Councilmembers,
The Sierra Club is concerned about the impacts of the use of bicycles off-road, including effects such as soil erosion, impacts on plants
and animals, displacement of other trail users, and impacts on other users' safety and enjoyment. Single track trails can present
difficult management, safety, and environmental protection situations.
These concerns argue for special regulation, with effective enforcement, of off-road bicycling. The following guidelines were
developed by the Sierra Club Wild Planet Strategy Team with the help of a Mountain Bicycling Task Force to help interpret and
implement the following policy on off-road use of bicycles:
-Trails and areas on public lands should be closed to all vehicles unless determined to be appropriate for their use through
completion of an analysis, review, and implementation process, and officially posted with signs as being open. The process must
include:
- application of objective criteria to assess whether or not environmental quality can be effectively maintained, and whether
the safety and enjoyment of all users can be protected;
- a public review and comment procedure involving all interested parties; and
- promulgation of effective implementing regulations where impacts are sufficiently low that vehicle use is appropriate.
A land management agency must take into consideration the following when assessing bicycle use:
1. Trails open to bicycles must successfully pass an agency review for suitability.
2. Trails open to bicycles should fit compatibly into the overall trail system, providing (to the extent possible) a satisfying and
safe bicycling experience that will minimize the desire of bicycle riders to enter closed areas.
3. Trails open to bicycles should be designed to need minimal enforcement, e.g. relying on natural barriers and terrain features
such as ridgelines to prevent bicycle riders from straying into closed areas. While signs can be important for regulating
bicycle traffic, trails needing excessive and unsightly signage are not appropriate.
4. Implementing regulations should be enforceable, clearly posted in appropriate locations such as trailheads, and emphasized
through agency patrols and outreach programs. The regulations should be simple, consistent, and generally understood and
widely accepted by all users.
5. Trails open to bicycles should have a monitoring plan developed and implemented.
When a land management agency reviews suitability of a trail for bicycle use, bicycle use should not be allowed where it would cause
the following measurable effects. This list is not all-inclusive.
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1. Significant soil erosion or significant damage to streams or fish habitat.
2. Rutting, impairment of trail drainage, breakdown of trail shoulders, and other forms of damage not correctable using U.S.
Forest Service trail maintenance standards and techniques.
3. Significant disturbance of plants or animals or their habitat.
4. Damage to archaeological, scientific, historical, or other significant resources, including rare natural features of interest for
scientific study.
5. Danger to the safety of bicyclists or other users because of bicycle speed, steep grades, steep terrain, sharp curves, slippery or
unstable trail surfaces, or limited visibility.
6. Significant displacement or annoyance of other non-motorized users.
The Initial Study Environmental Checklist for the Cerro San Luis pilot program notes that “a 2016 scientific study reviewed 274
separate peer-reviewed articles regarding the effects of passive recreation on wildlife, spanning numerous geographic areas,
taxonomic groups, and recreation activities…. Overall, Larson et al. identified a clear correlation between recreation and negative
effects to many wildlife species.…” It is also noted that “a 2012 study in Boulder, Colorado reviewed and cited numerous studies
concluding that artificial light, such as that from a headlamp or flashlight, can have negative effects on wildlife such as dazzling and
confusing individuals leaving them vulnerable to predation, disrupting foraging patterns and behavior, and disrupting movement.”
In response to the 2016 study, the Checklist dismisses the negative impacts to wildlife as occurring only at the individual and
community level, not population level. In response to the 2012 study, the Checklist dismisses this impact by saying, in effect, that
wildlife will get used to it, and likely already have due to a presumed equivalence between the distant light and sound from the
surrounding urban area and high-intensity headlamps moving directly through wildlife habitat.
By contrast, it is worth noting the policy adopted by the government of Australia in 2020, specifically “NATIONAL LIGHT
POLLUTION GUIDELINES 90: Prevent mobile light sources shining into nocturnal foraging and roost habitat. The light from mobile
sources such as mobile lighting towers, head torches or vehicle headlights should be prevented from aiming into nocturnal foraging or
roost areas, as this can cause immediate disturbance.”
We submit that an appropriate response to the cited scientific evidence would be for your council to require implementation of the
policy guidelines listed above.
Thank you for this opportunity to comment,
Andrew Christie, Director
Santa Lucia Chapter of the Sierra Club
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