Public comment is being requested for a proposed re-route of the CDT/CT in central Colorado. Details here as well as info on submitting comments: http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=31283
Useful information regarding the type of comment that they are looking for at this point:
"In the NEPA process, and especially with an EA (versus an EIS) not all public comments warrant consideration. Part of the criteria for publishing and responding to comments is that they must question the data, the analysis, or the completeness of the document. If you send an email, saying "bikes should be allowed" or "chose alternative 3" it is not likely to do any good at this stage in the process.
What you should do, is point to the fact that mechanized travel, i.e. mountain biking is presented in an unfair light. Part of this, is that the CDNST and accompanying environmental documents already provide for hiking and horseback riding as intended uses for this trail system. They are essentially "tiering" to previous documents to avoid re-analyzing these impacts, so they mention zero impacts of hikers and equestrians on the environment. Because of this, the discussion of mountain biking impacts on page 28 stand out as if they are separate and additive effects. Ideally, they should have analyzed the cumulative effects of adding mountain bikers, versus the already permitted uses. You should specifically mention that zero sources are cited in the discussion of mountain bike impacts on page 28. This points to a gap in the analysis. They will then have to justify these impacts by citing peer-reviewed journal articles, technical reports, or personal communication with experts. They will have a problem doing so, as very few sources exist, especially that paint mountain biking in such a negative light.
Another thing you can point to is the low traffic on this section. This is a remote section of the CDNST and CT so it doesn't get a lot of traffic, especially from bikers, so the resulting impacts should be low.
I might also suggest citing sources that provide a fair and balanced discussion of mountain biking impacts, as well as trail building strategies that will limit the impacts of all trail users on the environment.
I suggest
Pickering CM, Hill W, Newsome D, and Leung Y-F (2010) Comparing hiking, mountain biking and horse riding impacts on vegetation and soils in Australia and the United States of America. Journal of Environmental Management, 91:551-562.
and
Webber P (Man. Ed.) (2004) Trail Solutions: IMBA's Guide to Building Sweet Singletrack. International Mountain Biking Association: Boulder, CO."
Useful information regarding the type of comment that they are looking for at this point:
"In the NEPA process, and especially with an EA (versus an EIS) not all public comments warrant consideration. Part of the criteria for publishing and responding to comments is that they must question the data, the analysis, or the completeness of the document. If you send an email, saying "bikes should be allowed" or "chose alternative 3" it is not likely to do any good at this stage in the process.
What you should do, is point to the fact that mechanized travel, i.e. mountain biking is presented in an unfair light. Part of this, is that the CDNST and accompanying environmental documents already provide for hiking and horseback riding as intended uses for this trail system. They are essentially "tiering" to previous documents to avoid re-analyzing these impacts, so they mention zero impacts of hikers and equestrians on the environment. Because of this, the discussion of mountain biking impacts on page 28 stand out as if they are separate and additive effects. Ideally, they should have analyzed the cumulative effects of adding mountain bikers, versus the already permitted uses. You should specifically mention that zero sources are cited in the discussion of mountain bike impacts on page 28. This points to a gap in the analysis. They will then have to justify these impacts by citing peer-reviewed journal articles, technical reports, or personal communication with experts. They will have a problem doing so, as very few sources exist, especially that paint mountain biking in such a negative light.
Another thing you can point to is the low traffic on this section. This is a remote section of the CDNST and CT so it doesn't get a lot of traffic, especially from bikers, so the resulting impacts should be low.
I might also suggest citing sources that provide a fair and balanced discussion of mountain biking impacts, as well as trail building strategies that will limit the impacts of all trail users on the environment.
I suggest
Pickering CM, Hill W, Newsome D, and Leung Y-F (2010) Comparing hiking, mountain biking and horse riding impacts on vegetation and soils in Australia and the United States of America. Journal of Environmental Management, 91:551-562.
and
Webber P (Man. Ed.) (2004) Trail Solutions: IMBA's Guide to Building Sweet Singletrack. International Mountain Biking Association: Boulder, CO."