by Ed Lawrence, KTA Trail Care Chair
These comments on the Allegheny National Forest's "Tracy Ridge Shared Use Trail Project" proposal were submitted on behalf of the Mid State Trail Association in response to the proposal's 41 page Environmental Assessment (EA). The EA was itself developed by the ANF in response to public comments generated by the original "Scoping Proposal" which had set out the parameters of the project which would open sections of the currently 'hiking only' Tracy Ridge Trail System to mountain bikes. These comments are meant to bring to the attention of the Forest Supervisor the weaknesses, inconsistencies and contradictions in the EA, proposal and project.
To the Attention of Forest Supervisor Sherry A. Tune:
Tracy Ridge Shared Use Trail Project Proposal
These comments are being sent to you on behalf of the Mid State Trail Association (MSTA), an all-volunteer organization dedicated to maintaining, improving, and protecting the Mid State Trail (MST) and the quality of the hiking experience that it provides for its users. The MST, Pennsylvania's longest and wildest footpath, is a Department of Conservation and Natural Resources designated 'hiking only' trail.
Regarding the Proposed Tracy Ridge Shared Use Trail Project, the MSTA opposes the Forest Plan amendment that would remove the bike prohibition and we oppose the recession of the 1994 order that prohibits bicycle use. We support Alternative No.1 / No Action.
We agree with the validity of the 2007 Forest Plan assertion that 'bicycle use is unsuitable' on Tracy Ridge Natural Recreation Trails based on the 1994 finding that 'the soils and topographic conditions of the area do not support' their use. The Proposal's Environment Assessment (EA) seeks to discount this finding by saying that 'no analysis has been found to substantiate these statements'. However, the EA also tells us that mountain bikes were known to be riding the area prior to the finding, and so we must conclude that there were sufficient problems with that use that triggered the prohibition. It is probable that on-the-ground trail conditions at the time prompted and corroborated the 1994 finding.
This also explains why the trails would have been in need of rehabilitation. We believe that deference should to be given to the competence of this professional site specific assessment that would have been based upon direct observation. Prohibiting mountain bikes from using the Tracy Ridge Trails was a sound and correct management decision then, and remains one now.
The Proposal and EA consistently refers to these trails as being 'underutilized' by the hiking community as an underpinning and rationale of the proposal, but without supplying any benchmark standards or criteria for what would be considered optimal utilization for this area. Tracy Ridge's use levels are compared unfavorably with other hiking destinations in the National Forest but, again, without any context to determine if these other areas may, in fact, be being over-utilized. The proposal also glosses over the extent and degree to which use figures for these areas may be skewed by the presence of a trailhead bathroom. Sometimes more use is not ipso facto better use, from either a recreationist's viewpoint or a management perspective. The lack of a substantive use metric and analysis is a major failing to a proposal that then becomes premised upon a subjective, pejorative and nebulous concept of 'underutilization'.
What we do know about the Tracy Ridge Trail System is that in the 1990s it was, according to the EA, a 'magnet for day hiking and backpacking'. This description is supported by the Allegheny National Forest Hiking Guide put out by the Allegheny Group of the Sierra Club (Fourth edition, 1999) which says that the Tracy Ridge Trails get 'heavy' use. The EA also tells us that the Forest Service 'has not adequately maintained the system for a number of years', and that after being abandoned due to 'limited resources' use of some sections of the trail has reportedly diminished. It should not be a surprise that hikers would lose interest in those parts of a trail system that are not being adequately maintained. However, did the Forest Service ever reach out to hiking organizations before determining that the only salvation for Tracy Ridge was to open it to mountain bike use? The Keystone Trails Association (KTA), Pennsylvania's only statewide hiking organization, has had a robust Trail Care Program since 1985 that helps to maintain hiking trails across the state, but has never been contacted about partnering with the ANF to address the maintenance issues at Tracy Ridge.
The EA also consistently labels the Tracy Ridge Trail System as a prospective 'high quality' biking opportunity, but is it really? According to the EA, mountain bikers prefer a single track trail that offers 'variety', 'flow', 'slope', 'curve', 'technicality' and 'sinuosity'. However, in order to allay concerns about user conflict, the trail is described as being wide and flat, or relatively flat with excellent sight lines, or, elsewhere, as having a mostly gentle grade. The pictures of trail segments included in the EA also show a trail that does not conform with bikers' preferences. The EA further states that the machine built Jakes Rock Trail will have the sought after 'flow', as opposed to Tracy Ridge which is 'fairly flat' with 'rooty/rocky uneven tread' which, it says, makes it good for 'beginners and intermediate riders'. This hardly seems to be the constituency that this proposal was supposedly developed for or the type of trail riding these groups reportedly want. The EA also makes the claim that there will be little incursion on the North Country Trail because the trail sections that reach it will be signed as closed to bikes and 'not easily rideable by the casual mountain biker', but the 'casual mountain biker' is not going to be the problem and is not this proposal's targeted demographic. Experience shows that trail sections that are 'not easily ridable' are the very ones coveted by hard-core biking enthusiasts.
OTHER POINTS OF CONCERN:
Although the EA portrays, and downplays, shared use conflict and particularly the diminished quality of experience for hikers as a subjective he said / she said issue, its choice of the Morrison Trail, where bike use is described as being 'somewhat limited' or 'somewhat low', as the prime example of a shared use trail without incidents seems beside the point. The lack of user conflict complaints on the ANF can perhaps be attributed directly to the fact that, according to the EA, shared use trails have 'low bike use' or are 'not favored' for riding. Interestingly, the EA again uses the Morrison Trail as an example of a trail that does not 'show any additional wear from bikes', but why should it if it is seldom ridden? We agree that this Proposal 'will undoubtedly increase the potential for user conflict'. The EA is also quite clear in its bias prioritizing the experience of the mountain biker, although the biker's subjective desire for a so called 'remote backcountry feel' is never questioned or scrutinized. Hikers, however, who do not enjoy the experience of being jolted out of that ineffable mental zone that hiking can produce, by a bicycle bearing down on them are told, quite bluntly, that if they don't like it they are welcome to go elsewhere.
The EA states that the Proposal was 'carefully crafted to keep bikes off of the hiking-only North Country Trail', but, realistically, looking at the map, is a bike rider really going to ride 2 miles down the south leg of the Tracy Ridge Trail, coming to a supposed dead-end trail junction and then turn around? That is highly unlikely. Experience tells us that there will be a percentage of riders who will ignore any signage or 'education' in pursuit of the adrenaline thrill. For this same reason, some percentage of mountain bikers will not "stay on the trail corridor because it is the easiest path to travel' as the EA says it 'expects'. They will, in fact, do the opposite, and go off trail for exactly that reason. The EA also claims that the 'area will be monitored for compliance', no doubt with the same lack of resources that were used to maintain the trails to begin with. We believe that this Proposal will not only 'increase the potential for bike trespass on the North Country Trail' but actually facilitate it, putting at unnecessary risk a section of the NCT that is 'highly valued' by the hiking community.
One of the prime reasons given for opening the Tracy Ridge Trail to bicycles is the need for a new source of maintainers. The EA suggests that the system will collapse unless the Proposal is implemented. It states that 'currently there are no organized groups that provide maintenance' on the 34 mile system of trails. Yet, two paragraphs later, it contradicts that assertion when it says that the 'NCTA chapter maintains the NCT portion' which accounts for about 1/3 of the system. Again, what outreach has the ANF done to hiker groups for assistance before concluding that mountain bikers are the only group that can save Tracy Ridge? Indeed, will mountain bikers even actually log-out down trees or will they simply build ramps to juice jumps like they do on other trails in Pennsylvania, turning the system into a biker friendly obstacle course?
In conclusion, and for the reasons discussed above, the members of the MSTA believe that this Proposal should not go forward.
President (Volunteer) Mid State Trail Association