Letter from outdoor groups opposes allowing e-bikes on non-motorized trails on public lands

To: Chief Vicki Christiansen, USDA Forest Service

Deputy Director Dan Smith, National Parks Service

Acting Director(s) William Perry Pendley and Michael Nedd, Bureau Land Management

(Sent via electronic mail)

cc:  Andy Tenney, Division Chief, Recreation and Visitor Services, Bureau of Land Management

Michiko Martin, Director, Recreation, Heritage and Volunteer Services USDA Forest Service

Bob Ratcliffe, Division Chief, Conservation and Outdoor Recreation National Park Service

Date: July 26th, 2019

Re: E-bike Management on Federal Public Lands

On behalf of our millions of members, supporters and public land users across the country we write to object to any attempt by public land management agencies to legalize electronic motor bikes (e-bikes) on non-motorized trails.

We oppose any effort that would allow any class of vehicle with a motor – including all classes of e-bikes, which by definition have a motor – to be allowed on non-motorized trails.  A contrary interpretation would create an unmanageable slippery slope and threaten future management of all non-motorized trails and areas on public lands.

Non-motorized trails were created to ensure that the public could find recreational trail opportunities free from the ever-growing motorization and mechanization.  Millions of public land users including hikers, backpackers, hunters, horse packers, climbers, mountain bikers and many more, value non-motorized trails for recreation.  Opening non-motorized trails to motors would forever change the backcountry experience for these users. 

We recognize that e-bikes have a place on public lands and generally should be allowed where motorized vehicles are permitted. The existing motorized trail system provides plentiful opportunities for e-bike use with tens of thousands of miles of trails currently open to their use.

The Bicycle Products Suppliers Association, international power equipment companies and e-bike user groups created a classification system for e-bikes, based on motor and battery sizes and engagement systems for the motor.[1]  This classification system is confusing for land managers and lawmakers and the bikes themselves are often difficult to distinguish from one another. The fact remains that all e-bikes are motorized by definition, regardless of the size of the motor or how it is turned on.

We understand that federal land management agencies are currently considering policy changes to allow e-bikes on non-motorized trails. Such a policy is ill-advised and would undermine nearly a half century of management precedents and practices. First, allowing e-bikes on non-motorized trails would be un-manageable and send agencies down a slippery slope towards allowing further motorization of trails and potentially the entire backcountry. Federal land managers simply do not have the resources to police e-bikes on trails.  

Second, permitting e-bikes on non-motorized trails is contrary to long-standing “travel management” laws and policies dating back to the Nixon administration that require all motorized recreational uses of our public lands to be confined to a system of designated roads, trails, and areas.[2] Among other requirements, motorized trails must be located to minimize conflicts with other recreational uses of the public lands, as well as damage to soil, water, and other public land resources and harassment of wildlife. Separately, agencies are required to manage certain wildlands – including Wilderness Study Areas, Forest Service recommended wilderness, and BLM lands managed for wilderness characteristics – to preserve and protect wilderness character. National Scenic Trails are also required by law to be managed as non-motorized trails. In short, current laws and policies require that non-motorized trails remain non-motorized, and any contrary interpretation could only be supported, if at all, through full notice and comment rulemaking processes.

Millions of public land users across the country enjoy both motorized and non-motorized recreational experiences. Opening non-motorized trails to motorized bikes would effectively eliminate the non-motorized, primitive recreational opportunities. We strongly oppose any effort to change existing trail management rules or policies and encourage all federal land management agencies to reject any effort to open non-motorized trails to e-bikes or other motorized vehicles.

Sincerely,

Addison Oaks Trail Riders

Allegan County Pleasure Riders

American Endurance Ride Conference

American Hiking Society

American Flyers

Appalachian Trail Conservancy

Back Country Horsemen of America (and the 30 BCH states and 196 chapters, full listing at end)

Bay Area Barns and Trails

Blue Ridge Horsemen's Association

Brighton Trail Riders Association

Canalway Partners-Board Member

Carolina Mountain Club

Colorado Mountain Club

Colorado Plateau Mountain Bike Trail Assoc, Inc.

Conserving Carolina

Continental Divide Trail Coalition

County Line Riders of Catalina, Inc

Dallas Off Road Bicycle Association (DORBA)

East Mountain Regional Trails Council

Fort Custer Horse Friends Association

Grand Valley Trails Alliance

Greater Yellowstone Coalition

Highlands Plateau Greenway

Ice Age Trail Alliance

Idaho Trails Association

Indiana Trails Community

Ionia Horse Trails Association

Kensington Trail Riders

Maybury Trail Riders

Michigan Horse Council

Michigan Trail Riders Association

Montana Wilderness Association

Montana Backcountry Alliance

National Parks Conservation Association

Natural Resources Council of Maine

Nickel Plate Trail, Inc

North Carolina Horse Council

North Country Trail Association Incorporated

Oregon Equestrian Trails

Oregon Horse Council

Overmountain Victory Trail Association

Pacific Crest Trail Association

Partnership for the National Trails System

Pinckney Trail Riders Association

Pisgah Trailblazers

Pontiac Lake Horseman’s Association

Proud Lake Trail Riders

Quiet Trails Group

Rose Oaks Equine Adventurers

San Luis Valley Ecosystem Council

Tri-County Horse Association

The Wilderness Society

Winter Wildlands Alliance

Yankee Springs Trail Riders Association