Sierra Club Tahoe Area Group's letter to:

Subject: Tahoe Regional Trails Strategy

Representing the Tahoe Area Group of the Sierra Club, I offer the following comments regarding the Tahoe Regional Trails Strategy (TRTS). Management of National Forests under the Lake Tahoe Basin Management Unit (LTBMU), State of California and State of Nevada lands in the Tahoe Basin is a high priority for our Group, particularly when it comes to preserving the clarity and purity of Lake Tahoe and the natural environment of the lands surrounding it. Tahoe Area Group members in Nevada are members of the Toiyabe Chapter (more than 6,200 members); Group members in California are members of the Mother Lode Chapter (more than 17,400 members).  We have over 6,400 members in Nevada and Eastern California. Of those, nearly one-half reside in the western Nevada corridor from Reno/Sparks through Carson City and Minden/Gardnerville, including the Nevada communities that border Lake Tahoe. Many members both in and outside the Lake Tahoe Basin engage in recreational activities on LTBMU and State lands.

General Comments

The plan laid out in the TRTS is to add approximately 65 miles of new trails and trail connections to the existing 585 miles of official trails in the Tahoe Basin (an 11% increase) within the next five years. An additional undisclosed number of miles of new trails are also proposed in years 5 through 15. Additionally, 6 new trailheads are proposed along with 26 trailhead improvement projects. Most of the new trails (77%) being proposed in the next 5 years are proposed by the Tahoe Area Mountain Bike Association (TAMBA).

The Tahoe Area Group works proactively to make our Sierra Club outings more accessible and inclusive for persons of any age. So, while we applaud the goal of improving “trail options and accessibility for, especially for people with disabilities, underserved communities and the Washoe Tribe,” we are concerned about the potential for environmental impacts from the proposed near-term 11% increase in trail miles in the Basin combined with further unspecified increases in the next 20 years. These concerns are compounded by the fact that environmental analyses for these individual projects are increasingly being approved under categorical exclusions under the National Environmental Policy Act (NEPA) with no cumulative impacts being analyzed and with minimal public comment.

The increase in trails will bring an increase in numbers of people to the Basin at a time when it is already at maximum carrying capacity and Lake Tahoe’s water quality is suffering because of it (State of the Lake Report link). The current trail usage in the Basin, particularly during and after the pandemic, has increased to unsustainable levels causing user conflicts, an increase in unofficial trail development, trail erosion leading to degradation of our streams, alteration and compaction by mountain bike users, and e-bike users ignoring rules restricting their use to motorized trails. Greater and greater access will cause even more gridlock on roadways that are already at maximum capacity because most people drive to trailheads. An increase in trail miles has the potential to increase air and water pollution, habitat degradation, wildlife impacts (including threatened and endangered species) and reduce areas in the Basin that are free from human influence. At a minimum, there needs to be a Basin-wide cumulative impacts analysis done before any new trails and trailheads are added in the Basin.

More Trails DO NOT Equate to Less Traffic

Under the heading “Document Purpose” on page 30, the TRTS states: “The 2020 Regional Transportation Plan identifies a broad range of projects, programs, and strategies needed to comprehensively improve Tahoe’s transportation system over the next 25 years. The Active Transportation Plan (ATP) serves to help protect Tahoe’s natural environment by providing a framework for a comprehensive multimodal transportation system.” The new trails proposed in the TRTS are purely recreational trails. None of these proposed or conceptual trails are for transportation. People do not go to work on recreational trails. People do not go shopping using recreational trails. More trails will not alleviate gridlocked roads and by continuing to push this false narrative on the public, while continuing to allow increased density, height and coverage (resulting in more people in the Basin) without any cumulative impact analysis, is dishonest and certainly does not “help protect Tahoe’s natural environment.” In fact, it does just the opposite.

E-bikes and other motorized users

The Sierra Club is very much in support of e-bikes as an alternate, fossil-fuel free means of transportation on motorized trails or roads. However, they do not belong on single-track trails with other non-motorized users. E-bikes can easily travel at speeds up to 29 mph, way over 10 mph. Weighing on average between 35 and 70 pounds, e-bikes are substantially heavier than non-motorized bicycles. This combination of weight plus speed could be severely damaging, if not deadly, in a surprise encounter between an e-bike and a walker/hiker/mountain biker (let alone a horse).  In addition, most e-bikes use rechargeable lithium-ion batteries, which can pose a catastrophic fire hazard if they fail.

Due to their weight, e-bikes cause more trail damage, erosion, and degradation, requiring more costly trail repair.  A field study of the International Mountain Biking Association showed that a “Class 1 eMTB (electric mountain trail bike) could allow users to approach the turn more quickly [than a traditional MTB] leading to greater soil movement upon breaking and/or simply the weight difference [of ca. 20 lbs].”  The increased traffic brought by e-bikes will also put further stress on wildlife. The Sierra Club policy on e-bikes is: "Electric motorized bicycles (a.k.a. “e-bikes”) are motorized vehicles. Policy related to motorized vehicles is set forth in Sierra Club’s policy on Off-Road Use of Motorized Vehicles." See the Sierra Club’s policy on Off-Road Use of Motorized Vehicles here.

Under pressure from e-bike companies that have sprung up throughout the Basin, LTBMU is proposing expanded access to e-bikes, which will create particularly intense user conflict issues. See our comments (attached), dated March 28, 2021, to LTBMU on their Basin Wide Trails Analysis Project. The TRTS does not acknowledge that direction that LTBMU is heading and states only that “Land managers have the discretion to determine designated allowed and prohibited trail uses.” If the LTBMU are going to propose an increased e-bike and other motorized usage on the trails in the Basin, which certainly looks to be the case, then the TRTS should be upfront and honest about these intentions. Instead, the TRTS states the status quo – “e-bike and motorized users are prohibited from multi-use trails unless specifically designated” – even while e-bike users are increasingly and illicitly using these trails without consequence. The only intimation of what will soon be proposed by LTBMU are several pictures of motorbikes tearing up a single-track trail (pages 28 and 81). Images of dirt bikes tearing up single-track trails is generally not a desirable image to a majority of Tahoe recreationists and is not a compatible use on multi-use trails. What kind of message are these images trying to convey? Are they intended to indicate this is what we are supposed to accept or that this is already occurring? We do not need an increase in single-track trails for motorized traffic in the Tahoe Basin as the user conflicts, environmental impacts, and risks to the Outstanding National Resource Waters of Lake Tahoe are too high. Any increase in motorized trails in the Basin would require a full Environmental Impact Statement, not just an Environmental Assessment under NEPA.

It is unclear from the statement at the end of page 16 whether NV State Park trails restrict e-bikes to motorized trails like the rest of the Basin at the current time. So there is no confusion, there should be one policy for e-bikes throughout the Basin and this policy should be very clearly posted at all trailheads. E-bike sellers and rental companies should be required to provide their customers with clear guidance and rules so that they know where they can and cannot ride.

Cumulative Impacts

In addition to adding new trails, improvements to trailheads will provide greater access to more people, making the overcrowded roadways during summer months even more unsustainable and impactful to Lake Tahoe, which is seriously declining both in terms of lake clarity and near- shore water quality. Although an increase in trail miles will help disperse the large numbers of people, a continued increase in trail users diminishes not just the user experience (both from conflicts and diminished wilderness qualities) but also will impact wildlife, habitat values, and water quality of streams flowing into Lake Tahoe.

There needs to be a Basin-wide comprehensive cumulative impacts analysis of the increase in number of trails, trail usage, trailhead parking and increased traffic on roadways in the Basin before any individual project environmental analysis is approved, particularly if, as is usually the case, the projects are approved under categorical exemptions which lack adequate public involvement and comment periods, not to mention any notion of cumulative impacts. A comprehensive analysis of traffic impacts from increased recreationists should be combined with a comprehensive cumulative impacts analysis after TRPA’s unanalyzed, carte-blanch approvals for increased density, height and coverage throughout town centers throughout the Basin, particularly with regard to the consequences and impacts these approvals will have during wildland fire emergencies and evacuations.

Promoting increased tourism when the Basin is already over-saturated and beyond carrying capacity jeopardizes the health and safety of existing residents and visitors during a wildfire. The TRPA and Tahoe Transportation District needs a thorough Tahoe Basin Fire Evacuation Route Assessment that is based on the most current data available. This does not mean projects and strategies that refer to “forest resilience,” which is code-word for commercial logging operations that only create greater risks of wind-generated fires and loss of necessary soil moisture at a time when we desperately need our forests to help fight climate change.

What is needed is a thorough analysis of how both residents and tourists will be safely evacuated on the current roadways from a wildfire before any new trails, trailhead improvements or additional density, height and coverages are approved. The current situation is extremely likely to have unfortunate consequences since a panicked wildfire evacuation could easily lead to significant injuries and loss of life. Increasing the numbers of people in the Basin during the summer could increase the chances that residents and visitors will unsuccessfully compete (during increased panic) for access to clogged evacuation routes on an already over capacity road system.

As former Fire Combat Battalion Chief and Fire Marshal, Doug Flaherty, has stated, “the common "fire evacuation plan” usually contains a menu of evacuation routes with evacuation diagrams involving a given community or study area, as well as communications protocols, public alerting process and public safety resources, all of which are all very important. Agencies often use this type of plan as red-herring proof of mitigation, which dangerously allows projects to proceed through public review and approval. However, the truth is, these types of fire evacuation plans are usually not based on any real data or in-depth evacuation route capacity assessments to help determine whether roadways will be effective routes during panicked wildfire evacuation. In order to give a common "fire evacuation plan" a chance of success to be truly effective, the plan must be based and built on a data-driven road-by-road "evacuation route assessment," including capacity limitations and projected travel route time calculations. This is the only way to ensure “fit for purpose" public safety evacuation capacity effectiveness and work-ability.”

Lack of Enforcement, Signage, Education, Speed Limits, and Shuttle Services

1. The LTBMU currently has two enforcement staff for the entire Basin. Having personally witnessed people driving off-road in search of large landscape rocks, motorcycles riding on non-motorized single-track trails, e-bikes on these trails, and mountain bikes riding at least 25 mph down single-track trails without stopping for anyone in their way, two enforcement officials for the entire Basin is entirely inadequate. See the attached letter to Forest Supervisor, Erick Walker, regarding the latter two issues. Greater enforcement is needed, not more trails. Perhaps LTBMU could use some of the money from the “forest resilience” project’s timber sales that are occurring around the Basin to hire more enforcement staff.
2. Although posts along non-motorized trails have the familiar logo of a motorcycle with a line through it, there is no similar symbol for e-bikes. Some type of symbol needs to be created and added to all the signage on non-motorized trails around the Basin. Signage on non- motorized trails indicating that e-bikes are prohibited should be added wherever there is already signage or posts indicating direction or other information, not just at trailheads.
3. As stated above, all e-bike stores (either sales or rentals) should be mandated to instruct and inform their customers where they are allowed to ride and where they are not. TAMBA, as well as the bike shops, should have an active educational role in informing e-bike users where they are and, more importantly, are not allowed to ride. TAMBA should also increase their education to mountain bikers regarding not using multi-use trails as raceways and control their speeds, get off their bike and move off the path of hikers, who have the right-of- way, and not assume that hikers will move out of the way of bikers.
4. In addition to NO E-BIKE signs, there should be speed limit signs added wherever there is already informational signage and these speed limits should be enforced. There is no excuse or the me-first, get-out-of-my-way attitudes on the trails in Lake Tahoe when people are trying to get away from these types of experiences and attitudes on highways and roadways and have a little peace and quiet in nature.
5. As anyone driving along Highways 89 around Emerald Bay or 29 near Sand Harbor in the summer can attest to, there is a great need for alternative transportation that is reliable, frequent, and free to the user to alleviate gridlock and related environmental issues in these areas.

Survey

The TRTS state that a “survey was sent to various landowners, local governments, trail agencies, advocacy groups, and other private interest groups including backcountry horsemen, dirt bikers and motorcyclists, and bike shops.” Further on in this section, the TRTS state that “several different respondents identified the lack of OHV and e-bike accessible trails and the lack of equestrian parking as additional challenges. The actual survey (i.e., the questions), the people and entities where the survey was sent should be provided to the public. and the rationale behind those choices provided. The response about the lack of motorized trails in the Basin is an entirely predictable one from dirt bikers and motorcyclists. Who exactly was the survey sent to? Were any hiking groups or environmental advocacy groups provided with the survey? A survey is only as reliable as the quality of the questions and the breadth and scope of users that are given the survey. Sampling bias is one of the primary biases that could render a flawed survey. From the information provided in the TRTS, one can only conclude that this survey was highly biased and therefore should not be the basis for any decision-making.

Summary

The proposed and conceptual increase of trails and trailhead access in the Basin will have significant impacts on the environment and lead to an increase in numbers of recreationists, cars on the roadways, damage to wildlife habitat needs, increased sedimentation in our creeks and water quality impacts to an already declining Lake Tahoe. We appreciate you thoroughly and carefully considering these comments.

Tobi Tyler, Vice Chair
Tahoe Area Group, Sierra Club