My Letter to Marin Parks and Open Space

Re:RTMP TPEIR Comments.


As an avid trail user, former Greenpeace Media Crewman and 20 year resident of San Rafael, I'd like to direct you to the following issue I have with the recent RTMP TPEIR:

I believe that the statistical data for the RTMP TPEIR was secured by faulty methodology.

A. -B. [p.118 The data collection methodology was developed to provide unbiased survey protocols and a

statistically valid sample of visitors. Data collection included two components:

• a census of visitor use at 14 preserve locations (selected to be a representative sample

of the 34 preserves and access points) over a series of up to three peak time periods

(with a duration of two hours per period) to provide a reasonable picture of use activity

throughout the week]

This modeling represents serious omissions for a relatively medium sized preserve. Specifically, the study omits the widespread use of preserve trails at night by mountain bike riders and also use violations at other times, in areas not covered by the study. MCOSD have shown in the Indian Valley preserve that day-night game cams were used to gather data about trail usage. This is a far better method for getting a truer picture of who is using the trails and when. Why wasn't this method favored rather than the scant observation methods by citizen volunteers, that you chose on only 14 preserve locations? For a minimal cost, all trails in the system could have been monitored with day-night trail cams.

In my neighborhood near San Pedro Mountain Section 5 of the preserve mapping, we have a major problem with illegal bicycle riding on trails marked closed to bikes. Not only are the trails regularly over run by daytime mountain bikers, but also by night riders as well. This has been documented numerous times. Not only could accurate violation patterns be assessed for night riders, illegal trail builders and others, but there are also important wildlife use patterns that could have been obtained with trail cam methodology. This was recently demonstrated in National Park lands by the National Park Service, in Point Reyes. http://www.marinij.com/ci_21708120/wildlife-cameras-point-reyes-national-seashore-capture-rarely and http://www.nps.gov/pore/naturescience/wildlife_monitoring.htm

A great opportunity exists at this important time in Marin Open Space history, to get as accurate a picture as possible of trail use patterns and users, including wildlife. In fact, this is vital to managing a successful stewardship of these important lands. The current TPEIR is deficient in this respect. There is still time to get this data. Please don't squander this chance.

Also, nowhere in the report is there a listing of “excessive speed” as an environmental/safety aspect of special concern. The current preponderance of mountain bike speeding and it's effects are nowhere to be found on this TPEIR. Unfortunately, mountain bike speeding also could have been measured for the TPEIR. Speeding should be listed along with noise, air quality and other concerns in that section of the report. Recent accidents at the Indian Tree preserve show the urgency of this problem. Enforcement fines must be boldly increased.

It is no secret that mountain bike lobbying groups have been barraging yours as well as other land stewardship agencies in Marin County for more access to narrow trails. This demand on yours as well as other open space agencies is unprecedented in the annals of trail management history and deserves more study than the current report offers. No other user group is demanding new trails. Indeed the long and healthy trails of many of our western National Parks have existed for decades without the demand for new trails.

One quarter mile of the 680 trail cost nearly 1 million dollars. To open up new trails, especially to mountain biking, is risking an overspending trap that should be secondary to enforcement, maintenance and removal of invasive species and redundant trails.


John Parulis


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