Response to Criticism

The main opponent (SPRAWLDEF) of the flow trail has offered a number of criticisms in a letter sent to the EBRPD Board (here). This letter has been endorsed by the 20-member East Bay Public Lands Committee of the Sierra Club Bay Area Chapter.  We've summarized their key criticisms in bold followed by our response in regular font. 

1.  The flow trail would be sited in the heart of Wildcat Canyon Regional Park which is not a suitable location for this type of activity.

The implication of this criticism is that the proposed flow trail would be situated in a remote, pristine area.  In reality, the proposed trail parallels a steep existing fire road (Mezue Trail) in range-land dominated by non-native grasses that has been grazed by cattle for several centuries.  The site is within a half-mile of the highly populated East Bay Hills as documented in the EBRPD environmental study.  This study found no sensitive natural communities or rare plants near the site nor critical habitat.  The study did find that the site could potentially support some protected and sensitive wildlife and plant species, but the same could be said for the much larger surrounding area.  

One can’t help but ask critics of the proposed site “If not here then where?”  The obvious answer to those who know Wildcat-Tilden is that any other site could have much more significant environmental impacts and result in potential user conflicts, and be an easy target for those same critics.

2.  Flow trails are distinct from other types of trails and pose unique challenges for resource protection and public safety. The flow trail would introduce an entirely new type of mountain bike trail that has never been evaluated for its potential to result in significant environmental impacts. 

The main physical differences between a “flow trail” and a traditional narrow-trail are that a flow trail has a lot more turns (switchbacks) and these turns are banked with local soil typically taken from the new trail bed.  The frequent turns mean the flow trail would have an average slope of about 7⁰ as compared to many fire roads in EBRPD which are much steeper (Mezue average slope of 13⁰).   As SPRAWLDEF points out, the flow trail would adhere to recommended standards to reduce erosion (see 2nd paragraph on page 4 of their letter of April 24, 2023), and thus be far less prone to erosion than the majority of existing trails including Mezue. 

User safety would also be improved by the flow trail because bike speeds would be much less than seen on nearby fire roads like Mezue.  Hikers are not often seen in this part of the park but if they do come, both them and MTBers will be safer because virtually all MTBers will be going down the bike-only flow trail at slower speeds then they would on the existing fire roads.   The flow trail would rarely cross Mezue, if at all, and any crossings would be made safe to all users with proper design

3.  Flow trails warrant a Land Use Plan Amendment (LUPA).

A LUPA is an expensive and time-consuming study which is sometimes used when the Park District is looking at making a major change in an existing park that affects a large area, e.g. building a large picnic area with bathrooms, parking lots, etc. 

A flow trail is not a major change in land use (see more detailed discussion above). Hence, the request for a LUPA is unjustified and is simply a strategy to slow and obstruct the trail permitting process.  The normal CEQA process is sufficient as it will evaluate potential impacts of the project and determine the degree of study and potential mitigation of impacts that are needed to ensure legally required protection of natural resources and stakeholders’ interests.

4.  Without a careful examination of potential impacts and alternatives, this choice of location [for the flow trail] could inadvertently create more problems than it solves by inviting conflicts between users and causing impacts that could be identified and avoided with a more circumspect analysis.

EBRPD has repeatedly shown great caution in moving forward on any new trails.  Indeed, this is one reason they have only added about 20 miles of new trails through the entire 125,000-acre system in the last 25 years. Of course, another reason is that SPRAWLDEF and the Sierra Club East Bay Public Lands Committee (EBPL) have always opposed any increased access for off road cyclists. 

EBRPD has taken reasonable first steps to identify a possible location for the flow trail and to identify any critical environmental concerns (they found none).  EBRPD will do a deeper look of potential impacts and alternatives in its next step as part of the CEQA process.

5.  A flow trail is a 'biking-only downhill speed trail'.  In riding a flow trail MTBers use momentum-gaining techniques like “pumping” to gain velocity.

Since the flow trail would be bike-only, one is left wondering why it matters to SPRAWLDEF how bikes maintain their speed?  SRAWLDEF’s comments about “pumping” and characterization of a flow trail as a “downhill speed trail” have no basis in fact. 

Speed on a flow trail is controlled by its numerous turns and modest downhill slope thus making it slower than many of the existing fire roads. Proof of this can be found by comparing the speeds from Strava (a popular social-network app that is used by many athletes to track their routes) MTB runs on Mezue trail to the flow trail at Tamarancho in Fairfax.  The comparison shows that 90% of riders on the flow trail go less than 12 mph while for Mezue it is 16.7 mph (40% higher).  In other words, the vast majority of riders on the flow trail would go less than the EBRPD maximum speed of 15 mph while some exceed it on the Mezue Trail.  Both these trails are built on hillsides with mean slopes of 13-14° though the actual slope of the flow trail bed averages 7° thanks to the many switchbacks. 

The bottom line:  if MTBers want a fast-downhill experience, they will ride the existing fire roads which are shared with hikers and equestrians - potentially adversely affecting the safety of all users.  MTBers enjoy flow trails not for the speed but for the smooth, flow-like motion that they generate.  

6.  Because the flow trail would be one-way, riders must use a different trail to get to the top of the flow trail, which increases bike traffic on nearby trails thereby increasing the impacted area and the potential for conflicts with other trail users. 

It is true that MTBers will need a route to get to the top of the flow trail.  Most MTBers will use the nearby Leonards and Mezue trails because these are much shorter than any other route.  Havey Canyon is also a possible route but Leonards and Mezue are less than half as long and require about 20% less elevation gain.  The MTB traffic on Mezue and Leonards should have little impact on hikers as they are rarely seen on these trails and bike speeds while climbing are low and rarely result in conflict.  Any crossings of Mezue Trail by the flow trail can be engineered to maximize safety.  

If the Havey Trail does become overused once the flow trail is built, there are a variety of trail management practices that can be applied.  One possibility would be to add switchbacks to Leonards or Mezue so as to reduce the steepness of the climb and make it even more attractive as a way to access the top of the flow trail.  An added bonus would be that these switchbacks would reduce erosion, an obvious problem on these poorly designed legacy ranch roads.

Of course, new users of the Havey Trail would have an impact on the solitary, peaceful experience.  This doesn’t mean that new users don’t have a right to access this shared public open space.   Hikers eager for solitude still retain exclusive access to the equally lovely and more extensive Laurel Canyon.

7.  The new trail will bring even bigger crowds of MTBers to Wildcat/Tilden.

The flow trail might draw more MTBers to Tilden-Wildcat but that is consistent with one of the Park’s most important missions - encouraging more people to enjoy the outdoors. 

MTBing is an especially effective way to get teenagers outdoors and away from social media.  Indeed, anyone who spends much time in the park will quickly notice that one rarely sees a teenager in the park unless they are on a MTB.  In the 2023 riding season about 400 students and coaches from local schools (members of the NICA-NorCal organization) rode in Tilden-Wildcat 2-3 times a week.  Each practice covered about 10-15 miles so they had to re-ride the same fire roads several times a week. The flow trail could also help diversify the user community since it is within biking distance of several underserved communities.  Rich City Rides, which provides cycling opportunities for the most vulnerable members of society, supports (here) the flow trail because it will provide an easily accessible and fun MTB venue to Richmond. 

New users of the park have just as much right to access as current and long-time park users.  Increased use alone is not a reason to prohibit new trail construction. The impacts of additional users should be considered, managed, and impacts mitigated appropriately. The addition of trails is one way to manage increased users successfully. 

We would also point out this new bike-only trail would only be less than two miles long, so while it would certainly attract use it is unlikely to draw large numbers of riders from other parts of the Bay Area because, even with this addition, Tilden/Wildcat simply don’t have the kinds of trail networks that MTBers can find in places like Marin and Santa Cruz.

8.  MTBers already have sufficient trail access in Wildcat/Tilden. There are few places, if any, where East Bay hikers and walkers can now go to observe and enjoy nature without encountering mountain bikes. 

There are about 40 miles of trails in Tilden-Wildcat of which 18 miles are the narrow trails preferred by almost all users.   Of the 18 miles, MTBs are only allowed on less than one mile.  This obvious inequality is aggravated by the fact that hikers and equestrians are allowed to go off-trail and on rogue trails while MTBers are not.  Finally, hikers retain exclusive rights to the large and pristine Laurel Canyon and the Tilden Nature Area.  

9.  MTB use has become common on narrow trails designated for hiking only. MTBers pose a significant safety hazard to elders, small children, etc.  MTBers also build and ride rogue trails. 

For years, MTBers have respectfully advocated for more access to narrow trails in the parks but with little to show for it.  Many have lost faith in the public process and some are resorting to a form of civil disobedience by riding on illegal trails (hiker-only and rogue trails) or building their own.  Briones Park is the poster child for this behavior but the problems there are becoming increasingly common in other EBRPD-managed parks.  In Tilden-Wildcat, many of the rogue trails were started by cattle, hikers, and equestrians. Once those trails are started, it is not surprising some MTBers will use them given that it only takes 5-10 minutes to ride the less than one mile of legal narrow trail.  

If EBRPD provides trails like the proposed flow trail, this will reduce illegal trail riding and the construction of rogue trails.  Provided the trails provide the desired experience, MTBers would rather spend their time riding than shoveling dirt!  Support for this assertion comes from Crockett Hills where EBRPD built new trails with MTBs in mind and, because these trails provide a satisfying experience to MTBers, there have been no substantial bootleg trails built in the 10-yr period since construction. 

Paradoxically, those who oppose equitable access to existing trails or oppose well-designed new trails like the flow trail are providing a powerful incentive to some MTBers to build rogue trails and to ride hiker-only trails.   

Finally, the flow trail would be bike-only and be slower than many of the existing multi-use fire roads.  In addition, the flow trail would draw MTBers away from heavily used areas. Thus, it would enhance the safety and satisfaction of all users.

10. Mountain biking also impacts biological resources. Unauthorized trails and bootleg trails can disturb vegetation, fragment habitat, and increase trail density. 

We agree with all these statements but it is telling that the opponents don’t seem to mind that hikers and equestrians are allowed to use rogue trails and even make new rogue trails by traveling cross country.  Indeed, many of the rogue trails used by some MTBers frustrated by their limited trail access, were first laid down by hikers, equestrians and cows.  

11. The flow trail would put pressure on parking at Alvarado, Inspiration Point, and other peripheral parking areas. 

Most MTBers ride their bikes to Tilden-Wildcat from Richmond, El Cerrito, Albany and Berkeley which will minimize added pressure on parking.  This fact is documented in a recent EBRPD survey (here) that found that the vast majority of MTB users presently get to Tilden-Wildcat on their bikes.  

Potential pressure on parking should be considered, managed, and impacts mitigated appropriately.  This is one aspect of increased use and it will be covered in the EBRPD CEQA review process.

12. Park use by MTBers has grown but so has use by hikers.  What about building more trails for hikers? 

Frequent public comments by MTBers repeatedly point out the need for more access in part because the number of MTBers using the park has grown rapidly, especially since the start of the COVID pandemic. In 2023, about 400 MTBers from local high school and middle schools (members of the NICA-NorCal League) ride in Tilden-Wildcat 2-3 times a week.  They typically ride 10-15 miles during a single practice so they can cover all legal trails in one week! 

Despite the growth in MTBers and other users, the park has added only about 20 miles of new trail in the last several decades in ALL of its parks (none of it in Tilden-Wildcat).  Given the growth in the number of both hikers and MTBers, there is an urgent need to add new trails for all users.

Many hikers are supportive of the addition of a bike-only trail as a way to take pressure off multi-use trails in Wildcat-Tilden, and because they think MTBing is a great way to encourage more young people to get outside.

Finally, the MTB community has committed to raising funds for building the flow trail and to helping to maintain it.   

13. Trails are damaged by bikes.  EBRPD has no plan or funding to repair damage to nearby walking-only trails arising from illegal mountain biking. 

Bikes are not the only or even the greatest cause of damage to trails. Anyone who has done significant hiking in other areas where MTBs or horses are never observed, will see major erosion caused by hikers and/or grazing cattle.  In Tilden-Wildcat, many of the trails are ranch roads or trails built long before modern standards for erosion control were developed or implemented. Consequently, the bulk of damage comes from water run-off that is poorly controlled.  

The pictures in the SPRAWLDEF letter purporting to show evidence of erosion due to MTBing are hard to take seriously.  Only one of those pictures clearly shows a single tire track.  The erosion could be managed with proper trail design and maintenance.   Most who frequent Tilden-Wildcat recognize that there is a great need for EBRPD to increase their expenditures on trail maintenance. 

The MTB community is keen to provide volunteer labor for trail maintenance in Tilden-Wildcat.  BTCEB and NICA teams have done lots of trail maintenance (650 hours in 2022 and over 2000 hours in the past 4 years) in Crockett Hills and in other parks like China Camp.  NICA teams and BTCEB have written letters of commitment (here) to maintain the flow trail in part because trail work is a powerful means to engage youth and train the next generation of trail stewards.  

14. Crockett Hills was turned into a mountain bike park and it’s not far away so why don’t NICA teams use it to practice instead of asking for more trail access in Tilden-Wildcat.

Crockett Hills is not a “mountain bike park” and receives considerable use by hikers.    

The 400 riders from the local NICA teams practice 2-3 times immediately after school.  It is impractical for them to travel anywhere other than Tilden-Wildcat in the limited time they have after school.  Riders are also aware of the fact that driving generates pollution and congestion.   

15. Is there any proof that providing bikes access to narrow-trails will reduce the building of rogue trails?

Yes, the proof is at Crockett Hills.  There have been no substantial bootleg leg trails built there in the roughly 10-year period since the original trails were built.  This can be confirmed by the park supervisor. Additionally, SPRAWLDEF argued that rogue trails would be built if EBMUD opened short segments of the Bay Area Ridge Trail that crossed their property to bikes and this has not happened.

16. EBRPD has presented no plan to close and restore illegal rogue trails in Tilden-Wildcat. 

Closure and restoration of rogue trails is unlikely to be successful until EBRPD provides MTBers with trails that are satisfying.    One way to do this is to legalize rogue trails that don’t harm the environment.  This is the tact being taken in the Briones Pilot project. 

17. Wildcat Flow trail is a “recreation unit” which will be ridden as multiple loops, not a trail for getting from A to B.

Recreation units are considered by EBRPD to be facilities like picnic areas, bathrooms, and other built structures.  A flow trail is a bike-optimized trail which is not a recreation unit. 

Most people will not be riding multiple loops of the flow trail in a single day because of the 1.5 to 3+ mile distance and ~500 foot climb needed to return to the top of the trail.  It is true that during the course of a week, the local NICA teams may ride the flow trail more than once, just as they do other trails in the park.  They have to do this because the number of trails open to bikes are so limited in Tilden-Wildcat.

18.  EBRPD has no plan to fairly distribute mountain bike “recreation units” district-wide in the most appropriate locations. 

The MTB community supports landscape level trail master planning as we stated in the Trail Users Working Group more than 2 years ago.  However, the proposed flow trail has been progressing for several years and suspending this project to wait for full trail master planning would only exacerbate the current shortage of trails, user conflicts, illegal trail riding, and rogue trail-building.   The flow trail is an incremental improvement of an approach proven at Crockett.  As such, it provides an improvement that stands on its own merits and would help alleviate an urgent need to satisfy rapid growth and historical inequities in access to narrow-trails for MTBers. 

19. Park resources and park time went into this proposed park project with no evident Board agenda item and no consideration of alternatives, one of the reasons for a public planning process.

The Board Trails Study Session in December 2022 included an agenda item on the Wildcat Flow Trail which was open to public comment.   At that time, the project was just a proposal that was undergoing preliminary evaluation by staff.  Staff has since determined the flow trail warrants further study and is beginning the process to gather detailed public input and develop alternatives that will then be open to further detailed public comment.  This is the typical path taken by any proposed project. 

If critics of the flow trail have alternatives they can submit them here so that staff can consider them in the planning process.




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