The City of Portland is wrapping up its $350,000 Off-Road Cycling Master Plan, known as the ORCMP. This plan includes siting certain playground-like cycling facilities in developed parks, and a system of interconnected car-free trailways for bike travel. I support ORCMP design concepts, mostly!

The ORCMP also attempts to identify places for various kinds of mountain biking in the urban landscape. I think there may be places suited for mountain biking in the city, but at the same time, I feel very strongly that they do not belong in our protected natural areas. We haven't preserved our wild places just for the adventure of all-terrain bikes. River View Natural Area (RVNA) should not be included in ORCMP.

The ORCMP is based on assumptions that mountain biking is needed everywhere because of trends and perceived demand. Show us the numbers! There is a dearth of data on demand for proposed sites.

Mountain bikers claim they ride in order to experience nature. It's ironic they prefer to enjoy nature in the city on a machine. What's the hurry? That rush is not fair for nature or others hoping to enjoy the same area peacefully, one step at a time. It's common sense — mountain bikes are not compatible with natural areas.

In my opinion, the ORCMP fails to acknowledge some basic environmental ethics and important legal conditions that preclude mountain bikes from being allowed in Forest Park, River View Natural Area, and smaller natural areas in our region. Who will speak for Nature?

The mountain biking lobby has a plethora of arguments, appropriating terms like: 'sustainable', 'science-based', 'excluded user groups', 'carbon foot print', and so on, confusing the discussion of these issues. Hint: It's a bunch of malarkey! Beware of the Mountain Biking Industrial Complex.

I ask the Portland City Council and Metro Council to strongly affirm a commitment to keep the wild parts of our city wild, and free of mountain bikes.

My detailed comments on the ORCMP follow, ending with four action items for the City of Portland and Metro.

John Miller
Portland, Oregon
March 5, 2018

I support ORCMP design concepts, mostly!

I applaud the city's effort to create a region-wide master plan for off-road cycling. Portland is working with Metro at the staff level. It is unclear which elected officials, if any, favor cycling in protected natural areas.

What I am for:

• I'm for off-road cycling as defined as safe and separate bikeways for pleasure rides and commuter trips.
• I'm for all communities and towns in the region being interconnected via safe and simple bike trails. (Extreme mountain biking trails don't count toward such transportation connectivity.)
• I'm for providing lovely off-road (out of traffic) experiences. Riding through some woods or greenspace farther away from traffic enhances such rides.
• I am for facilities for bike rodeo-like experiences. The ORCMP distinguishes between casual cycling, cyclocross, pump tracks, and other forms of two-wheeling. Bike Parks will be good for youngsters in developed parks.

Where I'm Skeptical...

• Mountain biking is an active sport, inherently dangerous for both the rider and other trail users. In my opinion, there should be no dangerous downhill single track on city owned property, unless it is a very unique situation, for example in otherwise unusable gores alongside a freeway, near a hospital.
• I'm not aware of any policy that specifically allows single-track mountain biking trails in natural areas.
• I'm skeptical of mountain bikers ruse of in-town rides as a way of reducing the carbon foot print of their sport. They are casting their guilt on others, while attempting to blackmail the public into allowing them into protected urban natural areas. There are dozens of such ploys.
• Some assumptions in the plan are more useful to the mountain biking industry than to the community. For example, one consultant (company) specializes in purpose-built mountain biking facilities.
• Ride-To-Your-Ride is good, in concept. Mountain bikers want more sites and trails to satisfy their goal of riding to their ride, and to disperse load. This ideal is not attainable in practice, or at least has not been shown so with data matching potential sites, population, and demographics. Mountain biking facilities of every kind would need to be as numerous as ballfields and tennis courts in the city. Indeed, some old sport facilities should/could be converted to bike parks. R2YR will be doable in some places, but the fact that (undeveloped) wooded/mountain/hill slopes are not evenly distributed across the city-region does not mean our protected natural areas should be pressed under the wheels of gravity-fed recreation!

What I'm Against...

• I'm against government-sanctioned downhill single track trails on city-owned property. Why? Single-track accounts for a small minority of off-road cycling. A casual hybrid cyclist doesn't ride a trail with jumps and banked turns. Mountain bikes have shock absorbers and rugged hardware.
• I'm against mixing of mountain bikes and hikers on wooded hillside trails. Why? It's Common Sense.
• I'm against cycling in protected urban natural areas for reasons I will explore in sections below.

River View Natural Area (RVNA) should not be included in ORCMP

One remote possibility is that undeveloped cemetery land to the north of RVNA might be acquired from River View Cemetery to make a trail that goes down toward the Sellwood Bridge on that new property. I have no idea if this is feasible technically or financially, or whether the cemetery would even agree to it.

As for commuting and pleasure trips from Southeast Portland up to L&C College or points west, the River View Cemetery already provides safe daylight passage on pavement at a reasonable grade to many cyclists. There is no justification for using RVNA itself as a commuting route or transportation link. (Riders are grateful that the cemetery allows passage.)

So, why keep RVNA in limbo, waiting for the technical planning of an impossible trail that won't make mountain bikers happy? We need to settle this now, not later.

See Appendix I. for point by point responses to the ORCMP Proposed RVNA Recommendations.

Dearth of Data on Demand for Proposed Sites

No estimate has been made of the number of users to be expected anywhere. It's portrayed as many when it comes to need, but it's dismissed as few when it comes to impact. The strategy, we are told, is to spread the impact out over a large number of sites around the city, so that no one site has all the mountain bikes. Well that's not good. Mountain bikes will be everywhere — nowhere to go to escape them? Or will they have separate trails, spread all over the region? Large parts of the urban area have no hills at all — They will need to travel to ride. One guy interviewed at the 'Freedom Ride' protest said that he regularly drove from Hillsboro because RVNA was such a good ride. Show us some serious numbers! How many bikes/day are projected at River View or Forest Park? (There are so many more questions about increased numbers and their impact...)

Where would RVNA riders come from? What would keep bikers from driving to selected natural areas from all over Portland? What about bikers visiting from outside Oregon? Any estimates?

Mountain bikers claim that Forest Park and RVNA could (should) become international destinations. Promoters cite tourist dollars as a big justification for allowing access. Do we want to turn our quiet places into biking resorts? (You may laugh, but this could easily be an outcome.) How would one allow mountain bikers in Forest Park, scaled for local use, but avoid economic programming leading to unchecked demand/growth?

More miles of trails and more sites means that volunteers would be spread thin. It's wishful thinking to have many sites and many miles of trails at each site all maintained by a finite number of volunteers. The 'many sites' is a result of the 'ride-to-my-ride' mantra. The 'many miles of trails' is what would make it worth riding to a given site. The prospect of a large pool of dirt digging volunteers is no justification for allowing mountain bikes into protected natural areas.

It's Common Sense — mountain bikes aren't compatible with Natural Areas

Photo from ORCMP document

Consider two mountain biking styles as described in the ORCMP...

Freeride (FR) Freeride bikes are typically more heavy-duty than All Mountain bikes, with more suspension travel to accommodate the bigger jumps, drops, and higher speeds. Freeriders might wear open face or full face helmets and are more likely to wear protective equipment including: knee guards, arm guards, and spine and neck protection as they are seeking out challenging terrain and technical trail features.

Downhill (DH) Downhill style riding builds on both Cross Country and All Mountain riding skills and emphasizes technical descending with highly varied terrain conditions. Riders often hike or shuttle by car to the top of the descents. Downhill Trails may include natural obstacles, steep slopes and rugged terrain including off-camber turns, dirt berms, jumps, rock drops, rock gardens, and other natural features.

These styles don't sound compatible with quiet nature! Full face helmets? I'm glad they are protecting themselves from running into trees, seniors, and children! We wouldn't want anyone to get hurt! Seriously, even gentle forms of off-road cycling could be injurious or disruptive to wildlife and hikers in natural areas. The Leave No Trace ethic literally says if nature is changing its behavior in response to your presence, you are too close ‐ Back off!

Downhill mountain biking has its place, but it's not about quietly enjoying a forest, or allowing the forest to remain relatively undisturbed. There is a fantasy that a single bike silently passing along a level trail does no harm. But what if that one bike makes ten runs that day, or if dozens of bikers make five runs on a Saturday? What if the trail is steep and downhill, and is mainly for thrill, with whoops and hollers? This is not Off-Road Cycling.

Who will speak for Nature?

What about nature? Does any one stop to think about the creatures? We need to be more sensitive, and not say the animals can just get used to our presence. Deer, coyote, raccoon, cougar, elk, and so on are all stressed by our greater and greater presence.

Mountain bikers have no special rights in natural areas. With bikes left behind, the able-bodied can access any area the same as anyone, on foot. Also in that regard, animal rights should supersede human rights in the natural domain. That's why access is limited to small groups, and no competitive sports are allowed. If bikes are allowed into River View and Forest Park, they will have crossed the Rubicon.

Wilderness Watch: Mountain bikes have their place, but that place is not inside Wilderness. At a time when wilderness and wildlife are under increasing pressures from increasing populations, growing mechanization, and a rapidly changing climate, the last thing Wilderness needs is to be invaded by mountain bikes and other machines.

Beware of the Mountain Biking Industrial Complex

The Public may not be so much aware that their land is under attack. Too much is going on in people's lives to follow every single assault, whereas the mountain bike industry and culture has mobilized and is being very aggressive pushing this through locally, regionally, nationally, and internationally. The Public is not so vigilant.

The Public is concerned that private sponsorship is creeping into city programs under budgetary stress:

• Corporations are offering to convert public property into purpose-built playgrounds.
• At a River View Natural Area Management Plan open house, a mountain bike parts wholesaler offered to bankroll the construction and maintenance of all trails in RVNA!
• Some staff and land managers are mountain bikers. Without policy-level protections, staff actions (in offices and in the field) may be influenced by their riding and digging friends. For example, a trail manager suddenly left the parks department after being caught leading unauthorized mountain bike trail work in RVNA.
• Portland Public Schools is establishing sport clubs for mountain biking, with industry sponsorship. These mountain bike teams do not need to shred our protected natural areas, or Forest Park.

The MTB industry strategy is to push for access everywhere, in the hopes of gaining access to as many places as possible. Our national wilderness areas are also under attack.

A Little Perspective: Our Portland Heritage → Our Future Legacy

The Olmsted brothers, who envisioned Forest Park in 1903: This place of wild woodland characters should be intended only for passive recreation, for mental refreshment, which can only be derived from the quiet contemplation of natural scenery.

Thornton Munger, the first chair of the Committee of Fifty, appointed by the City Club to create Forest Park: The wilderness within a city is not a place for speeding; there should be no need for haste... it is hoped that the feeling of an extensive, uninterrupted forest sanctuary may be preserved.

PP&R's website on The Future of Our Park System: Parks, natural areas, playgrounds, and community centers are integral to the city's quality of life — they are places to unplug from technology, revered lands passed down from generation to generation, and an important source of low-cost, healthy activity and recreation.

Action items for Portland City and Metro Councils

1. Today: Remove River View Natural Area and other natural areas from consideration as mountain biking sites, permanently.
2. Tomorrow: Review guidelines pertaining to approved and restricted uses of developed parks vs natural areas.
3. Tomorrow: Separate the management of Natural Areas from the management of Recreation Areas. Make a clear distinction between the two management units.
4. Always: Resist the Mountain Biking Industrial Complex. Affirm a commitment to keeping the wild parts of our city and region wild, including our crown jewel, Forest Park.

The season to act is Now. Monied interests will not let up, unless legal frameworks are put in place.

John Miller is a retired computer scientist living in Southwest Portland. His interests range from transit systems, to stained glass, to recreational mathematics. He lives 2 kilometers from River View Natural Area in Southwest Portland, Oregon..

The Oregonian and The Intertwine have published John's OpEds regarding mountain bikes invading urban natural spaces.

John served as chair of his neighborhood for eight years, as secretary and president of Southwest Neighborhood Inc, as secretary and chair of the Multnomah County Citizen Involvement Committee, and as the only citizen member on Metro's Regional Urban Growth Goals and Objectives PAC. John was lecturer and system co-ordinator at Lewis & Clark College (25 years), and was System Architect for Metro (13 years). Since retiring, John has volunteered with Cycle Oregon, and with Travel Portland's Visitor Information Center. John writes here out of concern for the natural world. He has an ancient StumpJumper bike with fat tires.

APPENDIX I: Specific Problems with ORCMP Proposal's RVNA Recommendations

The ORCMP recommends: Continue the interim prohibition of off-road cycling until sustainable trails are identified or developed.

My Response: The prohibition should be made permanent for reasons given here. Do not allow this to go unresolved.

The ORCMP recommends: Complete detailed alignment planning and trail design for the natural surface trail loop described in the River View Natural Area Management Plan's Access and Management Concept as a model of a safe and sustainable shared-use trail, for cross-country off-road cycling, walking, running, and enjoyment of nature.

My Response: Negative. This was obviously written by an industry lobbyist! The Site Filter technically and legally should have eliminated RVNA as a potential mountain bike site. In order to protect it for all time, a Conservation Easement was placed on RVNA. This is a legal deed signed by Metro, the City of Portland, and the State of Oregon. If you don't know about, see the Links section below.

The ORCMP recommends: As part of the trail design process, estimate the anticipated levels of use by pedestrians and off-road cyclists. Use these estimates to inform trail design, construction techniques, and management strategies, including the designation of trails as shared- or single-use.

My Response: No! This is unnecessary data mongering. Bikes should be prohibited in order to protect natural areas. Hiking should be limited as well. From a hiker's perspective, sharing a trail means: Always be on the guard, ready to step off the trail to allow passage of a bike; Protect small children on your hike; Listen for any down-coming flying machines — chains rattling, braking, shifting.

The ORCMP recommends: If the City cannot identify a sustainable shared-use trail alignment that is consistent with best management practices while meeting site objectives, evaluate alternative approaches and management strategies (such as directional designations, time- and user-based restrictions).

My Responses:

• This is a moot point, since cycling should not be permitted in natural areas.
• Alternate Days or directions? Much of the year is muddy, when all trails would be closed. When open, let's say it rains on the Tuesday you want to Bike but then the next dry day is scheduled to be a Hike day. I think this alone would lessen interest in such places, especially if a hiker/biker shows up and finds the other class of user on the trail for whatever mistaken reason. There would be enforcement problems. Bikers claim that there are no such problems elsewhere in the world.
• Alternate Days could concentrate biking into two weekdays and one weekend day (maybe leave one day where trails are closed to all uses?) Presumably, those days might see mountain bike use doubled up and disturb wildlife twice as much.

APPENDIX II: TIMELINE (DRAFT!)

Previous Bike Plan
Forest Park Trails and trail building
River View trespassing
RVNA Purchase 7/2011
RVNA Management Plan [RVNAMP]
Cycling Restricted 3/16/2015
RVNAMP Approved 1/14/16 (with Steve Novick amendment)
ORCMP started
ORCMP ended after 14 meetings

APPENDIX III: LINKS

• Portland's Off-Road Cycling Master Plan [LINK]
• River View Natural Area Conservation Easement (7/22/2011) [LINK]
• Leave No Trace, Principle 6: Respect Wildlife [LINK]
• Sierra Club Policy on Bicycles [LINK]
• Environmental Impacts of Mountain Biking, International Mountain Biking Association [LINK]
• Let Forest Park remain Portland's sanctuary, Mike Lindberg, Oregonian OpEd [LINK]
• Mountain Bikes don't belong in Natural Areas, John Miller, Outside Voice, Intertwine [LINK]
• A Case Against Mountain Biking in Natural Areas, John Miller, submitted to Oregonian, May 2017, but was not run because 'Too much news was happening on the national scene' i.e. Trump. [LINK]
• Will Mountain Bikers Overwhelm Protected Natural Areas?, John Miller, Oregonian, Jan 2016, [LINK]
• Mountain Biking and Wilderness, George Wuerthner, February 9, 2018 [LINK]
• Mountain Biking Is Inappropriate In Wilderness, George Wuerthner, Earth Island Journal [LINK]
• Wilderness is conservation gold standard, George Wuerthner, February 10, 2018 [LINK]
• Why Mountain Biking is Inappropriate in Wilderness, George Wuerthner, July 12, 2014 [LINK]
• Gateway Green, a 25-acre former Multnomah County jail site [GG]

APPENDIX IV: My 'two-minute citizen' comments at Portland Parks Board Meeting.

(Nervously, after some confusion over when or if I would comment!)

You've heard from others:
   about Danger to hikers
   about Equity Issues
   about "S.C.O.R.P."
   about the protections placed on Forest Park
   and so on

You may Not have heard about Metro's immutable Conservation Easement covering River View.
Or that Parks is not the sole owner of the property.
(Parks /is/ charged with managing the natural area...)

You may have heard about a MEMO that BES (a co-owner) filed with the ORCMP
advising /against/ cycling in River View.
So, if Parks continues with the plan as is, we can expect it to play out in court!
That would be crazy.

You have may heard things like

"Everywhere else, mountain bikes are allowed without any harm",

and that

"Portland is basically stupid for not 'getting' that".

But Portland ISN'T 'everywhere else'.
We didn't build the Mount Hood Freeway.
We didn't Fluoridate Bull Run.
And we don't need to allow MOUNTAIN BIKES (shouting! LoL) into our Urban Natural Areas.

Arguments about trail design, Stewards, Little kids (feel good issues) are irrelevant,
because this is about Nature, not about Bikes.
It's about Nature, not playgrounds.

In my written comments (waved paper) I am calling on policymakers to settle this,
so that we can get on with our lives and perhaps go visit nature here in the city,
without the machinery around (as Mike Lindberg has said).

I will give similar comments to City Council when the time comes.

I'm hoping that the city can set this straight (what ever I said) NOW.
If not, Bikers will assume they have won, and they will be back in there in force.
They are salivating over these areas now...
We spotted 8 riders all in a row, in River View, just this morning!

This paper is on line @ address given, including the remarks I just made.
There are Appendices that aren't printed on paper.

Thanks.

APPENDIX V: NWTA is salivating over RVNA, Forest Park, ...

APPENDIX VI: John Miller's Nextdoor post on ORCMP

The ORCMP may go Off Road into our protected natural areas [LINK]

APPENDIX VII: Before West Multnomah Soil & Water District Board, 5/9/2018

What I want to advise you is to BE AWARE. Many of these properties you are hearing about have protections on them. For example, River View Natural Area is owned by a consortium, and Metro owns a Conservation Easement over it.

With regard to the Off-Road Cycling Master Plan (Where they are siting MTB parks all over the area) Metro has said that Mountain Biking is Nature-Based, and they think it can be done consistently within the conservation easement. We have asked Metro for an LEGAL explanation of what they mean by that, and we are still waiting for their response.

River View is a registered USDA Research Area. How does that work, with bikes running circles around a 147 acre natural area? Be very skeptical of anything that government (staff) tells you about the impact of mountain bikes! (There is no formal policy on these matters.) Thank you.

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