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. 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. 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.
Addison Oaks Trail Riders
Allegan County Pleasure Riders
American Endurance Ride Conference
American Hiking Society
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.
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
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
 Class 1 has the smallest motor and battery and a “pedal-assist” engagement system; class 2 has similar motor and batteries sizes but includes a traditional throttle “twist-assist” engagement system; and class 3 has a larger motor and battery size and a pedal engagement system.
 See Executive Orders 11644 and 11989; 43 C.F.R. part 8340; 36 C.F.R. part 212.