March 22, 2017
The Honorable Rob Bishop, Chairman; and
The Honorable Raul Grijalva, Ranking Member
House Committee on Natural Resources
1324 Longworth House Office Building
Washington, D.C. 20515
Dear Chairman Bishop and Ranking Member Grijalva:
I am writing to you on behalf of over 1,170 members of the Coalition to Protect America’s National Parks (Coalition). As a group, we collectively represent more than 30,000 years of national park management experience. We believe that our national parks and related public lands represent the very best of America, and advocate for their protection.
The Coalition strongly opposes H.R. 1349, a bill that would amend the Wilderness Act of 1964 (the Act) to authorize the use of non-motorized wheeled vehicles and devices, including bicycles, in designated wilderness areas. The legislation, as proposed, would reverse longstanding prohibitions on the use of bicycles in wilderness and is in direct conflict with the stated purpose and intent of the Act, as stated in Section 2(a) of the Act:
In order to assure that an increasing population, accompanied by expanding settlement and growing mechanization, does not occupy and modify all areas within the United States and its possessions, leaving no lands designated for preservation and protection in their natural condition, it is hereby declared to be the policy of the Congress to secure for the American people of present and future generations the benefits of an enduring resource of wilderness (emphasis added to underlined sections above).
The intent to limit “mechanization” was more specifically addressed in Section 4(c) of the Act, which states:
(c) Except as specifically provided for in this Act, and subject to existing private rights, there shall be no commercial enterprise and no permanent road within any wilderness area designated by this Act and except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area (emphasis added to underlined sections above).
The plain language of Section 4 (c) clearly distinguishes between “motors” and the broader category of “mechanization.” It specifically lists and prohibits five distinct categories of mechanical transportation and equipment, including “motorized” forms of transportation and “other forms” of mechanical transport. Despite this, mountain bike advocacy groups claim that wording in the Act is ambiguous with regard to bicycles and that the federal land management agencies with wilderness management responsibilities have misinterpreted and misapplied this section of the Act. The Coalition contends that such claims are not supported by the substantial administrative history of the issue.
While we are opposed to opening wilderness to bicycles, we support the well accepted exception allowing the use of wheelchairs to provide people with disabilities the opportunity to participate in wilderness experiences. Such use is consistent with the Americans with Disabilities Act of 1990 and National Park Service Management Policies 2006 Section 6.4.10.
The longstanding prohibition of bicycles in designated wilderness is not merely an agency’s interpretation (or misinterpretation) of the Act. Modern mountain bikes were not invented until many years after the passage of the Act and legislators could not have reasonably foreseen and therefore explicitly prohibited “mountain bikes” when the Act was passed in 1964. Despite this, the National Park Service, U.S. Fish and Wildlife Service, and Bureau of Land Management have consistently prohibited the use of bikes in wilderness since the late 1960’s. And, while the U.S. Forest Service initially interpreted Section 4(c) of the Act to allow the use of bicycles in National Forest wilderness, the Forest Service reconsidered its policy and revised its wilderness regulations in 1977 to expressly prohibit the use of bikes since then. Key to this decision by the four primary Federal land management agencies is that many thousands of miles of trails and an almost infinite variety of landscapes throughout the United States outside of designated wilderness are now available to mountain bike enthusiasts.
We urge attention to the contrast between bicycles in the 1960’s and the advanced technology that is characteristic of most mountain bikes of today. Through the use of strong lightweight space-age materials and advancements in bicycle technology, including special suspension systems and advanced gearing, mountain bikes now are highly efficient non-motorized vehicles. Mountain bikers today are fully capable, if allowed, of accessing and thus impacting even the most remote and rugged wilderness locations in America.
For over 50 years, the Section 4(c) provisions have guided decision-making that protected America’s wilderness areas from the harmful impacts, both ecological and social, of bicycles in places set aside for non-mechanized forms of travel. To reverse this longstanding protection now, when the popularity of backcountry mountain biking is at all-time high, would be a very harmful precedent that would pave the way for proposals for other exceptions to wilderness protections, each supported by their own special interest group(s). Such a precedent is not only in conflict with the intent of the Act, it would inevitably generate controversy and hostility among traditional wilderness users and result in tremendous pressure on wilderness management agencies to prepare costly and time-consuming revisions of existing wilderness management plans and regulations. Much worse, it would inevitably lead to the derogation of the wilderness character of these special places.
In closing, in 1964 the Wilderness Act endures as a unique and increasingly valuable decision by Congress to preserve the wildest and most treasured natural places in America. The Act, as written, has withstood the efforts of groups and individuals to compromise the integrity of these wild places for more than 50 years, and should continue to do so. We urge you to support the longstanding prohibition of bicycles in designated wilderness and step away from this ill-advised legislation.
Maureen Finnerty, Chair
Coalition to Protect America’s National Parks
cc: The Honorable Tom McClintock, Chair, House Subcommittee on Federal Lands
The Honorable Colleen Hanabusa, Ranking Member, House Subcommittee on Federal Lands
Michael Reynolds, Acting Director, National Park Service