The US Forest Service is considering expanding the use of E-bikes in the Tahoe National Forest. Without further agency analysis in the form of an Environmental Impact Statement, this expansion could significantly affect wildlife in the area, including several of California's mule deer herds.
Read our official comment below:
On behalf of the California Chapter of Backcountry Hunters & Anglers (BHA) and the organization’s several-hundred thousand supporters, we thank you for the opportunity to provide scoping input related to the potential effects of the proposed action regarding the introduction of Class 1, pedal-assist E-bikes on the Tahoe National Forest E-Bike Trail Designation Project (the Project). Wild public lands are an indispensable part of who we are as sportsmen and women, and so we are especially thankful for the collaborative partnerships we build with the agencies who manage those lands.
BHA aims to ensure North America's outdoor heritage of hunting and fishing in natural settings through education and work on behalf of wild public lands, waters and wildlife. The California Chapter of BHA (CA BHA) is dedicated to fulfilling BHA’s mission in the golden state to maintain California’s legacy of hunting and fishing on wild, intact lands and waters for future generations. Recognizing the pressures of a growing population and advancing technology, CA BHA champions the strict enforcement of non-motorized designations and promotes responsible recreation practices to protect these precious public lands.
Founded in 2004, BHA represents sportsmen and women across North America, advocating for public land policies that reflect the values of hunters and anglers, and ensuring that the Wilderness Act of 1964's intent is upheld. Our ability to hunt and fish is intrinsically linked to the preservation of habitat. The profound connection we experience while hunting in the backcountry or fishing on remote rivers fosters a deep respect for conservation. Protecting non-motorized areas is vital to maintaining these unique experiences for future generations. In a world increasingly encroached upon by development and motorized recreation, it is imperative to defend these wild lands from motorized intrusion to preserve the authentic connection to nature that defines our outdoor heritage. By safeguarding unfragmented habitats, we ensure that the freedom, challenge, and solitude of true backcountry hunting and fishing remain available for all to enjoy.
CA BHA stands firmly opposed to motorized use in designated non-motorized areas. These areas, set aside for their wild qualities and the opportunity they provide for solitude, are vital for the conservation of our natural landscapes and wildlife habitats. As stewards of the backcountry, we believe that maintaining the integrity of nonmotorized areas is essential for ensuring that future generations can experience the same unspoiled beauty and tranquility that we enjoy today. Motorized vehicles disrupt wildlife, degrade trails, and erode the quiet and peace that these areas are meant to offer.
Currently, the Tahoe National Forest has designated 103 miles of non-off-highway vehicle trails as open to Class 1 E-Bikes (80 miles currently existing and available for use and 23 miles yet to be constructed). The project proposes, under the guise of better meeting the demand for “quality opportunities available to E-Bike riders across the Tahoe National Forest”, to designate up to an additional 143 miles of non-off-highway vehicle trails as open to Class 1 E-bikes. Of the 143 miles of trail, some of which are currently open, some of which are under construction but approved, and some of which are in need of maintenance to be useable, not a single mile is open to motorized usage. The allowance of E-bikes, even restricted to Class 1, on these trails would have significant negative impacts on the region's wildlife. E-bike usage, and the resulting increased volume of people using the trails with E-bikes, would be particularly harmful for the region’s larger game species.
We are concerned that the reclassification of non-motorized trails to motorized use via the allowance of E-bikes will lead to further expansion of illegal motorized use and the proliferation of illegal user-created routes into the backcountry, compounding the existing impacts on wildlife habitat within the project area. CA BHA, and our thousands of members across the state, respectfully but strongly recommend the Forest Service conduct additional analysis of the existing nonmotorized system trails within the project area, the historical context for their creation, and their cumulative impacts on wildlife through the creation of a full Environmental Impact Statement before a final decision or modification of this proposal is made.
Below we outline our major points of concern with the project’s E-bike proposal.
E-bike caused impacts to wildlife:
1. Given the amount of overlay with important wildlife habitat inside the proposed project area, we believe that a full EIS should be completed for the entire project area. Simply stated, the introduction of e-bikes is not aligned with the protection of these areas and the intensification of use would further exacerbate impacts to ungulate winter range and overall ecosystem integrity. The increased likelihood of off-trail activities would further compromise the importance of riparian areas and the surrounding habitats for maintaining connectivity. Furthermore, opportunities to reduce the existing habitat fragmentation from motorized route designations, which this proposal expands, should be evaluated and analyzed to promote the minimum road system per the Forest Services’ own Travel management Rule.
2. The technology of e-bikes is so new and emerging that we currently lack sufficient research to confidently assert that e-bikes do not have an impact even greater than mountain bikes, which already have a negative impact on wildlife, especially big game species. Simply put, we do not know and there are too many assumptions in this EA to take such a large risk. Recreational impacts on wildlife, in general, are relatively understudied. But the existing studies that do exist, do show that recreation significantly impacts wildlife. When we narrow the focus specifically to e-bikes, the available literature becomes even more scarce. In the end, our local wildlife populations are once again taking a back seat to recreational interests. Shouldn't we "learn to swim" before "jumping in the water"?
3. The trails proposed to be opened to E-bike use are extremely close to known wildlife connectivity corridors. (Exhibit 1) Additionally, these proposed trails either bisect or are adjacent to the migration corridors of multiple mule deer herds (Exhibit 2) Indeed, one proposed E-bike trail, just north of Washington Ridge, is directly in the winter range of a mule deer herd (Exhibit 3). While we have mentioned an overall lack of research concerning the effects of E-bike usage on native wildlife, research that has been done on the impacts of recreation to native wildlife suggests that recreation, particularly louder forms of recreation, do significantly impact the behavior of animals, and their distribution over a given landscape. It stands to reason that class 1 E-bikes, which will allow a greater number of people to move at even higher speeds through the backcountry, will significantly impact wildlife behaviors if allowed on currently non-motorized trails. Because of the proximity of the proposed trails to the migration corridors of multiple mule deer herds, an EIS must be conducted by the agency to appropriately analyze the possible impacts of E-bike usage to wildlife before E-bike use can be allowed to expand in the Tahoe National Forest.
Expansion of motorized use into non-motorized backcountry areas:
1. Based on our understanding, there is currently a lack of focus for enforcement of illegal e-bike use on non-motorized trails, and we have concerns that this will continue if the proposal is adopted.
2. Based on current technologies, we see no existing or proposed framework that would allow enforcement officers the ability to distinguish between the different classes of e-bikes. The distinction between classes will only continue to become more difficult as designs, technology and software continue the trend of advancement, blurring the visual characteristics between classes of e-bikes even more than already exist and setting law enforcement up to fail. The allowance of Class 1 e-bikes will already bring significant impacts to non-motorized backcountry trails. The likely use of Class 2 and 3 e-bikes, and the difficulty in enforcing regulations will further exacerbate these impacts. An analysis, via an Environmental Impact Study, needs to be conducted before the public and the agency can gain a clear understanding of how this distinction could be differentiated by law enforcement.
3. It is our understanding that no additional law enforcement personnel would be provided or budgeted for as a part of this proposal. Given the proposed novel use, and current levels of enforcement of observed illegal use, we have concerns how existing law enforcement officers will be put in an impossible scenario of nearly unenforceable regulations.
4. Based on current illegal use of e-bikes within the non-motorized system of trails within the Tahoe National Forest, including the current and historic disregard for signage and nonmotorized trail designations, we have concerns that illegal behavior is likely to continue, especially without additional enforcement. This pattern of abuse will likely provide a gateway to the backcountry, puncturing this novel motorized use further into off-system, non-motorized trails. A full EIS should be required to analyze potential impacts of motorized trail use anticipating the expansion of illegal use beyond the trail networks included in this proposal.
Exhibit 1 - Wildlife Connectivity over Proposed E-Bike Trails:
Exhibit 2 - Mule Deer Migration Corridors over Proposed E-Bike Trails:
Exhibit 3 – Washington Ridge Winter Range: