by: Friends of Bidwell Park
Re: Comment on Draft Bidwell Park Master Management Plan and Environmental Impact Report
Many Friends of Bidwell Park (FOBP) volunteers have participated in trail maintenance and in the public trail planning sessions that started six or seven years ago. It's almost astonishing how little has been accomplished in the last six years. We're still at the point of "making a plan to make a plan." There was general agreement throughout the trail planning public process that the focus needed to be on improving the park's existing trails, rather than building new trails. Except for the Park Division's and volunteer work on the western segment of the Middle Trail and the work that the Chico Mountain Bikers have done on the Maidu Trail, all of the park's official trails continue to deteriorate, some of them severely. Bootleg trail construction continues unabated, especially on the south side of Upper Park. This is unlike the situation for the park's vegetation management program, where park staff, FOBP, CNPS and other groups and individuals who have an interest in improving the park's vegetation have not only created a usable vegetation management plan, but are implementing it (albeit slowly due to funding and volunteer constraints), with measurable annual goals.
FOBP believes that upgrading the Middle Trail in Upper Park to become an all-weather trail, usable year-round by walkers, bicyclists, equestrians, joggers, and hikers, should be a high priority. We also think that much more attention needs to be paid to closing and revegetating unauthorized trails throughout the park.
Although the disc golf project is supposed to be linked to a trailhead project, no information is provided in this section regarding hiking/biking trails in that area, nor does the Disc Golf Project Appendix H provide that information. Please provide a map showing the hiking/biking trail(s) that will be created at that site and provide a discussion in the EIR of any potential impacts from the creation of that trail(s). How many feet of new trail will be created by this project?
Based on a review of the Upper Park trail map (Exhibit 2), this plan does not appear to address the severe erosion problem that exists near the eastern end of the Upper Trail where the trail dips down through a steep ravine before veering south to connect with the Middle Trail. An alternative trail routing was mapped by park staff and members of the public and should be considered as part of the trails management plan.
The plan and map (Exhibit 1) does not show the north bank creekside trail in Lower Park where severe erosion is taking place along some segments of the trail.
"The planning process used during the preparation of this Trails Plan for Bidwell Park is illustrated in Exhibit 3." This statement is not true, even considering the disclaimer sentences that follow. As park volunteers who participated fully in all trail planning meetings (both before and after the creation of FOBP), we do not believe that this plan process sequence was followed. Many steps were omitted or done out of sequence (and of course, we're currently only about halfway through the process).
In paragraph 4, for most of the "key locations" included in the "limited field review", no information is provided as to what solutions the surveyor proposes for these "key locations." All of these "key locations' were identified as problem areas many years ago during the public trail meetings. What we need now are solutions. Also, no indication is given as to what type of qualifications this trail surveyor had—was this person a trail builder, a soil scientist, a biologist? What did this person know about local vegetation and soils?
Please explain the need for an "equestrian only" trail in Middle Park. Will this be an all-weather trail? How will cyclists and walkers be kept off this trail? In the past, all park trails have been multi-use, except where there were environmental constraints that necessitated limiting their use, e.g. Yahi Trail. What such constraints exist in this area?
The middle photo shows the Yahi Trail as it approaches Diversion Dam, which is not a swimming hole.
"The City should make its stand clear on unofficial mountain biking trails." There is a clear policy regarding the creation of new park trails by members of the public—they're not allowed. Unfortunately, there's no enforcement of this policy and, once created, there's no incentive to eliminate them and remediate the damage.
The middle photo appears to show the Middle Trail, not the North Rim Trail.
Although equestrians are already allowed to ride on south-side trails, the current condition of these trails precludes much usage by equestrians. When these trails are finally brought up to the Trails Manual standards (as FOBP hopes they will be), their usage by equestrians is likely to increase. Please explain what will be done to assess and possibly mitigate for the increase in equestrian traffic, whose likely impacts include increased soil erosion, increased infestations of invasive plants, and possible trampling of special species plants. Will the Park Division provide a regular patrol of the trails on the south-side? How will the wet-weather equestrian (and cyclist) trail usage prohibition be enforced in this more remote area?
Currently dogs are required to be on leash on the south side of Upper Park, but there is no enforcement of this law and, in fact, it is unenforceable, due to the remoteness of the trails here. Most of the dogs seen on the south side by FOBP during many visits to this area were off leash. The EIR does not include any discussion of the potential impacts of off leash dogs on the south side, especially to wildlife. Please discuss this problem and what mitigations would be appropriate.
A fire in Middle Park several years ago exposed one of the park's prehistoric sites to public view, where previously it had been hidden by dense vegetation. One of Middle Park's trails is directly adjacent to this site. Please explain how the mitigation measures described in this section would have been applied to protect this site from degradation. Would the existing trail be moved?
All of these objectives and implementation strategies require a significant amount of increased funding for park maintenance staff. Since the permanent park maintenance staffing levels have not been increased in about 20 years and there appears to be little or no public support for future increased staffing levels, the measures described here are extremely unlikely to be implemented. Please include a discussion of how these measures might be implemented without any increase in funding for park staff.
In particular, please discuss how the problem of the creation of new, unofficial Upper Park south side trails will be solved, considering that there's no regular park presence along trails on this side of Upper Park.