Environmental reviews: turn your leaf and cough

What environmental factors could be lurking here?

Its human nature to assume the things we like or accept as normal don’t have a large negative environmental impact.  Things we don’t consider to be that big of a deal can have huge effects, like man made clothing materials or earthworms.

Years ago, there was a video by an environmental group that involved a young mother who returned to an area where forest thinning operations had taken place and complained about how it was a travesty to have any logs cut.  Like a certain commercial from the 1970s, a tear literally did run down her cheek.  Yet, she explored this area wearing a North Face puffy jacket made with polyester and stuffed with dacryon.  Do you think she knew the difference in impacts she was illustrating?  That area of forest would be back to its old self in her lifetime.  Within her children’s lifetime that section of forest could be considered “old growth”.  Her jacket would pollute the environment for the next three hundred years (at a minimum).  The infrastructure required to create the materials of that jacket, i.e. petroleum, and ship them to factories and then to stores in her area directly destroyed hundreds of times the forests than the thinning operations.  The carbon released by all this shipping threatens every forest on the planet, which, if the math is right, is much larger than the forest she shed tears over.
​
Can we, as mountain bikers, find ourselves in a similar Catch-22?  Can we overlook a large impact that is front of our nose?  How can we quantify existing conditions at a site before creating trails?  Is there a way to quantify conditions after creating the trails?

​Reviewed for your safety

In the United States, most of the structures for environmental review were set up by the Environmental Protection Agency (EPA).  The EPA has been given the responsibility to codify the process of reviews under the National Environmental Policy Act (NEPA).  Under NEPA, reviews are designed to either alert the public to potential environmental impacts, allow elected officials to know what could be expected and/or create the frame work to flag projects with an undo impact on the environment that could be rejected, modified or reduced in scope.  The idea behind this rejecting, modifying or reducing impacts was always less about stopping a project and more about getting the project to be done in a less impactful way.

Because of this, almost all the environmental review methods in the United States are based on the premise that a person or persons is going to quite literally, “pave over paradise and put up a parking lot”.  In other words, they assume industrial level impacts.

Essentially, there are 4 types of environmental review in the United States.  Note that some states have their own version of these reviews and some call them slightly different names.  From the least amount of review to the greatest, they are:

• Environmental assessment (EA) – Think of this as a basic, “What the heck is here?”, report.  The purpose of this assessment is to quantify the current environmental conditions on a site.  It also will report if there are any current or historical reasons to believe there are negative environmental conditions, like leaking fuel tanks.
• Environmental site assessment (ESA) – These are basically “cover your ass” reports created for commercial or industrial mortgages and are primarily concerned with the environment in the sense of legal liability for contamination or cleanup.
• Environmental assessment worksheet (EAW) – An EAW is a report that is in the form of a set of standard questions that must be answered regarding existing conditions on a property or properties.  These often include some level of information of mitigations for a project or avoidances.  These will require public comment periods.
• Environmental impact statement (EIS) – The big kahuna of the reviews and can only be required to be done after the submittal of an EAW.  This level may require studies on existing conditions and on proposed remedies.  These will require public comment periods and often are the subject of lawsuits as the projects are large; pipelines, mines, etc.

As mentioned above, all these reviews were designed with assumption that a large project would be proposed for some commercial or industrial purposes.

If you are wanting to create urban mountain biking trails in a city park, natural area, urban wilderness or some other property, it’s likely that a review is warranted.  If you find yourself saying, “But we don’t want to do an environmental review because we might not get trails here,” it’s largely because you view “environmental reviews” as something based on anti-mountain biking nonsense.  While there can be some of that, as “environmental factors” are often a way to greenwash NIMBYism, there is a difference between real science and the pseudo-science of anti-mountain biking.

Here is the rub of environmental reviews, however: they assume you wanting to do one for large impacts, so the method of review is designed to look for and focus on the impacts, not the existing conditions.  Because of that, all these forms of review pay too little attention to existing conditions and ask leading questions designed to make any impacts seem like you are going to nuke the property.  This makes sense if your plan is to put in a shopping center or car dealership.  It makes less sense when you are putting in trails that will be less than 42” in width.

Because of that assumption of impact, if you are starting the process of inquiring about urban mountain biking with a city, its best to ask upfront what review requirements they have and what might be suggested.  One thing that should be done as part of any review process is an existing ecological health report, a type of report that is part of the NEPA report system, but can be done as form of voluntary review.  These are similar in size and scope as an EA but concern themselves exclusively with the existing ecological conditions, not any assumed commercial or industrial impacts.  Even if the city or land manager doesn’t require this, you should do it.  It will show that your mountain biking club is concerned about the environment and shows you take potential impacts seriously.

There are environmental firms that can do this, though they aren’t cheap.  The average cost of these reports is between $2,500 to $10,000.  If there is a college within your town that has an applied biology class, these can often be done by students as a class project.   Professors, especially those that do undergraduate study programs, love these types of projects.  They remove workload of the professor and give the students a taste of the real world.  If you don’t need this type of report immediately, these are often available through colleges for the high price of going and talking to professor and students.

One thing to specifically request with these types of reports is a GIS based conditions map, often called a “blob map” of the site.  These are usually drawn in stoplight colors (red, yellow, green) that show the relative sensitivity and land cover of the property.  They also may delineate streams, wetlands or swamps on site.  This information will be important when it comes time to design trails, as you can then route them into areas with low sensitivity to and avoid areas with high sensitivity.
​
These reports can also help with the public outreach for trails as you will have a full report that provides a ground truth to your project.

​Annual checkup

But constructing is just the first step.  It’s in the usage that any real impacts will occur.  It’s always a good idea, especially for the first trail system in a town, to monitor the conditions at the trail system.  How can this be done?

The simplest method is to work with the land manager and a local college or interns to create a weekly set of photographs (all geotagged) and reports of any negative conditions of on trail or impacts to the park.  These would include silting, erosion, invasive species, damaged plants, etc.  At the end of the year, these weekly reports can easily be compiled for a report.  Geotagging is important as this will tie the photos to locations along the trail or in the park.

If the land manager or your club can’t make monitoring happen with a third party, use existing trail management databases to do something similar.  Trailforks allows not only reports of trail conditions, but reports of issues at points with geotagging.  Not only is this helpful for sending out maintenance volunteers, but Trailforks allows these points to be exported as a CSV file for quick import into a Google Sheet or Microsoft Excel.  You can also import these files into Google Earth Pro and create maps with points. This will allow you to see problem locations or areas that are needing more maintenance than other locations.  Clustering of points might indicate soil or runoff issues.

​Keep it green

​When preparing to create an urban mountain biking trail, remember to focus on the ecology from the start.  Here are steps you should take:

• Ask the land manager/city if there is to be an environmental review and if so, what type
• Always do an ecological health report, whether or not the land manager or city wants one; this will give you a good basis in designing the trails and will prevent antis from claiming the last population of velociraptors live in that park
• Monitor the site after construction to find areas than might need work and to provide a ground truth basis to get access to more sites in town or allow other towns to use your data to help them have urban mountain biking
• Use geotagging of photos, or better yet, specific trail reporting databases like Trailforks and free GIS software like Google Earth Pro to give you a clue of where the trails might be having issues

When figuring out what the game plan should be for your urban mountain biking project, don’t forget environmental reviews.   

Velociraptors are native to every location you want to have mountain biking trails, but not hiking trails. Its a little known fact.