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    Oregon Equestrian Trails Public Comment to BLM Proposed E-Bike Regulations

    Re:  RIN 1004-AE72, Increasing Recreational Opportunities Through the Use of Electric Bikes
    I am submitting these comments on behalf of the members of Oregon Equestrian Trails, a 501(c)3 non-profit that builds and maintains trails in Oregon and works to ensure that public lands remain open to recreational equestrian use. 
    We oppose the proposed regulation allowing e-bikes on non-motorized trails, RIN 1004 -AE72, for the following reasons:

    1. The regulation is not needed.  A mechanism already exists by which e-bikes can become an allowed use on non-motorized trails.  If a regional director thinks a trail is suitable for e-bike use, he can go through a NEPA public process to change the designated use of that trail from “non-motorized” to “non-motorized + e-bike.”  The current rule-making is unnecessary.
    1. Increased access is not needed:  E-bikes already have access to BLM lands via thousands of miles of roads and trails that are open to motorized use.  There is not a pressing need to open non-motorized trails to e-bike use.
    1. E-bikes use will exacerbate trail over-crowding and jeopardize the safety and enjoyment of other non-motorized trail users.  Many non-motorized trails are already over-crowded, and adding e-bike riders to the mix will create even more congestion.  Conflicts between fast-moving mountain bikes and slower-moving hikers and horseback riders are already a serious problem.  Allowing fast-moving e-bikes on the trails will exacerbate these conflicts and further marginalize the hikers and equestrians whose safety and enjoyment are in jeopardy. 
    1. The current rule-making does not consider the impacts e-bikes will have on wildlife, habitat, and other trail users.  A programmatic NEPA review is needed to evaluate the proposed rule, per guidance from the Council on Environmental Quality.  The current rule-making ignores the extensive body of scientific research that is available on e-bike use.  A review of this research reveals that e-bike riders travel faster than mountain bikes, and crashes involving e-bikes result in more severe injuries than those involving mountain bikes. Further, studies have demonstrated that e-bikes are less maneuverable than mountain bikes, so significant trail modifications are necessary to safely accommodate e-bike use, especially when other types of trail users are present. These studies need to be fully considered before non-motorized trails are opened to e-bike use.
    1. The proposed rule does not contemplate the impact of technological advances on future e-bike use. The e-bike of today is heavy and expensive, with a short-lived battery.  It appeals primarily to older, more risk-averse individuals who ride conservatively.  However, future e-bikes will likely be lighter and less expensive, with longer-lived batteries, making them attractive to a younger and more athletic demographic that may engage in activities that damage the natural resource and put other trail users at increased risk. 
    1. It isn’t possible to enforce the requirement that e-bikes be allowed only when “they are not being propelled exclusively by a motorized source.” Once e-bike use is permitted, the rider will be free to ride the e-bike in a manner inconsistent with the intent of the rule – a manner that jeopardizes the safety and enjoyment of other trail users.
    1. We are in the midst of a worldwide crisis that is risking the health and livelihoods of millions of Americans.  The e-bike ruling deserves a robust public process – something that isn’t possible during the COVID-19 pandemic.  The e-bike ruling is not an urgent matter. We urge you to postpone this rulemaking process until after the threat to public health has passed.
    In summary, we oppose the proposed rule because it ignores available science and disregards the impact e-bikes would have on other trail users and wildlife.  Pursuing this rulemaking during a national health crisis is irresponsible. And the proposed rule isn’t even needed, because BLM’s regional directors can already utilize a NEPA process to determine whether to allow e-bikes on any trail.
    Kim McCarrel
    VP of Public Lands
    Oregon Equestrian Trails

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