**THEODORE A. SNYDER, JR.**

**P.O. Box 40**

**Walhalla, S.C. 29691**

**864/638-3686**

18 January 2009

National Park Service

36 CFR Part 4

RIN 1024-AD72

Proposed amendments to Current Regulations

For designating bicycle use on National Park

Service (NPS) lands

Gentlemen:

I am opposed to the proposed Rule change that would permit
superintendents of Park units to allow bicycle use on hiking and horse
trails, and under certain circumstances on new trails. I urge you to
retain the existing Rule as it currently exists.

My reasons are as follows:

1\. Uniformity. If individual superintendents are allowed to designate
trails for bicycle use, there would be a loss of uniformity in the way
bicycle trails are designated and managed. Depending on the individual
superintendent, there will be a range of bicycle use from none to
wide-open, with no defining criteria to control the designations. Thus,
even for Park units having comparable geology, terrain, climate, plant
life, and animal habitat, there can be wide differences in allowed uses.
The Park Service will lose its over-arching role of providing uniform
treatment and making sure that all uses meet the standards of the
Organic Act.

The proposed Rule, as I read it, would permit successive superintendents
of Park units to change, add to, or delete trails that could be used by
bicycles. The possibility of a constantly changing regime of bicycle
useable trails can only be prevented by retaining the current Rule.

The task of designating bicycle trails, of constantly monitoring their
use, and of removing the designations adds a heavy burden to the tasks
already assigned to superintendents. No provision is made for the
additional staff needed to comply with the proposed Rule. The likelihood
of adequate funding to enable compliance is remote.

2\. Wilderness. Many units of the National Park System have lands that
qualify for Wilderness designation. In many units where Wilderness has
been designated, there are additional lands that now qualify for
designation, or that are "potential" wilderness that may qualify for
future designation as Wilderness. The use of bicycles is not permitted
in designated Wilderness. The use of bicycles in areas that may qualify
for designation, now or in the future, can affect their wilderness
qualities. Such use could easily turn an area that qualifies for
Wilderness designation into one that does not. Once use of bicycles is
allowed in undesignated or potential wilderness that use will have a
tendency to create a claim to continued use based on "prior rights."
Whether an undesignated area is qualified or is potential wilderness is
a subjective decision in most cases. It is essential that a uniform
application of the definition of Wilderness be applied at one central
location.

I take at face value the preamble to Chapter 6 of the 2006 NPS
Management Policies, which states, in part:

"All NPS lands will be evaluated for their eligibility for inclusion
within the national wilderness preservation system. For those lands that
possess wilderness characteristics, no action that would diminish their
wilderness eligibility will be taken until after Congress and the
President have taken final action. . . . ."

It is essential that the non-wilderness use of bicycles be prevented
from the start in areas that possess wilderness characteristics and that
may be designated as Wilderness in the future.

3\. The proposed Rule violates the mandate of the Organic Act on its
face and in its spirit. 16 U.S. Code section 1 prescribes the
fundamental purpose of the units of the National Park Service to be: "to
conserve the scenery and the natural and historic objects and the wild
life therein and to provide for the enjoyment of the same in such manner
and by such means as will leave them unimpaired for the enjoyment of
future generations."

a\. Bicycles cause erosion far in excess of that caused by hikers. The
erosion impairs the surface resource, and does not leave it in a shape
that will survive for continued use by future generations. In many
places bicycle associations have "hardened" trails, especially at
watercourses and on steep grades, by paving them with flat stones. While
this armoring of the trail surfaces does help control erosion, it is an
admission that erosion is a problem attracting significant expenditure
of time and effort. And, of course, armoring alters the natural
landscape, permanently. What future generations inherit is not the same
natural scene that originally existed.

b\. The speed at which a visitor crosses an area results in a
proportionate de facto reduction in its size. The appearance of size is
vastly reduced by bicyclists who routinely traverse 35-50 miles of trail
in a day. I do not think Congress has in mind allowing visitors to whip
across Parks are scene blurring speeds.

c\. The Parks are not meant to be proving grounds or obstacle courses
that users conquer to prove their own mettle. The high-wall rock
climber, Charles Victor Tucker III, an inhabitant (at times illegally)
of Yosemite National Park, described his legacy as: "I provided a great
deal of inspiration to a lot of people to pursue a narcissistic
activity." Chongo, as he was usually known, had it right. Rock climbing,
and the related bicycle trail riding is a narcissistic activity.

The Organic Act contemplates that the activity of Park visitors will be
to enjoy the scenery, and the natural and historic objects and the
wildlife. Those features cannot be enjoyed in any degree by visitors who
are going as fast as possible, and who by necessity must keep their eyes
glued to the surface on which they are coursing. They have no time for
the scenery, no time for the natural objects, no time for the historic
objects, no time to smell the flowers. Those objects are wasted on the
trail bicyclists; they might as well not be there.

d\. The use of trails by hikers, horses and bicycles is incompatible. By
severe experience I have learned how one's mood is destroyed when one is
startled, surprised, when borne down upon by a cyclist flying many miles
an hour in a narrow trail, with no room to maneuver and no ability to
stop. A person who wants to experience the beauties of nature, the grand
vista, or the view of a solitary blossom cannot be sustained when he
must be ever alert for the speedy cyclist.

On top of that is the serious possibility of severe injury. A hiker will
be constantly exposed to the threat of harmful collision with cyclists.
Bicycles make very little traffic noise, and on crooked trails are not
easily seen in time for avoidance tactics.

The more remote an area, the greater the consequences arising from a
hiker-bicycle collision. The difficulties of communication with the
outside, and of evacuation over long distances pose severe hazards.

Please make these comments a part of the official record.

Theodore A. Snyder, Jr.

P.O. Box 40

Walhalla, SC 29691