Back Country Horsemen of Oregon response to the Public Comment to BLM Proposed E-Bike Regulations

As you probably know, the Secretary of the Interior is proposing to allow electric bikes, or E-bikes, on all non-motorized trails where mountain bikes are currently allowed. This change threatens decades of hard work to designate quality non-motorized trail opportunities in communities across the West.

Please take a few minutes to urge the BLM to abandon this foolhardy proposal. You can submit your comments online, via the Federal eRulemaking Portal that can be accessed at:  Click on the Comment Now button.

Comments are due by June 9, 2020.  At the end of this email you’ll find some useful talking points you can use, which were helpfully provided by our friends at Back Country Horsemen of America. 

Motorized mountain bikes are currently allowed on the majority of roads and trails on BLM lands. But in a give-away to the E-bike industry, the Secretary of Interior wants to allow motorized mountain bikes anywhere that regular bikes are allowed. While this means that any type of bicycle use would remain unlawful in federally-designated Wilderness, trail networks throughout BLM lands elsewhere could be opened to all classes of motorized E-bikes, including those that can be powered solely by a thumb throttle.

Feel free to use a couple of the talking points below in your comments.  At a minimum, please tell the BLM that E-bikes are motorized vehicles and belong on motorized trails. Encourage them to keep non-motorized trail networks, fought for by local communities across the country, non-motorized, so that hikers, equestrians and other recreationists can enjoy trails free from motors.
Thank you for taking action to protect our trails!

Attention: RIN 1004-AE72

Dear Secretary Bernhardt,

  • I am writing to voice my strong opposition to the Bureau of Land Management’s (BLM’s) proposed Rule to allow motorized bicycles (E-bikes) on non-motorized trails. I am deeply concerned that your proposed rule is unmanageable and would cause significant safety issues on our trails, generate significant user conflict, and open the door to further motorization of America’s backcountry wildlands.
  • E-bikes have a place on public lands and are currently allowed on the majority of roads and trails on BLM lands across the West. The BLM already has the tools it needs to designate new or existing trails as open to E-bike use. In fact, the BLM is evaluating new trail proposals right now—in Utah, Colorado, Montana and elsewhere—that would authorize E-bike use under existing regulations and policies.
  • E-bikes by definition have motors. The proposed Rule to classify E-bikes as “non-motorized” violates common sense, is inconsistent with existing laws and policies and would undermine years of hard work that has gone into planning, funding, and constructing our non-motorized trail networks.
  • The proposed Rule would “direct” local BLM land managers to “generally allow” three classes of E-bikes on non-motorized trails where use by mountain bikes is currently authorized. This includes motorized E-bikes that require no pedaling at all—that is, Class 2 E-bikes that can be powered via a throttle, similar to a motorcycle. The BLM should not “generally allow” any type of motorized use on non-motorized trails.
  • Introducing E-bike use in previously non-motorized areas and trails would result in significant safety concerns and increased conflicts between trail users. The BLM must analyze these and other social and physical impacts of the proposed Rule via the National Environmental Policy Act before issuing a Final Rule.
  • Equestrians seek out non-motorized trails on BLM public lands in order to get away from fast-moving vehicles and enjoy a peaceful, natural environment. We often will choose to avoid trails where there is a potential for encounters with fast-moving bicycles. Most equestrians would find the specter of sharing trails with fast-moving E-bikes unappealing, if not frightening. The result would likely be the loss of these traditional users on non-motorized trails should the BLM authorize shared use by E-bikes.
  • As equestrians, our selection among trails available in a given area is based, in large part, on safety concerns and the sometimes unpredictable response of our horses or mules in the event of a surprise on-trail encounter. The use of E-bikes, and their potential for travel at relatively high speeds, combined with their often silent approach, elevate the potential for such dangerous encounters.
  • Higher speeds on trails by one user group puts both user groups at risk. On average, equestrians travel along natural surface trails at speeds that average 5 mph or less. Of the three classes of E-bikes addressed in the proposed Rule, both Class 1 and 2 E-bikes provide motor-assisted speeds up to 20 mph, while Class 3 E-bikes provide the rider with a motor assist up to 28 mph. Capable riders can exceed the maximum motor-assisted speed. The proposed Rule fails to recognize the significant discrepancy in the range of potential speeds by trail users and the resultant safety hazards that are certain to accrue should E-bike use be authorized on non-motorized trails.
  • The BLM has neither the resources nor the personnel to adequately monitor or enforce E-bike use on its trails. When viewed on the trail, there are few visual differences among the three classifications of E-bikes addressed in the proposed Rule. Thus, restricting the use of one class versus another on a given trail or trails would be pointless and prove frustrating for BLM law enforcement personnel.
  • Many E-bikes sold on the market today are built with an appearance similar to the three classes of E-bikes addressed in the proposed Rule, yet exceed the maximum power and speed specifications the proposed Rule wishfully envisions. Worse still, a search on YouTube yields dozens of tutorials on how to “hack” or override the speed constraints programmed into nearly every E-bike from any manufacturer. These facts make irrefutable our claim that the BLM could neither adequately monitor nor enforce E-bike use on non-motorized trails.
  • I support expanding recreational opportunities on our public lands; E-bikes do indeed have their place. However, this rulemaking is simply the wrong way to go about increasing motorized E-bike opportunities on BLM lands. The BLM should abandon this rulemaking process. It’s unnecessary because the agency can already designate trails to allow motorized uses, such as E-bikes.

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