Open Letter to City Council
EMBA Open Letter, in advance of the May 31, 2022 River Valley Planning Modernization Phase 2 Update to the City of Edmonton Urban Planning Committee On Tuesday, May 31, City Council’s Urban Planning Committee will receive an update from Administration on results of the second round of public engagement in their River Planning Modernization project (RVPMP). The RVPMP is designed, in part, to expand the 1992 Ribbon of Green (RoG) plan from its original coverage area, replacing the 1975 Capital City Recreation Park plan and the interim SW+NE Ribbon of Green plan which was published, but not enacted as a bylaw, in 2020. Members of the public have the opportunity to register to speak for 5 minutes and answer questions from the Council committee in relation to Administration’s Phase 2 What We Heard Report (WWH Report) and their plans for completion of the comprehensive RoG and future work, currently out of scope for the RVPMP. Members of the Edmonton Mountain Bike Alliance (EMBA) will join other citizens in making representations to the committee. EMBA is a 100% volunteer-run and private donor funded non-profit society that is dedicated to improving mountain biking in Edmonton. EMBA has had a working relationship with the City of Edmonton since 2005, and has built and maintained narrow natural surface (“singletrack”) trails collaboratively under the City’s direction to meet an internationally accepted and sustainable standard (the Whistler Trail Standard). Pursuant to our written agreement with the City of Edmonton, EMBA is the only governmental or non-governmental organization conducting authorized maintenance on our City’s natural surface trails, and since our first Trail Day in 2006 we have coordinated, led, and trained volunteers on sustainable trail building and maintenance. Our organization promotes responsible trail use and etiquette and believe that our river valley’s system of natural trails should be open for the shared use and enjoyment of cyclists, trail runners, hikers and nature lovers, alike. This month, EMBA volunteers have set up our tent and information booth in river valley parks for several hours each weekend to inform users about the RoG and continue our promotion of courteous shared trail use by distributing hundreds of free bear bells to help cyclists alert other users of their presence on the trails. As of May 21, we have distributed 344 bear bells, donated to EMBA by the local Mud, Sweat & Gears chain of bike shops. Why is EMBA concerned about the Ribbon of Green? The current 1992 RoG plan sets out three Land Management Classifications (LMCs) for the area of the river valley that is governed by that plan, being the river valley and ravines west of the Walterdale bridge to (and including) Fort Edmonton Park. These three LMCs (Preservation, Conservation and Extensive Use (now “Active/Working Landscapes”)) have been carried forward into the SW+NE RoG and are proposed for carry forward into the comprehensive RoG plan now in development. The permitted uses of natural surface trails under the 1992 Ribbon of Green Preservation area LMC are limited to certain foot based activities, only. This restriction on use has been carried forward into the SW+NE RoG, which expressly states cycling and organized foot-based events to be prohibited activities in Preservation areas, and is presently proposed to be carried forward into the new comprehensive RoG. With expansion of the RoG coverage area to the entirety of the City of Edmonton’s river valley and ravine system, EMBA estimates that more than 90% of the existing singletrack natural trail system will now be located in areas designated as “Preservation”. In mountain bike-specific FAQs published to the RVPMP webpages subsequent to EMBA raising the alarm regarding this impact of the expansion of the Preservation designation, City Administration states that “the City is not banning or prohibiting mountain biking in the River Valley, and no trails are being closed at this time”. However, the FAQs also state that City Administration has no present intention of changing the permitted uses of Preservation area trails, and say “There is no plan to close/remove trails in advance of further work”. The FAQs and Administration’s Council Report for the May 31 meeting [i] both state that the RVPMP team’s plan is to seek funding from City Council for the 2023-2026 budget cycle to carry out “on-the-ground” assessments, to determine whether any Preservation area trails can be permitted to remain in place and open to cycling. But the on-the-ground assessments will likely take at least until the end of the 2023 summer cycling and trail maintenance seasons to complete, should funding for that project be provided at the end of this year. The Edmonton Journal recently reported that on May 9, 2022 City Administration estimated that an 8.5% property tax increase would be required should City Council choose to continue with funding of all new projects currently set in motion. So there is a significant risk that this additional new program may go unfunded for 2023 and beyond. The approach stated in the Council Report and mountain bike FAQs on the RVPMP website does not satisfy any of the diverse groups variously interested in use and conservation of the river valley. As the WWH and Council Reports [ii] make clear, Conservation first groups, joined by some vocal residents with properties backing onto Preservation areas, want the City of Edmonton to enforce the explicit prohibition on cycling set out in the existing RoG plan. Meanwhile, the express terms of that 1992 RoG have lead to conflict and confrontations between cyclists and other citizens taking enforcement into their own hands, and the conflict and confrontations can only be expected to increase, with calls in two recent editions of the North Saskatchewan River Valley Conservation Society’s “River Valley News” for the creation of a volunteer “River Valley Patrol“. While more than 4,500 people [iii] participated in the Phase 2 RVPMP public engagement process, with the “key concern raised [being] the exclusion of biking within the Preservation [LMC ] [iv]”, the Edmonton River Valley Conservation Coalition (ERVCC) has in it’s recent May Update newsletter stated that “Edmontonians do not feel the river valley is being adequately protected”, based on the views of 43% (97 people) of 225 participants in a survey conducted on that organization’s website. What City Administration’s policy means for EMBA is that our volunteers are not permitted to carry out badly needed maintenance work on many trails that continue to be heavily used. The express terms of EMBA’s Trail Maintenance Agreement with the City of Edmonton prohibit EMBA volunteers from carrying out any maintenance work on a trail located in a Preservation area. As a result of this prohibition and in light of the prior commencement of the RVPMP, in June 2021 EMBA approached Mayor Iveson’s office on behalf of one of our member cycling clubs to request City Council permission to carry out some minor trimming and pothole repair on “Six Shooter“, a natural surface trail located in the small wooded area bounded by three significant roadways; Groat Road, Emily Murphy Park Road and Saskatchewan Drive. Despite working thereafter with representatives of two branches of City Administration and participating this year in four 2 hour long mediated sessions with the City and conservation advocates, we have yet to receive this permission, 11 months later. EMBA’s difficulty in obtaining permission for trained volunteers to carry out minor maintenance, the purpose of which is to improve trail safety and mitigate future environmental damage, stems from the fact that in a city of over 1 million residents there is a broad range of perspectives that City Administration has tried to bring to consensus on the extent to which our citizenry, including nature lovers, hikers, trail runners and cyclists, are to be permitted to access and enjoy our river valley and ravine system. In her March 19, 2022 editorial published in the Edmonton Journal (“Edmonton’s river valley can’t be everyone’s outdoor playground“), Patsy Cotterill, a long time advocate for our native plant species through the Edmonton Nature Club and other conservation groups, decried the connectivity to Oleskiw Park that was created by the West-end Trails project of the City of Edmonton and River Valley Alliance, claiming that mountain bikers have created “a network of ever-widening dirt trails in Oleskiw’s riparian forest [“the home of deer and coyotes”] including right along the river”. Although 3 of the 5 natural surface trails in Oleskiw Park, including the one closest to the riverbank, predate the construction of the Terwillegar footbridge by many years, and all of these trails are contemplated by the terms of the City’s Oleskiw Park master plan, the bridge has indeed given Edmontonians access to and through Oleskiw Park. This amenity, and the multi-use and natural surface trails it connects to the Fort Edmonton footbridge and Wolf Willow community are enjoyed by people of all ages and abilities, and on many summer nights you are likely to encounter a group of young novice mountain bikers being lead by a trained instructor from one of the local clubs, as they learn the sport on the flat, twisty and fun singletrack. Yes, Oleskiw Park is home to many coyotes. But Edmonton is also home to 1 million people and the City Plan, passed in December, 2020, is expressly stated to be “an invitation to join in building a version of our city that respects and preserves the things we value today while also creating a city to attract and inspire its next million residents. [v]” So how to balance the interests of an expected two million urban residents against the legitimate concerns of conservationists for the promotion and protection of biodiversity? It is EMBA’s submission that summer mountain biking and winter fatbiking on our river valley’s network of narrow natural surface trails is a peculiar and inappropriate place to start. The City Plan The City Plan, which is the guiding document for all other policy of the City of Edmonton, states that “Edmonton is many things, but first and foremost it is a gathering of people. [vi]If th” The Plan’s 4 strategic goals are Healthy City, Urban Places, Climate Resiliency and Regional Prosperity. The Council Report states that the outcomes of the RVPMP are to be “in alignment with The City Plan [vii] “. Year-round cycling on the singletrack trails also aligns with a multitude of the more specific outcomes and objectives identified in the City Plan: 1.3.2 Support Edmonton’s identity as a winter city through its infrastructure, design, events and economy. 126.96.36.199 Celebrate our winter city through arts, recreation, events, story telling and inspired design 188.8.131.52 Increase opportunities for Edmontonians to be physically active throughout all seasons 2.1.1 Ensure publicly accessible spaces and facilities 184.108.40.206 Improve access to the North Saskatchewan river valley and ravine system 220.127.116.11 Facilitate access to City activities and programming for people of all ages and abilities 4.4 Edmontonians benefit from improved public transit and high quality active transportation networks that reduce greenhouse gas emissions (See page 76 for the accompanying picture of a winter fatbiker on the river.) 5.1 Edmonton protects, expands and improves access to its natural systems and open spaces in support of biodiversity and the health and enjoyment of all Edmontonians 5.1.1 Ensure protection, enhancement and opportunities for access to open spaces and the river valley and ravine system 18.104.22.168 Provide opportunities for people to access, enjoy and connect to open spaces and the river valley and ravine system 22.214.171.124 Provide wayfinding support and improved connections within and between open spaces and natural areas 126.96.36.199 Maintain the North Saskatchewan River Valley and Ravine System for natural areas protection, open space connectivity and use 188.8.131.52 Coordinate protection, restoration and enhancement of the North Saskatchewan River Valley and Ravine System and ecological networks through outreach, education and partnerships In describing the Green and Blue Network [viii] the City Plan states: “People need access to nature for recreation and health. The Green and Blue Network is used by people for cycling, walking, running, rolling, canoeing and relaxation.” and “Improved access to the River Valley and Ravine System reinforces Edmonton’s sense of place, its people and their connection to this place [ix].” “Urban vibrancy – Weaving biking into our city-building and design makes Edmonton a vibrant, attractive city that we’re proud of and that others are drawn to [x] .” Clearly, EMBA’s Values of “Legal trails, environmental stewardship, partnership and volunteerism”, and our Mission of “leadership and advocacy for building and caring for singletrack trails in Edmonton’s North Saskatchewan River valley”, are in alignment with the City Plan and so should also align with the terms and outcomes of the RVPMP and RoG. Year-round free access to cycling on our extensive network of trails contributes greatly to the health and quality of life of our citizens and will continue to be an important factor in attracting businesses and residents to our City. The prohibition of cycling in Preservation areas So if our sport and EMBA’s values and mission are in alignment with the City Plan, how have we ended up in a situation where the expansion of the Ribbon of Green plan to the entirety of Edmonton’s river valley and ravine system presently contemplates that approximately 90% of the system of natural surface trails will now be closed to cyclist and organized trail events? The SW+NE Ribbon of Green plan states that the exclusion of cyclists from these trails will “facilitate the quiet enjoyment and appreciation of nature” [xi] and “reduces user conflicts and environmental impact”[xii] . The WWH Report [xiii] and Council Report [xiv] both reinforce this perspective, with the WWH report stating: “Other participants expressed concern about the potential impacts of single-track trails, including ecological/environmental impacts in environmentally sensitive areas, as well as growing user conflict and risks to public safety.” In response, in addition to our continued advocacy of mutual respect and for courteous shared trail use, EMBA has attempted to lead a science based review of the environmental impacts of cycling as compared to other types of use, providing City Administration with references to a great many of the academic papers on this topic and conducting our own review of the papers relied on by the City for the assertion that these impacts are different. The conclusion of the preponderance of the research is that cycling has an impact that is on par with foot-based use and is significantly less impactful than equestrian use. The conclusion of Gary Sprung’s 2004 paper “Natural Resource Impacts of Mountain Biking – A Summary of Scientific Studies that Compare Mountain Biking to Other Forms of Trail Travel” is still an accurate summary of the science and encapsulates the current state of the debate in Edmonton:
Mountain biking, like other recreation activities, does impact the environment. On this point, there is little argument. But with regard to the non-human environment, people often debate whether or not mountain bikes cause more damage to trails, vegetation, and wildlife than other forms of recreation such as hiking and horseback riding. A body of empirical, scientific studies now indicates that mountain biking is no more damaging than other forms of recreation, including hiking. Thus, managers who prohibit bicycle use (while allowing hiking or equestrian use) based on impacts to trails, soils, wildlife, or vegetation are acting without sound, scientific backing. In contrast, if a manager prohibits one user group on the basis of providing a particular type of experience for another group, the evidence provided by social studies may or may not justify that decision. The wisdom of prohibiting particular user groups in order to satisfy the desires of other groups is a matter for politics rather than science.
All of this leads back to the May 31 Urban Planning Committee meeting. Because the Council Report indicates that the comprehensive RoG is not expected to be completed until Q3 of 2023 [xv] and that the site specific on-the-ground assessment of trails and detailed trail planning, including identification of recreational trail networks, are out of scope for the RVPMP [xvi] and required additional funding [xvii] , and due to the present policy outlined in the RVPMP team’s mountain bike specific FAQs, at that meeting EMBA will ask the Committee for a formal amendment of the 1992 RoG. The purpose of the amendment will be to include cycling as a permitted use on any trail within a Preservation area that is open to human activity, and to leave the determination of whether any trails in these areas need to be closed or moved for ecological reasons for the on-the-ground assessments planned by the RVPMP team as part of their proposed detailed River Valley trail strategy. EMBA believes that the benefits of adopting this approach, pending funding and completion of City Administration’s further study, far outweigh any perceived disadvantages. Firstly, by adding cycling as a permitted use the City will, for this interim period, be preserving the status quo that has persisted for several years, continuing to permit Six Shooter and other trails located in Preservation areas to be used and enjoyed by cyclists, without the threat of conflict with other citizens intent on taking enforcement of the City’s bylaw into their own hands. Equally as important, permitting volunteers to conduct their work under supervision of EMBA’s trained Trail Day leaders will minimize environmental damage while we await the on-the-ground assessment of trails. Potholes form in wet weather, and hikers and runners tend to go around potholes rather than through them, as cyclists are advised to do. When this occurs, the trail gets widened, or alternative “trail braiding” routes are created. EMBA volunteers drain the potholes, contour the trails so that they shed water, close braiding, and use proven trail building techniques to narrow the width of the trail. EMBA recognizes that much of the opposition to cycling on natural surface trails stems from other citizens’ frustration with the creation of new illegal trails and the building of jumps and other structures by a small minority of cyclists. In the near future, through the proposed trail strategy and possibly with the assistance of federal funding through the establishment of a National Urban Park, we look forward to the City recognizing a definitive, well signed and well maintained, comprehensive natural trail system, which will undoubtedly help to curtail the establishment of new illegal trails. A subcommittee of EMBA volunteers is currently engaged with the City of Edmonton in a community led project to raise donations for and complete the construction of the Bike Skills Park that is an unfunded component of the Queen Elizabeth Park master plan. That Bike Skills Park, with professionally designed and built features, will help to fill the demand for these amenities and again curb illegal building. We hope to receive the support of the Urban Planning Committee, City Council and citizens for our proposal to include cycling in the permitted uses of Preservation area trails and look forward to continuing to work with the RVPMP team as they finalize the comprehensive Ribbon of Green and complete their further work.
[i] Pp. 4 and 6 and Attachment 3 [ii] WWH pp. 20-22, Council Report p 6 [iii] Council Report p 5 [iv] WWH, p. 11 [v] City Plan, p. 6 [vi] ibid. [vii] Council Report, p1. [viii] City Plan, p.105 [ix] ibid, p.107 [x] ibid, p. 116 [xi] SW+NE Ribbon of Green, p. 68 [xii] ibid. [xiii] WWH, p.11 [xiv] Council Report, p. 5 [xv] Council Report, p. 6 [xvi] Council Report,Attachment 3 [xvii] Council Report, p. 6