Here is the testimony that your IMBA representatives submitted. Because no one but Wilderness supporters, like Gil Willis, were invited to speak at the hearing, IMBA had to submit their testimony in writing to the Committee chaired by Nick Rahall.

IMBA is working hard on this but cannot do it without the calls from West Virginians. Please call all five of our Congressional representatives now, before it is too late!


IMBA.com • PO Box 7578 • Boulder • CO • 303.545.9000 • 303.545.9076
February 25, 2008
The Honorable Raul Grijalva
Chairman, National Parks, Forests, and Public Lands Subcommittee
Natural Resources Committee
U.S. House of Representatives
Washington, D.C. 20515
Dear Mr. Chairman:
On behalf of the International Mountain Bicycling Association (IMBA), I write to offer
comments on HR 5151 — the Wild Monongahela Act.
IMBA was founded in 1988 and leads the national and worldwide mountain bicycling
communities through a network of 80,000 individual supporters and 750 affiliated clubs. More
than 39 million Americans participated in singletrack bicycling and 7.6 million were
“enthusiasts” of the sport in 2004, according to the Outdoor Industry Association. Nationwide,
IMBA members and affiliated clubs conduct close to 1,000,000 hours of volunteer trail and
advocacy work annually and are some of the best assistants to federal, state, and local land
managers.
IMBA teaches sustainable trailbuilding techniques and has become a leader in trail design,
construction, and maintenance. We promote responsible riding, volunteer trail work and
cooperation among trail user groups and land managers. IMBA has formal partnership
agreements with the National Park Service, USDA Forest Service, Bureau of Land Management
and US Army Corps of Engineers.
We feel it is important to protect remote and wild areas and support Wilderness. We also think it
is vitally important to provide opportunities for healthy, human-powered outdoor activities with
minimal environmental impact. Mountain biking is such an activity. We will endeavor to
support land use designations that meet the needs of both bicyclists and the environment.
Unfortunately, federal agency interpretation of the 1964 Wilderness Act bans bicycle access.
Every time a congressional Wilderness bill is proposed, cyclists risk losing access to trails they
have ridden for years. Further, they lose the potential to build new trails or expand bicycling
access in these lands in perpetuity. IMBA members take Wilderness bills very seriously and
want to be at the table to help craft land protection legislation. For this reason, bicyclists seek
modifications of Wilderness proposals that will protect the land while continuing to allow this quiet, low-impact, human-powered recreation on existing trails. When conflict exists, IMBA
suggests boundary adjustments, non-Wilderness trail corridors, grandfathering in our existing
use, or other land protections such as National Protection Areas, National Conservation Areas or
National Scenic Areas.
IMBA encourages the sponsors and the committee to amend the Wild Monongahela Act as
described below. With these changes, IMBA would support the bill in full.
In particular, IMBA is very concerned about the area known as Dolly Sods North and urges
extending the adjoining Dolly Sods National Scenic Area to protect the lands in that area. Dolly
Sods North contains 22.3 miles of high quality looping backcountry trails and is currently a
popular mountain bike destination. It has been a popular mountain bike destination since the
introduction of the first mass-produced mountain bicycles in the early 1980’s. The West
Virginia Mountain Bike Association (WVMBA) began doing trail maintenance on the trails in
Dolly Sods North in the early 1990’s and has continued trail maintenance to this day. In
addition, WVMBA has sanctioned competitive events in Dolly Sods North under a Special Use
Permit from the Monongahela National Forest and contributed trail maintenance as part of these
agreements.
The table below reflects current estimates of trails and mileages in the area of Dolly Sods North,
affected the Wild Monongahela Act. It may not be complete, but is a good faith effort to try to
identify all the trails open and ridden by mountain bikers. There are more trails and railroad
grades that are not system trails that exist and are currently used by the public that are not listed
here.
Dolly Sods North 22.3
509 Upper Red Creek 1.3
511 Blackbird Knob 4.7
514 Red Creek .5
520 Beaver Dam .7
521 Raven Ridge 2.8
522 Bear Rocks 2.4
523 Beaver View 1.2
524 Rocky Ridge 3.0
525 Harman 1.4
526 Dobbin Grade 4.3
IMBA is concerned that restricting access for bikes in Dolly Sods North would block access to
and from adjoining trails near Timberline Four Seasons Resort, Canaan Valley National Wildlife
Refuge, Canaan Valley State Park, Forest Service Road #19 and other areas of the Monongahela National Forest. All these areas see significant ridership and draw mountain bike visitors from
throughout the nation. These access restrictions could significantly harm the economy of Canaan
Valley, Davis and Tucker County, West Virginia. The WVMBA tells us that virtually all of the
tourism related businesses in Tucker County support keeping the trails in Dolly Sods North open
to bicycles. Furthermore, the Tucker County Commission, the Tucker County Convention and
Visitors Bureau and the Tucker County Chamber of Commerce all support keeping the Dolly
Sods North open to bicycles, necessary trail maintenance and special events.
IMBA proposes that the existing Dolly Sods National Scenic Area be extended to include Dolly
Sods North and improve legislative protections to prohibit development, resource extraction and
motorized access. Proposed legislative language is attached below. In addition, we suggest
redrawing the boundaries of current Wilderness to extend it north, making the northern boundary
the south side of Blackbird Knob Trail (511). These changes would be more consistent with the
approach recommended by the U.S. Forest Service in the 2006 Forest Plan, which excluded
Dolly Sods North from new Wilderness designations because of current uses in the area and
concerns over water issues.
Congress has used National Scenic Areas to protect and preserve wild lands yet allow for
significant and environmentally sound recreation on many occasions. Most recently, an NSAtype
designation was used in the Virginia Ridge and Valley Act to allow continuing access to a
popular mountain bike riding area, but also afford wild lands more protection from extractive
and motorized uses. Other examples are too numerous to recount here. Moreover, an Act of
Congress is the law of the land regardless of whether it is called Wilderness or something else.
So long as legislative language protective of wild places (as suggested below) is included in an
Act of Congress, it can be safely presumed that those protections will last in perpetuity, absent
some later action by Congress. Overall, this alternative will preserve access to trails in Dolly
Sods North as well as provide ample protections for important wild lands in West Virginia.
In addition to Dolly Sods North, mountain bikers are concerned about several other areas. The
following is a list of trails impacted in Roaring Plains West, the Cranberry Expansion and Big
Draft, along with some suggestions to mitigate unnecessary restrictions on bicycle access.
Roaring Plains West
Roaring Plains West 8.4
519 Flatrock Run 5.1
548 Roaring Plains 3.3
Proposal: Cherry-stem 548/519 in entirety – it’s really one trail.
Cranberry Expansion
Cranberry Expansion 25.1
212 Lick Branch 2.1
213 Rough Run 3.5
214 Tumbling Rock 3.0
242 Little Fork 3.5
250 Birch Log 3.0
688 North South 10.0
Proposal: Exclude all trails by drawing map boundaries to abut the trails and create
cherry-stems for the trails.
Big Draft
Big Draft 13.6
614 Blue Bend 5.0
615 South Boundary 4.8
618 Anthony Creek 3.8
Proposal: Redraw map boundary along Anthony Creek/ Blue Bend loop on the north side
and Trail 615 South Boundary to place the trails outside the Wilderness area. Preference
would be for Anthony Creek-Blue Bend to be excluded from Wilderness since these are
known to be ridden and maintained by mountain bikers.
The remaining areas in the bill – Cheat Mountain, Spice Run, and Dry Fork – are all acceptable
to IMBA and the WVMBA. We are opposed to any changes being considered to include Seneca
Creek/Spruce Knob, Roaring Plains East and Roaring Plains North in this legislation. We are
particularly concerned about Seneca Creek since it is one of the most popular mountain bike
destinations in West Virginia and is included in many mountain bike guide books. We are
especially grateful to the sponsors for not including these areas in the introduced bill and hope
they will not be included in any possible amendments.
As stated above, IMBA believes strongly that it is important to protect remote and wild areas and
support Wilderness. We also think it is equally and vitally important to provide opportunities for
healthy, human-powered outdoor activities with minimal environmental impact. Mountain
biking is such an activity. We will endeavor to support land use designations that meet all these
needs.
Thank you for the opportunity to submit comments on this important Wilderness bill. IMBA
looks forward to working with the committee and its members. Please contact me at any time if
you have any questions.
Sincerely,
Jenn Dice
IMBA Government Affairs Director.

IMBA.com • PO Box 7578 • Boulder • CO • 303.545.9000 • 303.545.9076
DRAFT
Subtitle __ —Dolly Sods National Scenic Area
SEC. ___. DOLLY SODS NATIONAL SCENIC AREA.
(a) Designation.—To further provide for the protection, preservation, and enhancement of
recreational, ecological, scenic, cultural, watershed, and fish and wildlife values, the Dolly
Sods National Scenic Area within the Monongahela National Forest is extended to include
the area known as Dolly Sods North, as depicted on maps described below.
(b) Boundary.—The Dolly Sods National Scenic Area shall consist of certain Federal land
managed by the Forest Service, comprising approximately _______ acres, as generally
depicted on the maps entitled “_________________”, dated __________.
(c) Map and Legal Description.—
a. SUBMISSION OF LEGAL DESCRIPTION.—As soon as practicable after the date
of enactment of this Act, the Secretary shall file a map and a legal description of the
Dolly Sods National Scenic Area with—
(1) the Committee on Energy and Natural Resources of the Senate; and
(2) the Committee on Natural Resources of the House of Representatives.
b. FORCE OF LAW.—The map and legal description filed under paragraph (1) shall
have the same force and effect as if included in this Act, except that the Secretary
may correct typographical errors in the map and the legal description.
c. PUBLIC AVAILABILITY.—The map and legal description filed under paragraph
(1) shall be on file and available for public inspection in the appropriate offices of the
Forest Service.
(d) Administration.—
a. IN GENERAL.—The Secretary shall—
(1) administer the Dolly Sods National Scenic Area—
(i) in accordance with the laws (including regulations) and rulesIMBA.com • PO Box 7578 • Boulder • CO • 303.545.9000 • 303.545.9076
applicable to the National Forest System; and;
(ii) to prohibit all motorized uses, except to protect the health and
safety of individuals in cases of an imminent threat of flood, fire,
or any other catastrophic event that, without intervention, would
cause the loss of life or property.
(iii) consistent with the purposes described in subsection (a).
b. APPLICABLE LAW.—Any portion of a wilderness area designated by subtitle A
that is located within the Dolly Sods National Scenic Area shall be administered in
accordance with the Wilderness Act (16 U.S.C. 1131 et seq.).
(e) Road Construction.—No new or temporary roads shall be constructed or reconstructed within
the Dolly Sods National Scenic Area except as necessary—
a. to protect the health and safety of individuals in cases of an imminent threat of flood,
fire, or any other catastrophic event that, without intervention, would cause the loss
of life or property;
b. to conduct environmental cleanup required by the United States;
c. to allow for the exercise of reserved or outstanding rights provided for by a statute or
treaty;
d. to prevent irreparable resource damage by an existing road; or
e. to rectify a hazardous road condition.
(f) Withdrawal.—Subject to valid existing rights, all Federal land within the Dolly Sods National
Scenic Area is withdrawn from—
a. all forms of entry, appropriation, or disposal under the public land laws;
b. location, entry, and patent under the mining laws; and
c. disposition under all laws relating to mineral and geothermal leasing.