Uri Driscoll: City flying blind as Red Bull-engorged trail tyrants take over Sunny Brae Tract

The Sunny Brae forest trail issues are far from resolved. While Kevin [Hoover] did a good job of reporting he uncharacteristically gave Forest Management Committee (FMC) members and city staff a pass by letting them avoid addressing certain key issues.

First of all, there was basically no public process prior to the design and development of the high-speed trail in question. The July 17 meeting that was claimed to be the approval process took place long after the trail was already developed, in place and in use. To say it was approved after it was built is like saying we don’t need permission because we grant our own forgiveness.

One lightly publicized meeting that was steamrolled by a single interest group hardly justifies the claim that all interests have been considered.

The only user group that was consulted by city staff prior to the development of the controversial trail was a small cadre of mountain bikers. They held secret meetings with city staff to push for turning this trail into a downhill bomber bike run.

Uri Driscoll badgeI must add that this trail in a pre-developed stage, while steep, had been in use for decades by horsemen and hikers. The exclusion of these users for a few high-skilled bike riders hardly seems “even handed” as one FMC committee member claims. It is an insult to the rest of us to even suggest such considerations were made.

There are numerous horseman associations in the county. The city failed to contact even one. I represent one of them as vice president and trail chairman. Our Northern California Horseman’s Association recently conducted two fundraising events for the Community Forest and raised over $12,000. At no time were we consulted on an issue that would remove a historic horse trail and in general set a precedent that is designed to ultimately lessen available trails. Certainly we were not told this effort was in progress prior to our fundraising events.

We submitted a letter to the City Council a month ago encouraging the city to maintain its shared trail policies rather than pursue segregating uses. This trail represents the very first Community Forest trail that bikers don’t share with the rest of the community.

I will add that both Mr. Halligan and Mr. Furniss of the FMC both know me personally. Dennis used to bring his daughter to our home for horseback riding lessons and Michael used to live right next door. While the Forest Management Committee was wondering how extensive the objections are, a simple phone call would have made that more obvious.

Arcata’s Open Space and Agriculture Committee also has four horse owners sitting on that committee. We were not approached through that venue either. It remains unclear who in the community was involved in this decision aside from a few bikers.

It was shocking to read that the original Forest Management guidelines were no longer relevant since the expansion of the Community Forest. I was surprised that Kevin Hoover did not ask the obvious questions; what management guidelines have been in use since that expansion? Have we been flying blind since then? What other elements of the original guidelines are being ignored?

More importantly why are we just now straying from our standard of shared use trails? How did that get decided? And when? Where is the transparency? At least one FMC member acknowledged their failings in the transparency department. The question of course remains; What are they going to do about it?

For the most part mountain cyclists are very cordial. I personally have had only a few close calls with speeding bikes in the Community Forest but I do know other folks who have been run into or their dogs run over.

I will continue to question why we are encouraging that type of activity in a small and precious network of community trails when doing so will only increase these types of problems.

Separating uses is but a small minded way to “solve” a problem. Such an approach simply does not take into account that it pencils out to fewer trails for us all.

Frankly I am surprised the mountain bike community is willing to risk so much of their hard earned capital. What they are saying by pushing for these separate use and high speed specialized courses is that they cannot exist on shared use trails.

They are also saying that they don’t want to share trails and the rest of the community should just go somewhere else because they have some Red Bull to work off.

They are transforming from selfless trail advocates into selfish trail tyrants right before our eyes. I certainly hope they come to their senses and put their old hats back on.

The other option could be to simply sell the whole Sunny Brae tract to the bikers since they are trying to take it over anyway. That way the rest of the community could recoup their investment.

My suggestion first offered to the FMC a couple of months ago was to have city staff meet with a variety of user groups individually at first in order to gather specific needs and wants. Later involve all groups through their representatives at a more public venue. Then the city will be able to say they have not merely capitulated to a single interest group but indeed involved the whole community. They cannot honestly say that right now.

Communication with the public is an integral tool to achieve success with planning and management efforts.

Uri Driscoll is a lifelong horseman and member of Arcata’s Open Space and Agriculture Committee.


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  1. Andrew S. said:

    If you plan on meeting with any city officials, please let me know so I am not blocked from the meeting. If I am blocked from any meetings I will write angry things on the internet forever.

  2. Dryasoctopetala said:

    So many “mountain biking plans” are found to be pre-determined by politicians and land managers, for whatever unknown reason these people “in authority” fold to the whims and wiles of mountain biker demands. By time any other stakeholder groups get a say in anything MTB-related, it is too late. This “process” is repeated, over and over again, all over North America as the yahoo MTBers take over the trails and build new ones — many without permission. There is no common-sense in it. The “RedBull” brand of MTB “community” really are “demons on wheels”, lying and laughing all the way — just dirtbikers without motors. But, electric MTBs are now making stealth inroads, along with fat bikes — morphing into motorized dirtbikes before our eyes, after all! Surprise! Surprise? We have been fooled, as our MTB-fawning authorities are foolish. Another fine mess in the making, folks. Wait and see.

  3. Ricardo said:

    It appears from this article that the City of Arcata may have violated state meeting laws if the decision regarding the trail designation change was conducted through a city appointed committee and proper notice was not forthcoming.

  4. Uri said:

    Hi Steve,
    Prior to the onset of mtn bike use in the Sunny Brea tract of the Community forest it was used heavily as a thoroughfare from a stable at the foot of the forest up the trails to the Arcata forest. Although the stable changed hands there are still private horse facilities at the top and bottom of these trails. I am not going to get into all the history here but there has been a long standing use of these trails by the horse community. The access points have been a challenge in recent years but we have been very patient with the city in their promise to develop better access points.
    I have been saying all along there needs to be due process and consensus and there should be no “losers”. The trail in question means one cannot walk or ride a horse or bike in an uphill direction even if no “downhiller” is on it. Where I am going to disagree with you is that the city did NOT balance the needs of the rest of the community.

  5. Kevin Hoover said:

    “…the Forest management plan. And if the city considers that plan obsolete, when was it abandoned and what guidelines have they been using since?”

    Uri, where did you get the idea that the FMC was “abandoned?”

    As my story plainly stated, the plan still applies to the original Arcata Community Forest. It is being updated to include new acquisitions.

    OBVIOUSLY the forest is being managed in accordance with California Forest Practice Rules, plus the 1979 Forest and Parklands Initiative from which all of our forest plans derive.


    I don’t have room in every story to state that the sky is blue, especially when you don’t seem to assimilate the rest of the clearly stated information.

  6. Kevin Hoover said:

    So the outrage over being “kept out of meetings that are meant to eliminate your use of favorite trails” has to do with some people going in and having a chat with Mark?

    I do that all the time. It looks like you want to as well. I guess Mark is then compelled to invited the bikers to your meeting, lest they be “kept out?”

    Again, how is it that this trail was a “favorite trail?” It’s never been open to public access.

    “In the season of sharing can’t we all agree to share our trails.”

    There are trails in the Community Forest that bikes aren’t allowed on. You haven’t complained about that. Is it your premise that all modes of transportation must have access to all trails, or what?

  7. Uri said:

    While I don’t think we are going to solve all the issues on this blog I appreciate the dialog.
    The meetings I spoke of are the ones Prior to the construction of the said trail. From a conversation with Mark Andre he let me know that some bikers met with city staff about constructing this trail as it has been. That only makes sense because the impetus came from somewhere. He did not indicate who attended this private meeting. I am surprised those people have not stepped up.
    I had attempted to contact Mark for a meeting to go over a time line of the process that led us to where we are now. He must be on vacation as he did not reply and thus I do not have that complete time line to share here.
    How did the original agreement to turn the trail in question into a select group of a single user group trail, get made? When I first saw this trail being re-contoured about two years ago and had heard it was intended to be a bike only trail I asked Mark Andre if that was the case. His response was that it was not.
    While I was unable to attend the July FMC meeting I did attend the following one to bring up my concerns. I also walked the trail with some members of our Open Space committee and recently elected councilman Paul Patino this summer. Because we have active trail users on our Open Space Committee and routinely express our interest in trail issues I certainly thought an issue of this magnitude would get brought to us in a timely way. While I respect the FMC members for the level of expertise they bring for managing the forest resource utilizing active trail uses that reside on another city committee would be wise.
    A agree with Bruce that this type of course does not fit the definition of a Back Country experience as is spelled out in the Forest management plan. And if the city considers that plan obsolete, when was it abandoned and what guidelines have they been using since?
    That is the real question Kevin needs to be asking. We all need to be asking.
    In the season of sharing can’t we all agree to share our trails.

  8. Bruce LeBel said:

    Hi Steve,
    I appreciate your engaging on this issue. In reply to your two points:
    On 1) I had been hiking that loop in SBF multiple times a week for years, typically uphill on the steep ridge trail that has now been reallocated for exclusive use by downhill mountain bikes. On all of those hikes prior to the trail being reconstructed as a mountain bike course I can only recall encountering a mountain bike twice at most. So I disagree with your contention, based on my extensive time on that trail. I also don’t understand your “uphill” comment given that this trail now precludes uphill use including a steel “keep out” sign at the bottom of the redeveloped trail section.
    On 2) In all my years running, hiking and riding in the Community Forest (I conservatively estimate 10,000 miles) the problem encounters or trail conflicts have been so rare that it makes the case for the value of the multi-use trails with established rights of way and typically courteous users. It was only after the development of the high-speed mountain bike course in SBF that I began encountering groups literally racing from top to bottom of SBF, in full protective gear and with gross disregard for anyone else who might be on the trail. The difference in behavior by riders that I experienced in my frequent hikes in SBF was completely different following the development of the special-purpose course for advanced high-speed downhill riders.

    Regarding your last sentence, the imbalance is that the developed special-purpose recreation facility of this high-speed downhill mountain bike course is in complete contradiction to the black & white words, standards and objectives of the Forest Management Plan, and that City staff made the decisions and did the work in contradiction to the FMP with no public process nor guidance or approval from either of the City Committees whose role is to provide such guidance.

    My suggestion is that the City reset the process. Redesignate the trail as multi-use. Go through a public process of revising the Forest Management Plan. And then if the revised plan allows for “developed recreation”, let the interest groups lobby for their respective playgrounds, while others attempt to keep the Community Forest “a back country experience”, as is defined in the current FMP.

  9. Ironoresteel Home said:

    Hi Karen,
    Having read through this a few times, I don’t think Kevin is the one using name calling and bullying tactics here. Pointed questions to be sure, but worthy of the answers we’re all still waiting for and fair game as Uri is contending that he and the group he represents have been treated unfairly.
    Holiday wishes to you and the family as well!
    Steve Jones
    Sunny Brae

  10. Ironoresteel Home said:

    Hi Bruce,
    Steve Jones here. My experiences riding and hiking in the Community Forest and on SPI property in Sunny Brae have led me to two conclusions different from ones expressed in your letter above.
    1. The Sunny Brae trail was much more of a de facto mountain bike race course previously. The improvements made by the City of Arcata have restored my ability/desire to both walk and ride uphill, my usual precursor to riding or walking downhill.
    2. I find the doubletrack trails, or roads as they should be called, in the Community Forest proper to be much more high speed than the downhill trail in Sunny Brae.
    I do agree with due process and consensus with regards to city property, but the ‘winner’ shouldn’t necessarily be the most strident or those who raised the most funds. I think the City of Arcata has carried off an excellent balancing act here that truly serves most users best.

  11. Bruce LeBel said:

    Uri’s opinion piece advocates for multi-use rather than precedent-setting exclusive use. I agree. I have run, hiked and biked in our Community Forests actively and regularly for over 20 years and have seldom had any problem with trail conflicts. That is, until the high-speed downhill mountain bike course was constructed in Sunny Brae Forest (SBF). Following that construction of the “developed recreation” facility for exclusive use of advanced and athletic mountain bikers, the entire SBF became a de facto mountain bike race course. I agree with Uri’s concerns about lack of transparency and lack of public process prior to construction of this exclusive-use high-speed mountain bike trail. A particularly disconcerting aspect of this failure of process is that the Forest Management Plan (FMP) specifically precludes high-speed cycling and any “developed recreation”, which this constructed course clearly fails on both counts. The FMP also states specifically that the Community Forest is to be a “back country experience”, which this course certainly is not, given the entry and exit gates, the steel “keep out” sign directed at hikers, and the Disneyland-like “ride-through tree” in addition to the engineered and constructed ramps, jumps and banked turns. These issues merit attention and review by City department heads, by City committees and by City Council.

    Further regarding Uri’s concerns regarding public process: If it’s OK to construct the “developed recreation” of this trail contrary to the FMP, what is to keep the SBF from becoming a constructed playground for other interests including, for example, a disk golf course, an exercise ParCourse, a canopy zip-line, a horse ring, a downhill off-road skate board course, … or whatever else some particular special interest group may express desire to have the City build for them in this tract of our Community Forest? I for one prefer the wise and proven guidance of the Forest Management Plan in favor of no developed recreation and the “back country experience”. And, to Uri’s point, what would be the process for those interest groups and their petitions?

  12. Kevpod said:

    He does raise important points.

    More important than this trail issue is his claim that a major stakeholder has been barred from participating in forest planning. If that’s happening with the forest, who else is being excluded from public process on what other issues?

    What meetings have the horsemen been kept out of? I need to find the decisionmaker there and ask them what justification there could be for this.

    Me and Jane Woodward of Ec Dev are usually the only people who go to Forest Management Committee meetings.

    Uri says the meetings are “lightly publicized.” They occur routinely, like clockwork every month, just like his Open Space Committee meetings. They’re posted online and at City Hall.

    Anyone interested in forest issues knows about the meetings, and can attend or go on the field trips. They generally don’t.

    The committee walked the whole Sunny Brae loop in August. Just me and Jane went along – no Uri or any other equestrians.

    It’s also hard to understand how this trail could be a favorite of equestrians when it hasn’t been open to public access for decades. Did SPI grant permission?

    Uri wants me to take the city to task on various points, and I am perfectly willing to do so. If there’s something to it, let’s address it.

    Hello, Uri?

  13. Karen Brooks said:

    Kevin, Uri raises important points, though his tone is harsh, it serves no purpose to start calling each other names and bullying each other when we have it within ourselves to solve this. We talk a good game about how stupid wars are and you guys are about to go for the throat over trails.

    Get a grip. Work this out. How about practicing a little peace and goodwill? Please. Merry Christmas and no bah-Humbugs.

  14. Uriah Heep said:

    Uri, I am tired of your bombastic and bigoted view of mountain bikers.

    Similar to your hatred of Snowy Plover protection.

    Similar to your hatred of native vegetation restoration efforts in the dunes.

    Another opinionated right-winger.

  15. Kevpod said:

    Further, Uri, how can this be a “favorite trail” when it has never been open to public access? Do horsemen trespass on private property, or did you have permission from SPI to use that trail?
    Also, you say “trails” which other trail or trails have you been eliminated from?
    Basically, my question is, are you just making stuff up or what?
    The reason I ask is that these allegations don’t seem to have factual grounding.

  16. Not A Native said:

    I understand Driscoll all too well. “Sharing” is his code word for “You can’t be on land I claim priority over”. Singletrack biking can’t be done safely on trails that horses are on or use. That’s just a fact and Driscoll knows it full well. So his ‘sharing’ actually means no singletrack in the public places Driscoll claims priority because he was there first.

  17. Kevpod said:

    Uri, you are apparently alleging that meetings took place which you were blocked from attending.
    If this is the case, we have a serious problem with public process at City Hall.
    I would like to know which meetings you were kept out of so that I can follow up and find out why this occurred.

  18. Kevpod said:

    Sure. Kevin Hoover, editor at large of the Mad River Union newspaper.

  19. Kevpod said:

    “How would you react if you had been working with the city raising funds sitting on committees and offering at every turn to help build and maintain valuable trial networks in our community forest and then be kept out of meetings that are meant to eliminate your use of favorite trails.”

  20. Kevpod said:

    And I’m still waiting to hear back from you, Uri, about which meetings you were “kept out of.”

  21. Uri said:

    I read this post a couple time to try to make sense of it. It is clear Mr. Not has not understood the main point I am making.
    We need to share trails.
    Why the mtn bike community thinks that they should have exclusive use of community trails has not been made clear. On any of these posts or in any public way.
    Still waiting…..

  22. Not A Native said:

    The arguments that Driscoll makes are the same ones that some motorists try to pass off to block bicycle lanes sharing roadways. What it boils down to is a group has had sole use of public resources for some time and can’t abide with other users gaining access and status to use them. If there is any trail hog, its Driscoll who is essentially asserting squatters rights to public property. That strategy to control land was used 150 years ago, Driscoll is doing it again.

  23. Uri said:

    One of the points I am making is that you are not keeping the community in mind when you are pushing others off trails. There are only so many trails or potential trail alignments.
    I don’t expect everyone to appreciate the nuances of horse but we have encountered hundreds of people over the years that want a picture with our horse or ask if their child can pet them. We enjoy sharing that and obviously it means a lot to those who may not be able to keep horses but are drawn to than anyway.
    But this is not about horse vs bikes. Even though you probably never had a kid want to pet your bicycle. It is about how we share our trails.
    I am going to call it what it is. A selfish trail grab.
    You are wrong there are all sorts of places to use bikes safely. It is just the mentality that you don’t want to do so that is causing you to try to take trails from the rest of us.

  24. Ironoresteel Home said:

    Copied from my letter to the editor:

    Dear Editor,

    I strongly disagree with the tone and message of Uri
    Driscoll’s column in last week’s Union.

    As a hiker and mountain biker I support channeling the
    gravity crowd onto a more appropriate trail. I used to ride regularly on the
    Sunny Brae trail 20+ years ago (before the city purchased it) until the
    unregulated high speed downhill cyclists made it seem dangerous to ride or walk
    uphill. Now that they have an outlet in the new trail, I can safely ride or
    walk up the revamped old trail–a wonderful improvement!

    The mixed use trail model is getting long in the tooth and
    should evolve, as the City of Arcata is doing in the Sunny Brae Forest. Perhaps
    I would be more a fan of all users on the same trails if I belonged to the
    group to which all others are required to defer–the group whose animals are
    allowed to defecate, urinate, and ride on, unfettered by the need to clean up
    after them. As a hiker, being forced to
    stand off the trail while another user group trots by strikes me as
    un-egalitarian and is reminiscent of the serfs tugging at their forelocks while
    the mounted gentry rode by in medieval Europe.

    Although I’m 60 years old and more of a cross country bike rider
    and commuter, I really enjoy riding the new downhill trail. I find it to be
    more intermediate than “black diamond,” and not particularly high speed. With
    the well-designed banked turns and technical features it makes 10-20 mph
    exciting. A ride on this new trail is over quite quickly and then it’s back
    uphill at 5 mph for another go-round. I count three alternative routes back to
    the top with no user conflicts in sight. Thanks to the city, the trail builders
    and the fund raisers–well done!

    I also abhor the implied concept that the Northern California
    Horseman’s Association fund raising efforts should have resulted in their having veto
    power over any aspect of the city’s trail plan. As an Arcata resident and
    homeowner I would say to you “our trails are not for sale to your special
    interest group.” And while I don’t know if this was indeed an “historic horse
    trail,” in more than two decades of use I have never seen a horse (or horse
    poop) on the Sunny Brae trail.

    Steve Jones
    Sunny Brae

  25. dan said:

    I feel cyclists are the ones pushing for more trails and races in the area. We try to keep the community in mind, but there are no places for cyclists to use trails in a safe manner, hence the need for one way trails and bicycle only trails. Horses are animals no matter how hard you train them they are still animals, bicycles can scare horses and put people in danger. They also damage trails when ridden on surfaces not meant to support their weight. We are not taking the trails that are multi-use away from being multi-use, we are simply building trails for the cyclists to use in the the manner in which bicycles were intended for. Fast and efficient.

  26. Kevin Hoover said:

    “and then be kept out of meetings that are meant to eliminate your use of favorite trails.”

    What meetings has anyone been kept out of? I’ve been to all the recent Forest Management Committee meetings.
    I’m usually the only member of the public there. I think there was an HSU student on class assignment at the last one.

  27. Rik Rieder said:

    I do not drink red bull, but one time I had to ride the entire length of single track on trail 10, stuck behind a line of 5 horseback women, all drinking beer as they rode along. They were not interested at all in my respectful request to pass. Rather than force my way through, I chose not to risk causing one of them to be thrown, and had to walk along, staring at a horse’s rear end for like ten minutes. They were kind of smug about themselves when we reached the road, where I told them they owed me a beer.

  28. Uri said:

    Tony and Andrew and the rest of the bike community think on this if you will. How would you react if you had been working with the city raising funds sitting on committees and offering at
    every turn to help build and maintain valuable trial networks in our community forest and then be kept out of meetings that are meant to eliminate your use of favorite trails.
    Keep in mind I have been and remain in support of multi use trails. Some in the bike community who had also been working in that direction are now saying that they don’t want to share our trails but want them for them selves that feels like a betrayal.
    I still don’t get why this trail cannot be a shared use trail. What the city has done is to say even if there are no bikes bombing down it I can’t hike or ride my horse up it. That is just stupid.
    Don’t even get me started on all the illegal eroding trails bikers have all over the community forest and neighboring lands.
    Would you guys be willing to keep your downhill bomber run in exchange for horses and hikers only on the Beith creek loop?
    Again this special facility course and encouraging the use of high speed bike traffic is contrary to existing language in the forest management plan. The city staff obviously overstepped their authority something that was very unlike dealings I have had with them in the past. You are right they are usually very good at building consensus, they just blew it in this case. I and others are just calling them on it.
    I appreciate the dialog and hope it continues. It had been absent which is why we are here now rather than out enjoying our community trails.

  29. Karen Brooks said:

    I am not happy about the movement against multi-use trails on public lands in residential neighborhoods. The SunnyBrae Forest, in particular, was promoted for purchase to save it from logging and expand the Arcata Community Forest. I do not recall any wording that this tract of land would be focused toward one user group and the city could be setting itself for lawsuits as most matching public funds require broad access for recreation.

    A petition, no matter how many signatures, does not negate another user group’s right to access. We all have to advocate for multi-use or risk being excluded all together. I urge the city to “take the high road” and work to bring the community of users together. We are all friends and neighbors and need to work towards a forest we can all enjoy.

  30. Tony Lucchesi said:

    Uri, I took a deep breath before responding as I want to do my best to be respectful of the opinions of others. It didn’t help though. First off, I think the logic is pretty flimsy that decades of trespassing on what was then private property somehow gives the horse community vested rights to the trail in question. The same would be true for all user groups.The City ownership/management of the forest is a new day for us all.

    I have ridden the new trail. When I am out there, I see kids out doing what kids are supposed to do, being outside having fun, not sitting in front of a screen. Your demonization of the mountain biking community might have appealed to your sense of style as a writer, but it just isn’t true. That crazed on Red Bull gambit feels like it’s straight out of Reefer Madness. The trail demographic in Humboldt probably has an average age of about 40. At 59, I raise that average a bit all by myself. We all want to see more kids on trails.

    Your statements that there was some sort of secret cabal between the City and the mountain bike community are just silly. I have known and worked with City officials in all capacities for decades of my own and have never seen them be anything but fair and willing to do whatever it takes to take all interests into consideration.Indeed, the most difficult part of working with the City is that they continually strive for consensus.

    Frankly, your tirade against the mountain bike community does nothing but reflect poorly on yourself and the horse community. It is childish to say that not even ONE trail in the community forest can be designated for bicycles. Please do yourself a favor and visit a town like Ashland Oregon some time to see how successfully the mountain bike community shares with hikers and horseback riders and what their trail network does to vitalize the economy of the City.

    I’m going to cite a conservative personal estimate and say that I have around 50,000 miles of single track trail experience in my life. My experience is that by far the greatest trail damage is done by horses but I still support horses on trails because although it’s not my passion, I recognize that is the passion of others. This is Humboldt County, not Marin. We have room for all.

    It is pointlessly divisive to say that having trails designated for one user group means there are less trails for all. To extend that logic, then NO trails in the forest should be just for hikers and off limits to bicycles because after all, limitations means less trails for all. If this is what you really believe, I will look forward to your supporting this change in City policy.

    I suspect that what this really comes down to is that you’re not looking for fairness, but you’re just anti-fun.

  31. Andrew S. said:


    The above link leads to a petition signed by 200 community members in favor of the creation of Single-Use mountain bike trials. We range from families to college students to retirees. Labeling us as “Red Bull-engorged trail tyrants” is both disingenuous and inflammatory. For years we have shown up to trail work days to help create multi-use trials. We have held numerous events to help raise money for the Ridge Trail and other forest improvements. Just as there are hiker-only trails, we believe the creation of biker-only trails not only addresses one of the largest user groups in the city, but will alleviate pressure from other trails in the system. This is not being done in secret, and this very negative and biased view will not dissuade us from working with other user groups to build a trail system that works for everyone. Your assertion that the creation of single-use trails somehow reduces the number of trails is wrong.

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