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Act Now to Oppose Electric Bikes in the Middlesex Fells

ACTION ALERT: It’s not too late to oppose electric bikes in the Fells

The Department of Conservation and Recreation (DCR) is still considering a regulation change that could allow Class 1 (pedal-assist) electric bicycles access to all DCR trails currently open to traditional mountain bikes, including most fire roads, the Mountain Bike Loop, and the single-track Reservoir Trail in the Fells. 

We have been encouraged that our lobbying on this topic has resulted in further discussion with DCR and EEA staff and they have indicated they are re-evaluating their position. Thanks to more than 100 Fells supporters who provided public comment so far — your outreach to state officials has made a difference!

While we know a re-evaluation is underway, we have still not been assured that DCR’s e-bike regulations will prioritize visitor safety and environmental protection, so we still need more voices to stand up for the Fells. 

It’s not too late to make your voice heard

Email the following state officials and tell them, “e-bikes should not be allowed in the Middlesex Fells”. Feel free to personalize with additional comments.

Please also copy (via email “CC” line) Friends of the Fells at action@fells.org, so we can keep track of public comment on this issue.

 

Trail Damage and Tracks

We’ve recently learned that DCR is on the verge of a regulation change that would allow Class 1 electric bicycles access to all DCR trails currently open to traditional mountain bikes, including most fire roads, the Mountain Bike Loop, and the single-track Reservoir Trail in the Fells.

DCR’s rule change is patterned after National Park Service regulations enacted in the fall of 2020 based on bike industry-sponsored research and currently being challenged in court by Public Employees for Environmental Responsibility (PEER.org), an organization of national park service professionals.

We recognize that e-bikes can be a climate-friendly transportation option for people to commute, recreate, and promote physical and mental health. However, DCR’s proposed approach to regulating e-bikes does not adequately address safety issues and environmental impacts.

 

Why allowing e-bikes in the Fells is a bad idea

  • Operating e-bikes on natural surface trails is likely to increase safety risks for riders and other park users. E-bikes allow riders to travel faster than they could otherwise, potentially increasing risks to other trail users. We also believe many natural surface trails are too narrow for safe shared e-bike use.
  • Operating e-bikes on natural surface trails is highly likely to accelerate environmental damage in sensitive areas of the Fells, including vernal pools and rare native plant communities.
  • DCR lacks the capacity to enforce this new use on its properties. DCR’s enforcement capacity is virtually non-existent today. Distinguishing between classes of e-bikes, speed limits, and halting the potential proliferation of unauthorized trails is beyond its capability.
  • DCR claims their proposed regulations follow the National Park Service (NPS) rulemaking on e-bikes. NPS e-bike policy grants park supervisors broad authority to regulate e-bikes, including banning them if they determine they are incompatible with park operations. However, DCR is expected to issue a blanket regulation allowing Class 1 e-bikes on all DCR trails where traditional bikes are currently allowed. We believe DCR park managers and the public should have a say in evaluating whether e-bikes pose unacceptable safety and environmental risks to their parks, and urge DCR to follow NPS in evaluating e-bike use on a park level, taking into account specific site conditions.

DCR has not yet finalized their e-bike regulations, so there’s still time to make your voice heard. DCR does not plan to provide the public with an opportunity to comment on the current draft of this rule change before it is enacted, so your voice is urgently needed today.

Thank you for joining us in protecting the Fells and its visitors.

Jeff Buxbaum
Board Chair

Chris Redfern
Executive Director


Additional background information on DCR’s anticipated e-bike regulations

  • Friends of the Middlesex Fells Reservation and 18 nonprofit and DCR friends groups across the Commonwealth wrote a letter last spring urging DCR to properly analyze safety risks and environmental impacts of e-bikes, and to enact regulations it originally proposed in 2019 that prohibited Class 1 electric bicycles on natural surface trails. The letter asked that analysis include suitability of trail segments to accommodate e-bikes safely, enforcement capacity, impact on other users, erosion, habitat degradation, wildlife disturbance, and cumulative impacts to the natural environment. To date, DCR has not provided evidence that they have conducted any risk analysis prior to opening up parks to e-bike use.
  • DCR’s proposed e-bike regulation is patterned after National Park Service regulations enacted in the fall of 2020 using bike industry-sponsored research as a justification. These regulations were quickly challenged in court by Public Employees for Environmental Responsibility (PEER.org), arguing that the National Park Service has not adequately studied safety risks and environmental impacts. On June 30, 2021, the National Park Service responded by rescinding their order on e-bikes and asked park supervisors to re-evaluate allowing e-bikes in their parks.
  • The U.S. Department of Transportation/Volpe Center has begun a research study on the impact of e-bikes to provide guidance to the National Park Service and other federal and state agencies, noting that there is a “dearth of data or research to support science-based management of e-bikes on trail and transportation infrastructure on public lands”. This study will conclude in June 2022. We urge DCR to partner with Volpe Center and/or other partners to conduct observational studies to better understand the safety and ecological impacts of e-bikes on natural surface trails in the Fells and other DCR properties before promulgating new e-bike regulations, and commit to a science-based approach to managing this new recreational use that protects visitor safety and natural resources.
  • E-bikes allow people with physical limitations to enjoy the recreational and health benefits of riding a bike. And, they are an increasingly popular climate-smart transportation option. However, given DCR’s inability to adequately monitor and prevent the current unpermitted uses of traditional bikes, its proposed approach to regulating e-bikes does not address safety issues and environmental impacts of allowing e-bikes on natural surface, multi-use trails.