Post by tomhedden on Sept 21, 2012 14:02:08 GMT -5
The NJTLC strongly opposes the PPA's proposal to revise The Comprehensive Management Plan by requiring all permitted events to also secure a bond with the county or municipality where the event is occurring. While obvious from the context of the proposal that the PPA is targeting motorcycles, the likely practical application of this revision would unfairly impact any groups applying for Special Use Permits: equestrians, educational groups, scouts...
The PPA justifies their proposal with three key points:
They conclude with "These revisions would hopefully deter the illegal creation and/or expansion of trails and would cover the costs associated with any damages."
While their first point may be true, this has NOTHING to do with the motorcycle events that are covered by Special Use Permits. These events (when they are run and what route they follow) are thoroughly reviewed by the Pinelands Commission and the NJ DEP. The courses are simply not allowed to enter sensitive areas.
The second point is totally untrue. There are probably only between eight and twelve applications for Special Use Permits filed in any given year for motorcycle events. The State Forest staff and the Park Police are present during the events (often this includes the Superintendent) and they do check that the host organization has done a thorough clean up after the event is over.
The third point is also untrue. Prior to an enduro, the hosting club does ride the course to ensure that it is safe and clearly marked. However, there are very specific rules in place preventing riders from other clubs from "practicing on the course" or carrying a GPS unit to map the course so they could return later. Not only is this strictly enforced as a competition rule, it's part of the culture of the sport to keep the courses off-limits during the rest of the year. Much of the enduro world has to rely on an honor system and this point is one of its key facets. While there may be people riding old enduro courses, they are not likely to be a part of the permitted hosting club or even enduro riders. It is more likely that they are simply trail-riding and have no connection to any organized event.
In truth, this proposal would actually have the exact opposite effect from the stated "hope" of The PPA.
The second aspect of the PPA's conclusion contains an uncomfortable implication for both the enduro clubs and impacted counties and municipalities. The assessment of blame for "damages" could be quite subjective and create justification for lawsuits. This is completely unfair to the counties and municipalities and by extension the taxpayers who fund them and pay their legal fees. The real "hope" of the PPA would appear to be offsetting the positive economic impact of the commerce generated by enduros with the possibility of increased legal fees to township and county solicitors. In the opinion of the NJTLC, that would be the reason for suggesting that these entities (who have no say in the course planning or jurisdiction over any clean up or remediation) hold the bond.
Organized, permitted events are NOT the problem. The NJTLC encourages The PPA to focus their efforts on steps that would actually mitigate the damage being done by illegal and irresponsible activity.
The PPA justifies their proposal with three key points:
- "Off-road Vehicles have caused significant damage throughout the state-owned lands..."
- "The Pinelands Commission spends an enormous amount of time reviewing dozens of enduro/motorcycle race permits for natural resource impacts. Typically, these permits have been granted for NEW trails, and do not require review by anyone on the commission staff or by state forest staff following the race to ensure that the maps were followed and damages were not incurred."
- "There is plenty of evidence to show that enduro event trails are continuously used throughout the year after events have ended."
They conclude with "These revisions would hopefully deter the illegal creation and/or expansion of trails and would cover the costs associated with any damages."
While their first point may be true, this has NOTHING to do with the motorcycle events that are covered by Special Use Permits. These events (when they are run and what route they follow) are thoroughly reviewed by the Pinelands Commission and the NJ DEP. The courses are simply not allowed to enter sensitive areas.
The second point is totally untrue. There are probably only between eight and twelve applications for Special Use Permits filed in any given year for motorcycle events. The State Forest staff and the Park Police are present during the events (often this includes the Superintendent) and they do check that the host organization has done a thorough clean up after the event is over.
The third point is also untrue. Prior to an enduro, the hosting club does ride the course to ensure that it is safe and clearly marked. However, there are very specific rules in place preventing riders from other clubs from "practicing on the course" or carrying a GPS unit to map the course so they could return later. Not only is this strictly enforced as a competition rule, it's part of the culture of the sport to keep the courses off-limits during the rest of the year. Much of the enduro world has to rely on an honor system and this point is one of its key facets. While there may be people riding old enduro courses, they are not likely to be a part of the permitted hosting club or even enduro riders. It is more likely that they are simply trail-riding and have no connection to any organized event.
In truth, this proposal would actually have the exact opposite effect from the stated "hope" of The PPA.
- Bonding will force the clubs to increase fees to cover costs and liabilities. Forcing the fees for events to increase will drive riders from participating and encourage them to ride independently, seeking new trails on their own. The NJTLC's position is that there will be a far smaller environmental impact from 300 riders on one approved trail than from five or six riders on sixty different trails which they find themselves.
- It appears that the PPA is trying, through financial hardship, to eliminate enduros from the Pinelands. While they may not care that this plan is regressive and cruelly targets the poor and unemployed first, they should note that stopping organized riding will also remove the Pinelands Commission and the NJ DEP from the planning process and encourage independent riding. This will, without question, "increase the creation and/or expansion of trails".
The second aspect of the PPA's conclusion contains an uncomfortable implication for both the enduro clubs and impacted counties and municipalities. The assessment of blame for "damages" could be quite subjective and create justification for lawsuits. This is completely unfair to the counties and municipalities and by extension the taxpayers who fund them and pay their legal fees. The real "hope" of the PPA would appear to be offsetting the positive economic impact of the commerce generated by enduros with the possibility of increased legal fees to township and county solicitors. In the opinion of the NJTLC, that would be the reason for suggesting that these entities (who have no say in the course planning or jurisdiction over any clean up or remediation) hold the bond.
Organized, permitted events are NOT the problem. The NJTLC encourages The PPA to focus their efforts on steps that would actually mitigate the damage being done by illegal and irresponsible activity.