North Arroyo Loop Illegal Trail (BLM inventory segment 2P)

When was the North Arroyo Loop (illegally) constructed?

The mountain bike trail “North Arroyo Loop” (red) was constructed on a sensitive ridgeline somewhere between 2019-2020.

This illegal mountain bike trail is still being shared (as of 12/2021) on public social media mountain bike ride-sharing sites, TrailForks.com, and bike club sites, Santa Fe Fat Tire Society.[1]The Santa Fe Fat Tire Society recently removed their sanction on Trailforks.com of some of the illegal trails constructed in the Sombrillo ACEC, although their website still links to maps of these … Continue reading    Recently a YouTube video, Cryptobiotic Crust Wonderland, was shared of riders on this trail, along with other newly constructed illegal trails in the Sombrillo Area of Critical Environmental Concern (ACEC).

These recently built trails traverse fragile sedimentary layers that are protected under the BLM Sombrillo (ACEC).

The white spots on the map link to photos of the damage to the environment from mountain bike activity, and trail construction using tools to dig trail beds and saws to cut pinon and juniper trees.

It is illegal for the public to construct trails using tools like these on BLM lands. The BLM is required to comply with the Federal Land Policy and Management Act (FLPMA) and the National Environmental Protection Act (NEPA).  These laws require the BLM to conduct official environmental assessments and public scoping periods before any trail building occurs.

Please note that this trail was not constructed by the BLM or any other authorized entities.  It was built illegally by some irresponsible mountain bikers, potentially ruining future access to the general area. The BLM is investigating illegal trail building in the Nambé Badlands.

The Friends of the Nambé Badlands encourage local mountain bike clubs and organizations to publicly speak out against illegal trail building and to promote responsible mountain biking.

How can we determine when the illegal trail North Arroyo Loop (BLM inventory segment 2P) was constructed?

Determining when the  “North Arroyo Loop”  illegal trail was constructed is important.

As of May 2012, when the BLM completed the Sombrillo Resource Management Plan, an EIS Record of Decision (ROD) was issued, any new planning and construction of trails in the Sombrillo ACEC would require proposal-specific NEPA evaluation and approval.

Since no additional NEPA assessments and approvals, Findings of No Significant Impacts (FONSI) or Records of Decision (ROD) have been recorded for the Sombrillo ACEC, any trail construction that has occurred since May 2012 has been undertaken without NEPA evaluations and approvals and is therefore illegal[2] See the NEPA definitions here https://www.ecfr.gov/cgi-bin/text-idx?SID=b8e357969cec1b9f0e5b6a7ae1f574f4&mc=true&node=pt40.37.1508&rgn=div5#se40.37.1508_11, contrary to Federal Statute (42 U.S.C. 4321).

The “North Arroyo Loop” illegal trail (BLM inventory segment 2P) was constructed in late 2019.  Evidence shows this illegal trail did not exist in 2011, including:

  • Input and direct observations from long-time users of this area;
  • GPS tagged photographic evidence;
  • Historical aerial imagery;
  • Photographic evidence of freshly cut pinon and juniper trees by those who created these trails; and
  • Evidence from social media and internet postings.

This section compares aerial imagery from 2011 – 2021 with GPS field recorded track data taken in October  2020, to estimate when the trail was illegally constructed.

Can we see North Arroyo Loop (BLM segment 2P) from 2021 aerial imagery?

Yes, you can see the newly constructed trails from aerial imagery collected on 3/2/2021.

The map region covers parts of the two new mountain bike trails constructed between 2020-2021 in the BLM Sombrillo Area of Critical Environmental Concern. The colored tracks on the right-side map are GPS track data collected on 4/24/2021.  The green trail, with BLM GIS segment #62, is a long-existing trail, the section shown here in green is the north end of the “West Loop” trail.  The magenta GPS track to the east was measured on a new trail referred to as “Razor’s Edge” on social media and leaderboard mountain biking sites.  The red-colored GPS track to the west is the new trail referred to as “North Arroyo Loop” on social media.

Is North Arroyo Loop (BLM inventory segment 2P) visible from 2017 aerial imagery?

No, “North Arroyo Loop” (BLM inventory segment 2P) does not appear on aerial imagery collected on 6/10/2017.

The green trail, with BLM GIS segment #62, is a long-existing trail, the section shown here in green is the north end of the “West Loop” trail.

Neither of the trails, “Razors Edge” or “North Arroyo Loop”, existed in 2017, as foot trails, or bike trails.  At that time people respected the fragile ridgelines where these trails now exist. The sedimentary formations along these ridgelines called out to be protected under the BLM Sombrillo Area of Environmental Concern, designated in 1988.

Did North Arroyo Loop (BLM inventory segment 2P) exist in 2015?

“North Arroyo Loop” (BLM inventory segment 2P) does not appear on aerial imagery collected on 11/1/2015.  Locals in the area who have hiked and biked the area for 30+ years verify that “North Arroyo Loop” (BLM inventory segment 2P) is a recently constructed trail (constructed between 2019-2020).

Did these trails exist in 2013?

No.  “North Arroyo Loop” (BLM inventory segment 2P) does not appear on aerial imagery collected on 10/2/2013, and local hikers and bikers confirm these are new trails.

Did these trails exist in 2011?

No.  “North Arroyo Loop” (BLM inventory segment 2P) does not appear on aerial imagery collected on 6/16/2011.  The aerial imagery for this area is somewhat washed out due to the sun angle when it was collected.  For this reason, we have also posted (below) the 2011 imagery on the left, and the 2021 imagery on the right with no GPS tracks.

No, these two mountain bike trails do not appear on aerial imagery collected on 6/16/2011.

Summary Assessment of When North Arroyo Loop (BLM inventory segment 2P) Was Constructed

  1. Aerial imagery proves these trails were constructed after 2017.
  2. The earliest social media post of the North Arroyo Loop trail is 9/20/2019.
  3. Observations by locals who bike and hike the Sombrillo ACEC suggest this trail was constructed between late 2019 and the spring of 2020.
  4. Photographic evidence of freshly trampled vegetation in the middle of the newly constructed singletrack trails indicates recent development.
  5. Photographic evidence of freshly cut tree limbs and green cuttings indicates recent trail construction.
  6. The depth of these trails in the soft soil was minimal when we hiked the trails and GPS photo-documented.
  7. In places where the trails traversed cryptobiotic soil crusts, the trail bed depth was very shallow for such soft and fragile soils.

Our best estimate of when these trails were first constructed, based on these data and observations, is:

  • North Arroyo Loop Trail was constructed in the fall of 2019
  • Razors Edge Trail was constructed in the early fall of 2020.

References

References
1 The Santa Fe Fat Tire Society recently removed their sanction on Trailforks.com of some of the illegal trails constructed in the Sombrillo ACEC, although their website still links to maps of these illegal trails.
2 See the NEPA definitions here https://www.ecfr.gov/cgi-bin/text-idx?SID=b8e357969cec1b9f0e5b6a7ae1f574f4&mc=true&node=pt40.37.1508&rgn=div5#se40.37.1508_11
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