Razor’s Edge and North Arroyo Loop Illegal Trails

When were they constructed, and are they authorized trails?

The mountain bike trails, “Razor’s Edge” (magenta) and “North Arroyo Loop” (red) were constructed on the tops of ridgelines somewhere between 2019-2020.  They are shared 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 these trails, along with other newly constructed trails in the Sombrillo Area of Critical Environmental Concern.  These recently built trails traverse fragile sedimentary layers inside the “Tesuque Formation” that are rich in mammalian fossils from the Miocene Epoch.  Usage of these unauthorized trails by mountain bikers has boomed in the past year.

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 to construct trails using tools like these on BLM lands.

Environmental Damage Between 2019-2021 on These Unauthorized Trails

How can we determine when these trails were constructed?

Determining when the “Razor’s Edge” and “North Arroyo Loop” trail were 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 Area of Critical Environmental Concern 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 Area of Critical Environmental Concern, any trail construction that has occurred since May 2012 has been undertaken without NEPA evaluations and approvals[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).

Among the trails that have been constructed since 2011 are “Razor’s Edge” and “North Arroyo Loop.” Evidence shows they 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 on April 24, 2021, to document the trails constructed without NEPA evaluation and approval.

Can we see these trails 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.

Are these trails visible from 2017 aerial imagery?

No, these two mountain bike trails do 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 these two new 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 are rich in fossils of mammals from the Miocene Epoch (23.0 Ma – 5.3 Ma).

Did these trails exist in 2015?

No, these two mountain bike trails do 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 these trails did not exist in 2015.

Did these trails exist in 2013?

No, these two mountain bike trails do 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, these two mountain bike trails do 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, I 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.

Evidence on Social Media and Competitive Leaderboard Apps

Photos from Social Media

Summary Assessment of When These Trails Were Constructed

  1. Aerial imagery proves these trails were constructed after 2017.
  2. The earliest social media post of the North Arroyo Loop trail was made on 9/20/2019.
  3. The earliest social media post of the Razors Edge trail was made on 2/18/2021.
  4. Observations by locals who bike and hike the Sombrillo ACEC suggest the trails were constructed between late 2019 and 2021.
  5. Observations of trail construction signatures made in 10/11/2020 showed that the persons constructing the trail intentionally hid the start of the Razor’s Edge trail from the line of sight from the existing Main West Loop (BLM Segment 62).  Evidence of excavation of the trail bed in the ridgeline was not observed until the new trail could not be seen from the popular trail segment #62.  Once out of sight from trail segment #62, the evidence of recent trail construction using picks, shovels, and saws to cut trees was significant and photo-documented.
  6. Photographic evidence of freshly trampled vegetation in the middle of the newly constructed singletrack trails indicates recent development within the past 1-2 years.
  7. Photographic evidence of freshly cut tree limbs and green cuttings also indicates recent trail construction.
  8. The depth of these trails in the soft soil was minimal when we hiked the trails and GPS photo-documented.
  9. In places where the trails traversed cryptobiotic soil crusts, the trail bed depth was also 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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