On Jun 16, 2026, at 11:20 PM, Serge Issakov <serge....@gmail.com> wrote:Dear Jordan,
As Secretary of the California Association of Bicycling Organizations (CABO), and with CABO President Jim Baross CC'ed, I am writing to convey our organization’s strong opposition to SB 569.
- CABO favors local control over local issues, as elected officials are best positioned to address them directly. SB 569 creates unnecessary and costly hurdles for local governments, forcing them to overcome significant bureaucratic obstacles to remove infrastructure elements they have determined cause more problems than they solve.
- One of the most significant obstacles created by this bill is the requirement for findings that are prohibitively difficult, and probably impossible, to determine. Showing that "the proposed postremoval corridor design is not predicted to result in an increase in the frequency or severity of crashes involving vulnerable road users" might sound easy, but is in fact practically impossible to prove. For example, no methodology predicted the carnage—at least 40 crashes, including one death—that resulted from the Class IV bikeway built on south Cardiff 101 in 2020. No such methodology exists. Too many factors and variables are at play. CABO opposes requiring anyone to prove something that is likely impossible.
- The network continuity requirement in 891.6(b)(1) is at least as challenging to meet. The referenced "level of stress analysis" is highly subjective. Many argue that the aforementioned section of 101 in Cardiff is more stressful for cyclists now than it was before the creation of the Class IV bikeway. How exactly is this measured?
- Other factors are important too. If a given bikeway project does not significantly increase bike usage or show any safety improvements, but creates community problems—like limited parking or impacting traffic, including for emergency and delivery vehicles—local leaders should be allowed to consider those factors when deciding whether to remove the bikeway. SB 569 would prohibit them from doing so.
Best regards,
Serge IssakovCABO Secretary
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