Forest Service rewrites travel rules to open all National Forest roads
Travel Management; National Forest System Lands
Forest Service· National Forest System landsFederal Register 2026-17211 ↗
A new rule would presume every National Forest road and trail is open to motorized use unless proven otherwise.
What’s at risk
Wildlife habitat, sensitive ecosystems, and existing conservation protections across all National Forest System lands are at risk. The rule shifts the burden from justifying access to justifying any closure or restriction, and requires annual review of every closed or restricted route.
If this goes through
If this rule is finalized, the default across all National Forest System lands flips to open motorized access, making it harder for the Forest Service to maintain protections for watersheds, wildlife corridors, and wilderness-adjacent areas.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
10 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The agency explicitly states that no cooperating or participating agencies will be designated, even though the proposed rule affects resources governed by the Clean Water Act, Endangered Species Act, National Historic Preservation Act, and Wilderness Act, which are administered by EPA, FWS, SHPO offices, and other agencies. The section on Cooperating and Participating Agencies says those entities are merely "encouraged to provide input through the public comment opportunities." This forecloses the interagency coordination that NEPA regulations require when a proposed action has effects on resources within another agency's jurisdiction or special expertise. The agency should explain why no cooperating agencies are warranted and, if it proceeds, designate relevant Federal agencies as cooperating agencies before the draft EIS is published.
- The agency provides only a 30-day written-comment period for a nationwide, programmatic rulemaking that will revise the regulatory framework governing motor vehicle use on all 154 national forest units and 20 national grassland units, and explicitly states that no public scoping meetings are planned. For a rulemaking of this scope and complexity, a 30-day window with no in-person or virtual scoping opportunities is inadequate for rural communities, Tribal governments, and members of the public without reliable internet access to participate meaningfully. The agency should extend the comment period to at least 90 days and hold regional scoping meetings or virtual public meetings.
- The notice acknowledges that threatened, endangered, and sensitive species, soil, water, air, scenic integrity, and cultural resources are all expected to be affected, but then immediately defers all meaningful analysis to future site-specific decisions, saying that estimating site-specific effects "would be highly speculative." This is circular: the agency uses the programmatic nature of the rule to avoid analyzing the very resource impacts that a programmatic EIS is designed to evaluate at the appropriate scale. The agency should commit to quantitative or scenario-based analysis of foreseeable resource impacts at the programmatic level before the final rule is issued.
- The proposed rule removes the minimization criteria from subparts B and C, criteria that were the primary substantive tool for limiting resource damage from motorized use. The document says the agency is "exercising its independent statutory discretion" as the basis for this removal, but provides no analysis of what resource protections, if any, will replace the minimization criteria. The agency cites 16 U.S.C. 551 and 7 U.S.C. 1011(f) as authority but does not explain how those statutes supply equivalent substantive standards. The agency should provide a legal and factual analysis demonstrating that removal of minimization criteria is consistent with its statutory duty to protect NFS resources.
Show all 12 points from the document
- The proposed rule establishes a presumption that all existing roads, trails, airfields, and access routes are open to appropriate public use, and states that "commonly available public data sets, including aerial imagery, may be used as evidence that a physical route or airfield exists." However, the document simultaneously acknowledges that aerial imagery alone would not establish Forest Service jurisdiction, legal access, or that a feature is part of the forest transportation system. This creates a direct internal contradiction: the open-unless-closed presumption could apply to routes whose legal status is unresolved, which may expand motorized use onto unauthorized or disputed routes before jurisdiction is clarified. The agency should resolve this contradiction by specifying that the presumption applies only to routes already verified as part of the forest transportation system.
- The document states that over-snow vehicle use maps have been established on only 25 of the estimated 101 units that receive adequate snowfall to warrant over-snow travel management, meaning 76 units lack completed OSVUMs. Despite this large gap, the proposed rule removes the existing framework that was driving completion of those maps without explaining how the revised regulations will ensure the remaining units achieve over-snow travel management planning. The agency should analyze and explain how the proposed rule will address the 76 units without OSVUMs before finalizing the rule.
- The document states that Tribal governments and Alaska Native Corporations will be offered government-to-government consultation "during rulemaking and EIS development," but also states that no cooperating or participating agencies will be designated and that the only current public input mechanism is a 30-day comment period. Meaningful government-to-government consultation cannot be accomplished through a standard public comment process. The document identifies cultural resources, traditional cultural properties, and sacred sites as resources that will be affected, yet provides no timeline, process, or mechanism for Tribal consultation separate from the general comment period. The agency should publish a Tribal consultation plan with specific timelines before the draft EIS is released.
- The document says the purpose of the proposed action is deregulatory and cites E.O. 14408 as a key driver, but also states that the agency is "exercising its independent statutory discretion" separate from the Executive Order. This dual justification creates an analytical gap: if the statutory authority alone justified the changes, the agency should be able to show that the rule would be the same with or without E.O. 14408. Without that showing, it is unclear whether the rule is grounded in a reasoned statutory analysis or is simply implementing a political directive. The agency should provide an independent statutory analysis demonstrating that the proposed changes are warranted under 16 U.S.C. 551 and other cited authorities, separate from the Executive Order.
- The document proposes to exempt class 1 electric bicycles from motor vehicle use designation requirements on trails where bicycle use is allowed, but acknowledges the EIS will analyze alternatives retaining e-bikes as motor vehicles. At the same time, the document says effects of the e-bike exemption "could directly affect" soils, water, plant and animal communities, and other resources. The agency is proposing to make the exemption the default position before the EIS has evaluated those impacts, which inverts the NEPA process by selecting an approach prior to completing environmental review. The agency should not commit to the e-bike exemption as the proposed action until the EIS has completed its comparative analysis of alternatives.
- The document acknowledges that 6 of 154 national forest units and all 20 national grassland units without completed MVUMs still lack motor vehicle use designations after more than 20 years of implementation. Despite this, the proposed rule replaces the existing framework that was intended to drive completion of those maps with an open-unless-closed presumption that would apply on units that never completed travel management planning. The agency provides no analysis of how the presumption will interact with units that have no MVUM baseline, which could result in de facto opening of routes that were never formally designated. The agency should analyze the specific effect of the access presumption on the units lacking completed MVUMs before finalizing the rule.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
The U.S. Department of Agriculture (USDA) is initiating an environmental impact statement and rulemaking to revise the Forest Service's travel management regulations, 36 CFR part 212. The proposed action would establish a uniform national policy favoring increased access while simplifying regulatory requirements and preserving local decision-making. The proposed access rule would establish a national policy with a presumption that existing roads, trails, airfields, trailheads, and other access routes and points on National Forest System lands are open to appropriate public use unless closure or restriction is req…
On the record for this fight
8 people have filed on this fight through PLAN, and 7 have been found on the agency’s own posted comments.
- Roz, Georgia
- Rachael, Oregon
- and 6 readers who haven’t put a name on it yet
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial; switch yours off in your record. All boards
Did the agency answer?
10 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe agency provides only a 30-day written-comment period for a nationwide, programmatic rulemaking that will revise the regulatory framework governing motor vehicle use on all 154 national forest unit
The agency provides only a 30-day written-comment period for a nationwide, programmatic rulemaking that will revise the regulatory framework governing motor vehicle use on all 154 national forest units and 20 national grassland units, and explicitly states that no public scoping meetings are planned. For a rulemaking of this scope and complexity, a 30-day window with no in-person or virtual scoping opportunities is inadequate for rural communities, Tribal governments, and members of the public without reliable internet access to participate meaningfully. The agency should extend the comment period to at least 90 days and hold regional scoping meetings or virtual public meetings.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states that over-snow vehicle use maps have been established on only 25 of the estimated 101 units that receive adequate snowfall to warrant over-snow travel management, meaning 76 units
The document states that over-snow vehicle use maps have been established on only 25 of the estimated 101 units that receive adequate snowfall to warrant over-snow travel management, meaning 76 units lack completed OSVUMs. Despite this large gap, the proposed rule removes the existing framework that was driving completion of those maps without explaining how the revised regulations will ensure the remaining units achieve over-snow travel management planning. The agency should analyze and explain how the proposed rule will address the 76 units without OSVUMs before finalizing the rule.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document says the purpose of the proposed action is deregulatory and cites E.O.
The document says the purpose of the proposed action is deregulatory and cites E.O. 14408 as a key driver, but also states that the agency is "exercising its independent statutory discretion" separate from the Executive Order. This dual justification creates an analytical gap: if the statutory authority alone justified the changes, the agency should be able to show that the rule would be the same with or without E.O. 14408. Without that showing, it is unclear whether the rule is grounded in a reasoned statutory analysis or is simply implementing a political directive. The agency should provide an independent statutory analysis demonstrating that the proposed changes are warranted under 16 U.S.C. 551 and other cited authorities, separate from the Executive Order.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document proposes to exempt class 1 electric bicycles from motor vehicle use designation requirements on trails where bicycle use is allowed, but acknowledges the EIS will analyze alternatives ret
The document proposes to exempt class 1 electric bicycles from motor vehicle use designation requirements on trails where bicycle use is allowed, but acknowledges the EIS will analyze alternatives retaining e-bikes as motor vehicles. At the same time, the document says effects of the e-bike exemption "could directly affect" soils, water, plant and animal communities, and other resources. The agency is proposing to make the exemption the default position before the EIS has evaluated those impacts, which inverts the NEPA process by selecting an approach prior to completing environmental review. The agency should not commit to the e-bike exemption as the proposed action until the EIS has completed its comparative analysis of alternatives.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe agency explicitly states that no cooperating or participating agencies will be designated, even though the proposed rule affects resources governed by the Clean Water Act, Endangered Species Act,
The agency explicitly states that no cooperating or participating agencies will be designated, even though the proposed rule affects resources governed by the Clean Water Act, Endangered Species Act, National Historic Preservation Act, and Wilderness Act, which are administered by EPA, FWS, SHPO offices, and other agencies. The section on Cooperating and Participating Agencies says those entities are merely "encouraged to provide input through the public comment opportunities." This forecloses the interagency coordination that NEPA regulations require when a proposed action has effects on resources within another agency's jurisdiction or special expertise. The agency should explain why no cooperating agencies are warranted and, if it proceeds, designate relevant Federal agencies as cooperating agencies before the draft EIS is published.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe proposed rule establishes a presumption that all existing roads, trails, airfields, and access routes are open to appropriate public use, and states that "commonly available public data sets, incl
The proposed rule establishes a presumption that all existing roads, trails, airfields, and access routes are open to appropriate public use, and states that "commonly available public data sets, including aerial imagery, may be used as evidence that a physical route or airfield exists." However, the document simultaneously acknowledges that aerial imagery alone would not establish Forest Service jurisdiction, legal access, or that a feature is part of the forest transportation system. This creates a direct internal contradiction: the open-unless-closed presumption could apply to routes whose legal status is unresolved, which may expand motorized use onto unauthorized or disputed routes before jurisdiction is clarified. The agency should resolve this contradiction by specifying that the presumption applies only to routes already verified as part of the forest transportation system.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document acknowledges that 6 of 154 national forest units and all 20 national grassland units without completed MVUMs still lack motor vehicle use designations after more than 20 years of implemen
The document acknowledges that 6 of 154 national forest units and all 20 national grassland units without completed MVUMs still lack motor vehicle use designations after more than 20 years of implementation. Despite this, the proposed rule replaces the existing framework that was intended to drive completion of those maps with an open-unless-closed presumption that would apply on units that never completed travel management planning. The agency provides no analysis of how the presumption will interact with units that have no MVUM baseline, which could result in de facto opening of routes that were never formally designated. The agency should analyze the specific effect of the access presumption on the units lacking completed MVUMs before finalizing the rule.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe document states that Tribal governments and Alaska Native Corporations will be offered government-to-government consultation "during rulemaking and EIS development," but also states that no cooper
The document states that Tribal governments and Alaska Native Corporations will be offered government-to-government consultation "during rulemaking and EIS development," but also states that no cooperating or participating agencies will be designated and that the only current public input mechanism is a 30-day comment period. Meaningful government-to-government consultation cannot be accomplished through a standard public comment process. The document identifies cultural resources, traditional cultural properties, and sacred sites as resources that will be affected, yet provides no timeline, process, or mechanism for Tribal consultation separate from the general comment period. The agency should publish a Tribal consultation plan with specific timelines before the draft EIS is released.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe notice acknowledges that threatened, endangered, and sensitive species, soil, water, air, scenic integrity, and cultural resources are all expected to be affected, but then immediately defers all
The notice acknowledges that threatened, endangered, and sensitive species, soil, water, air, scenic integrity, and cultural resources are all expected to be affected, but then immediately defers all meaningful analysis to future site-specific decisions, saying that estimating site-specific effects "would be highly speculative." This is circular: the agency uses the programmatic nature of the rule to avoid analyzing the very resource impacts that a programmatic EIS is designed to evaluate at the appropriate scale. The agency should commit to quantitative or scenario-based analysis of foreseeable resource impacts at the programmatic level before the final rule is issued.
A hole PLAN found in the agency’s own analysis, quote verified against the document
- PendingThe proposed rule removes the minimization criteria from subparts B and C, criteria that were the primary substantive tool for limiting resource damage from motorized use.
The proposed rule removes the minimization criteria from subparts B and C, criteria that were the primary substantive tool for limiting resource damage from motorized use. The document says the agency is "exercising its independent statutory discretion" as the basis for this removal, but provides no analysis of what resource protections, if any, will replace the minimization criteria. The agency cites 16 U.S.C. 551 and 7 U.S.C. 1011(f) as authority but does not explain how those statutes supply equivalent substantive standards. The agency should provide a legal and factual analysis demonstrating that removal of minimization criteria is consistent with its statutory duty to protect NFS resources.
A hole PLAN found in the agency’s own analysis, quote verified against the document
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