The USFS Travel Management Rule Is Being Rewritten

Advocacy

September 18, 2026

What Travel Management Means For The Trails We Ride And Maintain, And How To Ensure Your Voice Is Heard.

Summary

The U.S. Forest Service has issued a Notice of Intent to rewrite the Travel Management Rule, shifting toward an “open unless closed” framework for motorized recreation. While this update introduces modernization—such as clarifying Class 1 pedal-assist e-bike access and expanding adaptive equipment options—it also poses challenges around maintenance backlogs, safety standards, and local trail stewardship.

The USFS is accepting public comments through September 23, 2026. See instructions below to submit your comments.

The Forest Service has announced a plan to rewrite the rule governing motorized travel on National Forest System lands. This is our detailed analysis of the NOI and its implications for the mountain biking and trail stewardship communities. Comments close September 23, 2026.

First and foremost, this is a revision, not a repeal of the Forest Service Travel Management Rule. The proposal as it stands would make significant changes to how the Forest Service approaches access, route designations, mapping, annual review, and local decision-making with regards to motorized recreation. This will have spillover effects.

Some of those changes could improve access for mountain bikers and other trail users. Others could make access decisions less predictable, weaken the connection between access and stewardship, or put additional burdens on already-stretched Forest Service districts and the volunteers who help maintain their trails.

Second, note that the USFS’s recent announcement is a Notice of Intent (NOI)—not final policy. That will come next spring when the agency releases the Draft Environmental Impact Statement, as occurred with the Roadless Rule. As with all planning and policy changes, the devil is in the details.

CAMTB Supports a Modernized Travel Management System With Durable Access

That means better maps, sensible treatment of Class 1 pedal-assist bicycles, improved access for people using adaptive equipment, meaningful local decision-making, adequate maintenance, clear standards, and public involvement in decisions that change the character of trails.

Our white paper contains the full analysis, and your organization can adapt our model comment letter for member organizations.

Here are the issues we think California mountain bikers and trail stewards should understand.

The Proposed Travel Management “Open Unless Closed” Approach is the Biggest Change

The NOI proposes a national presumption that existing roads, trails, areas, airfields, trailheads, and other access routes or points are open to appropriate public use unless closure or restriction is required by law, another governing instrument, or supported by specific, documented and justifiable reasons.

CAMTB is concerned about changing the starting point from deliberate designation to presumed openness.

This is not a motorized-versus-non-motorized fight. A mapped, authoritative system tells every user where a particular form of travel is allowed. It also gives land managers a clear and defensible basis for managing conflicts, protecting resources, and communicating with the public.

A presumption of openness could instead create uncertainty over which physical routes count as “existing,” whether a route is actually part of the managed transportation system, and what happens when a district does not have the capacity to review it. CAMTB’s maintains a position that changes should be deliberate, documented, and grounded in actual conditions on the ground.

Undocumented Routes should be Evaluated—Not Automatically Opened

One of the NOI’s important questions is how broadly the Forest Service should define an “existing” route.

CAMTB supports a process that allows legitimate undocumented access routes and unmet access needs to be identified and evaluated. But a physically visible route is not automatically an appropriate permanent Forest Service transportation route.

Some informal routes were created because an established route became impassable. Others may never have been evaluated for drainage, slope stability, habitat, cultural resources, or conflicts with other users.

Our position is straightforward: give legitimate routes a path to evaluation and designation, but do not turn years of unauthorized route creation into presumed authorization.

Open On Paper Does Not Mean Passable on the Ground

The Forest Service has substantial unmet maintenance needs across the transportation system it already manages. Its FY 2026 deferred-maintenance reporting identifies approximately $11.4 billion in deferred maintenance, while also noting that the agency cannot reliably estimate deferred maintenance for high-clearance and closed roads. Those categories matter because they could be affected by the proposed presumption of openness.

Congress has also documented major unmet trail-maintenance needs. The underlying statutory findings draw on older GAO data, so they should not be mistaken for a 2026 snapshot—but they remain relevant to the question of whether new access expectations can be created without addressing maintenance capacity. The practical lesson is simple: declaring a route open does not repair it.

On California’s national forests, fire, floods, debris flows, and storms can change trail and road conditions dramatically. A route that was passable when it was designated may later have failed drainage, washed-out tread, unstable slopes, or a missing crossing. Our member organizations see those conditions firsthand. That’s why CAMTB is asking the Forest Service to tie any presumption of openness to routes that have actually been verified as maintained and passable for the use in question.

Annual Review Requires Real Capacity

The proposal would require annual reviews of closed or highly restricted routes and other access points, while also considering additional routes and updating maps. The NOI conditions that review on available appropriations.

That raises a basic question: What happens when a district does not have the staff or funding to complete the review?

CAMTB does not want an administrative backlog to determine public access. A route should not become open simply because a district could not get to the paperwork. The Forest Service should have the people, funding, and field capacity necessary to carry out whatever new responsibilities the final rule creates. The Draft EIS should evaluate those costs and the activities that could be displaced by them.

Keep A Real Framework For Safety, Conflict, And Resource Protection

The NOI proposes changes to the designation criteria that have guided travel-management decisions for years. CAMTB recognizes that those criteria have not always produced the outcomes that recreationists want, and we support giving responsible officials more flexibility to develop forest-specific solutions. But flexibility should not mean the absence of standards. Land managers still need a clear framework for considering resource effects, public safety, conflicts among users, and the physical characteristics of a route.

For mountain bikers, that’s important because we depend on thoughtful trail design and management too. A blind corner, narrow sidehill traverse, steep exposure, or mixed-speed trail can create predictable conflicts even before an injury occurs.

Good trail management is preventive. The Forest Service should retain the ability to respond to reasonably anticipated conditions, supported by documented site information and professional judgment.

Volunteers Are Part of the Infrastructure

There is another reason this matters to CAMTB and our member organizations: we are not just trail users. We are trail stewards. Volunteers and partners completed more than 60 percent of Forest Service trail-maintenance work in 2025, maintaining nearly 26,000 miles of trail.

CAMTB member organizations have long-standing maintenance agreements and partnerships with Forest Service districts. Many volunteers spend years building tread, repairing drainage, clearing fallen trees, restoring routes, and helping keep particular trails open and sustainable. That work depends partly on knowing what kind of trail the Forest Service asks the organization to steward. A sudden change in authorized use or trail character could affect a volunteer organization’s maintenance plan, equipment needs, volunteer participation, or willingness to renew a partnership. The Forest Service should recognize that as an operational consideration, not simply as a matter of volunteer sentiment.

Class 1 Pedal-Assist: Yes to the Fix, But Keep it Separate

CAMTB supports the proposed treatment of Class 1 pedal-assist bicycles as non-motorized for the purposes addressed by the rule. A Class 1 e-bike provides assistance only while the rider is pedaling and stops providing motor assistance at 20 miles per hour. The Forest Service currently manages Classes 1, 2, and 3 as motor vehicles, with site-specific decisions governing where they may be used. The proposed Class 1 provision would be a targeted modernization. But we want to be clear: support for this provision is not support for a general open-by-default approach.

CAMTB also wants the Forest Service to clarify exactly how the Class 1 provision would work. Would it apply automatically on trails where bicycles are already allowed, or would each unit have to take an additional action? What environmental-review process would apply? What would the role of stakeholders be? Those questions should be answered in the final rule.

Better Access for Adaptive Equipment

CAMTB also supports the proposed authorization for low-powered electric mobility devices used by people with mobility disabilities. This is an opportunity to make access more predictable for people who rely on adaptive equipment while giving land managers objective standards they can actually administer.The Forest Service should use the existing Americans with Disabilities Act framework for Other Power-Driven Mobility Devices (OPDMDs) as a model rather than creating an entirely separate system.

The criteria should focus on observable characteristics such as device type, dimensions, power, and assisted speed rather than requiring field personnel to inquire into a person’s medical condition. The agency is still developing the details, creating an important opportunity for adaptive equipment users and supporting organizations to participate in the rulemaking.

Several other provisions deserve attention

Key terms are undefined. Words such as “minor,” “clerical,” “iterative,” “substantive,” and “local” could determine whether the public is involved in a decision. CAMTB believes the agency should define those terms in the rule and subject them to public comment. The Forest Service should not treat a change in authorized use type or trail character as “minor” simply because it affects a small number of miles.

Areas are different from routes. The proposed presumption would reach areas as well as roads and trails. Area designations can authorize travel across a broad landscape rather than along a defined alignment, making resource and user-conflict effects harder to bound and manage. CAMTB therefore recommends excluding areas from any presumption of openness.

Travel decisions should remain consistent with forest plans. The NOI would clarify that travel-management decisions are distinct from the procedures used to develop or revise land-management plans. CAMTB believes that distinction is appropriate, but route-level travel decisions should still conform to applicable forest-plan direction.

Public involvement should remain meaningful. Core requirements concerning public participation and monitoring should not simply migrate into agency directives where they can be changed without the same public process.

Better maps are a clear improvement. CAMTB strongly supports implementing Section 127 of the EXPLORE Act, which requires digital, downloadable motor-vehicle and over-snow vehicle use maps. We want those maps to use open, machine-readable data standards so that public agencies, trail organizations, accessibility organizations, and mapping applications can distribute accurate information—including information that works offline.

What You Can Do Now and Next Spring

This is a rulemaking, and your firsthand experience matters.

Please read the CAMTB white paper, then adapt the model comment letter for member organizations or write your own.

Please do not submit the model letter unchanged.

The most valuable thing your organization can add is information that the Forest Service cannot get from a regional template:

Name your forest and district.
Identify specific trails or roads.
Describe actual maintenance or safety conditions you have observed.
Give your volunteer hours and number of active volunteers.
Describe your maintenance agreement or partnership.
Explain what a change in authorized use would mean for your organization.
Identify specific locations where trail width, sight distance, grades, exposure, or closing speeds create foreseeable conflicts.

A focused comment about one forest and several trails you know well can be more useful than a generic statement about every national forest.