Millions of Trail Users at Risk: 93 Organizations Warn Forest Service Against Upending Longstanding Trail Access Rule

Submitted Comments

 

Silver Spring, MD – September 24, 2026

 

A far reaching coalition of 93 trail organizations, user groups, businesses, and government agencies representing the interests of millions of non-motorized, motorized, and mixed-use trail users across 32 states are calling on the Forest Service to maintain the five decade long practice that has provided guardrails for permitted trail uses on the 165,000 miles of trails across the National Forest System. 

 

The “closed unless designated open” principle has provided clarity to hikers, horseback riders, off-road vehicle enthusiasts, mountain bikers, and everyone in between on where to expect these use types in order to avoid user conflict and unsafe conditions. The Forest Service proposal to flip this on its head and allow all trails to be open to motorized uses unless specifically closed puts all motorized and non-motorized users at risk. 

 

The USDA Forest Service just closed the comment period on a Notice of Intent to update the longstanding Travel Management Rule (adopted in 2005). American Hiking Society, American Trails, and Back Country Horsemen of America along with 88 others are leading efforts to call on the Forest Service to maintain the parts of the framework of the Travel Management Rule that preserve the “closed unless designated open” criteria and the public process while modernizing other key components. 

 

Key Organization Leaders Statements

 

“Horse riders object to the reversal of a core principle contained within the 21-year-old Travel Management Rule that allows motorized use only on trails and routes that are formally designated as open to motorized travel,” said Craig Ferdig, Chairman of the Back Country Horsemen of America. “The proposal by the Department of Agriculture would reverse that. Going forward, motorized trail use automatically would be authorized on any trail, unless there is adequate justification not to do so. That would lead to a chaotic situation in which the safety of all national forest trail users would be put at risk.” 

 

"We appreciate that the Forest Service chose to update the Travel Management Rule rather than repeal it, but flipping the long-standing default from 'closed unless designated open' to 'open unless designated closed' would move the burden to the wrong side of the process for every trail user," said Mike Passo, Executive Director of American Trails. "This isn't a motorized-versus-non-motorized issue; it's about whether trail decisions hold up. Hikers, equestrians, mountain bikers, OHV riders, and snowmobilers all depend on trail decisions that are predictable, transparent, and safe. A faster process that produces more errors, more disputes, and less public input doesn't serve anyone." 

 

“The 63 million strong hiking community has relied on five decades of precedent to safely recreate on Forest Service trails. Upending the foundational principle that guides all users will result in the harm and a loss of enjoyment by motorized and non-motorized users alike” said Tyler Ray, Senior Director for Programs and Advocacy, American Hiking Society “The Forest Service should modernize the Travel Management Rule while also maintaining the longstanding practices that have mitigated user conflicts and enhanced safety by building on 50 years of shared understanding for what trails are open to what use types.”

 

Main Areas of Concern with Proposed Changes to the Travel Management Rule

 

Flipping 50 Years of Policy on Its Head and Opening the Flood Gates for User Conflicts and Safety Concerns

 

The Forest Service proposes replacing the TMR's foundational default that trails are closed to motorized use unless specifically designated as open. Going forward, trails would be presumed to be open to motorized use unless specifically designated as closed. This change would reignite the motorized vs. non-motorized feud that the 2005 Travel Management Rule has made great strides towards tampening down by reinforcing the shared understanding amongst all use types. 

  

Curtailing Public Input in Trail Access Decisions

 

The proposal would make "Minor, clerical, or iterative" changes exempt from environmental review and public comment, only requiring “substantive change” to go through a public process. These terms are currently undefined and could result in significant access changes bypassing the collaborative process that's built public trust in travel planning since 2005.

 

Volunteer Trail Maintenance at Risk

 

Volunteers conduct about 60% of trail maintenance on national forests each year. Many maintain specific non-motorized trails because they trust the experience will stay non-motorized. Removing that certainty could cause volunteers to walk away from maintenance agreements — a real threat to trail upkeep capacity, independent of the rule's other effects.

  

An Unfunded Mandate: Severely Limited Staffing and Funding Asked to Do More 

 

Proposed annual reviews across 174 forest units (154 forests + 20 grasslands) would require significant new staff time, mapping  work, public engagement, and environmental analysis — with no cost estimate or dedicated funding identified, raising feasibility concerns given the Forest Service's current budget constraints.

 

The Ask Isn't "No Change" — It's "Don't Lose the Safeguards"

 

Notably, our letter doesn't oppose reforms. It asks for a transparent, recurring, collaborative review process that keeps all user groups at the same table, while preserving the safety, resource-protection, and conflict-reduction functions the current criteria serve.