Restoring Access to America’s Public Lands

Recommendations for Reform of the U.S. Forest Service Travel Management Rule

Trails Preservation Alliance | coloradotpa.org

Background

Prior to 2005, roads and trails on federal public lands were generally open for all uses unless specifically posted as closed, so long as those uses complied with the governing land use plan. This “open unless posted closed” standard—rooted in long-standing common law and public access principles—mirrors the way Americans use every other public road and sidewalk, and it provided widespread, legal access to roads and trails for hiking, biking, hunting, angling, and motorized recreation.

The U.S. Forest Service reversed that presumption when it issued its 2005 Travel Management Rule, declaring all routes closed to motorized use unless affirmatively designated open. The change had no grounding in statute; it was purely administrative. The Rule was intended to protect existing open routes and eliminate illegal, user-created trails. After two decades of implementation, it has done the opposite: legal, long-used system routes have vanished from official maps while access has steadily declined even as demand for motorized recreation has grown.

The Problem

The consequences of the closed-unless-open presumption are now well documented:

• Widespread closures of legal routes. Of the 28,351 miles of trails in Colorado, only 8 percent are open to motorcyclists, and nearly 50 percent of Colorado’s public land is restricted from motorized use—a share that grows with each new designation.
• Inventory failures that close trails by default. The Forest Service has repeatedly failed to identify existing system trails when conducting the initial inventories required for Travel Management Plans. As plans have been revised, route inventories—the starting point for every plan—have shrunk, not because trails were closed for good reason but because they were overlooked. Long-used legal routes have been dropped from Motor Vehicle Use Maps and closed by default, without ever being acknowledged, evaluated, or subjected to public comment. Because Travel Management Plans rely on existing inventories as their baseline, every omitted route disappears from future planning unless independently rediscovered. Errors therefore compound over time, resulting in a continual reduction of legal access even where no affirmative decision to close a route was ever made. This pattern has repeated across the West.
• Overconcentration of use. A growing number of users are pushed onto an ever-shrinking network of routes, concentrating impacts on the trails that remain open and fueling a cycle of further closures.
• Lost access for every use that depends on motorized travel. Virtually all use of public lands depends on motorized access. Current policy closes the door not only to recreation but to hunting and the retrieval of legally harvested game, angling, wildfire prevention and suppression, fuels reduction, search and rescue, and routine land stewardship. Roads closed for emergencies routinely stay closed for years after the emergency has passed.
• Economic harm to rural communities. In Colorado alone, off-highway vehicle recreation contributed $2.9 billion to the economy in 2024 and supported nearly 18,700 jobs. Recreation-dependent communities take the hit as access declines.

These outcomes are inconsistent with the multiple use mandates Congress imposed on the Forest Service through the Multiple Use Sustained Yield Act, the National Forest Management Act, and the Organic Act of 1897, which direct that the national forests be managed for a balanced combination of uses—including recreation, wildlife and fish, watershed, range, and timber—for present and future generations.

Recommendations

The Trails Preservation Alliance recommends that the U.S. Forest Service repeal Subpart B—Designation of Roads, Trails, and Areas for Motor Vehicle Use—of the 2005 Travel Management Rule and adopt the following reforms as it revises its travel management regulations and policies.

1. Restore the presumption that routes are open unless posted closed.

State plainly in regulation that National Forest System roads and trails designated for motorized use are open unless specifically designated and signed closed. This restores the pre-2005 standard, aligns agency policy with the public’s reasonable expectations, and complies with the multiple use mandates of the agency’s authorizing statutes. Do not re-open cross-country travel by OHVs (which was allowed prior to the 2005 rule).

2. Maintain functional trail networks.

Travel management decisions should evaluate the connectivity of motorized route systems. Closing a single route that isolates large portions of an otherwise usable network should be avoided unless no reasonable alternative exists. Route networks should be managed as integrated systems that provide meaningful recreational, administrative, and emergency access.

3. Hold closures to a clear evidentiary standard.

Permit restrictions on motorized access only where a need is identified based on clear and convincing evidence of resource protection or public safety concerns. Closures should be a documented management decision—not the default result of administrative oversight, incomplete inventories, or unexamined assumptions.

4. Require transparency for every closure.

Every closure should be (a) clearly signed on the ground at the points where the restriction begins and ends; (b) depicted on updated official maps available in both digital and printed form; and (c) subject to public notice in the Federal Register and at least one local newspaper, with a minimum 30-day comment period. Users acting in good faith should never face federal violations for riding a well-established route that carries no indication of closure.

5. Keep closures narrow, temporary, and regularly reviewed.

Apply every restriction to the smallest area, and for the least amount of time, practicable. Review each closure at least every five years to determine whether it remains justified. Emergency closures should remain available to land managers—but routes must be reopened within a reasonable time once the emergency has passed, ending the practice of indefinite “temporary” closures. Expired closures should automatically terminate unless affirmatively renewed.

6. Fix the inventory problem at the root.

Require complete, accurate, and publicly verifiable inventories of existing roads and trails before any Travel Management Plan is developed or revised. Under NEPA, the no-action alternative must accurately capture on-the-ground conditions; the agency may not under-report existing motorized routes or treat temporary restrictions as the baseline. Routes omitted from an inventory should never be closed by default without ever having been evaluated.

7. Commission independent, third-party route inventories.

The agency should not grade its own homework. The Forest Service should commission qualified third parties—state OHV and trails programs, counties, recreation organizations, and independent GIS contractors—to inventory and verify existing routes before travel management planning begins, drawing on historical Forest Service and USGS maps, aerial and satellite imagery, GPS track data, and on-the-ground survey. Organized recreation groups already work hand-in-hand with land managers on these routes and can ground-truth inventories at little cost to the agency. Any discrepancy between a third-party inventory and the agency’s own should be publicly disclosed and reconciled on the record before a plan moves forward.

8. Establish a standing public nomination process.

Accept and consider public proposals for additions to designated motorized networks at any time—including new routes, conversions of existing or administratively closed routes, and routes overlooked in prior agency inventories. Give priority to proposals that improve network connectivity, protect natural resources, enhance access for fuels reduction and wildfire response, or expand motorized recreation opportunities, and act on conversion proposals on an expedited basis. The agency should provide a written disposition explaining whether each proposal is accepted, modified, or denied.

9. Protect access for all uses that depend on motorized travel.

Travel management policy must recognize that motorized routes serve far more than recreation including access for individuals with disabilities and aging Americans who cannot reasonably access many public lands without motorized transportation. Hunters depend on them to reach the backcountry and to retrieve legally harvested game. Anglers depend on them to reach water. Firefighters depend on them for prevention, fuels reduction, and suppression; search and rescue teams depend on them in emergencies; and land managers depend on them for stewardship of the lands themselves. Closure decisions should expressly weigh these uses, and route networks should be managed to sustain them.

10. Partner with recreation groups and states on maintenance.

Work collaboratively with organized recreation groups to maintain and construct trails, and take full advantage of state funding streams. Colorado and many other states dedicate OHV permit revenue to motorized trail work on public lands—trails that remain open to all user groups. Volunteer programs such as the TPA Trail Crew, which contributed over 4,000 hours in 2025 maintaining 861 miles of trail across the national forests of Colorado and Utah, demonstrate that the recreation community is a force multiplier for under-resourced land managers, not a burden. Leveraging qualified volunteers, state OHV programs, and partner organizations allows the Forest Service to meet its statutory obligations at substantially lower cost while improving the accuracy of travel planning.

11. Maintain clear guardrails.

None of these reforms legitimizes illegal use. The open-unless-posted-closed presumption applies only to existing system roads and trails designated for motorized use; it does not open user-created routes, does not permit cross-country motorized travel, and does not affect congressionally designated wilderness areas or national parks.

Conclusion

Public lands were set aside for public use. Congress’s answer to competing demands on these lands was multiple use—not default closure. The real failure of the 2005 rule isn't simply closures—it's that the process creates a one-way ratchet where inventory errors become permanent policy. Restoring the presumption that roads and trails are open unless posted closed will bring travel management back in line with the law, halt the quiet erasure of legal routes, relieve the overconcentration of users on a shrinking network, and preserve access for recreation, hunting, game retrieval, angling, firefighting, search and rescue, and land stewardship alike—for this generation and the ones that follow. This standard served the Forest Service and the public for generations, providing certainty to users while preserving the agency's full authority to close routes when justified.

Legislation now before Congress, the Public Lands Access Restoration Act introduced by Representative Jeff Crank, would codify these reforms. But the Forest Service need not wait: the agency created this problem administratively in 2005, and it can fix it the same way.

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