Comments on Travel Management; National Forest System Lands

Docket No. FS-2026-0100

36 CFR Parts 212 and 261

September 22, 2026

U.S. Department of Agriculture | Forest Service

RE: Travel Management; National Forest System Lands - Docket No. FS-2026-0100

Dear U.S. Forest Service:

The Trails Preservation Alliance (TPA) appreciates the opportunity to comment on the U.S. Department of Agriculture’s Notice of Intent to prepare an Environmental Impact Statement and revise the Forest Service’s Travel Management regulations at 36 CFR Part 212.

TPA strongly supports the Forest Service undertaking a comprehensive review of the 2005 Travel Management Rule (TMR).

This is a much-needed correction to restore access to public lands consistent with the Forest Service’s statutory multiple-use mandates. For far too long, the agency has strayed from this important direction and elevated select concerns above other legitimate uses. The result has been disappointingly apparent and, in TPA’s view, contrary to those statutory mandates.

For TPA, this rulemaking goes directly to the organization’s origins. The Trails Preservation Alliance was formed in 2008, in part as a response to the original Travel Management Rule and the threat it posed to motorized access. For nearly two decades, protecting meaningful motorcycle access through Travel Management has been central to our mission.

Since then, TPA has participated extensively in Travel Management planning, administrative and legal advocacy, federal policy discussions, stewardship partnerships and congressional engagement concerning public-land access. Most recently, TPA has advocated for the principles contained in the Public Lands Access Restoration Act (PLARA) and testified before Congress regarding the need to restore meaningful access and reconsider the closed-unless-designated-open framework that has governed motorized recreation.

We therefore approach this rulemaking with nearly two decades of practical experience with federal Travel Management decisions. In our experience, the existing framework has contributed to significant losses of meaningful motorized access, incomplete route inventories, fragmented trail systems and increasing concentrations of recreation onto fewer remaining routes.

The Forest Service now has an opportunity to replace that framework with one that better reflects modern land-management capabilities, current law, changing recreation demand and the multiple-use mission of the National Forest System.

TPA supports many of the directions identified in the Notice of Intent, particularly:

• establishing a meaningful presumption of access;
• requiring regular review of closed and highly restricted routes;
• improving recognition of credible evidence that routes exist or historically existed;
• considering new and restored access opportunities;
• replacing the former national minimization framework with modern, site-specific management;
• providing greater flexibility for local decision-making; and
• modernizing how the Forest Service inventories, maps and manages transportation and recreation systems.

The details of the eventual rule will matter tremendously. At this Notice of Intent stage, TPA encourages USDA to ensure the following principles are fully carried forward into the proposed rule and Draft Environmental Impact Statement.

I. RESTORE A MEANINGFUL PRESUMPTION OF ACCESS

TPA strongly supports establishing a national policy under which existing roads, trails, trailheads and other access routes and points are presumed open to appropriate public use unless closure or restriction is required by law or supported by specific, documented and justifiable reasons.

Under the current motor-vehicle designation system, a road or trail must be affirmatively designated for motorized use. In practice, routes that existed and were used for decades can effectively disappear from the legal motorized system if they are omitted during inventory or designation. Once omitted or closed, those routes can disappear from the baseline considered during subsequent planning efforts, creating a one-way ratchet in which each successive process begins with an increasingly smaller motorized system.

A presumption of access does not mean unrestricted access. It does not mean opening National Forest lands to cross-country motorized travel, nor does it eliminate the Forest Service’s authority to protect natural resources, public safety or other legitimate management interests.

It establishes a more reasonable starting point:

Public access to an existing road or trail should not disappear without an actual reason and an accountable management decision.

TPA recommends that the revised rule clearly establish this principle and ensure that it is implemented consistently throughout the National Forest System.

The significance of this change is not merely semantic. A presumption establishes the starting point for agency analysis and determines who bears the practical burden when information is incomplete. Under a closed-unless-designated framework, uncertainty tends to result in lost access. Under an access-oriented framework, uncertainty should trigger evaluation: determine what exists, identify any legitimate concern, and make a reasoned decision.

That approach is consistent with multiple-use management. It does not predetermine the outcome for every route, but it ensures that access itself is treated as a legitimate public value rather than as an exception that must continually be re-earned.

II. THE NEW PRESUMPTION MUST ADDRESS THE LEGACY OF THE OLD SYSTEM

TPA believes this is one of the most consequential issues presented by this rulemaking.

The Notice of Intent explains that a new presumption would guide future decisions rather than automatically changing existing Motor Vehicle Use Map designations. TPA understands the practical and legal difficulties associated with changing thousands of individual route designations through a national rulemaking.

However, simply applying a new presumption prospectively would leave a fundamental problem unresolved.

For approximately two decades, Travel Management decisions have been made under a regulatory framework requiring motorized routes to be affirmatively designated open. If USDA now determines that a presumption favoring access represents better national policy, there must be a meaningful pathway to reconsider decisions produced under the former framework.

Otherwise, the Forest Service risks creating a presumption of access for the future while permanently grandfathering the consequences of the opposite presumption from the past.

A shrinking baseline in practice

Although it involves BLM rather than Forest Service lands, the Labyrinth Rims/Gemini Bridges Travel Management Area in Utah illustrates the structural problem. BLM’s original route inventory identified a substantially larger network. After hundreds of miles were closed in an earlier Travel Management decision, the later planning process largely began with the smaller network that had survived the previous decision. Additional closures were then considered against that already-reduced baseline.

The pattern is straightforward:

Inventory → closures → smaller baseline → new planning process → additional closures → still smaller baseline.

Routes lost in earlier processes can effectively disappear from consideration in later ones.

TPA is not asking USDA to automatically reopen every route previously closed to motorized use. We are asking USDA to create a meaningful reconsideration pathway for legacy closures and restrictions. That pathway should allow the Forest Service to consider credible historical use, current conditions, network connectivity, the continuing basis for a closure, and whether modern management alternatives can address the original concern while restoring appropriate access.

Public nominations should receive a documented disposition and should not disappear into an indefinite administrative process. The precise mechanics can be developed in the proposed rule, but the principle should be established now:

A change in national policy should have a meaningful path toward changing outcomes on the ground.

At this stage, TPA does not believe USDA needs to prescribe every implementation detail. The important point for the proposed rule is that legacy decisions cannot be treated as categorically beyond reconsideration simply because they predate the new policy. A workable framework can prioritize routes where historical use, connectivity, incomplete inventories, changed conditions or improved management tools indicate that another look is warranted.

This would allow the Forest Service to move forward without attempting a wholesale national reopening, while still giving the new policy practical meaning on forests where the effects of the old framework are already embedded in current maps and designated systems.

III. REQUIRE DOCUMENTED JUSTIFICATION AND MEANINGFUL REVIEW OF CLOSURES

TPA supports requiring closures and restrictions to be supported by specific, documented and justifiable reasons based on actual conditions. The revised rule should move away from closure as an administrative default.

Restrictions should respond to identifiable resource concerns, public-safety issues, conflicts among uses, legal requirements or legitimate management limitations. Where restrictions are necessary, they should be no broader and no longer than reasonably necessary to address the underlying issue.

TPA strongly supports regular review of closed and highly restricted roads, trails and other access routes and points. Review should be meaningful rather than a box-checking exercise and should consider whether:

• the original basis for the restriction still exists;
• circumstances or resource conditions have materially changed;
• modern management tools could allow access to resume;
• the restriction has harmed network connectivity;
• displaced recreation is causing impacts elsewhere; and
• reopening, seasonal access, rerouting or another management alternative is appropriate.

Emergency authority remains essential for wildfire, flooding, infrastructure damage and immediate public-safety concerns. But temporary closures should not quietly become permanent closures. Once the conditions giving rise to a temporary restriction are resolved, reopening should be the expected outcome unless a new documented basis supports continued restriction.

Meaningful review is especially important because the justification for a restriction can change over time. A resource concern may be resolved, a reroute may become feasible, maintenance capacity may improve, or a partner may be available to address the condition that originally led to closure. A modern rule should encourage managers to recognize those changed circumstances rather than allowing yesterday's solution to become today's permanent baseline without reconsideration.

IV. CORRECT ROUTE INVENTORY FAILURES

Accurate inventories are foundational to sound Travel Management. A management decision cannot adequately evaluate a transportation or recreation system if the agency does not know what routes actually exist or historically existed.

This is not a hypothetical concern for TPA.

Pike and San Isabel National Forests

TPA’s long involvement with Travel Management on the Pike and San Isabel National Forests has reinforced a basic problem with a designation-based system: if an existing route is absent from the map or underlying inventory, the practical consequence for the motorized user may be indistinguishable from a closure. TPA’s experience there also demonstrates the value of detailed route-by-route review and local knowledge in protecting a functional motorized system.

San Rafael Swell

TPA has encountered an even more pronounced example through BLM Travel Management planning in Utah’s San Rafael Swell. TPA and its partners identified substantial shortcomings in the baseline route inventory, including roads and trails used for decades that were absent from the starting inventory. As TPA explained in congressional testimony earlier this year, the no-action baseline itself omitted hundreds of miles of existing routes; subsequent alternatives were therefore built from an incomplete starting point. TPA and partner comments have continued to identify substantial route mileage that was not adequately reflected or analyzed.

This is exactly the outcome the revised TMR should prevent.

An inventory should be a tool for understanding the system. It should never become an unreviewed closure mechanism.

The San Rafael experience also shows why inventory accuracy matters beyond raw mileage. TPA and its partners identified an omitted approximately three-mile constructed route paralleling Utah Highway 72 that can connect OHV routes without forcing users onto the highway. Omitting a short segment like this can remove connectivity and create a public-safety problem far out of proportion to its mileage.

TPA also knows of existing physical roads, trails and connectors that do not appear on current designated motorized systems and whose administrative histories are not always readily apparent to the public. We do not assume that every such route was improperly omitted, nor do we suggest that evidence of a physical route automatically establishes its legal status or appropriate use.

But absence from the current designated system should not end the inquiry.

A modern Travel Management framework should provide a transparent mechanism to identify the route, determine its administrative and legal status, evaluate its historical use and role in the larger network, and make an actual management decision about whether appropriate access should be restored or established.

TPA intends to develop a separate list of specific roads, trails, trail systems and connectors that warrant evaluation or reconsideration for use in future implementation and planning discussions.

The revised rule should encourage consideration of credible evidence including historical Forest Service and USGS maps, aerial and satellite imagery, GPS information, state and county records, previous travel maps, ground surveys, local knowledge and other historical documentation.

Evidence that a physical route exists does not, standing alone, determine legal status or authorized use. But the inverse is equally important:

A route should not effectively be closed simply because it was omitted from an inventory.

TPA also encourages USDA to make inventory improvement a collaborative process. States, counties, tribes, organized recreation groups and knowledgeable local users often possess maps, GPS information, historical records and on-the-ground knowledge that can help the Forest Service identify discrepancies and understand how individual routes function within a larger network. The agency should be able to use that information efficiently rather than treating the official inventory as effectively closed to correction.

The objective is not to convert every line visible on an aerial photograph into a motorized route. It is to ensure that credible evidence produces evaluation instead of administrative disappearance. Identify it, evaluate it and make a decision.

V. CREATE AND MAINTAIN ADEQUATE, CONNECTED AND FUNCTIONAL SYSTEMS

Travel Management should not be limited to deciding which portions of an existing system should remain. The Forest Service should also ask whether transportation and recreation opportunities are adequate, appropriate, connected and functional.

TPA strongly supports consideration of appropriate new roads, trails, trailheads, restored connections and other access opportunities.

Mileage alone is a poor measure of meaningful access. A single trail segment may provide the connection between two much larger networks. Closing that segment can eliminate a loop, strand otherwise legal mileage, prevent access to a destination, force unsafe highway travel, or substantially reduce the practical value of surrounding routes.

Figure 1 - Why connectivity matters. The mileage of a closed connector may be small, while its effect on the larger system is substantial. A functional Travel Management analysis should consider whether a route creates loops, connects otherwise isolated trail systems, provides access to trailheads or destinations, avoids unsafe road travel, distributes recreation pressure, or supports maintenance and emergency access. The question should be how the network functions, not merely how many miles remain open.

Rio Grande National Forest

TPA recently raised this same principle during the Rio Grande National Forest’s Over-Snow Travel Management process. TPA emphasized that total mileage or acreage alone cannot adequately measure recreation opportunity because a fragmented network may contain significant mileage while failing to provide practical access or meaningful recreation experiences. TPA encouraged the Forest to consider routes that connect otherwise isolated riding areas, preserve historic access, create loops, and connect communities, parking areas, trailheads and groomed systems.

The revised TMR should expressly recognize network connectivity and functionality when evaluating closures, additions and changes in designation.

The same principle should inform USDA’s reconsideration of the existing “minimum road system” concept. Rather than treating minimization of transportation infrastructure as the objective, the Forest Service should strive for an adequate and appropriate transportation system capable of supporting legitimate public-access needs alongside resource protection, safety and reasonable maintenance capacity.

Connectivity should also be considered when evaluating proposed closures. A route that appears insignificant when viewed in isolation may be essential when viewed as part of the larger system. Conversely, a carefully selected connector or reroute may improve recreation quality, distribute use, simplify maintenance and reduce conflict without requiring a major expansion of the overall footprint.

This is why TPA believes 'adequate and appropriate' is a better organizing principle than simply pursuing the smallest possible transportation system. The goal should be a system that works for the public and can be responsibly managed.

VI. MANAGE RECREATION RATHER THAN CONCENTRATING IT

One unintended consequence of continually reducing available recreation mileage is overconcentration.

Recreation demand does not disappear when a trail closes. Users are displaced onto the routes that remain. As recreation demand increases while available mileage decreases, more people become concentrated onto fewer roads, trails, trailheads and staging areas.

That concentration can create greater physical impacts, congestion, user encounters, parking problems and conflict. Those effects can then become arguments for additional restrictions, producing a self-reinforcing cycle:

Less access → greater concentration → greater impacts and conflicts → additional restrictions → still greater concentration.

The San Rafael Swell and San Rafael Desert planning processes illustrate the displacement problem. Large amounts of route mileage were affected by Wilderness designations and additional Travel Management decisions, while TPA and its partners repeatedly raised concerns about the resulting displacement of recreation onto the remaining route system.

Closing a road or trail does not eliminate the recreation demand that occurred there. It redistributes that use somewhere else.

Travel Management analysis should therefore consider where displaced users will go, what routes will absorb that use, whether those routes will experience increased impacts or conflict, and whether the closure will make the overall system less functional and more difficult to manage.

Sometimes the problem is not simply overuse. It is overconcentration.

This does not mean that every closure will create unacceptable displacement. It means displacement should be part of the analysis rather than an afterthought. Managers should consider the cumulative function of the system and recognize that concentrating recreation can create exactly the resource and user-conflict problems that Travel Management is intended to solve.

VII. REPLACE THE OLD MINIMIZATION FRAMEWORK WITH MODERN, SITE-SPECIFIC MANAGEMENT

TPA strongly supports removing the national minimization criteria following the rescission of Executive Orders 11644 and 11989.

For decades, motorized Travel Management has operated under a national framework directing agencies to minimize specified effects and conflicts associated with motorized recreation. Whatever the original intention, in practice “minimization” has too often tipped the balance against public access, rather than beginning with the question of whether responsible access can be sustainably managed under actual, site-specific conditions.

Put more simply:

The old question was too often, “How do we minimize this use?”

The better question is, “How do we responsibly manage this use?”

Today’s Forest Service has access to high-resolution aerial imagery, GPS and GIS mapping, digital route inventories, monitoring technology, improved trail design, seasonal management, targeted restrictions, permit systems, rapid communication, education, enforcement and strong recreation partnerships.

Modern land management should use those tools.

TPA does not advocate eliminating resource protection. Where a route creates a genuine and documented resource or safety problem, managers should have the authority and tools necessary to address that problem. But resource protection and responsible access are not opposing objectives.

Bear Creek / Cap’n Jacks - management instead of permanent loss

TPA’s experience in the Bear Creek Watershed near Colorado Springs provides an example of solving a legitimate resource concern without simply accepting permanent loss of recreation opportunity. Historic motorcycle access was affected by concerns involving greenback cutthroat trout habitat. TPA and local partners ultimately worked with the Forest Service and others toward a replacement/rerouted trail, supported by OHV funding, to restore motorcycle access while addressing the resource concern.

That is the type of problem-solving a modern Travel Management framework should encourage:

identify the actual problem → use modern management and partnerships to address it → preserve or restore responsible access where possible.

Seasonal restrictions, hardened crossings, targeted reroutes, improved drainage, trail reconstruction, education, monitoring and focused enforcement can all be preferable to eliminating an opportunity entirely. The appropriate tool will vary by site, which is precisely why TPA supports moving away from a rigid national minimization framework and toward accountable, site-specific management.

The Forest Service should retain the ability to close routes when closure is genuinely necessary. But where a management solution can protect the resource and preserve public access, the rule should encourage managers to pursue that solution.

VIII. PRESERVE LOCAL DECISION-MAKING - WITH NATIONAL GUARDRAILS AND ACCOUNTABILITY

TPA supports greater decision-making authority for local Forest Service officials. Conditions vary tremendously among National Forests and Grasslands, and local managers are generally best positioned to understand those differences.

However, local flexibility must operate within clear national principles. A national presumption of access will have little practical value if individual units can recreate the former presumption of closure through inconsistent local implementation.

The revised rule should therefore combine:

national principles favoring responsible access + documented local decisions based on actual conditions.

Significant closure and designation decisions should be transparent enough for the public to understand what was decided, why it was decided, what evidence supports it, when it will be reviewed and how reconsideration may be requested.

Local discretion should enable better management - not eliminate accountability.

IX. CREATE A STANDING PUBLIC PROCESS FOR ROUTE NOMINATIONS

• Travel Management should not operate only during periodic, resource-intensive revisions of entire Travel Management Plans.
• Members of the public, tribes, local governments, states and recreation organizations should have a practical mechanism to nominate:
• omitted existing routes;
• routes for reopening or reconsideration;
• existing physical routes whose administrative status warrants clarification;
• new routes;

important network connections;

changes in authorized use; and

other improvements to transportation and recreation systems.

The process should not guarantee approval. It should guarantee meaningful consideration and a documented disposition.

This is particularly important where the public can identify an existing physical route but cannot readily determine whether it was omitted from an inventory, previously evaluated, formally closed, or simply lost in the administrative history. The public should not have to reconstruct decades of agency records before it can ask the Forest Service to evaluate the route.

A standing nomination process should provide the mechanism for determining that history and making a transparent decision based on current law, actual conditions, connectivity, recreation needs and modern management capabilities.

TPA intends to develop a supplemental list of trails, trail systems, existing connectors and other access opportunities that warrant evaluation or reconsideration. These examples can help inform future implementation and illustrate how a route-nomination process should work in practice.

Priority should be available for nominations that restore connectivity, correct inventory problems, address recreation concentration, improve safety, provide access to recreation destinations, support multiple uses, improve emergency or administrative access, or provide a management solution superior to continued closure.

A nomination process would also give the public a constructive alternative to waiting for the next forest-wide Travel Management revision. Transportation systems are not static: recreation patterns change, communities grow, new information emerges, old closures become outdated and opportunities for sustainable connections become apparent. The Forest Service should have a practical way to respond to those changes between major planning cycles.

TPA views this as an important bridge between the high-level presumption of access and real-world implementation. A presumption matters most when there is a usable process through which an overlooked, disconnected or unnecessarily closed route can actually be brought forward for consideration.

X. LEVERAGE RECREATION PARTNERSHIPS AND STEWARDSHIP

Motorized recreation organizations are not merely users of National Forest trails. Across the country, organized recreation groups provide labor, equipment, funding, education and expertise that directly support the Forest Service’s stewardship mission.

TPA has firsthand experience with this model. Our professional statewide Trail Crew works directly with federal land managers to maintain trails and sustain recreation infrastructure. In 2025 alone, the crew maintained 861 miles of trail and contributed more than 4,000 hours of field and program work across Forest Service and BLM units in Colorado and Utah.

These partnerships can expand maintenance capacity, collect field information, identify emerging problems, assist with inventories, support education, leverage state OHV funding and address issues before closure becomes necessary.

Maintenance and administrative capacity are legitimate considerations. But lack of agency capacity should not automatically translate into loss of public access.

Before capacity becomes justification for closure, managers should determine whether qualified partners, state programs or other resources can reasonably address the problem.

Stewardship partnerships should be part of the solution to access challenges.

This is particularly important as the Forest Service confronts limited staffing and maintenance resources. Organized motorized recreation has a long history of investing directly in the infrastructure it uses. The revised rule should recognize that partner capacity can change the management equation and should encourage units to consider those resources before concluding that a route must be restricted because the agency cannot maintain it alone.

XI. RECOGNIZE THE MANY PUBLIC USES THAT DEPEND ON ACCESS

Although TPA primarily represents off-highway motorcycle recreation, the consequences of Travel Management decisions extend far beyond motorcycles.

Forest roads and trails provide access for hunters, anglers, campers, mountain bikers, equestrians, dispersed recreationists, trail workers, firefighters, search-and-rescue personnel, land managers and many others. Motorized access is particularly important for people who cannot reasonably reach remote public lands solely by foot because of age, physical ability, distance or terrain.

Travel Management decisions should therefore evaluate the full access consequences of closures and restrictions.

A route is not merely a line on a map. It may be the means through which many different members of the public reach and experience their National Forests.

The same road or trail may serve several of these purposes at once. A connector valued by motorcycle riders may also provide access for hunters, maintenance crews or emergency response. Travel Management decisions should therefore look beyond a single recreation category and consider the broader public function of the transportation network.

XII. SUPPORT APPROPRIATE CLASS 1 E-BIKE ACCESS

TPA supports USDA’s proposed direction regarding Class 1 electric bicycles.

• Class 1 e-bikes should generally be managed consistently with traditional bicycles on National Forest System trails where traditional bicycle use is permitted, subject to applicable law and justified site-specific restrictions.
• If a trail is appropriate for a traditional mountain bicycle, pedal-assist technology alone should not automatically require that Class 1 e-bike use be managed under the same framework as motorcycles, ATVs or other motor vehicles.
• This approach expands responsible recreation access while preserving the Forest Service’s authority to address circumstances where a site-specific restriction is actually justified.

XIII. RETAIN APPROPRIATE RESOURCE AND LEGAL GUARDRAILS

• TPA’s support for increased and improved access should not be misunderstood as support for unrestricted cross-country motorized travel. It is not.

Nor is TPA proposing that the revised Travel Management Rule override Wilderness protections, valid existing rights, applicable environmental statutes or other legal restrictions governing particular lands.

The purpose of reform should be to establish a better Travel Management framework within those legal boundaries.

Where motorized use is legally prohibited, those restrictions remain. Where documented resource or safety concerns require management, managers should address them. But where access is lawful and can be responsibly managed, national policy should favor keeping the public connected to its public lands.

XIV. CONCLUSION

For TPA, this rulemaking represents far more than another administrative revision.

Our organization was formed in 2008, in part as a response to the original Travel Management Rule.

For nearly two decades, we have worked with riders, clubs, land managers, policymakers and other partners to deal with the consequences of Travel Management decisions on the ground.

That experience spans both Forest Service and BLM lands. While the agencies operate under different authorities and this rulemaking applies specifically to the Forest Service, the recurring structural problems TPA has encountered across federal Travel Management are remarkably consistent:

incomplete inventories;

closures becoming the baseline for the next round of planning;

lost connectivity;

recreation displaced onto increasingly limited systems; and

management processes that can make it far easier to remove an opportunity than to restore one.

We have also seen the opposite. We have seen local knowledge improve planning, recreation partners maintain routes agencies lacked the capacity to maintain themselves, and reroutes solve legitimate resource problems while restoring motorcycle access.

Responsible access and responsible stewardship are not opposites.

The Forest Service now has an extraordinary opportunity to modernize the national framework governing that access. TPA encourages USDA to develop a rule that:

• establishes a meaningful presumption of access;
• provides a real pathway for reconsidering legacy closures and restrictions;
• requires documented justification for restrictions;
• regularly and meaningfully reviews closed and highly restricted routes;
• corrects incomplete route inventories;
• recognizes credible evidence of existing and historical routes;
• creates and maintains adequate, connected and functional recreation systems;
• considers appropriate new and restored access opportunities;
• evaluates displacement and overconcentration before closing routes;
• replaces the old national minimization framework with modern, site-specific management;
• preserves local flexibility within meaningful national guardrails;
• creates a standing public route-nomination process;
• leverages recreation partnerships and stewardship capacity;
• recognizes the many public uses dependent upon access; and
• appropriately allows Class 1 e-bike use on trails open to traditional bicycles.

The fundamental principle is straightforward:

The old question was too often: “How do we minimize this use?”

The better question is: “How do we responsibly manage this use?”

Where genuine problems exist, address them. Where access can be responsibly sustained, preserve it. Where historic access has been lost without adequate justification, create a meaningful opportunity to reconsider it. And where growing recreation demand demonstrates the need for additional sustainable opportunities, allow transportation and recreation systems to evolve rather than continually shrink.

Public access is not the opposite of conservation. It is one of the values our public lands exist to provide.

TPA appreciates USDA undertaking this important review and looks forward to continued participation as the proposed rule and Draft Environmental Impact Statement are developed.

Respectfully submitted,

Chad Hixon
Executive Director
Trails Preservation Alliance

REFERENCES

1. USDA Forest Service, “Travel Management; National Forest System Lands,” Notice of Intent, Docket No. FS-2026-0100, 36 CFR Parts 212 and 261 (2026).
2. Trails Preservation Alliance, “Executive Director Testifies Before House Natural Resources Subcommittee on Federal Lands” (2026).
3. Trails Preservation Alliance, comments and administrative record materials concerning the Labyrinth Rims/Gemini Bridges Travel Management Area.
4. Trails Preservation Alliance, “Outdoor Recreation Act - S. 3266,” and related Pike and San Isabel National Forest Travel Management materials.
5. Trails Preservation Alliance, “San Rafael Swell / San Rafael Desert Travel Management Plan Reassessment.”
6. Trails Preservation Alliance, supplementary comments regarding the San Rafael Swell Travel Management Plan, including the Utah Highway 72 connector.
7. Trails Preservation Alliance, Rio Grande National Forest Over-Snow Travel Management Plan comments (2026).
8. Trails Preservation Alliance, 2016 End of Year Report (Bear Creek / Cap’n Jacks).