Comments on Proposed Rescission of the 2001 Roadless Area Conservation Rule

Docket No. FS-2025-0001

RIN 0596-AD66

October 6, 2026

U.S. Department of Agriculture

Forest Service

RE: Special Areas; Roadless Area Conservation - Docket No. FS-2025-0001

Dear U.S. Forest Service:

The Trails Preservation Alliance (TPA) appreciates the opportunity to comment on the U.S. Department of Agriculture and U.S. Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule. 1

TPA supports full rescission of the 2001 Roadless Area Conservation Rule.

TPA is a Colorado-based nonprofit organization dedicated to protecting and sustaining off-highway motorcycle recreation and the trails that support it. Our work includes public-land advocacy, collaboration with federal land managers, rider education, volunteer stewardship, and operation of a professional trail crew that works directly with federal land-management agencies to maintain sustainable trail systems.

Our support for rescission is based on a straightforward principle: adaptive, site-specific management based on current conditions is preferable to a nationwide prohibition established 25 years ago.

The landscapes covered by the 2001 Roadless Rule are not static. Wildfire, drought, insects and disease, changing forest conditions, watershed and wildlife needs, recreation demand and surrounding communities have all changed since many Inventoried Roadless Areas were mapped. The Forest Service itself identifies the need for greater flexibility to respond to changing and localized conditions and recognizes forest-level planning as the framework for balancing competing values and uses within its multiple-use mission. 1

The appropriate management of a landscape should be determined by the conditions, resources and needs that exist today - not solely by a national prohibition adopted in 2001.

1. ADAPTIVE, SITE-SPECIFIC MANAGEMENT IS PREFERABLE TO A NATIONWIDE STATIC PROHIBITION

Since adoption of the Roadless Rule, conditions across many National Forest System lands have changed substantially. Drought, extreme temperatures, wildfire, insects and disease have altered landscapes and created management needs that may not have existed or been contemplated in 2001.1

Recreation needs have changed as well. Existing routes may require relocation or reconstruction. Sustainable connections may be needed to improve trail-system functionality. Post-fire landscapes may require entirely different management approaches. Changing use patterns may create new resource concerns or new opportunities.

Adaptive management does not dictate a particular outcome. It allows managers to evaluate the conditions that actually exist and determine, through applicable planning, environmental review and public involvement, whether action or restraint is appropriate.

That analysis should be capable of considering forest health, hazardous fuels, wildfire resilience, watershed restoration, habitat improvement, existing roads and trails, historic access, recreation demand, emergency response, community needs and opportunities for sustainable recreation.

Transportation access can also be necessary to accomplish beneficial land-management objectives. Fuels reduction, forest restoration, watershed work, habitat improvement, emergency response and recreation management can all require some form of access. TPA believes these decisions are better made through site-specific analysis than predetermined by a nationwide prohibition established decades earlier.

2. RESCISSION RESTORES DISCRETION; IT DOES NOT REMOVE THE EXISTING MANAGEMENT FRAMEWORK

It is important to distinguish rescission of the 2001 Roadless Rule from removal of environmental protections on National Forest System lands. The proposed rescission does not itself authorize a road, timber project, motorized trail or other ground-disturbing activity. Existing land management plans will continue to govern these lands, and future proposals remain subject to applicable law and site-specific review.1

NEPA remains applicable. Forest Plan requirements remain applicable. Travel Management decisions remain applicable. Wilderness and Wild and Scenic River designations remain applicable. Endangered species protections, water and watershed protections, Tribal interests and consultation requirements, private rights and other applicable requirements remain in place.

The Forest Service also recognizes that near-term effects of rescission will continue to be bounded by existing land management plan direction, operability, budget and legal constraints, and characterizes foreseeable management opportunities as generally modest and localized.1

Rescission removes one national regulatory layer; it does not remove the Forest Service planning system or the environmental laws governing National Forest System lands.

TPA supports maintaining appropriate environmental safeguards while allowing individual proposals to be evaluated on their merits and according to current conditions.

3. ROADLESS CHARACTERISTICS AND MOTORIZED RECREATION ARE COMPATIBLE

“Roadless” does not mean “Wilderness,” “nonmotorized” or “trailless.”

The 2001 Roadless Rule did not prohibit motorized recreation within Inventoried Roadless Areas. The Forest Service’s 2026 Draft Environmental Impact Statement identifies approximately 5,200 miles of motorized trails within the potentially affected roadless areas.2

Those existing trails demonstrate an important fact: roadless characteristics and responsible motorized recreation can coexist.

Federal regulations already recognize this distinction. The Colorado Roadless Rule expressly includes semi-primitive motorized recreation among roadless area characteristics and provides that current and future management of motorized and non-motorized trails is to occur through applicable forest travel management processes.3

The Idaho Roadless Rule likewise recognizes a management continuum and provides that existing roads and trails are not affected by the rule, with future management decisions occurring through the applicable travel management process.4

The physical scale of motorized trails provides additional perspective. Using an intentionally generous illustrative assumption that every one of the approximately 5,200 miles of existing motorized trail were 15 feet wide, those trails would occupy approximately 9,455 acres. Most motorized trails, particularly motorcycle singletrack, are substantially narrower than 15 feet. TPA uses this assumption solely to provide perspective on scale; it is not a Forest Service estimate of trail width or actual disturbed acreage.2

Properly located, designed, maintained and managed motorized trails can provide meaningful recreational access while occupying an extraordinarily small portion of the surrounding landscape.

4. MODERN MOTORIZED RECREATION IS MANAGED RECREATION

Motorized recreation management has changed substantially over the past several decades. Today’s legitimate motorized trail systems increasingly rely upon designated routes, Motor Vehicle Use Maps, trail standards, seasonal restrictions where appropriate, signing, monitoring, enforcement, trail maintenance, restoration, rider education, volunteer stewardship and partnerships among land managers, clubs and nonprofit organizations.

A legal, designated trail can be mapped, located away from sensitive resources, designed for sustainability, monitored, maintained, rerouted when necessary, closed seasonally when justified and managed through enforceable rules. Unauthorized user-created routes provide few of those advantages.

In some circumstances, carefully planned trail systems and logical connections can improve resource protection by concentrating recreation on sustainable corridors. The South Rampart Travel Management Plan, for example, recognized that more properly designed and maintained trails and additional loops could reduce illegal, unsustainable user-created routes and off-trail travel.5

TPA sees the benefits of managed recreation firsthand through our stewardship partnerships with federal land managers. Sustainable recreation infrastructure should therefore be viewed as one of the management tools available to the Forest Service - not as inherently incompatible with protection of roadless characteristics.

5. ROADLESS DESIGNATIONS SHOULD NOT BECOME DE FACTO WILDERNESS

TPA recognizes an important distinction: the Roadless Rule itself does not close motorized trails. Indeed, state-specific Roadless regulations expressly demonstrate that trail-management decisions can and should occur through applicable Travel Management processes.

Our concern instead arises from the cumulative effect roadless status can have in subsequent planning. TPA and our partner organizations have participated in Forest Plan revisions, Travel Management processes and project-level decisions where roadless status has become an additional factor supporting restrictions on motorized access, discouraging consideration of new or relocated trails, limiting connectivity, or complicating projects within or adjacent to Roadless Areas.

South Rampart and Pike-San Isabel Travel Management

The Pike-San Isabel National Forest provides a documented example of this concern developing over multiple planning processes. During development of the 2011 South Rampart Travel Management Plan (SRTMP), the Forest Service expressly identified consistency with adjacent special management areas, including roadless areas, as a planning issue. The preferred alternative simultaneously proposed new managed motorized recreation opportunities - including approximately 16.5 miles of new motorcycle singletrack - while also closing and rehabilitating motorized routes associated with the Rampart East Roadless Area.5

In its analysis, the Forest Service specifically stated that closure and rehabilitation of the end of NFSR 327 would preserve roadless-area value and elsewhere identified NFSR 327 and NFSR 324.B as accessing the East Rampart Roadless Area. At the same time, the agency recognized that properly designed trails, loops and connections could concentrate use and reduce illegal or unsustainable user-created routes. 5

One of the new singletrack opportunities proposed through the SRTMP was located immediately west of the Rampart East Roadless Area. Concerns about motorized use and roadless character continued into the later forest-wide Pike-San Isabel Travel Management process.

In 2016, a coalition of wilderness, quiet-use and conservation organizations submitted scoping comments urging the Forest Service to use travel planning to protect and restore, among other values, the Forest’s “wild, roadless character” while addressing motorized use.6

During that same planning process, TPA and its partners specifically cautioned against allowing the Colorado Roadless Rule to become a barrier to otherwise appropriate motorized recreation. TPA pointed to the Colorado Roadless Rule’s express recognition of semi-primitive motorized recreation and its direction that motorized trail decisions occur through applicable Travel Management processes. TPA also expressed concern that Roadless Areas could increasingly be managed as “Wilderness like” areas despite the important legal distinction between the two designations.7

The proposed South Rampart singletrack discussed above was never ultimately constructed.

TPA does not contend that proximity to the Rampart East Roadless Area was the sole reason - or necessarily the determining reason - that the proposed trail was never implemented. The history nevertheless illustrates the practical concern underlying these comments.

A managed motorized trail opportunity had been considered through a formal Forest Service planning process. The proposed alignment was adjacent to a Roadless Area. Roadless compatibility and protection of roadless characteristics became part of the planning discussion. Motorized recreation organizations continued advocating for the opportunity during a subsequent Travel Management process. Ultimately, the proposed trail was not implemented.

This is precisely why TPA distinguishes between protecting existing access and preserving the flexibility necessary to address future access and management needs.

An existing motorized trail may remain legal today, while a future reroute, connector, relocation or other sustainable recreation project becomes increasingly difficult to consider because of the area’s roadless status or proximity to a Roadless Area.

TPA does not cite the South Rampart/PSI history to suggest that consideration of roadless characteristics was improper, nor do we suggest that organizations should be prevented from advocating for more restrictive management. Rather, the record demonstrates the practical concern: a roadless designation that legally accommodates motorized recreation can nevertheless become an additional basis for advocacy and subsequent planning decisions seeking increasingly restrictive management.

Over time, an administrative roadless designation can therefore begin to function more like a nonmotorized allocation or de facto Wilderness, despite the absence of a congressional Wilderness designation and despite federal regulations recognizing motorized recreation as compatible with roadless characteristics.

TPA supports responsible resource protection. We simply urge the Forest Service to maintain the important legal and management distinctions between Roadless Areas and congressionally designated Wilderness, and between roads, designated motorized trails and unmanaged cross-country motorized travel. These are materially different forms of use and disturbance and should be treated accordingly.

6. FOREST HEALTH, WILDFIRE RESILIENCE AND RESTORATION REQUIRE MANAGEMENT FLEXIBILITY

Forest health provides perhaps the clearest example of why management flexibility matters. The Forest Service acknowledges that additional public access can increase human-caused ignition potential in some locations. At the same time, the agency recognizes that existing Roadless Rule prohibitions can limit mechanical thinning options and some fire-control tactics.1

The Forest Service identifies substantial Roadless acreage with relatively high likelihood of high-intensity wildfire and approximately 9.8 million acres of overlap with the wildland-urban interface. The proposed rule states that rescission could increase opportunities for hazardous-fuels treatments and, where justified, strategically placed roads that improve suppression effectiveness near communities and critical infrastructure.1

TPA does not contend that vegetation treatment or transportation access can prevent wildfire, nor do we suggest that these activities are appropriate everywhere. Rather, land managers should be able to consider fuels reduction, forest-health treatments, watershed restoration, habitat improvement, emergency access, post-fire recovery and other management tools where site-specific conditions demonstrate a need.

A regulatory framework intended to protect landscapes should not unnecessarily inhibit the ability to restore or protect those same landscapes when conditions materially change.

The appropriate level of activity will vary dramatically by landscape. That is precisely why adaptive, site specific management is preferable to a single nationwide prescription.

7. COLORADO AND IDAHO PROVIDE IMPORTANT LESSONS

TPA recognizes that Colorado and Idaho operate under separate state-specific Roadless Rules and that the proposed national rescission would not eliminate those rules.1

The Colorado Roadless Rule expressly operates within the context of multiple-use management and recognizes primitive, semi-primitive nonmotorized and semi-primitive motorized recreation among roadless characteristics. It also expressly leaves current and future motorized and non-motorized trail-management decisions to applicable Travel Management processes.3

Idaho provides an especially useful example of an adaptive roadless framework. Rather than treating every roadless acre identically, the Idaho Rule establishes a management continuum consisting of Wild Land Recreation, Special Areas of Historic or Tribal Significance, Primitive, Backcountry/Restoration, and General Forest, Rangeland and Grassland classifications.4

Different activities are appropriate under different classifications. For example, Idaho’s Backcountry/Restoration classification permits limited temporary road construction or reconstruction for specified community-protection and hazardous-fuels circumstances when the applicable regulatory findings are met, while requiring temporary roads to be decommissioned after their authorized purpose is completed.4

Not every roadless landscape has identical characteristics, needs or appropriate management.

Some areas may appropriately receive highly restrictive management. Others may require restoration, fuels treatment, transportation access or sustainable recreation infrastructure. TPA does not recommend simply applying either the Colorado or Idaho Rule nationwide. Rather, these state-specific approaches demonstrate that protecting roadless characteristics and allowing adaptive management flexibility are not mutually exclusive policy choices.

If USDA or the Forest Service considers future roadless guidance, state-specific petitions or other geographically tailored frameworks, the experience of Colorado and Idaho should be carefully evaluated.

8. LOCAL DISCRETION MUST REMAIN MULTIPLE-USE DECISION-MAKING

TPA generally supports returning appropriate management decisions to individual forests and applicable Forest Plans. However, local discretion by itself does not guarantee balanced outcomes. TPA has extensive experience participating in federal land-management planning and recognizes that approaches toward motorized recreation can vary significantly among individual units and decision-makers.

Post-rescission implementation should therefore not simply replace one national presumption with inconsistent local presumptions against motorized recreation. Site-specific decision-making should remain grounded in the Forest Service’s multiple-use responsibilities, applicable Forest Plans, objective resource information and meaningful participation by affected recreation communities.

Where a proposed motorized route, reroute, connector or other recreation project is inappropriate because of demonstrated site-specific resource concerns, those concerns should guide the decision. Conversely, former Inventoried Roadless Area status should not itself become a substitute for that site-specific analysis.

9. TPA RECOMMENDATIONS FOR POST-RESCISSION IMPLEMENTATION

• Maintain the distinction between Roadless Areas and Wilderness. Roadless status should not itself create a presumption that an area must be managed as nonmotorized.
• Recognize motorized recreation as compatible with roadless characteristics. Existing federal regulations in Colorado and Idaho already demonstrate that these concepts can coexist.
• Protect existing legal motorized access. Former IRA status should not, standing alone, constitute sufficient justification for future route closures.
• Allow genuine consideration of sustainable future recreation opportunities, including trail relocations, reroutes, connectors and new routes where site-specific analysis demonstrates they are appropriate.
• Distinguish roads from trails. A narrow designated motorcycle trail, a full-width forest road and unmanaged cross-country motorized travel create fundamentally different management considerations and should not be treated as equivalent disturbances.
• Use current landscape conditions in future decisions, including wildfire history, forest health, fuels, watershed and habitat conditions, existing infrastructure, recreation demand and community needs.
• Preserve flexibility for restoration and forest-management activities, including fuels reduction, forest health treatments, watershed restoration, habitat improvement, emergency response and post-fire recovery.
• Require meaningful multiple-use participation in local planning. Motorized recreation organizations, clubs and affected communities should have meaningful opportunities to participate in decisions affecting access and recreation infrastructure.
• Encourage collaborative transportation planning. Strategic trail systems, logical connections and sustainable reroutes can improve both recreation opportunities and resource protection.
• Do not use former IRA status as a substitute for site-specific analysis. Decisions to close a motorized route, change a recreation allocation, or reject an otherwise appropriate trail relocation, reroute or connector should be supported by the applicable planning process and site-specific resource considerations.
• Evaluate the experience of Colorado and Idaho if future state-specific petitions, national guidance or other roadless-management frameworks are considered.
• Preserve motorized recreation as an expressly recognized roadless characteristic in any future roadless framework. Future roadless rulemaking or state-specific petitions should not automatically equate roadless management with nonmotorized management.

Conclusion

TPA supports full rescission of the 2001 Roadless Area Conservation Rule.

Our support is not based on a desire to develop every roadless landscape. We do not believe every Roadless Area is appropriate for additional motorized recreation, road construction or active forest management.

Those determinations should be made based on the characteristics and needs of the landscape that exists today, through appropriate planning, environmental review, multiple-use management and meaningful public participation - not predetermined by a nationwide prohibition adopted 25 years ago.

The existence of approximately 5,200 miles of motorized trails within potentially affected roadless landscapes already demonstrates that roadless characteristics and sustainable motorized recreation are not mutually exclusive. Modern designated trail management further demonstrates that responsible recreation can be planned, monitored, maintained and adapted to protect resources.

Forest health, wildfire resilience, watershed restoration, habitat improvement, emergency response and changing recreation needs likewise demonstrate why land managers need the ability to consider site specific solutions. Rescission provides an opportunity to restore that flexibility while retaining the extensive environmental laws, Forest Plans and planning processes that continue to govern National Forest System lands.

TPA encourages the Forest Service to select full rescission and, in its implementation, preserve the distinctions between roadless and Wilderness, between roads and trails, and between responsible managed recreation and unmanaged use.

Protecting roadless characteristics and providing responsible, sustainable recreation opportunities do not have to be mutually exclusive.

Thank you for considering these comments.

Sincerely,

Chad Hixon

Executive Director

Trails Preservation Alliance

Sources And Authorities

1. U.S. Department of Agriculture, Forest Service, “Special Areas; Roadless Area Conservation,” Proposed Rule, 91 Fed. Reg. 53827 (Aug. 20, 2026), Docket No. FS-2025-0001, RIN 0596-AD66. See particularly Purpose and Need, Rationale, Scope of the Proposed Rule, and Summary of Potential Impacts.

2. U.S. Department of Agriculture, Forest Service, 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement, Vol. I (2026), Docket No. FS-2025-0001-224064. The DEIS identifies approximately 21,808 miles of trails in potentially affected areas, including approximately 5,200 miles of motorized trails. The 9,455-acre figure in these comments is a TPA illustrative calculation assuming a uniform 15-foot trail width.

3. 36 C.F.R. Part 294, Subpart D (Colorado Roadless Area Management), including §§ 294.40, 294.41 and 294.46(e)-(f). Section 294.41 recognizes semi-primitive motorized recreation among roadless area characteristics; § 294.46(e) assigns motorized and non-motorized trail decisions to applicable forest travel management processes.

4. 36 C.F.R. Part 294, Subpart C (Idaho Roadless Area Management), including §§ 294.20-294.29, particularly §§ 294.22, 294.23 and 294.26.

5. U.S. Department of Agriculture, Forest Service, South Rampart Travel Management Plan Environmental Assessment, Pike and San Isabel National Forests, Pikes Peak Ranger District (Aug. 2011). See, among other portions, the identified planning issues concerning roadless areas; Alternative B’s 16.5 miles of new single-track motorized trail; discussion of NFSRs 327 and 324.B and the East Rampart Roadless Area; and analysis recognizing that properly designed trail loops can reduce illegal and unsustainable user-created routes.

6. Central Colorado Wilderness Coalition et al., Scoping Comments on Pike-San Isabel National Forest Travel Management Planning Process, Sept. 8, 2016 (comments addressing ecological integrity, motorized use, and protection/restoration of wild and roadless character).

7. Trails Preservation Alliance, Colorado Off-Highway Vehicle Coalition, and affiliated organizations, Comments on Pike & San Isabel National Forests Public Motor Vehicle Use Draft Environmental Impact Statement, Nov. 1, 2019. See General Comment 9, Colorado Roadless Rule, and discussion of the South Rampart Travel Management Plan.

8. U.S. Department of Agriculture, Forest Service, “Special Areas; Roadless Area Conservation,” Proposed Rule; Extension of Comment Period, 91 Fed. Reg. (Sept. 2026), extending the comment deadline to Oct. 6, 2026.