Cal4Wheel Supports Long Overdue Reform of the Forest Service Travel Management Rule

On September 23, I submitted a detailed comment letter on behalf of Cal4Wheel supporting the USDA Forest Service’s proposed revisions to the Travel Management Rule. This rule governs how motorized roads, trails, winter travel areas, trailheads and other access points are designated and managed throughout our national forests.

For Cal4Wheel members, this rulemaking has enormous consequences. California contains more than 20 million acres of Forest Service land, including many of the state’s most valued four-wheel-drive trails and OHV networks. Unfortunately, the existing Travel Management Rule has spent the past two decades operating like a one-way ratchet. Routes can be closed or omitted from the designated system during a single planning process, while reopening them may require years of environmental review, scarce funding and defense against litigation.

California’s experience tells the story.

Tahoe National Forest evaluated 869 miles of user-created roads and trails during implementation of the existing rule but added only about 62 miles to the official transportation system. Plumas National Forest inventoried approximately 1,107 miles of non-system routes and added only about 234 miles as motorized trails. Stanislaus National Forest closed system roads and restricted hundreds of additional miles to highway-legal vehicles, removing opportunities for motorcycles, ATVs and other non-highway-legal OHVs. On Eldorado National Forest, litigation over meadow standards resulted in the closure and supplemental review of 42 route segments.

Those decisions did not simply remove mileage from a map. They broke loops, isolated destinations, eliminated vehicle-class opportunities, concentrated use on fewer surviving routes and reduced the alternate access needed when wildfire, snow damage, washouts or restoration work make another route unavailable.

The Forest Service is now considering replacing the existing closed-unless-designated system with an “open unless closed” presumption for existing roads, trails and access points. Anti-access organizations have responded with claims that this would unleash uncontrolled cross-country travel across national forests.

That claim is false.

The proposal does not authorize people to create new routes through undisturbed land. It does not open Wilderness areas to motorized vehicles. It does not eliminate seasonal restrictions, fire closures, vehicle-class limitations or emergency authority. Existing Motor Vehicle Use Maps would remain operative during implementation. NEPA, the Endangered Species Act, Clean Water Act, National Historic Preservation Act, National Forest Management Act and applicable forest plans would continue to govern Forest Service decisions.

What would change is the starting point. Instead of allowing access to disappear because an existing route was missed, omitted or never processed through an expensive planning procedure, the Forest Service would need a lawful and factually defensible reason to close or materially restrict it.

Opponents have also claimed that the proposal abandons resource protection. That argument assumes closure is the only legitimate form of management. Cal4Wheel members have repeatedly proven otherwise.

When water-quality concerns threatened the Rubicon Trail, Cal4Wheel, El Dorado County, the Forest Service, the Rubicon Trail Foundation, Friends of the Rubicon and other partners responded with drainage improvements, hardened crossings, sanitation facilities, monitoring, education and continuing maintenance. The underlying problems were addressed without sacrificing the trail. Similar tools can be used elsewhere, including seasonal restrictions, short reroutes, bridge and culvert work, targeted restoration, vehicle limitations and volunteer-supported maintenance.

Our comments also support eliminating the former national minimization criteria, which have too often been interpreted as a continuing obligation to reduce motorized access. The West Mojave provides a sobering example. After multiple planning processes and extensive route closures, the same underlying minimization theory was used to secure a January 2026 court order closing approximately 2,200 additional miles of OHV routes. Under that approach, every new closure can be called further “minimization,” but no amount of retained access is ever considered enough.

Cal4Wheel also asked the Forest Service to replace the minimum-road-system concept with an adequate and functional transportation network. Forest roads and trails support far more than recreation. They provide access for wildfire suppression, fuels treatment, evacuation, search and rescue, grazing, utility work and post-fire recovery.

We requested enforceable implementation deadlines, annual review of closures, accurate digital and printable maps, a public route-nomination process, practical access for dispersed camping and winter recreation, recognition of volunteer maintenance capacity and stronger protections for disabled visitors who depend upon motorized transportation to reach public lands.

The revisions should also align with the Outdoor Americans with Disabilities Act, which proposes measurable protections for motorized access. Its benchmark of 2.5 miles of authorized motorized road per square mile would help identify where route attrition has made public lands functionally inaccessible. Where closure is unavoidable, genuinely comparable replacement access should be required. People with disabilities should not be confined to a handful of developed sites while the broader forest remains accessible only to those who can travel long distances on foot.

Cal4Wheel is not asking the Forest Service to ignore resource damage or public-safety hazards. We are asking it to manage actual problems instead of automatically managing people out.

These proposed revisions offer a rare opportunity to restore balance, local judgment and common sense to national forest travel management. Cal4Wheel supports that effort, and we will remain actively involved as the environmental review and rulemaking proceed.

Click here to read the full Cal4Wheel comment letter on the Travel Management Rule proposed revisions