Comments Submitted on 09/11/26
To submit comments: https://www.regulations.gov/document/FS-2026-0100-0001
Travel Management - VVCC Feedback - 091126.pdf
Verde Valley Cyclists Coalition Comments Regarding Proposed Revisions to 36 CFR Parts 212 and 261 Docket No. FS-2026-0100
Dear U.S. Forest Service:
The Verde Valley Cyclists Coalition (VVCC) appreciates the opportunity to comment on the Forest Service's proposed revisions to its Travel Management regulations.
VVCC is a 340-member nonprofit organization serving cyclists throughout Arizona's Verde Valley. Our mission is to advocate for Verde Valley cyclists by providing memorable, safe riding experiences while preserving and expanding biking access through partnerships.
VVCC has a long history of collaborating with the U.S. Forest Service and community partners to support sustainable trails, responsible recreation, volunteer trail stewardship, and public access.
Earlier this year, VVCC surveyed its membership regarding e-bike ownership and potential areas for e-bike advocacy. Expanding Class 1 e-MTB access was the most frequently identified advocacy priority among members. That member input helped inform VVCC's position in support of expanded Class 1 e-bike access, as well as the recommendations reflected in our comments.
Class 1 E-Bikes and Local Decision-Making
VVCC supports expanding Class 1 e-bike access while preserving meaningful local Forest Service authority to manage that access. Class 1 e-bikes can expand riding opportunities, help cyclists continue riding as they age or their abilities change, and allow more people to access and enjoy public lands by bicycle.
Trail systems vary considerably in design, use levels, recreation settings, environmental conditions, and potential for user conflicts. We therefore support allowing Class 1 e-bikes on trails open to bicycles by default, while preserving Ranger District authority to restrict Class 1 access on specific trails based on local conditions and management needs. The Verde and Red Rock Ranger Districts are best positioned to make those site-specific decisions.
Access Must Be Accompanied by Resources
VVCC supports streamlining administrative processes that unnecessarily delay reasonable travel-management decisions. However, increased access brings increased responsibility for maintenance, education, monitoring, and enforcement.
This is particularly important with Class 1 e-bikes. As e-bike technology evolves, distinguishing Class 1 e-bikes from more powerful devices can be challenging in the field. If Class 1 access expands, local Forest Service units need the staffing, funding, and tools necessary to educate users, monitor impacts, and effectively enforce those distinctions.
VVCC and other local partners can assist with education, stewardship, and outreach, but already constrained Ranger Districts and community organizations should not be expected to fully absorb the costs. The Federal government should work with bicycle and e-bike manufacturers, industry associations, and retailers to establish clear and consistent e-bike identification standards and encourage industry support for education, signage, and other implementation needs.
Maintain a “Closed Unless Open” Approach for Roads and Routes
VVCC supports maintaining a “closed unless open” approach for roads, trails, and other access routes. A route should be open to public use only after the Forest Service has determined that the route and its allowable uses are appropriate. The physical existence or historic classification of a route should not, by itself, create a presumption that it is appropriate for public access or for a particular use.
This is particularly important across the Verde and Red Rock Ranger Districts, where former roads and roadbeds are now managed as non-motorized trails and unauthorized or user-created social trails may have physically existed for many years. Former roadbeds now managed as non-motorized trails should not become available for motorized use simply
because they were historically roads, and the existence of an unauthorized or user-created social trail should not make it appropriate for public access.
Local Ranger Districts should retain authority to determine the appropriate uses of existing routes and whether unauthorized or user-created routes should be adopted, redesigned, rerouted, restored, or closed based on current recreation needs, resource conditions, sustainability, safety, and management objectives.
Maintain Meaningful Public Participation
VVCC supports streamlining clerical corrections and minor travel-management changes that do not meaningfully alter public access or allowable uses. However, substantive changes to trail access or allowable uses should continue to include meaningful public involvement.
Local trail organizations, recreation users, conservation organizations, municipalities, and other stakeholders can provide valuable information about recreation patterns, user conflicts, resource conditions, and local management needs.
The goal should be a proportionate public process: simple changes should be simple, while consequential changes deserve meaningful community input.
Conclusion
VVCC supports modernizing the Travel Management Rule and believes greater local decision-making can produce better outcomes. We encourage the Forest Service to develop a final rule that:
1. Provides meaningful Ranger District-level discretion to manage trail access and allowable uses based on local conditions.
2. Allows Class 1 e-bikes on trails open to bicycles by default, while preserving Ranger District authority to restrict Class 1 access on specific trails based on local conditions and management needs.
3. Preserves resource conditions, trail sustainability, public safety, user conflicts, maintenance capacity, and enforcement capacity as meaningful considerations in access decisions.
4. Maintains clear distinctions between Class 1 e-bikes and higher-powered devices and provides federal and bicycle-industry resources for education, signage, monitoring, and enforcement.
5. Maintains a “closed unless open” approach for roads, trails, and other access routes, under which physical existence or historic classification alone does not establish that a route is appropriate for public access or for a particular use.
6. Maintains meaningful, proportionate public participation for consequential access decisions.
VVCC values its collaborative relationship with the Forest Service and believes successful recreation management requires balancing access, stewardship, and sustainability. Local organizations such as VVCC will continue to be important partners in trail stewardship, education, and responsible recreation. However, increasing access without providing local Forest Service units with the resources necessary to manage it is not sustainable.
Greater local flexibility should therefore be accompanied by the authority and resources necessary to successfully implement those decisions on the ground.
We appreciate the opportunity to provide input and look forward to participating as the proposed rule and Draft Environmental Impact Statement are developed.
Sincerely,
Tracy Randall - President, Verde Valley Cyclists Coalition
