How NEPA Reform Affects Trails on National Forest Lands
The United States Forest Service (USFS) is undergoing the most significant structural change in its history. While the full implications will take time to be entirely realized, local trail organizations should be paying close attention. For partners like IMBA and its network of local organizations, the reorganization will impact how relationships are built, projects are delivered, and advocacy is carried forward on the ground. The reorganization was originally announced in July 2025 with a single two-month public comment period. Final details of the changes were released on March 31, 2026.
The stated aim of the reorganization is to reshape the agency by bringing the agency closer to its customers, eliminating layers of bureaucracy, and consolidating redundant functions. This has resulted in a sweeping shift away from the long-standing nine-region model toward a state-based structure more similar to the structure of the Bureau of Land Management (BLM). Regional offices are being eliminated and replaced by 15 state directors, each responsible for coordinating forest operations, partnerships, and intergovernmental relationships.
National leadership will move from Washington D.C. to Salt Lake City, Utah to be “closer to western landscapes,” while administrative and technical functions are being centralized into operational service centers in Fort Collins, Colorado; Albuquerque, New Mexico; and Missoula, Montana. Research functions, once semi-independent across stations, are being consolidated under a unified structure based in Fort Collins, though still geographically distributed. The USDA has indicated that the restructuring will move forward in phases through 2026 and 2027.
As a result of this reorganization, mountain bike advocacy and trail management will be influenced more at the state and forest level, which may not be radically different for most mountain bike stakeholders. Trail advocates will need to continue to focus on local relationships and local credibility to advance goals and move projects forward. However, recreation—although growing in demand—will have greater competition with timber, resource extraction, and motorized uses under the current administration’s leadership. Land management decisions as a whole will likely become less consistent across regions due to the changing structure. Trail organizations who remain adaptive, vigilant in maintaining relationships, and focus on proactive problem solving will likely continue to see success.
How The Reorganization Impacts Trail Advocacy & Maintenance
This shift reinforces what we already know: trail work happens locally. Our trail building efforts are inherently project-based and typically occur at the ranger district level. Similarly, while IMBA’s Government Affairs policy work engages national leadership, much of our advocacy is rooted in local relationships with recreation planners, district rangers and forest supervisors.
When surveyed, few IMBA Local organizations reported regular engagement with USFS regional offices. The reorganization may not dramatically change day-to-day interactions for most, but it will require a reset in understanding who holds decision-making authority and how to engage effectively.
In 2025, IMBA submitted detailed public comments on the reorganization, emphasizing the need for a phased, transparent approach backed by cost analysis and stakeholder engagement in order to maintain the agency’s effectiveness. While the USFS did adopt a two-year phased implementation approach, the final plan falls short of IMBA’s recommendation for transparent cost analysis and robust stakeholder engagement. This leaves many details unclear and unanswered, including: the cost and staffing impact this reorganization will have on budgets, on morale; and on the management of forest natural resources, recreational trail assets, and public access.
However, our focus remains clear: ensuring trails can continue to be planned, built, and maintained effectively. This includes safeguarding volunteer agreements, supporting education and training, and strengthening partnerships between local organizations and federal land managers.
What Local Trail Organizations Can Do Today
For local trail organizations, the practical effect is a more decentralized and potentially more variable system to navigate. While the intent is to push leadership closer to the field, the consolidation of support functions may reduce overall capacity. Relationships that once existed at the regional level will need to be rebuilt in new configurations, often at the state or forest level, to renew or elevate local credibility. Local trail organizations can be proactive partners by focusing on relationships, agreements, and communications in order to leverage opportunities to assist.
Relationships
Map the new structure to identify local decision-makers and issue leads.
- Reconnect with District Rangers, Forest Supervisors, and Recreation Staff Officers.
- Who handles agreements, NEPA, and recreation?
- How has their role changed?
- How can you help?
- Partner to become force multipliers for understaffed forests: explore how you can shift from a project advocate to a capacity partner to retain and strengthen your relationships.
Agreements
Audit and update agreements as soon as possible.
- Types of agreements to review or explore before operations shift to the new structure:
- Cost-share, Partnership, and Stewardship Agreements
- Programmatic Recreation Agreements (multi-project vs. individual project)
- MOUs that help shape and drive communication and procedural structure
- Note: Ensure these renewals are compatible with the new structure.
- Track the Forest Service schedule of proposed actions (SOPA) for proposals that will impact trail assets in your forest.
- Note: Here is a sample SOPA for White Mountain National Forest.
- UPDATE, May 19, 2026: The Forest Service no longer publishes a quarterly SOPA document. Each individual national forest or grassland must now maintain its own isolated “Proposed Projects” website. Sign up with your individual forests for updates. Track their Proposed Projects for topics affecting recreation or other areas of interest. Here is sample "Proposed Project" for a MTB trail found on the White River National Forest "Proposed Projects" page. Learn more about this change and NEPA reform in this IMBA review.
Communications
Align your message and align your broader partnerships.
- Consistently align mountain bike access with:
- Economic development and tourism
- Conservation through sustainable resource management and planning
- Health and wellness
- State-level organization will strengthen your success. Bring partners together:
- OREC or State Outdoor Recreation Offices
- Governor’s staff
- State Legislators
- Offices of Tourism and Economic Development.
To support IMBA Local Organizations and Trail Champions navigating partnerships with the U.S. Forest Service, IMBA’s subject matter experts have prepared a new online resource. The guide covers the Agency’s hierarchy, planning fundamentals, operational success, and the legal anchors of building a formal partnership.
New IMBA Resource: Working with the U.S. Forest Service
Compounding Challenges: Funding, Workforce, & Reforms
These structural changes are unfolding alongside a series of compounding challenges. The agency remains critically underfunded while grappling with a shrinking workforce. Burnout is high, institutional knowledge has been lost through previous workforce reductions, and despite the growing demand for recreation, it risks being deprioritized in favor of timber, energy extraction, and motorized uses.
Policy shifts may further strain capacity. Potential rescission of Roadless Area protections could increase project demand in sensitive areas. NEPA reform may accelerate timelines but place additional pressure on already stretched planning departments. Anticipated changes to the 2005 Travel Management Rule could introduce further uncertainty and slow progress on the ground.
Layered into this reorganization is the broader federal hiring freeze. While the USDA exempted 52 “National Security and Public Safety” positions which were deemed essential to protect forests, agriculture, and public safety, many other roles remain unfilled. Even exempted employees may face relocation, further contributing to disruption and uncertainty within the agency.
Continue to be a Valued Partner
We recognize the USFS has always been a decentralized agency, and this reorganization will likely amplify that reality. Success, therefore, will depend on our ability to adapt quickly, orient ourselves within the new structure, and continue to be valuable partners on the ground.
IMBA’s strong brand recognition and longstanding relationships with the Forest Service are critical assets. Maintaining those relationships and demonstrating our value through successful project delivery, stewardship, and community engagement will be key. Early navigation of the new system will not only help get trails built but also position IMBA and our partners as trusted collaborators within the evolving framework.
All of this matters beyond trails. Outdoor recreation generated $1.2 trillion in economic output in 2023, about 2.3% of U.S. GDP and supports 5 million American jobs. Access to high-quality trails is a cornerstone of that economy, particularly in rural communities.
Ultimately, success in this new landscape will come down to capacity both within the agency and across our network. The trail community is well-positioned to adapt, but doing so will require proactive engagement, clear communication, and a continued commitment to collaboration.
