How the U.S. Forest Service Reorganization Impacts Trails
On April 3, 2026, the U.S. Department of Agriculture finalized a sweeping rewrite to the National Environmental Policy Act, commonly known as NEPA. These changes alter how the Forest Service reviews and approves environmental impacts of projects on National Forest lands.
What Is NEPA and Why Does It Matter for Trails?
NEPA is a federal law that requires agencies to evaluate environmental impacts of projects and decisions before acting. For trail advocates, it has been the primary process through which the public can review, comment, and engage with projects on National Forest lands.
What Changed?
Environmental review should now be faster. Changes to page limits and deadlines are now law: 75 pages for Environmental Assessments (EA) with a one-year maximum timeline, and 150 pages for Environmental Impact Statements (EIS) with a two-year maximum timeline. While NEPA efficiency is needed, compressed timelines and page limits may mean less thorough analysis. It also means less time for public engagement around projects that could benefit or impact trail-based recreation. The same changes are true for other areas of community interest.
Categorical Exclusions (CE) are now much broader and more discretionary. Staff now have more latitude to approve projects without a full Environmental Assessment or Environmental Impact Statement. For trail advocates this could cut both ways: trail approval may move faster, but so can other proposals that impact trail corridors.
Public participation mandates have been lowered. The procedural requirements for public scoping, alternatives analysis, and comment periods that were built into NEPA’s regulations are no longer binding; meaning a considerably lower floor for public engagement. We have less power through commenting to shape favorable outcomes for mountain bikers, which is also true for all stakeholders. This change limits the effectiveness of public advocacy.
What This Means for Trail Organizations
The process and opportunities that IMBA Local organizations and other trail groups have used to elevate impacts to trails and negotiate better project outcomes will now be shorter, less formal, and in some cases, absent entirely. This doesn't mean mountain bikers lose our voice, it means we need to assert our voices earlier in the process before a project is in review.
Three priorities outlined in IMBA's Forest Service reorganization review are important to remember as we navigate these changes:
Relationships: Get to know your Forest Service recreation staff before a project lands on their desk. A trail organization that is already a trusted partner will have far more influence than one submitting comments on a 30-day timeline.
Agreements: Programmatic MOUs, cost-share agreements, and stewardship contracts don't rely on NEPA. These establish your organization's role and partnership formally with the agency.
Tracking: The Forest Service no longer publishes the quarterly Schedule of Proposed Actions (SOPA) document. Under the unified 7 Code of Federal Regulations (CFR) Part 1b framework finalized by the U.S. Department of Agriculture (USDA) in April 2026, each individual national forest or grassland must now maintain its own isolated “Proposed Projects” website. Be sure to sign up with your individual forests for updates. Track their Proposed Projects for topics affecting recreation or other areas of interest. For example, here is a sample "Proposed Project" for a MTB trail found on the White River National Forest "Proposed Projects" page.
Where NEPA Reform Could Help Trail Projects
Noncontroversial projects will move faster within the agency. Routine trail requests like re-routes and new singletrack in areas with existing trail infrastructure have always been strong Categorical Exclusion candidates. With Categorical Exclusion authority now more broad and more discretionary, a supportive District Ranger has more latitude to approve these projects quickly without preparing a full Environmental Assessment or Environmental Impact Statement.
Major constraints are still based upon known key factors: willingness of the agency, level of public controversy, any significant wildlife concerns, or other discoveries found in the extraordinary circumstances review; and ultimately whether the project is consistent with the Forest Plan. Categorical Exclusions cannot approve projects carte blanche.
Under the new USDA regulations, it is reported that there are 39 Categorical Exclusions that do not require additional documentation. These might be used for trail maintenance, drainage projects, signing, and other projects that generally avoid significant new ground disturbance. There also appear to be 48 new Categorical Exclusions that do require supportive documentation to create a written record that justifies the use of the Categorical Exclusion, which will be recorded via a Finding of Applicability and No Extraordinary Circumstances (FANEC) document.
Stewardship and maintenance work may be easier to approve without new documentation. Minor re-routes, tread repairs, and volunteer stewardship agreements may oscillate between meeting and not meeting the threshold for a FANEC. Regardless, the more flexible Categorical Exclusions framework should allow Forests to authorize minor trail work more quickly.
eMTB access decisions could benefit as well, however, this will be more complicated because e-bikes continue to be managed under the Forest Service’s motor vehicle designation framework. eMTB access questions are often stuck in limbo because these would require amendments to the motorized recreation plans under the Travel Management Rule Plans (TMRP), which often triggers NEPA review and can’t fit under a Categorical Exclusion. If framed appropriately, newly expanded Categorical Exclusion authorities could allow a Forest to make limited eMTB trail designation changes in areas appropriate for expanded eMTB access without a full Environmental Analysis, but this will need to continue to evolve over time.
Where NEPA Reform Could Hurt Trail Projects
Timber sales, road building, and other proposals near trails may move faster, too. The same streamlined NEPA and expanded Categorical Exclusion authorities that could benefit trail projects applies equally to projects that can threaten trail access. A timber sale adjacent to popular trails or a new road into backcountry riding areas can now clear NEPA faster and with less opportunity for public input. Public comment timeframes that provided opportunities to weigh in on projects in the past may be compressed further, or even removed entirely under the new regulations, which can reduce ability to fully scrutinize the impact and relay written concerns to the agency.
Less analysis can also mean less documentation of trails and trail benefits. Shorter Environmental Analyses and Environmental Impact Statements with strict page limits could mean the agency may not document trail projects as thoroughly as under the previous framework. Documentation like this has historically been helpful for trail advocates as a tool to shape project outcomes, and when necessary, as the basis for legal challenges.
What NEPA Reform Doesn’t Change
Political pressure and collaboration still matter. NEPA is a process law—it governs how decisions get made, not who gets a seat at the table. Relationships with elected officials, state offices of outdoor recreation, and wildlife agencies remain as important as ever. In fact, these partnerships are even more critical in a structure that gives individual officials more discretion.
Litigation remains an option. Reforms to NEPA have reduced procedural opportunities for public input, but not the ability to challenge agency decisions in court. Legal challenges to NEPA are still available, should agencies not follow the Administrative Procedures Act.
The Wilderness Act is untouched. Congressionally designated Wilderness remains off limits to bikes regardless of any NEPA changes. NEPA reform does not affect trail access in Wilderness, and no amount of Categorical Exclusion (CE) authority allows a Forest to permit bikes in Wilderness.
IMBA's Government Affairs team is tracking NEPA reform and its implications for trail management closely. As the Forest Service issues new guidance under the revised framework, we will provide updated resources for local organizations navigating this new landscape.
