For nearly 40 years, IMBA has been on a mission to get trails on the ground for not only mountain bikers but hikers, runners and equestrians by working with our federal land agency partners. IMBA recently analyzed the USDA reorganization plan announced July 24, which would phase out the nine U.S. Forest Service regions and consolidate Forest Service and Department of Agriculture work to offices in five cities; among other substantial changes.

Overall, the plan raised many questions because it lacked sufficient detail to thoroughly understand the impacts. IMBA prepared a detailed public comment in order to explain how this consolidation could create a myriad inefficiencies which would benefit from a cost analysis and a strategic, phased approach. It could affect the ability to gain approvals to get trails on the ground, impact trail maintenance, threaten strong research, stall ongoing education on sustainable trails, and hamper effective partnerships between IMBA, IMBA Local member organizations and federal land managers. Together, these risks could have effects on local economies that depend on recreation.

Secretarial Memorandum

On August 1, U.S. Secretary of Agriculture Brooke L. Rollins initiated a 30-day public comment period for the plan, with comments due August 26. The comment period was then extended to September 30. The plan, communicated via a Secretary’s Memorandum (Secretary Memorandum: SM 1078-015), “authorizes and directs the actions necessary to effectuate the consolidation, unification, and optimization of functions within the Department of Agriculture (USDA) to achieve improved effectiveness and accountability, enhanced services, reduced bureaucracy and cost savings for the American people.”

The Secretary’s Memorandum communicates that the USDA reorganization plan will be guided by four key principles: Align Workforce with Resources, Relocate Resources Closer to Customers, Eliminate Bureaucratic Layers; and Consolidate Support Functions. The described reorganization focuses on aligning the USDA workforce with available resources through voluntary retirements and reassignments, relocating many Washington, D.C.–based staff to lower-cost regional hubs, eliminating unnecessary management layers by consolidating regional offices, and streamlining operations by merging overlapping support functions such as HR, IT, communications, and grants management. The changes aim to reduce costs, improve efficiency, and bring USDA staff and services closer to the people they serve while maintaining critical functions like wildfire response, agricultural grading, and research.

Read IMBA’s full comments to the U.S.D.A.

Summary of IMBA’s Comments

IMBA has been working alongside our partners with Outdoor Alliance to mitigate how large-scale reductions in force will jeopardize vital public lands work, including the implementation of the bipartisan EXPLORE and BOLT Acts, thus risking further erosion of mission-critical capabilities at the Forest Service. IMBA submitted comments by the August 26 deadline, contributing to the outdoor community’s collective response to the plan and the future of the Forest Service, by focusing on this as an opportunity to strengthen how the USDA stewards our public lands.

IMBA’s comments detailed the almost 40-year history during which IMBA and the Forest Service have partnered to advance sustainable trail standards, train thousands of professionals, and mobilize millions of volunteer hours that multiply agency capacity. The comments detail the deep respect IMBA has for the Forest Service, and recognize the agency’s critical role in delivering recreation infrastructure that fuels local economies, supports community health, and sustains America’s connection to public lands.

USDA’s proposed reorganization, while aimed at reducing bureaucracy and improving efficiency, risks undermining the Forest Service’s ability to carry out its mission across its 193 million acres. Eliminating regional offices, consolidating functions, and reducing staff could disrupt recreation management, erode institutional knowledge, delay trail and infrastructure projects, and weaken partnerships that communities and economies depend on. Perhaps most problematic, the plan as outlined lacks sufficient detail, cost-benefit analysis, and safeguards to ensure that efficiency gains do not come at the expense of effectiveness.

IMBA recommends a strategic, phased approach to reorganization that reinvests cost savings into filling critical Forest Service vacancies at the forest level, prioritizes the recreation economy, and expands partnership management capacity. Extending Direct Hiring Authority, strengthening public-private partnerships, and ensuring adequate staffing for recreation, fire recovery, and volunteer stewardship are essential to sustaining the agency’s relevance. Given outdoor recreation’s $1.2 trillion contribution to the U.S. economy, investment in Forest Service  recreation programs is an investment in rural vitality, community well-being, and the enduring value of America’s forests and grasslands.

Read IMBA’s full comments to the U.S.D.A.

Mass Terminations and Personnel Changes

Coming on the heels of mass reductions in force earlier in 2025, this plan adds to concerns regarding whether remaining public employees can effectively steward America’s public lands. The USDA has lost critical staff in positions protecting trails, national parks, and public health and safety; as well as professionals at the Forest Service responsible for recreation planning, trail restoration, wildfire mitigation, and conservation planning, among other work. These massive personnel changes are fundamentally reshaping the agency while leaving remaining staff overburdened and under-resourced. Remaining employees are concerned the losses could drive a historic loss of institutional knowledge, and will be hard to reverse. IMBA’s comments recommend an Institutional Knowledge Retention and Transfer Plan.

Since April, the USDA has shed more than 16,000 employees via buyout offers and mass layoffs, putting public land management at risk. Additional reporting by Politico indicates the Department is aiming to cut a total of around 30,000 – or 30 percent – of its employees through a combination of deferred resignation offers and firings through a reduction in force.