Roadless 2.0: Why a 25-Year-Old Fight May Be Ready for a Different Answer: Guest Post by Don Amador

OHV Folks and Mad River RD Staff with South Fork Mountain IRA after 2015 Route One Complex Fire

For many California OHV riders, the words “Roadless Rule” probably don’t mean much. You may have heard them in a club meeting, seen them in another public-land fight, or watched another battle unfold over a trail that seemed perfectly reasonable but somehow became tangled up in federal land-management policy. For those of us who have been involved in public-land recreation for decades, however, the Roadless Rule is a familiar—and sometimes frustrating—part of the landscape.

Now, after 25 years of litigation, policy battles and changing conditions on our national forests, the Forest Service has proposed rescinding the national 2001 Roadless Area Conservation Rule. The proposal would remove the nationwide prohibitions on road construction, road reconstruction and timber harvesting in inventoried roadless areas (IRAs) and return those decisions largely to individual forests through their existing land-management planning processes. For California’s OHV community, I think this is something much more interesting than simply another logging issue. It could be an opportunity to reset the way we think about roadless country, forest health and managed motorized recreation. I call that potential reset “Roadless 2.0.”

First, let’s clear up one misconception. The 2001 Roadless Rule did not close all the roads and OHV trails inside inventoried roadless areas. The Forest Service’s original analysis considered—and rejected—an alternative that would have prohibited motorized recreation in roadless areas. The new 2001 ROADLESS AREA CONSERVATION RULE RESCISSION DRAFT ENVIRONMENTAL IMPACT STATEMENT (DEIS) makes the distinction even clearer. It identifies approximately 5,200 miles of motorized trails within the potentially affected roadless areas and recognizes that trailheads around the periphery of IRAs can provide motorized trail access into those areas. Existing OHV use on trails designated for motorized use remains governed by the applicable Forest Plan and Travel Management decisions.

How did we get here? The original Roadless Rule was adopted in January 2001 after years of controversy over how the Forest Service should manage the remaining large blocks of relatively undeveloped national forest land. The rule established national restrictions on road construction, road reconstruction and most timber harvesting within inventoried roadless areas. It immediately became controversial. Environmental organizations viewed it as one of the most important conservation protections ever placed on National Forest lands. Many timber, mining, recreation and multiple-use interests viewed it as another example of Washington imposing a broad management prescription on vastly different landscapes. And the litigation began.

California became part of that long-running legal and administrative struggle. For years, questions surrounded how the Roadless Rule interacted with Forest Plans, Travel Management and local decisions. For riders, however, the practical question was usually much simpler: “Can I legally ride on my motorcycle, ATV or UTV on that trail?” That question didn’t always have a simple answer.

The world has changed dramatically since 2001. California had already experienced major wildfires, but we had not yet experienced the landscape transformation of the last decade. Since then, California has endured fire seasons that have fundamentally changed portions of our national forests. The Camp Fire, Caldor, Dixie, Mendocino and August Complex Fires, Mosquito, and many others have left landscapes dramatically different from what they were when the original Roadless Rule was created.

              

                                         2019 Post Fire Trail Survey of 2015 Rt. 1 Complex Fire – Pilot Creek OHV Trail System

                                               South Fork Mountain IRA – Six Rivers National Forest

In some areas, what was once called an Inventoried Roadless Area could now reasonably be described by riders as an “Inventoried Treeless Area.” That’s obviously a little tongue-in-cheek, but there is a serious point behind it. A designation created around the idea of maintaining relatively intact, undeveloped forest landscapes now exists in places where fire, drought, insects, disease and extreme weather have radically altered the landscape. The question shouldn’t simply be, “Was this area roadless in 2001?” The better question is, “What is the appropriate management strategy for this landscape today?”

Dan East Trail BEFORE 2015 Rt.1 Complex Fire – Dan East Trail AFTER 2015 Rt. 1 Complex Fire

                         

Pilot Creek OHV Trail System – South Fork Mountain IRA – Six Rivers National Forest

This isn’t an argument to pave the backcountry. Most OHV riders don’t want every mountain road turned into a highway. We don’t want every remote forest landscape turned into a subdivision or motocross track. And we don’t need to pretend that every roadless area is appropriate for motorized recreation. Some places are genuinely remote, special and appropriate for rugged backcountry non-motorized recreation.

But there is a huge difference between saying that some places should remain undeveloped and saying that a national rule adopted 25 years ago should determine the transportation and management options available on every roadless landscape regardless of what has happened since. That’s where I think Roadless 2.0 comes in.

To me, Roadless 2.0 starts with a simple concept: manage the landscape we have—not simply the landscape we mapped in 2001. That means looking at each area based on current conditions, including wildfire history, forest health, fuels, watershed conditions, wildlife, existing roads and trails, historic access, recreation demand, community needs, fire response, post-fire recovery and the potential for sustainable motorized recreation.

The DEIS recognizes that the current planning system includes both Semi-Primitive Motorized and Semi-Primitive Non-Motorized recreation settings. It also identifies approximately 3.1 million acres of potentially affected IRAs as Semi-Primitive Motorized. Motorized recreation is therefore already part of the Forest Service’s legitimate recreation planning framework. Roadless does not have to mean nonmotorized.

California is also showing us what managed OHV recreation can look like. OHV recreation itself has changed. We have moved a long way from the old image of “just go ride wherever you want.” Today’s legitimate OHV system is increasingly based upon designated routes, MVUMs, trail standards, seasonal restrictions, route signing, resource monitoring, law enforcement, trail maintenance, restoration of damaged routes, user education, clubs and volunteers, and purposefully designed trail systems.

This is where conservation and OHV interests have found more common ground than we sometimes did in the past. A legal, designated trail can be mapped, signed, monitored, maintained, rerouted when necessary, closed seasonally, designed around sensitive resources and enforced. An illegal user-created route has none of those advantages. A carefully planned trail connection can sometimes be a conservation tool by concentrating use onto a durable corridor and keeping riders out of fragile areas. A logical loop or connector can also prevent riders from reaching a dead end and creating their own way around it.

The DEIS recognizes that new transportation infrastructure can provide additional access to dispersed recreation and that some temporary roads could potentially become trails after management activities are completed. That’s an important concept for California and for other fire-affected national forests.

The DEIS says the proposed rescission would return decision-making to individual forests and existing land-management plans. That’s good. But local decision-making needs to mean multiple-use decision-making where the OHV community gets skin-in-the-game by showing up and participates.

The DEIS identifies road construction needs associated with much more than timber harvesting. It specifically identifies fuels reduction, pre-commercial thinning, watershed restoration, habitat improvement and recreation development as activities that can require transportation access. That is a very different landscape than the Roadless debate of 2001 and leaves room for hybrid fuel reduction/recreation projects that can meet multiple objectives.

And here’s something every California rider should understand: the Roadless Rule isn’t the only thing that determines whether you can ride. Even if the national Roadless Rule disappears, your Forest Supervisor doesn’t simply get to say, “Open it all.” Forest Plans still matter. NEPA still matters. The Travel Management Rule or a revised version still matters. The MVUM still matters. Wilderness designations still matter. Wild and Scenic River protections still matter. Endangered species protections still matter. Private property rights matter. Tribal interests matter. Site-specific environmental analysis still matters. Roadless 2.0 is not a blank check.

What should California OHV riders support? I think the answer is pretty straightforward. We should support an alternative that ends the one-size-fits-all national prohibition, returns appropriate decision-making to individual forests, requires genuine consideration of motorized recreation, recognizes the difference between roads, motorized trails and unmanaged cross-country travel, and encourages strategic and collaborative transportation access planning efforts.

Roadless 2.0 could be an opportunity. But only if the recreation community helps define what that opportunity looks like.

The Forest Service is currently accepting comments on the proposed rescission, with the comment period scheduled to close September 21, 2026.  https://www.fs.usda.gov/managing-land/planning/roadless

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Don Amador is a longtime public lands advocate with over 30 years of experience in recreation policy, trail stewardship, post-wildfire recovery, and collaborative land management and is former Chair of the CA State Parks Off-Highway Motor Vehicle Recreation Commission.

 

 

2 thoughts on “Roadless 2.0: Why a 25-Year-Old Fight May Be Ready for a Different Answer: Guest Post by Don Amador”

  1. I value your opinion and many of your points are valid. I just don’t think the current approach will get you there. The value of Roadless Areas as described in the 2001 effort has not changed. What has changed is the desire for other values such as motorized access and fuel treatments have increased. Certainly, there are selected places in the roadless rule landscape where motorized trails and timber/fuels reduction treatments are appropriate. Implementing such actions, however, is not achieved by rescinding the Roadless Rule. It is done by maintaining the Roadless Rule and proposing a list of things that have changed over the last 25 years that have value if they are addressed. The current propose rule is like suggesting I disassemble my car to fix the alternator. The current approach will end up in court for decades and for many of the same reasons building roads in Wilderness Study Areas remains nearly impossible. This proposed regulation lacks defendable rational for the change while there remain many good economic and ecological arguments for keeping these areas mostly roadless. It is great to talk about making local decisions but one must remember any decision must also address national and regional concerns.

    It is also important to remember you are talking about an agency that has trouble deciding if limited use of chainsaws is appropriate in any given Wilderness Areas that have hundreds of trees per mile crossing a trail even though it has the legal authority to do so. That’s a local decision. This is because of a lack of trust in the Forest Service not being willing to discuss a consistent and transparent standard of when and where this type of action would be appropriate. It is also because local decisions can take years to implement. Sure, there will always be people against any mechanized trail management in Wilderness, but a reasonable, transparent and thoughtful (not just local) rule can be sustained on the ground and in court. I think that is true for the Roadless Rule question as well. Furthermore, such a process would be more likely to stay in place as we move from one administration to the next.

    Finally, there is no funding to increase the activity levels on National Forests. The proposed budget by this administration greatly reduces its budget and personnel. There is already a billion-dollar backlog in road maintenance that keeps me from getting to places I would like to go that already have roads. The Forest Service does not currently meet its targets for timber volume or fuel treatments acreage. And despite a program where over a million acres of fuel treatment occur each year, fire acreage on an annual basis continues to increase. That means that if this regulation is implemented it will come down to the question of should we provide more miles of motorized trails or increase the number of treated acres that would reduce the chance that human infrastructure will burn.

    None of these questions are raised let alone addressed in the current proposal.

    Reply
  2. The idea that roadless areas that experienced high severity fire would have been less likely to have experienced that effect if not for the roadless rule is unfounded and not explained. Roadless areas often didn’t have roads in 2001 for a reason. They are often steep and are low productivity sites for trees. This makes them tactically and/or economically more difficult to implement fuel treatments and suppress fire. Roads are also a significant source of fire starts. NTM, some of the most heavily managed and roaded lands out there have burned to crisp in the Sierra in recent years.

    Roadless doesn’t mean one cannot manage it. The situation is simply too complicated to make such a sweeping claim, and for me, it discredits the author. In fact, I find no compelling or substantive reasons in this article to rescind the roadless rule. It’s lots of hand waving from a road advocate. As soon as we start discussing substantive examples, it leads to tweaking the roadless rule, rather than rescinding it, which doesn’t lead to the ultimate goal of those that want more roads for recreation.

    I have worked with OHVers on collaborative groups. Negotiating with them was notoriously difficult, as they came to the table with a “no net loss” mantra, regardless if the road proposed for closure was “fun” to actually drive a vehicle on or not or lead to some place “fun”.

    Reply

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