Re: Special Areas; Roadless Area Conservation — Draft Environmental Impact Statement (FS-2025-0001)
On behalf of the Vermont Mountain Bike Association (VMBA) and our 28 Chapters and nearly 9,000 members, I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule.
VMBA is a long-standing partner of the U.S. Forest Service on the Green Mountain National Forest. Through numerous challenge cost-share and volunteer agreements, our Chapters have built and now maintain over 100 miles of trail in the Forest, including trail systems in the Moosalamoo National Recreation Area and in both Rochester and Manchester districts, and our volunteers contribute more than 1,000 hours of stewardship each year. We know firsthand how much careful planning, partnership, and trust goes into building trails on National Forest land, and how easily that work can be undone.
While few of the trails we currently manage sit within Inventoried Roadless Areas, the Roadless Rule matters to us for reasons that go beyond our existing or planned future trail map.
First, the scale of what is at stake nationally is enormous. IMBA estimates that roughly 10,794 miles of trails currently open to mountain bikes lie within the approximately 45 million acres that would lose protection under this proposal, alongside more than 25,000 miles of hiking trails. These include nearby Eastern destinations our members travel to ride, such as the Seneca Creek and Tea Creek areas of the Monongahela National Forest and Wolf Ridge on the George Washington National Forest. Roadless areas are among the only places in the National Forest System where riders can find long, remote, quiet backcountry experiences that remain open to bikes. Once a road is built through that landscape, its character cannot be restored.
Second, Roadless Areas represent the future of quality trail opportunities, including in Vermont. Backcountry, unfragmented landscapes are rare in the Northeast. The Green Mountain National Forest's roadless areas are exactly the kind of places where future, thoughtfully planned trail connections could offer experiences that cannot be replicated on roaded or developed land. Removing these protections forecloses options before communities like ours can plan for them.
Third, the proposed approach shifts the burden onto forest staff and partners. Rather than pairing rescission with a replacement framework, the proposal defers decisions to individual forest plans and to state or Tribal petitions, one unit at a time. As a partner that already depends on limited Forest Service staff capacity, we are concerned this piecemeal approach will create years of uncertainty, uneven protections across forests, and more pressure on the very staff who make partnerships like ours possible.
Fourth, Vermont has learned hard lessons about watersheds. The flooding our state experienced in 2023 and 2024 showed how road infrastructure on steep, forested slopes can concentrate runoff, damage trails, and threaten downstream communities. Unroaded forests protect clean water and resilience. New roads in steep terrain add maintenance liabilities the agency is already struggling to fund.
Finally, the Forest Service's own analysis acknowledges the tradeoff. The draft EIS recognizes that expanded road-based access would come at the expense of quiet, remote backcountry experiences, could increase user conflicts, and could reduce recreation benefits by an estimated $6.1 million per year. Outdoor recreation is a cornerstone of Vermont's rural economy, contributing to more than $2.1 billion - almost 5% - of our state’s GDP.
VMBA respectfully urges the Forest Service to retain the 2001 Roadless Rule. If the agency proceeds with changes, we ask that it adopt meaningful national safeguards, including a "No Net Loss of Trails" policy, baseline trail inventories, firm limits on new road construction, protective buffers around existing trails, and continued investment in local Forest Service staff and partnerships.
Thank you for the opportunity to comment, and for your continued partnership with Vermont's mountain bike community.
Nick Bennette
Executive Director, Vermont Mountain Bike Association
nick@vmba.org