November 2, 2026
Submitted via public participation portal to: https://www.regulations.gov/commenton/NPS-2026-0166-0001
Proposed Rule on Bicycle Use in Park Areas: RIN 1024-AE97
The National Parks Conservation Association (NPCA) is the leading citizen voice for the national parks. Founded in 1919, our mission to protect and enhance America’s National Park System for present and future generations. We are a national non-profit organization with more than 1.9 million members and supporters. The Coalition to Protect America’s National Parks (the Coalition) consists of over 5,400 members and supporters, including current, former and retired employees and volunteers of the National Park Service. Collectively, Coalition members have amassed more than 50,000 years of experience in caring for America’s most valuable natural and cultural resources. In pursuit of its mission, the Coalition studies, educates, speaks and acts for the preservation and protection of the National Park System and mission-related programs of the National Park Service (NPS). We value the chance to share our concerns with the NPS Proposed Rule on Bicycle Use in Park Areas.
We affirm bicycling (including riding class 1 pedal-assist e-bikes) is an acceptable recreational activity on some roads and trails in national parks. We are supportive of thoughtful NPS planning for bicycle use in parks, and this proposed rule offers a uniform framework to support such planning. However, there are portions of this rule that raise concerns and should be addressed before NPS moves forward.
- National parks are more visited than ever, and offering an alternative to private vehicles in a front-country setting could benefit park visitors and staff. While these benefits are in some cases self-evident, we urge deliberate research to ensure that presumed benefits to the public and NPS are real and adequately understood.
- While this proposed rule keeps some semblance of park manager authority intact, it also establishes a new assumption of bicycle allowance, requiring managers to take additional action to close an area of a park to bikes/e-bikes. Without greater staffing to back this approach, it creates an unnecessary — and in some cases untenable — burden on NPS staff who are already understaffed and underfunded.
- All e-bikes (including class 1 pedal-assist models) have a motor, therefore we assert that e-biking constitutes a motorized use. This proposed rule does not acknowledge that e-biking is a motorized activity, and this omission undermines NPS’s long-standing approach to management of motorized use.
Agency mandate and science-based rulemaking
NPS has an obligation under the Organic Act to “promote the use of the Federal areas know as National Parks, monuments, and reservations hereinafter specified … by such means and measures as conform to the fundamental purpose … which purpose is to conserve the scenery and the natural and historic objects and the wild life therein to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations” (16 U.S.C. 1). To uphold this legal mandate, NPS must ensure that rulemakings, such as the one proposed, are backed by research, and NPS should make public the background materials and studies that were used to justify the proposed rule.
Acknowledgement and analysis of impacts — Bikes/e-bikes can enhance visitors’ experiences in national parks and (potentially) remove vehicles from congested park roadways or reduce demand on over-burdened park shuttle systems. However, bikes/e-bikes also affect park operations, visitor experience, and natural and cultural resources. Potential harm to resources and ecosystem functioning as well as visitor experience and safety in a multi-use setting associated with bicycle expansion must be considered alongside ways bikes/e-bikes would benefit the public.
Responsibility to maintain a spectrum of visitor experiences — Expanding access for one user group should not come at the expense of others. NPS should evaluate how increased bike — and particularly e-bike — use may affect hikers, equestrians, and people seeking slow-paced recreation. Accessibility and recreation goals should be pursued in ways that account for the distinct purposes and conditions of individual parks and areas in parks rather than assuming that expanded bike/e-bike access is universally beneficial.
Adaptive management based on monitoring — We recommend that NPS commit to creating and staffing a five-year monitoring plan to observe and analyze impacts to resources (wildlife, soils, water, cultural sites, etc.) and visitor experience (congestion, crowding, safety, etc.) at any new area open to bikes/e-bikes. Adaptive management is a hallmark of good recreation resource management, and NPS should be prepared to change management strategies (including possibly disallowing bikes/e-bikes) according to analysis of monitoring data.
Management Authority
Under the proposed rule, all park roads open to motor vehicle use (crucially including long-term closed roads, administrative roads and some “improved” trails) would be presumed open to bikes/e-bikes unless expressly closed. This broad, blanket expansion of bike/e-bike allowance in parks is a significant policy change, and it runs counter to the science-based park management principles incumbent upon NPS by law.
Park managers must retain authority (36 CFR 1.5) to evaluate each park (and discrete areas or sites therein), to determine where and when bicycling is appropriate. Further, park managers are expected to apply the best available science and site-specific knowledge and adaptive management of bike/e-bike use in parks. The possibility for an area previously open to bikes/e-bikes to be closed (e.g., permanently, seasonally, certain days/times of day) or actively managed (e.g., for number at one time, directional travel, etc.) must be allowable and feasible.
The proposed rule also makes clear that bikes/e-bikes are prohibited in areas of the national park system designated or recommended as wilderness. Undeveloped and roadless parts of the National Park System should receive the same treatment as wilderness. We recommend extending the proposed rule section on wilderness to preclude a park manager from designating open to bikes/e-bikes any trail in a roadless and undeveloped area that has been recommended, proposed or found eligible for wilderness in a formal planning process.
Staffing for Education and Enforcement
While we recognize the benefit of bicycling for visitors to parks, we also acknowledge the essential role NPS staff play educating visitors about appropriate recreational behavior, and when necessary, providing enforcement to protect high-quality visitor experiences, safety and resource integrity.
Chronic understaffing and underfunding at NPS have crippled the ability for NPS to consistently manage record-high visitation numbers. Even with plenty of educational materials available to bike and e-bike riders about where they can currently ride, visitors make mistakes that result in unlawful behavior. NPS staff capacity will need to be bolstered to provide adequate enforcement and education regarding which roads/trails are open to bikes and/or e-bikes and the class of e-bike that is permitted. If the proposed rule is finalized without greater staffing, there will certainly be damage to park resources and compromised visitor safety.
We will continue to advocate for NPS and other public land management agencies to be fully staffed in order best serve the public and steward the lands entrusted in their care. Simply put, parks and public lands must be adequately staffed for bike/e-bike recreation to be successfully and sustainably implemented.
Motorized Use
Unfortunately, the proposed rulemaking suggests that because e-bikes do not use an “internal combustion engine” their management should be considered distinct from other types of motorized use regulation. While not changing the definition of either “bicycle” or “e-bicycle”, the justification for changes in management practices raises serious concerns about long-term motorized use policy on park lands. As stated above, all e-bikes (including class 1 pedal-assist models) have a motor, and we assert e-biking constitutes a motorized use.
Off-road vehicle (ORV) use is required to be regulated within the National Park System. NPS administration of regulations applying to ORVs such as all-terrain vehicles (ATVs), watercraft, and snowmobiles, has been subject to robust planning and study, resulting in regulations crafted to ensure NPS is guided by its mission and subsequent management policies. NPS Policy Memorandum 19-01, issued on August 30, 2019, defines an e-bike as “a two- or three-wheeled cycle with fully operable pedals and an electronic motor that provides propulsion assistance.” These classifications within NPS policy affirm that it is unreasonable to consider e-bicycles as equivalent to traditional bicycles and therefore, management policies and decisions must be distinct for each type of bike.
E-bikes are fundamentally distinct from traditional bicycles in that they are motorized, bringing with them the same opportunities and challenges as other motorized vehicles. NPS must acknowledge that e-bikes, regardless of management principles outlined in this rulemaking, are motorized vehicles and as such there will be roads/trails that are appropriate for traditional bike use and not for e-bike use. It is also necessary for park managers to regard e-bikes differently in some cases when exercising their authority under 36 CFR 1.5 to close areas to certain bicycle use.
Connected Landscapes
Parks belong to much larger, yet connected ecosystems and cultural landscapes, and the decisions made on adjacent public lands can have profound impacts on the resources preserved within the parks. Bikes and e-bikes allow recreationists to travel farther and faster across public lands. With expanded bike/e-bike allowance, areas that currently see limited visitation may experience significant upticks in human use, resulting in unintended resource impacts. Displacement of wildlife (alteration of migration patterns and changing behavior patterns, such as increasing vigilance behaviors) is one example of unintended impacts of bicycling that can occur absent careful and site-specific planning. We support a connected approach to recreation planning, and we recommend NPS seeks policy alignment with other land management agencies.
Park-specific considerations
Each of the 433 park sites managed by NPS is unique. Urban parks, such as Cuyahoga Valley on the doorstep of Cleveland or Minute Man outside of Boston, have vastly different infrastructure, visitor use patterns and special resource conditions from remote parks, such as Olympic and Redwood in the heart of West Coast forests and seashores. Informed NPS staff at each park must account for unique considerations, such as:
- Shared trail safety—many parks have multi-modal pathways where bikes/e-bikes will share a trail with walkers and people with mobility devices, strollers and dogs. NPS must provide education (including but not limited to signage) about and enforcement of appropriate speeds, safe passing, proper directional travel and other shared trail ethics. Further, park managers must be able to respond to unique and changing conditions of specific roads/trails.
- Shared road safety—many park roads are narrow, winding and congested. NPS must account for rider and driver safety when considering ways to integrate and manage bikes/e-bikes into existing transportation infrastructure (noting that adding separated bike paths is not physically possible in steep, rocky or sensitive terrain).
- Resource protection—many roads and trails in parks have sensitive resource considerations ranging from wildlife movement, erosion susceptibility, rockfall and other geohazards. NPS must consider these special conditions as part of a full assessment of an area’s appropriateness for bikes/e-bikes.
- Community connection—parks are connected to surrounding landscapes and communities, often for commuting as well as for recreation. NPS must coordinate with local partners to create compatible bike use plans and educate riders about regulations in different areas.
- Community input and Tribal consultation—expanded access should come with expanded opportunities for community input and Tribal consultation. NPS will need to be adequately staffed and resourced to respond to these responsibilities to be a good partner and neighbor.
- Visitor safety education—in some cases, park conditions necessitate special best practices for visitor safety, such as carrying bear spray in bear country. NPS will need to communicate such safety advisements to bike/e-bike riders. Similarly, park managers must retain the ability to responsively close trails and roads when conditions are exceedingly unsafe (e.g., grizzly bear frequented, rockfall episodes, flash flooding threats, etc.).
- Collaboration with concessioners/rental companies—a great many e-bikers in parks use rental equipment. These visitors are very often novice riders, unfamiliar with bicycling etiquette and their own rental equipment. NPS must work closely with concessioners and rental companies to offer good operation instructions, tutorials and thorough safety and park regulation education in order to ensure successful expanded e-bike use in parks.
- Fire risk mitigation—many parks have very limited infrastructure and emergency response. NPS must consider the possibility of e-bike battery-caused fire in its assessment of the appropriateness of e-bikes on certain roads/trails.
Conclusion
We urge NPS to retain appropriate review and public participation requirements, limit categorical exclusions to actions that genuinely qualify, and require site-specific analysis before expanding bike/e-bike use. We support appropriate recreational opportunities, including bicycle use where compatible with park purposes and resource protection. However, broadening access without adequately evaluating resource sensitivity, visitor experience and safety, and operational impacts risks undermining the very resources and experiences NPS is charged with protecting. Thank you for the opportunity to comment.
We very much look forward to continuing to engage on the successful implementation of recreation policy in national parks.
Respectfully,
Cassidy Jones
Senior Visitation Program Manager
National Parks Conservation Association
Tucker Johnson
Associate Director, Government Affairs
National Parks Conservation Association
Emily Thompson
Executive Director
Coalition to Protect America’s National Parks