Hiking, fishing, biking, and non-motorized boating account for 111.5 million activity participations on national forests in fiscal year 2024, about 15 times the reported off-highway vehicle (OHV) figure. Trailheads, river put-ins, fishing access points, dispersed campsites, and hunting units are reached by vehicle, so the condition of the road system governs access for these visitors as much as for riders.

The Forest Service's own National Visitor Use Monitoring (NVUM) survey shows the pattern. Designated wilderness received 8.8 million of 188.3 million site visits, 4.7 percent, and the other 95 percent occurred at developed sites or in the general forest. Visitors rate road condition 4.5 on a five-point importance scale, the same as signage and parking lot condition. The 2001 Rule's limits on road reconstruction therefore reach far more hikers, anglers, campers, and hunters than riders.

The Forest Service's cost-benefit analysis quantifies a possible recreation loss of $6.1 million a year from reduced quiet, remote recreation. It describes the offsetting gain, the expansion of road-based recreation, as "uncertain" and "limited," and it assigns that gain no value.

Valued with the agency's own per-day estimates (Bowker et al., 2009), a 0.25 percent change in road-dependent national forest recreation is worth about $22 million a year to recreationists, more than three times the loss the agency quantified. Retaining or restoring less than one-tenth of 1 percent of that use would offset the projected $6.1 million loss entirely. BRC asked the Forest Service to define and report projected gains on the same footing as losses.

Road-dependent recreation on national forests is worth about $8.9 billion a year in net value to visitors, and each 1 percent of that use retained or restored is worth about $89 million a year. Net economic value is what visitors would be willing to pay above what they actually spend. The total breaks into $7.2 billion from road-reached hiking and non-motorized boating and $1.7 billion from OHV use, camping, and hunting.

The literature review draws on the Recreation Use Values Database, a Forest Service-sponsored compilation maintained at Oregon State University, and reviews 35 studies from it. In the Forest Service's own national study of its visitor survey (Bowker et al., 2009), OHV use in the Interior West is valued at $108 per person per day, three to four times the value of backpacking. A Utah study of OHV riders found that moving land from open to limited access caused relatively small welfare losses, while prohibiting access caused much larger ones (Jakus et al., 2010). That result is the multiple-use argument in the agency's own research: managers can manage use route by route at low cost, and a closure costs far more.

The FY2024 Interagency Recreation Visitation Data Report credits the Forest Service with 7.1 million OHV visits, 4.3 percent of national forest visits, against 28.4 percent on Bureau of Land Management land. BRC's analysis, built only from Forest Service survey categories, puts national forest OHV use at 17.8 to 26.1 million visits, 2.5 to 3.7 times the reported figure. At the Bowker et al. values, the central estimate is worth about $1.1 billion a year, against $361 million at the reported figure.

Three lines of evidence point the same way:

• The interagency report defines OHV use to include four-wheel-drive vehicles and snowmobiling. NVUM tracks those separately, including "driving for pleasure," which 20.3 percent of national forest visits involve.
• Of 114 national forest reporting units, 46 report OHV use under 2 percent of visits and six report zero. Two of the six, Apache-Sitgreaves and Six Rivers, manage designated motorized route systems under the Travel Management Rule.
• Forests that do capture motorized use match BLM levels in the same states. Manti-La Sal in Utah reports 32.9 percent.

The interagency report does not say how the Forest Service built its figure, so the undercount is inferred. BRC asked the agency to disclose its method and re-estimate.

Each 1 percent of non-ski national forest recreation that rescission retains or restores supports about 1,060 jobs, $58 million in labor income, $108 million in value added, and $174 million in economic output a year. These figures use the four measures the National Park Service reports in its annual Visitor Spending Effects series, built from the Forest Service's own visitor spending data.

The base is large. Non-ski recreation on national forests supported an estimated $9.0 billion in local visitor spending, 106,000 jobs, and $10.8 billion in value added in FY2024. The cost-benefit analysis does not report this layer. The outfitters, guides, lodging, food service, and retail businesses near inventoried roadless areas are predominantly small entities, which is why BRC asked for the analysis to appear in the regulatory flexibility analysis.