Better Recreation Data Should Improve Public Lands Without Tracking Individual Visitors
Federal agencies want better data on dispersed recreation, but the July 29 pilot proposal needs stronger tests for accuracy, bias, privacy and transparency.
Federal land managers regularly make decisions about trails, parking, toilets, campgrounds, boat launches, permits, staffing, emergency response and resource protection without a complete picture of how people use the landscape. Developed sites can be counted. Dispersed recreation is harder. A hunter leaving a gravel road before dawn, an angler walking into an unsigned stream crossing or a family camping outside a developed campground may never appear in the surveys agencies rely on.
Section 133 of the EXPLORE Act directs federal agencies to test better ways to measure low-use and dispersed recreation. On June 29, the Forest Service, National Park Service, Bureau of Land Management, Bureau of Reclamation, U.S. Fish and Wildlife Service, Army Corps of Engineers and National Oceanic and Atmospheric Administration opened a public-comment period on proposed protocols and pilot locations. Comments are due July 29, 2026. The law requires pilots at no fewer than 10 management units under each participating secretary. [1]
The basic goal deserves support. Better data can help agencies recognize use that is currently invisible, direct maintenance to places people actually visit, identify emerging safety or resource problems, and make a stronger case for budgets and staff. Bad data can do the opposite. It can shift money toward the easiest visitors to count, treat social-media activity as a substitute for actual use, or give a false sense of precision to decisions that still require local knowledge.
The pilot should test the methods, not assume they are interchangeable
The Forest Service says the pilots may combine manual visitor counts, trail-permit summaries, mechanical counters and visitor logbooks with newer sources such as anonymized location information from smartphones, social-media activity, aerial photography and satellite imagery. The interagency project page also identifies tools such as questionnaires, comment cards, GPS, game cameras and community science. [2][3]
Each method measures something different. A trail counter can record movement but may not distinguish a hiker from a hunter making repeated trips. Permit data can be accurate where permits are required but irrelevant on open-access lands. A visitor logbook depends on voluntary participation. Social-media posts may overrepresent highly photographed destinations and younger, connected users. Smartphone location data can miss visitors who disable tracking, carry no phone, lose service or use devices in ways the vendor cannot reliably classify. Remote imagery may confirm vehicles or site conditions without explaining what people were doing.
That does not mean these tools should be rejected. It means the pilots should compare them against ground-truthed observations, disclose error ranges and identify which populations or activities each method is likely to miss. A useful national protocol will probably be a menu of validated methods rather than one universal formula. A remote hunting area, an urban national park, a reservoir and a coastal wildlife refuge do not present the same measurement problem.
Privacy deserves the same practical treatment. The agencies describe the digital information as anonymized and propose to use it to describe patterns, not to identify individual visitors. That is an important distinction, and there is no basis in the notice to claim the pilots are intended as an enforcement-surveillance system. At the same time, federal privacy guidance cautions that removing direct identifiers reduces risk but does not guarantee that data can never be reidentified, particularly when location records are detailed or combined with other information. The Federal Trade Commission has also treated precise location information as sensitive because it can reveal visits to places that expose personal associations or behavior. [4][5]
The answer is not a blanket ban on digital data. It is data minimization and clear rules. Agencies should collect the least granular information that can answer the management question, aggregate it before analysis where possible, limit retention, prohibit vendors from reusing or selling it, document how it was obtained, and prevent individual-level information from being repurposed for routine enforcement. Public reports should explain methods and uncertainty without publishing details that could expose a person or encourage damaging crowding at sensitive sites.
The public should ask whether the proposed pilots can produce fair and usable information
The Federal Register notice asks for comments on two issues: the utility and adequacy of the proposed protocols, and whether the proposed management units are appropriate places to test them. Those questions create room for a focused comment that supports improved measurement while demanding validation and safeguards.
I recommend asking the agencies to:
Include pilot units that represent urban and rural areas, high-use and low-use sites, motorized and non-motorized recreation, hunting and fishing seasons, developed facilities, and dispersed landscapes with limited cellular coverage.
Validate emerging digital methods against direct counts or other trusted observations and publish accuracy, uncertainty and known demographic or activity biases.
Explain how data from different agencies and vendors will be standardized so that comparisons do not imply more consistency than the methods can support.
Adopt privacy rules covering collection, aggregation, retention, contracting, secondary use, security and deletion, with no routine use of individual-level location data for enforcement.
Require local managers and communities to review results before pilot estimates are converted into budgets, restrictions, fees or permit decisions.
The full protocols and proposed locations are available through the BLM ePlanning page, which is also the official place to submit comments.
Suggested message: I support improving federal recreation-use data, especially for dispersed and low-use activities that current surveys miss. Please test the protocols across a representative range of landscapes and seasons, validate digital estimates against direct observations, publish uncertainty and bias, and adopt enforceable privacy, retention and vendor-use safeguards. Aggregate data should improve management and funding decisions without enabling routine tracking of individual visitors.
Partner spotlight: Outdoor Alliance works across several human-powered recreation communities and regularly engages on federal public-land policy. The organization’s broad recreation perspective can help connect data quality with access, visitor experience and resource protection. The primary action for this article remains the official federal comment process.
This proposal fits directly within the PLWCF project. Reliable recreation data can help agencies explain needs and prioritize investments, but information is not a substitute for capacity. Someone still has to maintain the counter, audit the vendor, interpret the result, consult local staff and turn a national protocol into a defensible decision. The advocacy guidecan help readers prepare a concise comment focused on those implementation questions.
Federal agencies should know more about how the public uses public land. They should also be honest about what the data cannot show and disciplined about how much information they collect. A well-designed pilot can do both.
Garrett Robinson is the Chair of the Mid-Atlantic Chapter of Backcountry Hunters & Anglers, and a retired Marine Corps Master Gunnery Sergeant with 26 years of active-duty service. The views expressed here are his own and do not necessarily reflect those of any organization or entity. He lives in Stafford, Virginia.
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