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Comment in Opposition to Rescinding the Roadless Rule Oct 6, 2026 · @Great Lakes Wildlife Alliance Docket FS-2025-0001 (RIN 0596-AD66, 91 FR 53827) Great Lakes Wildlife Alliance opposes rescinding the 2001 Roadless Area Conservation Rule and asks the Forest Service to withdraw the proposal, including for Wisconsin's Chequamegon-Nicolet National Forest. GLWA is a volunteer 501(c)(3) based in Madison. We work to protect wolves and other wildlife in Wisconsin and the Great Lakes region. Wisconsin's roadless areas are small, and access is not the problem The proposal would remove protection from about 69,000 acres of the Chequamegon-Nicolet, less than 5% of its 1.5 million acres (Iron Mountain Daily News). The rule limits new road construction and logging. Trout Unlimited notes these lands are typically open to hunting, fishing and firewood cutting (Outdoor Life). The rest of the forest is already heavily roaded. The Forest Service has cited about 9,000 miles of Forest Service road on the forest, and said its road budgets were falling as maintenance costs rose (WXPR, 2014). The head of the Great Lakes Timber Professionals Association has said the rule has not limited timber supply or constrained logging in northern Wisconsin (WJFW). New roads are not needed for access. The science points one way: fewer roads, more wildlife Road density is the best-known predictor of where wolves can live. University of Wisconsin-Madison researchers found it was the best predictor of wolf presence in northern Wisconsin (Pratt et al., 2008). In Michigan's Upper Peninsula, wolf occupancy held steady below about 0.4 km of road per km² and fell sharply above it, with a threshold near 0.7 km/km², or about 1.1 miles per square mile (Journal of Wildlife Management, 2005). The Chequamegon-Nicolet is already past that threshold. Total road density, counting closed and primitive roads, was reported at 3.1 miles per square mile on the Chequamegon and 4.9 on the Nicolet, roughly 2.8 to 4.4 times the Michigan figure (Schienebeck testimony to the House Natural Resources Committee, 2024). The same testimony says the Forest Service's 2004 plan focused road closures on wolf pack areas and low-road-density areas. The 69,000 roadless acres are among the few large blocks where low road density remains. GLIFWC staff have also said these areas help maintain high water quality (Iron Mountain Daily News). What we ask of the Forest Service 1. Withdraw the proposed rescission of 36 CFR part 294, subpart B. 2. If it proceeds, require the final environmental impact statement to analyze road density and wolf and other wildlife habitat on the Chequamegon-Nicolet's roughly 69,000 roadless acres. 3. Consult GLIFWC and the tribes whose treaty rights cover the forest before any decision. Wisconsin tribal organizations have said they were not consulted (WJFW). We stand with them as allies and do not speak for them. Respectfully submitted, Melissa Smith, Executive Director and Founder, Great Lakes Wildlife Alliance 117 Ardmore Drive, Madison, WI 53713 · msmith@wiwolvesandwildlife.org · (608) 234-8860 October 6, 2026