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I am urging the United States Department of Agriculture against rescinding the 2001 Roadless Area Conservation Rule that establishes prohibitions on logging operations in roadless areas. Even since I was young, I always loved to explore the beautiful forests of my area. I loved seeing the old-growth redwoods of California, the immersively of their beauty and their age. It felt heavenly to be around the old-growth forests, places that have been around longer than any of us. But now it seems that this beauty, the experiences that shaped my childhood are threatened. It now seems that our children may never experience the beauty and magnificent of the world that we did. That is why I am urging you to the bottom of my heart to not rescind the 2011 Roadless Area Conservation Rule. Much of the National Forests the Roadless Area Rule protects are old-growth forests. Old growth forests are not only personally important to me, they also have a special ecological role. A study from Gilhen-Baker et al. (2022) found that many endangered species rely on old-growth forests as habitats. These endangered species, the richness and beauty of the world, may go extinct if the Roadless Area Conservation Rule is rescinded. Old-growth forests are important for biodiversity. Old-growth forests in Northern Europe are associated with greater species richness and a higher degree of unique species, increasing both the greater alpha and beta diversity (Nirhamo, 2025). It is likely that the results in boreal Europe are applicable to many parts of the US including Washington and Idaho. If the Roadless Area Conservation Rule is rescinded, that could allow logging or road construction across old-growth forests, destroying or harming these ecological vital areas forever. The intent of rescinding the Roadless Area Conservation Rule is to reduce regulatory burden and return decisionmaking to the local level, protecting people and forests from wildfires. As someone living on the West Coast, wildfires are a significant concern for me. I am concerned for my neighbors and the forests if one day flames will be next door. So, I am thankful that the USDA is looking to address wildlife risk. However, I do not believe that rescinding the Roadless Area Conservation Rule will reduce wildlife risk. In fact, I believe wildfire risk will increase. A study from Bradley et al. (2026) challenged the assumption that forest protection corresponds to increased wildfire risk. They found the opposite, that higher levels of protection causes less severe wildfires. Unprotected forests may experience logging or other harming operations that can reduce the health and strength of the forest in the event of a fire. Rescinding the Roadless Rule would seem to result in more wildfire risk and severity, not less. I recommend that USDA consider the studies and science regarding efficient land management practices. Often prescribed burning is significantly more efficient at reducing wildlife risk than logging practices. Prescribed burning thins out the fuel in the forest, leading to less fuel on the ground that could become a severe fire. I would recommend rescinding the Roadless Area Conservation Rule, not only to protect against wildfires, but for the beauty and magnificent of these areas. The Roadless Area Conservation Rule is essential to creating efficient, safe and ethical land management practices. It protects against wildfires and protects the ecological productivity of the world. Instead of rescinding the rule and allowing logging, I would recommend considering prescribing bringing to reduce wildlife risk. The choice to protect the beauty of our world, to protect the dignity of our children and their childhoods is in your hands. I hope you make the right choice. Thank you for your time and your service. References Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent‐fire forests of the Western United States? Ecosphere, 7(10). https://doi.org/10.1002/ecs2.1492 Gilhen-Baker, M., Roviello, V., Beresford-Kroeger, D., & Roviello, G. N. (2022). Old growth forests and large old trees as critical organisms connecting ecosystems and human health. A review. Environmental Chemistry Letters, 20(2), 1529–1538. https://doi.org/10.1007/s10311-021-01372-y Nirhamo, A., Aakala, T., & Kouki, J. (2025). Forest biodiversity in Boreal Europe: Species richness and turnover among old-growth forests, managed forests and clearcut sites. Biological Conservation, 306. https://doi.org/10.1016/j.biocon.2025.111147

Dear Secretary Rollins and Chief Schultz: As a grandparent, I know the importance of stewardship, not consuming everything but leaving for the next generation what was left for me. We've been taking our grandkids to National Forests and roadless areas since they were very small. My first outdoors photos of my eldest grands were on the Mt Baker side of Stevens Pass, followed by many trips in the Cascades, including the Chiwawa and Chelan area. While my home address may be Mount Vernon, my real home is a cabin outside the Mt Baker Snoqualmie NF, nearby is the OkaWen NF. I step outside and I'm in the forest. I walk a little ways, I'm in the national forest. I'm closer to roadless nf than I am to a super market or hospital. It's a wonderful place for grandkids, grand nieces and nephews to visit. Wildlife is abundant, streams are beautiful. But it's the PNW and landslides from disturbed soils are a concern. Fires are constantly starting along the national forest roads where people drive and camp. No road would have been built where the Little Giant Fire started. And when it burned long enough to escape its valley, it tumbled down the slopes and leapt over the Chiwawa River and then it jumped the nf road. And studies show this, we do not need more roads to stop fires. We need safe slopes so another Oso does not happen. We need good water in our aquifers and wells. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Healey, 2020 (https://doi.org/10.1088/1748-9326/aba031)” A rule that has survived multiple administrations and multiple rounds of circuit-court review should not be rescinded on the present record. CommentID: RLC-20261006-SLBYA0

I am writing in opposition of rescinding the Roadless Rule. I support the Alternative 1, the No Action alternative. National forests provide people with many recreational opportunities, like hunting, fishing, hiking, camping and rafting. I personally like the opportunities for camping, hiking, swimming and just being in nature that national forests provide. We need to have pristine areas of wilderness. Wildlife needs somewhere to live without human intervention, preferably large areas that aren’t fragmented. “Habitat fragmentation is considered to be one of the single most important factors leading to loss of native species (especially in forested landscapes) and one of the primary causes of the present extinction crisis” — Heilman et al., 2002 (https://doi.org/10.1641/0006-3568(2002)052[0411:FFOTCU]2.0.CO;2) We also need clean air and water and forests help with that. “Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes.” — DellaSala et al., 2011 (https://doi.org/10.2489/jswc.66.3.78A) “Logging roads have been linked to great increases in erosion rates and sediment delivery to streams—up to 850% over rates in undisturbed habitat” — DellaSala et al., 2011 (https://doi.org/10.2489/jswc.66.3.78A) Opening up the land to more roads, logging and mining could cause more pollution, disrupt wildlife and cause fires. “our findings—that forests with the highest levels of protection from logging tend to burn least severely—suggest a need for managers and policymakers to rethink current forest and fire management direction” — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492) I believe all national forests need to be protected. Each area has its own ecosystem, habitat and climate and all are important. We need the diversity of flora and fauna of each area. Each landscape offers something unique and is worthy of protection. The national forests belong to everyone and we should not open them up to corporations, but protect and save them for future generations. Once we destroy our public lands there is no getting them back.

I vigorously oppose this proposed rescission. The stated reasons for this rescission are false, misleading, or timber industry propaganda. In particular, the reason relating to preventing wildfires is ridiculous. The facts are contrary to this reason. When USDA Secretary Brooke Rollins announced the rescission of the 2001 Roadless Rule on June 23, 2025, the headline rationale was wildfire. Roads, the argument went, are needed to "manage fire" inside America's 44.5 million acres of inventoried roadless areas. The peer-reviewed science says exactly the opposite. What the published research actually shows: The most decisive data point comes from a 2026 study in Fire Ecology by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz of The Wilderness Society. The authors analyzed 32 years of contiguous-U.S. wildfire records across all eight Forest Service regions. Their finding: Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha). That is roughly a fourfold difference. Ignition density decreased steadily as distance to roads increased — from about 6 fires per 1,000 ha within 250 m of a road to fewer than 2 fires per 1,000 ha beyond 2,000 m. The pattern holds for human-caused, natural, and undetermined fires alike. As the authors conclude: "building roads into roadless areas is likely to result in more fires." A separate national analysis (Balch et al., Proceedings of the National Academy of Sciences, 2017) explains why. Human-started wildfires accounted for 84% of all U.S. wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Roads are the primary vector through which human ignitions reach previously remote landscapes. What about fire severity? Bradley, Hanson, and DellaSala (Ecosphere, 2016) found that forests with higher levels of protection burned at lower severity, not higher, even though they generally carry the highest biomass and fuel loads. Johnston et al. (Environmental Research Letters, 2021) confirmed that while roadless areas saw greater fire extent over three decades, there was no significant difference in fire severity after accounting for biophysical conditions — and suggested the greater extent of fire may even confer ecological resilience. The Wildland-Urban Interface claim doesn't hold up either Forest Service Chief Tom Schultz testified to the Senate Energy and Natural Resources Committee that 24.5 million acres of inventoried roadless areas sit within one mile of the Wildland-Urban Interface (WUI), calling that figure "our primary concern." The Wilderness Society performed a straightforward GIS analysis using the Forest Service's own WUI dataset. The actual figure is 2.8 million acres — a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not the 42% Schultz implied. Even if every acre near the WUI mattered, the Forest Service already has 23.3 million acres of non-roadless forest land available near communities for fuel reduction. There is no operational need to build new roads through pristine backcountry to address the genuine fire risk facing homes and infrastructure. What this means for the rescission The wildfire rationale is the only public-facing justification USDA has offered for rescinding the Roadless Rule. The actual Federal Register notice tells a different story: it cites Executive Orders 14192 (deregulation), 14225 (timber production), and 14154 (energy unleashing), and states the goal is to facilitate domestic production of "timber, energy and mineral production... to the maximum possible extent." Wildfire is the cover story. Industrial access is the policy. Anyone responding to the rulemaking should know that the empirical case for the wildfire rationale collapses on contact with the published science. Roads bring fire. Roadless areas are not the problem. They are part of the solution. Sources Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, article 8. doi.org/10.1186/s42408-026-00450-2 Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. doi.org/10.1073/pnas.1617394114 Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10), e01492. doi.org/10.1002/ecs2.1492

Dear Chief Schultz, As a person who approaches stewardship as a moral and not merely a practical matter, I'm asking the Department to reconsider rescinding these protections. Little Lake Creek is the closest forest to my home, and one we enjoy. This area is special to me and my neighbors as a relatively accessible roadless area Regarding the Little Lake Creek in the National Forests in Texas, Texas: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 (https://doi.org/10.1029/WR020i011p01753); Sugden & Woods, 2007 (https://doi.org/10.1111/j.1752-1688.2007.00016.x) Rescinding the Roadless Rule would open the Little Lake Creek, National Forests in Texas to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Once roads are allowed in an area it is changed forever--the plant and wildlife adapt to human presence. We need to have spaces where this does not happen. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. Beyond the headline fights over wildfire, recreation, and water, the Roadless Rule plays a quieter but essential role in federal land law and ecological assessment. Section 7 of the Endangered Species Act requires the Forest Service to consult before any action that may affect listed species — and the rule's road-construction prohibition has shielded countless management decisions from triggering that consultation. The rule also props up federal forest planning: peer-reviewed analyses of forest plan adequacy consistently find that forest plans alone, without the Roadless Rule's overlay, fail to provide adequate safeguards for sensitive species and intact landscapes. And state-level conservation rankings (NatureServe and others) repeatedly identify roadless areas as concentrated in the rarest, most threatened ecosystems in the lower 48 — the kinds of places where a road, once built, cannot be undone. “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” Don't dismantle what's standing. With gratitude, CommentID: RLC-20261002-QY0OUQ

The position set forth in this comment is that rescission is unwarranted and the Rule should be preserved. CommentID: RLC-20260930-NYAKV6 I oppose recission of the Roadless Rule. This Rule has demonstrated its benefits over many years and there is absolutely no justification for rescinding it. Benefits must continue to accrue to habitats, resident flora and fauna, fire prevention, carbon sequestration, and human enjoyment of wild places. Please do not allow the Roadless Rule to be rescinded. Our local roadless areas include areas of Mt. Baker-Snoqualmie National Forest, where I look forward to hiking and birding in two weeks. These natural areas must be protected. There are too few of them left. I submit the following information to support my position. "The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress." "The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling." “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” Respectfully submitted, Julie Kinder Anacortes, Washington 98221

I oppose the Roadless Area Conservation proposal for the following reasons, which are all quoted. "The most decisive data point comes from a 2026 study in Fire Ecology by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz of The Wilderness Society. The authors analyzed 32 years of contiguous-U.S. wildfire records across all eight Forest Service regions. Their finding: Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha). That is roughly a fourfold difference. Ignition density decreased steadily as distance to roads increased — from about 6 fires per 1,000 ha within 250 m of a road to fewer than 2 fires per 1,000 ha beyond 2,000 m. The pattern holds for human-caused, natural, and undetermined fires alike. As the authors conclude: "building roads into roadless areas is likely to result in more fires." A separate national analysis (Balch et al., Proceedings of the National Academy of Sciences, 2017) explains why. Human-started wildfires accounted for 84% of all U.S. wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Roads are the primary vector through which human ignitions reach previously remote landscapes. What about fire severity? Bradley, Hanson, and DellaSala (Ecosphere, 2016) found that forests with higher levels of protection burned at lower severity, not higher, even though they generally carry the highest biomass and fuel loads. Johnston et al. (Environmental Research Letters, 2021) confirmed that while roadless areas saw greater fire extent over three decades, there was no significant difference in fire severity after accounting for biophysical conditions — and suggested the greater extent of fire may even confer ecological resilience. The Wildland-Urban Interface claim doesn't hold up either Forest Service Chief Tom Schultz testified to the Senate Energy and Natural Resources Committee that 24.5 million acres of inventoried roadless areas sit within one mile of the Wildland-Urban Interface (WUI), calling that figure "our primary concern." The Wilderness Society performed a straightforward GIS analysis using the Forest Service's own WUI dataset. The actual figure is 2.8 million acres — a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not the 42% Schultz implied. Even if every acre near the WUI mattered, the Forest Service already has 23.3 million acres of non-roadless forest land available near communities for fuel reduction. There is no operational need to build new roads through pristine backcountry to address the genuine fire risk facing homes and infrastructure. What this means for the rescission The wildfire rationale is the only public-facing justification USDA has offered for rescinding the Roadless Rule. The actual Federal Register notice tells a different story: it cites Executive Orders 14192 (deregulation), 14225 (timber production), and 14154 (energy unleashing), and states the goal is to facilitate domestic production of "timber, energy and mineral production... to the maximum possible extent." Wildfire is the cover story. Industrial access is the policy. Anyone responding to the rulemaking should know that the empirical case for the wildfire rationale collapses on contact with the published science. Roads bring fire. Roadless areas are not the problem. They are part of the solution." I am quoting the sources used for the above as well: Sources Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, article 8. doi.org/10.1186/s42408-026-00450-2 Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. doi.org/10.1073/pnas.1617394114 Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10), e01492. doi.org/10.1002/ecs2.1492 Johnston, J. D., et al. (2021). Does conserving roadless wildland increase wildfire activity in western US national forests? Environmental Research Letters, 16(8), 084040. doi.org/10.1088/1748-9326/ac13ee The Wilderness Society (2025). Forest Service Chief Grossly Exaggerates Roadless Rule Concern: WUI Analysis. PDF

To the USDA Roadless Rule Rulemaking Team: I currently live in the rainforest in Washington State, and grew up in rural West Virginia near the Monongahela National Forest. With the time I’ve spent in my home in the forest and in the backcountry, I know what the roadless rule is, what it protects, and what it prevents. This rule was hard-won, and created from the practical need to protect lands that are invaluable to our watershed, air quality, and health. This rule matters, and it should remain intact. One of my favorite areas to visit is Glacier Peak in northern Washington — which is currently protected under the roadless rule. The magic of this natural area is clearly preserved by the limit on roads in the area. The work, time, and emersion in nature it takes to get into the Glacier Peak wilderness is what keeps me coming back. My first time on the Pacific Crest Trail many years ago — far from any roads and only accessible by trail, I remember cresting a ridge to be surrounded by volcanos! I could see Mt St Helens, Mt Adams, Mt Rainer, and Mt Hood in the vista around me. If this rule is receded, these beautiful, rich, and biodiverse places are put at great risk for development, logging, increased wildfire risk, and watershed degradation. Bulldozed roadbeds would be the end of our excursions into the backcountry. Regarding the Glacier Peak I in the Mt Baker-Snoqualmie National Forest, Washington: The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Healey, 2020 (https://doi.org/10.1088/1748-9326/aba031)” The rule works. The public wants it. Keep it. Thank you, Briana McElfish CommentID: RLC-20260928-D5Y8I2

I am a nature lover and California resident who has lived in multiple areas that have been devastated by wildfires (Los Angeles and Napa Valley) and I am in vehement opposition to repealing the Roadless Area Conservation Rule. The USFS incorrectly asserts that repealing the roadless rule will allow for better wildfire mitigation. However, it has been repeatedly shown that land development and the subsequent presence of humans is by far the biggest cause of wildfires. An analysis that reviewed three decades of wildfire data found that the highest designated wilderness areas had the lowest density of wildfire ignitions, while lands within 50 m of roads had the highest wildfire ignition density. The study found that “for human-caused, natural, and undetermined fires, wildfire ignition density decreased as distance to road increased” (1). Another 2017 study which analyzed two decades of wildfire data found that a whopping 84% of wildfires were started by humans (2). Together, this evidence suggests that making these areas more accessible to humans is counterproductive to reducing wildfire risk. It is true that unmanaged lands have greater biomass and fuel loading, theoretically increasing the severity of fires in those areas. However, we have real-world data that directly refutes this overly simplistic and ultimately incorrect hypothesis. A study that analyzed data from 1500 fires in the Western US (which is exactly where lands protected by the roadless rule are located) over almost 40 years found that protected lands experienced LOWER fire severity, while those with “more intense management” experienced higher burn severity (3). While wildfires are indeed a serious and growing problem here in California, this misguided attempt to repeal the roadless act will only exacerbate this issue by making lands more vulnerable to wildfire ignitions, and less resilient to fires once they start. Citations: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 J.K. Balch,B.A. Bradley,J.T. Abatzoglou,R.C. Nagy,E.J. Fusco, & A.L. Mahood, Human-started wildfires expand the fire niche across the United States, Proc. Natl. Acad. Sci. U.S.A. 114 (11) 2946-2951, https://doi.org/10.1073/pnas.1617394114 (2017). Bradley, C. M., C. T. Hanson, and D. A. DellaSala. 2016. Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere 7(10): e01492. 10.1002/ecs2.1492

Hello, I am writing to you to oppose any interference within or around our United States National Parks. This includes for building roads within our National Parks and logging/timber harvesting. We grew up in school in Texas, proudly singing: “This land is my land, this land is your land, from California to the New York island. From the Redwood forest to the Gulf stream waters, this land was made for you and me.” We sang this through Elementary school programs where we received applause from community members and parents alike. As you were reading the lyrics, perhaps you were evening singing them in your head. “Our land”, specifically our United States National Parks bring JOY, AWE, and HAPPINESS to Americans and those that come to America to tour the National Parks to see “the American Wilderness” in its natural state. Millions of families have precious memories of family vacations to visit our National Parks. We do not come for roads, and we do not come to see tree stumps. An argument for increased “forest fires” is not based in fact given MULTIPLE peer reviewed studies negate this narrative. In fact, an “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." (Aplet, Hartger & Dietz, 2026) In addition, we should consider that Humans are the cause for many forest fires – so we cannot blame the ecology of the forests when there are studies that clearly point towards our Human contribution to these fire events. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction.” Again, building roads through our forests is dangerous as it will cause MORE wildfires. This is in DIRECT DISAGREEMENT with the assertion that building roads would DECREASE wildfires. Clearly – our National Parks will be further debased and harmed by such irresponsible stewardship. (Balch et al, 2017) Arguing that increased biomass would increase the number and severity of forest fires is additionally false. “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks.” (Bradley, Hanson & DellaSala, 2016) In summary, we the People assert that the Roadless Rule should remain. It is crucial to PROTECT our United States National Parks from corporate interests that would act NOT in the best interests of “Our land.” We should root out and REJECT any claims on our National Parks that are made in the best interest of financial gain and industry “needs.” We ask that our National Parks be protected, preserved, and cared for to maintain the ecosystem for animals, biodiversity, to reduce risk of wildfires, water supply, and to preserve this land for Americans now and in the future. After all, “this land was made for you and me!” References: Aplet, G.H., Hartger, P. & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8. https://doi.org/10.1186/s42408-026-00450-2 Balch, J.K., Bradley, B.A., Abatzoglou, J.T., Nagy, R.C., Fusco, E.J., & Mahood, A.L. (2017). Human-started wildfires expand the fire niche across the United States, Proc. Natl. Acad. Sci. U.S.A. 114 (11) 2946-295. https://doi.org/10.1073/pnas.1617394114. Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does Increased Forest Protection Correspond to Higher Fire Severity in Frequent-Fire Forests of the Western United States? Ecosphere, 7, 1-13. https://doi.org/10.1002/ecs2.1492 Sincerely, Deborah A. Lee Belton Texas 76513