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I am writing in favor of keeping the 2001 Roadless Area Conservation Rule as-is and in opposition to this proposed change that would rescind the 2001 Roadless Area Conservation Rule. Keeping roadless areas of our national forests is vital for long-term resource security, safety, and conservation. Rescinding the Roadless Rule and increasing the number and total length of roads will endanger our national forests by increasing the risk of wildfire and introduction of invasive species. Roads can increase the frequency of wildfires (eg, Narayanaraj and Wimberly 2012, Bowring et al 2024) - and even though fragmentation may reduce burn area, forest fragmentation is harmful to plants and animals in many ways and should not be viewed as an overall benefit or solution for wildfires. Similarly, roads (ie, human mediated travel) are a known dispersal pathway for invasive species (eg, Mortensen et al 2009, Ladin et al 2023, Solano et al 2021, Haubrock et al. 2026); many pest insects threaten our forests and to speed their spread into currently roadless areas could cause irreparable harm and economic loss (Lovett et al 2016). The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). Rescinding the roadless rule will be harmful to fish and wildlife by increasing forest fragmentation, destroying habitat, increasing soil disturbance and run-off into waterways, and increasing the likelihood of human-wildlife conflicts (Croke and Hairsine 2006, Robinson et al 2010, Boston 2016). These conflicts will be great in magnitude if the roads lead to more timber production and mining. Increased timber production and mining is harmful to fish and wildlife. Furthermore, increasing roads and areas where natural resources are extracted will reduce access for recreation and have a negative economic impact on the tourism industry. The Forest Service's own analysis shows economic losses from reduced tourism and recreation caused by rescinding the Roadless Rule. Our National Forests should remain intact and roadless so Americans can enjoy them now and for centuries in the future. Short-term gains from resource extraction are not more important that the long-term integrity and preservation of our natural areas and resources for all Americans and future Americans to enjoy. Finally The rule states that "local decision making would remain subject to the substantive requirements of the Endangered Species Act". However, current changes to the Endangered Species Act means that any roads, timber harvest, of mining that removes habitat and other resources necessary for endangered species to survive would not be a violation of the Endangered Species Act. Therefore, endangered species are at highest risk by rescinding the Roadless Rule. Species cannot survive if their habitats are destroyed, degraded, and fragmented. I urge the USDA to protect our natural resources and do NOT rescind the Roadless Rule. Narayanaraj and Wimberly 2012 - https://doi.org/10.1016/j.apgeog.2011.09.004 Bowring et al 2024 - https://doi.org/10.1038/s41467-024-53460-6 Mortensen et al. 2009 - https://doi.org/10.1614/IPSM-08-125.1 Ladin et al. 2023- https://doi.org/10.1038/s41598-022-25989-3 Solano et al. 2021 - doi: 10.1093/jee/toaa278 Haubrock et al 2026 - doi: 10.1002/brv.70121 Lovett et al 2016 - https://esajournals.onlinelibrary.wiley.com/doi/pdf/10.1890/15-1176 Croke and Hairsine 2006 - https://cdnsciencepub.com/doi/10.1139/a05-016 Robinson et al 2010 - doi:10.1139/A10-002 Boston 2016 - DOI 10.1007/s40725-016-0044-x

The 2001 Roadless Area Conservation Rule is a crucial piece of legislation that, when initially proposed, had a final environmental impact statement that "...sought to meet the public's sentiment for protection roadless areas and the clean water, biological diversity and dispersed recreational opportunities, wildlife habitat, forest health and other public benefits provided by these areas." Based on the comments I've seen from the public over the many years, as well as in response to the U.S. Forest Service seeking to repeal this act now, the public still holds strong to these values being protected back in 2001 when the rule was enacted. Nothing has changed. Arguments have been made that this rule has acted as a barrier to fighting forest fires, specifically Tom Schultz of the Forest Service stated, "For nearly 25 years, the Roadless Rule has frustrated land managers and served as a barrier to action – prohibiting road construction, which has limited wildfire suppression and active forest management," To my knowledge, Tom Schultz does not support his claim with any evidence. On the contrary, in a study conducted by the National Institutes of Health reported that 78 percent of human caused wildfires happen half a mile from roadways. (see citation 1) Creating more roadways will not fix the issues with fighting wildfires, it will exacerbate it. More roads means more areas for potential wildfires to start, its nonsensical to cut down the forest in favor of roadways to save them from wildfires, when the presence of the roadways themselves are part of the problem to begin with. Another factor that is often brought up to support the repealing of this rule is timber production. By repealing this act it will open up more land to extract timber for construction and energy production. But we have safer and more effective forms of energy production in the form of green energy at our finger tips that could be used for energy production that does not risk conservation lands and endangered species. Wood has been on the decline as a major energy resource and in an assessment from the FAO of the UN. (see citation 2) Timber is not an essential enough resource to demand the destruction of these lands. Efforts to revitalize the United States timber industry is a wasted effort that seeks to maintain a form energy production that does not stand up to the wants, desires and needs of the American population. And the repealing of this rule is a consequence of this poor judgement from the current administration. No statements or evidence provided in support of repealing the 2001 Roadless Area Conservation Rule has convinced myself or other members of the public that this is a necessary or needed effort. Please reconsider this proposition and keep our wild areas wild and road free. Citations 1. Bowring SPK, Li W, Mouillot F, Rosan TM, Ciais P. Road fragment edges enhance wildfire incidence and intensity, while suppressing global burned area. Nat Commun. 2024 Oct 24;15(1):9176. doi: 10.1038/s41467-024-53460-6. PMID: 39448625; PMCID: PMC11502787. 2. FAO. 2022. Global forest sector outlook 2050: Assessing future demand and sources of timber for a sustainable economy – Background paper for The State of the World’s Forests 2022. FAO Forestry Working Paper, No. 31. Rome.

Repealing the 2001 Roadless Area Conservation Rule will cause irreparable damage to our country. It will only serve to increase the amount of wildfires rather than decrease it. This study (doi: 10.1038/s41467-024-53460-6) explains how fragmenting forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. What’s more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administration’s Federal Register filing. The construction of roads would further exacerbate this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider.

I strongly urge you to keep the Roadless Rule in place! Repealing the 2001 Roadless Area Conservation Rule would cause immense harm to our country. It would actually increase the risk of wildfires, which are already a significant and growing risk to all. A recent study, "Road fragment edges enhance wildfire incidence and intensity, while suppressing global burned area" by Bowring, Li, Mouillot, Rosan, and Ciais (doi: 10.1038/s41467-024-53460-6), concludes that fragmenting or dividing forests into smaller areas via roads could directly result in an increased likelihood of extreme wildfires. In addition, 13% of roadless land currently protected has experienced wildfires of high or moderate severity between 1984 and 2024, as per the Trump administration’s Federal Register filing. The construction of roads would directly increase this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. I strongly object to this measure to remove protections from our public lands, and strongly urge the Department to keep the Roadless Rule.

Last year, when a similar repeal of the roadless rule was proposed, it was shut down. All of the same objections still apply. According to a recent study (doi: 10.1038/s41467-024-53460-6) fragmenting the forests into smaller areas will only increase the risk of severe wildfires and the danger they present to surrounding communities. The construction of further roads will not only make things more dangerous, but will mar the beauty of the great forests, which, as public land, belong to the people and are a source of great pride for many. I object vehemently to the proposal to remove these protections from our public land and ask the department to reconsider.

As an American, I have always loved our forests and am proud to have such incredible wildlife in our country. Rescinding the Roadless Rule would destroy the landscapes I and so many other Americans love so much. More than that, it has been proven scientifically that dividing forests with roads increases the likelihood of extreme wildfires (doi: 10.1038/s41467-024-53460-6) which will endanger our landscapes, our wildlife, and our people. 90% of wildfires start within half a mile of a road, and they can quickly burn out of control, destroying our treasured landscapes. This land also acts as a vitally important carbon sink as our summers continue to grow hotter and our environment continues to suffer damage due to human interference. Earlier this month, the UN announced that our planet is past the point of no return from environmental damages due to global warming. Destroying more of our forests will only make this problem worse. If the administration is concerned about damages from wildfires and other natural disasters, our priority should be preserving these areas, not opening them to development by corporate interests.

I am a second-year biological sciences student. I grew up visiting national forests and picking up roadkill in my own neighborhood. The current administration's decision to allow roads to be built in protected areas will do far more harm than good. Building roads in heavily wooded areas increases wildfire risk (doi: 10.1038/s41467-024-53460-6), and the presence of those roads also increases the risk of car-wildlife collisions- in the state of California alone, those collisions are major depopulating force for endangered animals and they cost 200 million dollars per year (https://phys.org/news/2024-06-roadkill-natural-disaster.html). Keeping these national forests largely roadless is critical to conservationist and the wider public's interest.

Going through with this decision to repeal the 2001 Roadless Area Conservation Rule will cause immense harm to our country. Rather than reduce the risk of wildfires, it will only increase it. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. What’s more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administration’s Federal Register filing. The construction of roads would further exacerbate this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider. As I type this comment in the sweltering heat of yet another record-breaking summer, it's clear that no effort to mitigate the effects of climate change is too small. Rescinding the Roadless Rule would be an enormous step back. Carbon sinks that decrease the impact of the greenhouse effect are shrinking and disappearing as humans continue to develop our environment; the Roadless Rule protects old-growth forest and significant carbon storage. According to the Wilderness Society, wildfires are 4x more likely to start in roaded areas than in roadless forests. Per the Sierra Club, roughly 90% of wildfires start within half a mile of a road. Repealing the Roadless Rule would have a negative impact on public health and would not improve access to the outdoors. The priority needs to be protecting undeveloped, biodiverse areas to mitigate extreme weather that causes heat illnesses in many disabled people, and expanding protection of those areas. Improved and expanded ADA-compliant trails and facilities specifically would be of much more use to disabled people than exposing crucial carbon sinks to corporate interests. Additionally, 60 million Americans rely on national forests for drinking water, as intact forests filter water naturally. Roads will pollute these waters with runoff, making the water crisis worse. Wildlife habitats for salmon, trout, elk, and other species that depend on undammed, unlogged streams and connected landscapes would be destroyed, depleting food sources and risking species endangerment and extinction. As aforementioned, wildfires are 4x more likely to start near roads. About 90% of wildfires start within half a mile of a road! This fact directly rebuts the administration's stated rationale- they are lying to us to push an agenda. Roadless protected areas contain vast swaths of the country's remaining old-growth forest and significant carbon storage, as well. PLUS the existing road network already carries an $8.5+ billion maintenance backlog; building more roads would only add to it and make that backlog worse for all workers and citizens. This is an easy decision if you think about it for longer than one second. DO NOT allow roads to be built in these protected areas. DO NOT allow the Roadless Rule, established in 2001, to be brushed aside or forgotten. Save the people- save the land.

Going through with this decision to repeal the 2001 Roadless Area Conservation Rule will cause immense harm to our country. Rather than reduce the risk of wildfires, it will only increase it. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. What’s more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024. The construction of roads would further exacerbate this risk. Not only would our beautiful forests, be marred by these potential roads but they would also become much more dangerous to surrounding communities. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider.

This year, I personally had a death in our family, and it was hastened by wildfire smoke directly. I watched when the smoke rolled in, my loved one declined dramatically more quickly. Even when the fires don't reach our homes, we are harmed. And, even when the smoke doesn't reach our homes, we are harmed. We need to protect our forests, for many reasons. We need to preserve unfragmented habitat, for humans, for animals, for climate change, for biodiversity, and for so, so, many innumerable reasons. We need to reduce wildfires. There are many good actions we could be taking towards those ends and this isn't the way forward. ( https://doi.org/10.1016/j.ijdrr.2018.09.016 ) If we want to reduce wildfires we should be putting our focus on climate change generally, and chipping away at some of our best carbon sinks isn't how we do that. We can't afford the long term carbon losses from careless fragmentation and unplanned wildfires. ( https://doi.org/10.1007/s44246-025-00206-8 ) Again, this just isn't the way forward. Fire interacts with fragmentation in ways that are detrimental to biodiversity. When fire and fragmentation act together they can cause local extinctions, even when their separate effects are neutral. Then feedback loops can happen that completely collapse the present ecosystem, when otherwise that wouldn't occur. ( https://doi.org/10.1111/brv.12687 ) Forest fragmentation has also been shown to directly increase forest mortality by increasing stress, damaging habitats, and heightening vulnerability to disturbances, like, for example, wildfires. ( https://doi.org/10.3390/f16040565 ) During the linked systematic review, out of 119 articles, 107 research articles reported a negative effect of forest fragmentation, thereby indicating that an increase in forest fragmentation leads to an increase in forest mortality. Eleven articles reported positive effects of forest fragmentation, comprising often rare, localized, and context-specific scenarios where increased fragmentation led to a reduction in forest mortality. A large percentage of these studies were on temperate forests, in America. At best, you could say we need more research on the subject in some specific situations and, perhaps, more long term data and studies. But the current data we have does not support fragmenting our forests by building these roads. Repealing the 2001 Roadless Area Conservation Rule is intensely harmful to America and all Americans, as it will actually increase wildfires. See this study, (doi: 10.1038/s41467-024-53460-6) dividing forests into smaller areas via roads can directly result in an increased extreme wildfires. We need to protect our beautiful American forests from being marred by more potential roads. This would create a much more dangerous situation for surrounding communities, in many ways. The Roadless Rule protects old-growth forest and significant carbon storage, which we need to continue to keep in mind because increasing wildfires are driven by global climate change. According to the Wilderness Society, wildfires are 4x more likely to start in roaded areas than in roadless forests. According to the Sierra Club, roughly 90% of wildfires start within half a mile of a road. I strongly object to this measure to remove protections from our public lands.

Going through with this decision to repeal the 2001 Roadless Area Conservation Rule will cause immense harm to our country. Rather than reduce the risk of wildfires, it will only increase it. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. Whats more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administrations Federal Register filing. The construction of roads would further exacerbate this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

As an American citizen, repealing the Roadless Rule is a matter of great importance to me and would directly impact my life and the place I call home. I am a fifth generation resident of Montana, and the protection and appreciation of public lands is one of the greatest things those before me have passed on. I recreate on public lands multiple times per week, and I value them as natural resources but more importantly as the places that house our natural relatives. Going through with this decision to repeal the 2001 Roadless Area Conservation Rule will cause immense harm to our country. Rather than reduce the risk of wildfires, it will only increase it. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. What’s more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administration’s Federal Register filing. The construction of roads would further exacerbate this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. Furthermore, the construction of roads in previously undeveloped habitat would result in habitat fragmentation, which is known to have significant negative effects on biodiversity, particularly resulting in biodiversity loss (see https://doi.org/10.1146/annurev.ecolsys.34.011802.132419). The biodiversity of this country is incredible, but has already been threatened many times and has required significant conservation work to maintain. Further habitat fragmentation due to the construction of roads and the resulting loss of biodiversity would have tremendous consequences, including on the economy. One argument for repealing the Roadless Rule is that the resulting logging and mining would benefit the economy, however, that is not the only economic factor to be considered. Studies have shown that the biodiversity has economic value and that the loss of biodiversity has negative impacts on the economy (see https://doi.org/10.1146/annurev-resource-100518-093946). There are many reasons to object to the repealing of the Roadless Rule. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider.

The 2001 Roadless Area Conservation Rule is a necessary protection for the increasingly fragile natural world and repealing will No Doubt result in greater chances of forest fire ignition, disturbance of important ecosystems, damage and harm to animals and their lives in protected areas, and degrade what little precious natural scenes we have left. Wildfire study (doi: 10.1038/s41467-024-53460-6) bolsters my comment about fires. I work in conservation thus am on the road a lot between reserves and my lived experience is that more roads result in higher levels of road kill and disturbed animal movements. I comment with the strongest of objections to this change - we should as a country be moving to Protect our natural habitats rather than cause them any further harm. Energy should be placed into new and more protective laws rather than such damaging ones as this. There is no Real need for this to be repealed. I urge a reconsideration.

Going through with this decision to repeal the 2001 Roadless Area Conservation Rule will cause immense harm to our country. Rather than reduce the risk of wildfires, it will only increase it. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. What’s more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administration’s Federal Register filing. The other danger presented is the removal of water-retaining vegetation, which will lead to more water flowing back into rivers and out to sea rather than filling local aquifers through natural soil saturation processes. One of the stated intents of this bill is to prevent wildfires: How does worsening drought risks and increasing chances of fire ignition accomplish this goal? I'm firmly against this encroachment on the last few wild spaces in this great country and know that I, along with many others, would be heartbroken to see our national forests further shrunk by economic encroachment.

This will ruin our wilderness. This will not reduce wildfires, it will increase them. See study: doi: 10.1038/s41467-024-53460-6. This study clearly shows that dividing forests into smaller areas with roads could result in more wildfires. In addition, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administration’s Federal Register filing. Building more roads would increase this risk even more. America is known for its pristine, gorgeous forests - we have the best in the world! But outside of beauty, they would harm surrounding communities. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider.

It's been a sweltering 100+ degree record-breaking summer here in Baltimore. Rescinding the Roadless Rule would be an enormous step back from what we need in this and all areas of the world. Carbon/heat sinks like our old-growth, national forests are shrinking and disappearing as humans continue to expand their spread into the wild, rather than improving quality of life where we already reside. According to the Wilderness Society, wildfires are 4x more likely to start in areas with roads than in roadless forests. From the Sierra Club: roughly 90% of wildfires start within half a mile of a road. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting forests via roads could actually directly result in an increased likelihood of extreme wildfires. We have already seen more than enough death and destruction from increasingly widespread, dangerous wildfires in this country's last few years. I am a heat-intolerant, asthmatic disabled person. Repealing the Roadless Rule would have a negative impact on public health in general and would decrease my access to the outdoors specifically. The priority needs to be protecting undeveloped, biodiverse areas to mitigate extreme weather that causes heat illnesses and respiratory problems in many of my fellow disabled people. Our national forests are one of the great gems of this land. We need to be expanding protection of these vital, natural areas, not decreasing them. Now more than ever.

Going through with this decision to repeal the 2001 Roadless Area Conservation Rule will cause immense harm to our country. Rather than reduce the risk of wildfires, it will only increase it. A recent study (doi: 10.1038/s41467-024-53460-6) concludes that fragmenting or dividing forests into smaller areas via roads could actually directly result in an increased likelihood of extreme wildfires. What’s more, 13% of roadless land currently protected experienced wildfires of high or moderate severity between 1984 and 2024 as per the Trump administration’s Federal Register filing. The construction of roads would further exacerbate this risk. Not only would our beautiful forests, which are a source of pride for many Americans, be marred by these potential roads but they would also become much more dangerous to surrounding communities. I strongly object to this measure to remove protections from our public lands and urge the Department to reconsider.