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The roadless rule currently conserves considerable swaths of the iconic American landscape for recreation, while simultaneously protecting wildlife and irreplaceable forested lands from excessive encroachment from development. I strongly oppose this revision to the roadless rule, which pretends to be in the best interest of fire mitigation, but is truthfully an attempt to dismantle our public lands for private profit. What use is it to cut down and destroy what little woods that remain just to sell them to foreign markets that are oceans away? Further, I have not yet seen the U.S. Forest Service appropriately respond to literature supporting the roadless rule as it currently stands. I would like to see detailed review and thorough response to Kilbride et al. 2026 (DOI: 10.1111/csp2.70411), Cornwall 2026 (DOI: 10.1126/science.aem2421), Olden et al. 2026 (DOI: 10.1371/journal.pwat.0000538), and Bishop 2026 (ISSN: 0001-8368). I believe in the strength of the USFS to protect the places Americans value most, and to serve many interests. I strongly disagree with the idea that these rule changes are in the best interest of the public, who you serve. We are not so poor as to have to destroy our lands, nor so rich that we can afford to.

Opposition to Rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001 (RIN 0596-AD66) I submit this comment on behalf of the Global Wildfire Collective, a program of the Conservation Biology Institute, in opposition to the proposed rescission of the Roadless Rule. The Draft EIS's central rationale, that rescission will reduce wildfire risk, is not supported by the best available science. 1. Roads concentrate human-caused ignitions. Most U.S. wildfires are started by people (Balch et al. 2017, PNAS; Headwaters Economics 2026 found 77% of 1992-2024 fires were human-ignited). Ignitions cluster along roads (Syphard et al. 2007, Ecological Applications; Syphard & Keeley 2015, Int. J. Wildland Fire). Dr. Alexandra Syphard, our Director of Science, has publicly described roads as the dominant place where ignitions occur. The Forest Service's own 2001 Final EIS concluded that new roads would likely increase human-caused fires and that prohibiting them would not increase acres burned. The Draft EIS does not explain this reversal. 2. Roads alter fuels. Building roads into roadless landscapes disturbs the land and can introduce invasive species that are often more flammable than native vegetation, compounding ignition risk. 3. The data show no fire penalty from roadless protection. Kilbride et al. (Conservation Science and Practice, doi:10.1111/csp2.70411) analyzed four decades of fire data and found inventoried roadless areas burned at rates statistically indistinguishable from developed national forest lands (rate ratio 1.13, 95% CI 0.92-1.36 for 1984-2023; 0.89 for 2014-2023). The higher burn rates sometimes attributed to roadless areas come from designated wilderness, which this rule does not affect. Healey (2020, Environmental Research Letters) found similar results. Dr. Syphard has stated that claimed fire-reduction benefits of road building are not supported by any evidence, and about 30 prominent wildfire scientists signed her letter critiquing the Draft EIS. 4. Home protection depends on where and how homes are built. Structure loss is driven largely by housing location, arrangement, and conditions near buildings (Syphard et al. 2012, PLOS ONE; Calkin et al. 2014, PNAS). Roadless areas are remote from most communities, so backcountry road building does little to protect homes and diverts attention from home hardening, defensible space, and community planning. 5. The existing rule already allows needed fire management. 36 CFR 294.13(b) permits road construction for imminent fire threats and cutting of small-diameter timber to reduce uncharacteristic wildfire effects. Prescribed fire and suppression are not prohibited. The Draft EIS does not show that full rescission is necessary. 6. Costs and process. The Forest Service cannot maintain its existing road network, and the Draft EIS does not adequately account for the long-term costs and ecological harm of new roads, including sediment and invasive species. Roadless areas protect watersheds supplying drinking water to at least 25 million people (PLOS Water, 2026). The initial 30-day comment period was far shorter than typical for an analysis of this scale, and 164 members of Congress have requested more time, public meetings, and full Tribal consultation. Robin Jones, Director, Global Wildfire Collective A program of the Conservation Biology Institute www.globalwildfirecollective.org | www.consbio.org

As a biologist, I work in these forests. It is critical to keep intact forests not only for ecosystem health for wildlife but for ourselves. Dividing forests up and making them more accessible by adding roads introduces invasive species, fire risk, and fragments healthy habitat. It is worth more intact than it could every be divided and drained of resources. For more info check out these papers: CRIST, M.R., WILMER, B. and APLET, G.H. (2005), Assessing the value of roadless areas in a conservation reserve strategy: biodiversity and landscape connectivity in the northern Rockies. Journal of Applied Ecology, 42: 181-191. https://doi.org/10.1111/j.1365-2664.2005.00996.x Kilbride, J. B., Johnston, J. D., Kennedy, R. E., Meigs, G. W., and Francis, E. M. (2026). Roadless status under the Roadless Area Conservation Rule is not associated with increased wildfire in the US National Forest System. Conservation Science and Practice, 8(10), e70411. https://doi.org/10.1111/csp2.70411 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.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Research from Oregon State University published on September 8th, 2026, shows that there is no significant difference in the number of fires, nor in their severity, between forest areas with roads and those without. This research is available at this link: https://conbio.onlinelibrary.wiley.com/doi/10.1111/csp2.70411 Forests without roads provide essential habitat for many species, including many that are threatened or endangered. Losing or severely diminishing the population of these species has knock-on effects for forest health, tourism, and recreational use. Please reverse course and preserve the 2001 Roadless Area Conservation Rule.

I am vehemently opposed to the repeal of the Roadless Rule for countless reasons. As a lifelong Oregonian and professional in the field of Environmental Advising, the repeal of the Roadless Rule would only lead to further degradation of the few intact forest ecosystems that remain in the United States. Roadless Areas function as one of the last reprieves from the environmental destruction caused by capitalism that runs rampant throughout our government and society. The effort to repeal the Roadless Rule is an obvious effort put forth by the current administration to allow additional logging and resource harvest from these Roadless Areas. The proposal to repeal the Roadless Rule falsely claims that it will help in the fight against wildfires, however, studies have shown that the more roadways through an area, the more ignitions. Additionally, a recent study from the University of Oregon authored by Kilbride et al. (https://conbio.onlinelibrary.wiley.com/doi/10.1111/csp2.70411) concluded no significant difference between the amount of lands burned in Roadless Areas versus developed areas. Thus, greater supporting the fact that the claims surrounding any benefits that repealing the Roadless Rule would have, are entirely false. Roadless Areas function not only as intact ecosystems providing habitat for both humans and animals, but they also protect our clean water and provide some of the last safe havens for endangered species (for which protections under the current administration have systematically been being diminished). Roadless Areas are also protected from invasive species that would be brought in from road traffic, logging, and additional human disruption. Not only do Roadless Areas have both intrinsic and extrinsic value for the ecosystem benefits they provide, but they also have indescribable inherent value. These places harbor old growth trees older than the society in which we live in. They have spiritual value. Walking into these places is a special gift that not many people get to experience. We should be preserving these places for future generations to also get to experience the beauty of nature and the landscapes that we get to live in. Government agencies and resource extraction companies should not be allowed to disrupt these places for economic benefit, let alone any reason at all. Additionally, to claim that adding roads to Roadless Areas would be positive for fighting wildfires only contributes to the ideology of wildfire suppression that has got us to the point of fuel loading that we’re at today. Chad Hanson’s book, “Smokescreen”, does an excellent job at exposing how resource extraction companies and government agencies promote a false narrative of logging as a way to combat wildfire. In fact, logging only increases wildfire risk by adding slash to the landscape and by increasing solar radiation subsequently drying out ground fuels and adding to the flammability of ladder fuels. I believe if you were to show anyone a logged landscape versus a post-fire landscape, they would be able to distinguish how much more beautiful and healthy a post-fire landscape can be compared to a post-logging landscape. Logging disrupts soils, plant communities, wetlands, rivers, streams, and habitats, it also adds chemicals, invasive species, and trash into the landscape. In post-fire areas you’ll find an abundance of bird species, ungulates, predators and prey species, not to mention some of the most beautiful displays of wildflowers, amongst many other animals and plants. When left in the landscape, large timber, both burned or unburned, can retain moisture much better than the small diameter remnants left on the ground from logging. I could go on and on about how ridiculous this proposal to repeal the Roadless Rule is and how passionately I oppose the repeal of the Roadless Rule as a taxpaying citizen. The role of government is to represent the people, it is not to represent corporate interest or personal gain within a capitalist economy and government structure. Please listen to reason. The logging, destruction and development of our public lands is directly adverse to the wants and needs of the American people. The only proposed alternative I support is “Alternative 1”, which is to retain the existing Roadless Rule (“No Action”).

My name is Ted Kerasote and I live on the edge of the Bridger-Teton National Forest, where I hunt, hike, ski, and ride my horses and mountain bike. I've been a freelance nature, sports, and adventure travel writer since the 1970s and have made a substantial portion of my income from writing about recreational opportunities on our national forests. The Roadless Area Conservation Rule has not only augmented my subject matter, it has also generated $24 billion in annual benefits in the lower-48 (see Earth Economics: https://www.eartheconomics.org/news/roadless-rules?utm_source=gemini#:~:text=In%20an%20initial%20economic%20analysis%20of%20ecosystem,importance%20of%20continuing%20to%20protect%20these%20lands.) Moreover, these roadless areas provide key habitat for big game and other species as well as cold-water fisheries protection, providing hunting and fishing opportunites for millions of Americans. As for the argument that roadless areas cause more fires because their flammable timber can't be thinned, a recent study published in Conservation Science and Practice found that “IRAs [inventoried roadless areas] across western states NFS land are not associated with a significantly greater rate of burning—or a greater rate of moderate- and high-severity fire—relative to roadless or developed lands.” (See: “Roadless status under the Roadless Area Conservation Rule is not associated with increased wildfire in the US National Forest System,” (https://conbio.onlinelibrary.wiley.com/doi/10.1111/csp2.70411) In the light of all the benefits the Roadless Rule has bequeathed to America's people and wildlife—and the lack of evidence showing that lands designated as roadless burn at a greater rate than roaded areas—the Roadless Rule should be kept in place.

Recinding the 2001 Roadless Area Conservation Rule conserves approximately 60 million acres of National Forest System lands. Rescinding this rule would diminish protections for rivers, compromise drinking water quality, and reduce recreational opportunities (Olden et al 2026). Building roads into these areas will decrease forest ecosystem functions, increase fire risk and will increase road maintenance costs at an agency that already has a 10.8 billion backlog in deferred maintenance (Mildrexler et al. 2026). These areas burn at lower rates that roaded areas (Killbride et al. 2026). The rescinding of this rule has no appreciable benefits and is scientifically, economically, and biologically irresponsible. David J. Mildrexler, Logan T. Berner, Beverly E. Law, Mary S. Booth, Roadless rule rescission threatens highest integrity forest ecosystems in the United States, Biological Conservation, Volume 321, 2026, 111950, ISSN 0006-3207, https://doi.org/10.1016/j.biocon.2026.111950. Kilbride, J. B., Johnston, J. D., Kennedy, R. E., Meigs, G. W., & Francis, E. M. (2026). Roadless status under the Roadless Area Conservation Rule is not associated with increased wildfire in the US National Forest System. Conservation Science and Practice, e70411. https://doi.org/10.1111/csp2.70411 Olden, Julian D.; Postel, Sandra L.; Dombeck, Michael P.; Kesting, Helen; Freeman, Patrick; Comte, Lise (2026-07-15). "Assessing the value of the U.S. Roadless Rule for people and nature". PLOS Water. 5 (7) e0000538. Public Library of Science. doi:10.1371/journal.pwat.0000538. ISSN 2767-3219.

Dear Lawmakers, I am writing to express my vehement opposition to rescinding the 2001 Roadless Area Conservation Rule. The Roadless Rule has always been widely supported by the American people, from individual recreationists to environmental activism groups to tribal governments to state governing bodies. In the 25 years that the Roadless Rule has been in effect, it has directly protected nearly 60 million acres of undeveloped forest land, including old growth trees and habitats for countless species. Repealing this law would have terrible and far-reaching consequences for the environment and all life that calls these protected lands home. In the proposal to rescind the Roadless Rule, the Trump administration has cited reduction of wildfires as the primary driver. However, research such as a 2026 meta analysis of wildfire data across the Western United States (Killbride, et al., 2026), shows that roads through forested areas do not correspond with a significant reduction in wildfires. In fact, as supported by USDA research (Short, 2017), the vast majority of wildfires (85%) are started directly or indirectly by human activity. Opening protected forest land to development increases human contact, placing these forests at risk for fires originating from human activity. While I am also extremely concerned about the long and devastating wildfires in recent years, the best way to address fire risk is by taking climate change seriously and using legislation to support environmental stewardship. Instead of sacrificing our precious forest land, we should be prioritizing climate action, including investing in clean energy technology, funding public transportation to cut down on emissions, and heavily regulating the environmental impact of large corporations on an industrial level. The proposal also states that repealing the Roadless Rule will help manage forest land. However, this seems directly at odds with the dramatic cuts made to the Forest Service in 2025 and 2026 (Rose, 2026). With 6,000 employees terminated in 2025 alone and millions of dollars slashed in a 75% reduction to the Forest Service budget, the United States government already lacks the necessary resources to properly manage forest land. Eliminating the Roadless Rule under such circumstances guarantees corporate exploitation of our natural resources. Finally, on a personal level, I’ve been able to experience and enjoy some of these incredible forest areas across several states. Being able to spend time in areas such as the Gila National Forest near Silver City, New Mexico, and Two Medicine area near Glacier National Park has shown me firsthand how breathtaking our country is. Opening these areas up to roads, developers, logging, and mining will devastate these precious environments. I urge you to choose to uphold the 2001 Roadless Area Conservation Rule to protect these ecosystems and ensure their conservation for generations of Americans to come. Sincerely, Johanna Monson Geerts Citations Kilbride, J. B., Johnston, J. D., Kennedy, R. E., Meigs, G. W., & Francis, E. M. (2026). Roadless status under the Roadless Area Conservation Rule is not associated with increased wildfire in the US National Forest System. Conservation Science and Practice, e70411. https://doi.org/10.1111/csp2.70411 Short, Karen C. 2017. Spatial wildfire occurrence data for the United States, 1992-2015 [FPA_FOD_20170508]. 4th Edition. Fort Collins, CO: Forest Service Research Data Archive. https://doi.org/10.2737/RDS-2013-0009.4 Rose, G. (2026, June 12). The hollowing of the forest service. nrdc.org. https://www.nrdc.org/media/hollowing-forest-service