Opposes rescissionA0 noneSubstance 4/24Posted August 22, 2026 On Regulations.gov
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Dear Secretary Brooke L. Rollins:
In my experience as an outdoor enthusiast who has used national forests in multiple regions over many years, I have come to understand that roadless areas are not the norm but the exception — the product of deliberate regulatory protection — and that the proposed rescission would remove the instrument responsible for maintaining that exception.
My time spent in nature not only enriches my life but helps me restore my energy, feeling recharged to continue working as a health care provider contributing to the public health and well being of my community.
The Rule has, for nearly twenty-five years, preserved the character of places like the one described here; rescinding it would be an irreversible administrative act with irreversible consequences on the ground.
Regarding the Griffith Lake 09084 in the Green Mountain and Finger Lakes National Forests, Vermont:
What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value.
What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value.
What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value.
What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value.
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.
“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." — Research - Fire Safety”
“Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation. The surfaces of unpaved roads can route fine sediments to streams, lakes, and wetlands, increasing the turbidity of the waters, reducing productivity and survival or growth of fishes. Roads have been responsible for the majority of hillslope failures and gully erosion in most steep, forested landscapes. Alteration of hydrodynamics and sediment deposition can result in changes in channels or shorelines many kilometers away, both down- and up-gradient of the road crossing. — Conservation Biology, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)”
The Department is urged to give full weight to the administrative record compiled over more than two decades before proceeding with any rescission action.
Yours truly,
Jen Walsh
CommentID: RLC-20260823-4QZHY9