Opposes rescissionA0 noneSubstance 6/24Posted August 25, 2026 On Regulations.gov
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Comment on the Proposed Rescission of the 2001 Roadless Area Conservation
I wish to register my strong Opposition to the Proposal to Rescind the 2001 Roadless Area Conservation Rule.
Dismantling national protections across roughly 45 million acres of Inventoried Roadless Areas (IRAs) threatens intact wildlife habitat, clean drinking water sources, and local outdoor recreation economies—all while ignoring the agency’s own historical mandate to preserve these unroaded lands.
1. Inconsistency with Agency Purpose and Historical Record
When establishing the Roadless Area Conservation Rule, the Forest Service explicitly justified its national action by identifying that unroaded lands contain "some of the last, best unprotected wildlands anywhere in our Nation." The agency recognized then that piecemeal, forest-by-forest planning had historically failed to prevent the fragmentation of intact ecosystems. Eliminating national prohibitions and returning management entirely to individual forest plans removes the vital baseline protection required to keep these unroaded characteristics intact across public lands.
2. Wildfire Risk and Human Ignition Realities
The draft environmental impact statement relies heavily on the premise that road construction is necessary to manage wildfire risk. However, peer-reviewed fire ecology research demonstrates that the overwhelming majority of human-caused wildfires originate near road corridors. Expanding road networks into remote, unroaded interior areas increases ignition points rather than decreasing total risk. Furthermore, the existing 2001 Roadless Rule already contains explicit exceptions allowing land managers to conduct hazardous fuel reduction, forest health treatments, and emergency firefighting operations. Complete rescission is an unnecessary measure that opens pristine areas to industrial exploitation under the guise of fire mitigation.
As one example, the Prescott National Forest is currently using mastication machines to efficiently and effectively reduce fuel loads in the Black Canyon Inventoried Roadless Area -- without requiring any roads in the IRA. Our forests can be effectively managed without rescinding the roadless rule.
3. Fiscal Responsibility and Road Maintenance Backlogs
The U.S. Forest Service already faces a massive backlog in deferred maintenance on the existing network of more than 370,000 miles of national forest roads. Permitting new road construction and reconstruction in remote, topographically challenging areas creates long-term financial liabilities for taxpayers while degrading the natural infrastructure that provides clean municipal drinking water to millions of Americans.
4. Conservation and Economic Values
Inventoried roadless areas provide core sanctuary for native fish, big game, and threatened species, forming the backbone of the nation's outdoor recreation economy. Fragmentation through logging road networks degrades irreplaceable old-growth ecosystems, harms watershed integrity, and destroys primitive backcountry recreation experiences that cannot be replicated once lost.
Conclusion
The Forest Service should uphold its long-standing duty to conserve wildlands and protect watersheds for present and future generations. Rather than rescinding the 2001 Roadless Area Conservation Rule, the agency must maintain these bedrock protections. I urge the Department to select the "No Action" alternative in the Final Environmental Impact Statement and keep the national Roadless Rule intact. Thank you for considering these comments.