Opposes rescissionA0 noneSubstance 5/24Posted August 27, 2026 On Regulations.gov
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To the U.S. Department of Agriculture and the U.S. Forest Service:
My name is Todd Cowley. I am a medically retired U.S. Army sergeant, a Nationally Registered Paramedic, a full-time student, and a father writing from Charleston, South Carolina, near the Francis Marion National Forest. I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, and I ask that it be withdrawn in full.
1. The wildfire justification is backward. The Department frames this rescission as wildfire risk management. The published science points in the opposite direction: the overwhelming majority of U.S. wildfires—roughly 84 percent—are human-ignited, and ignition density is concentrated near roads and human access (Balch et al., PNAS, 2017). Roadless designation is not a fire hazard; road construction expands the ignition footprint into backcountry that currently burns less often from human causes. If the Department’s goal is to protect communities from fire, the evidence supports concentrating fuel-treatment and defensible-space work in the wildland-urban interface, where homes actually are—not opening remote, low-access acreage to road construction. As someone who has worked in emergency services, I take fire risk seriously; that is exactly why I object to a policy that increases human access and the resulting risk of ignition while directing resources away from the communities that need protection.
2. The fiscal case fails on its own terms. The Forest Service already carries a multibillion-dollar deferred-maintenance backlog on its existing road system—hundreds of thousands of miles of roads it cannot currently afford to maintain. Constructing new roads into remote, low-productivity timberland at taxpayer expense to access timber of marginal value, while existing infrastructure crumbles, is not stewardship. It is a liability transferred to future taxpayers—my son among them.
3. Water. The national forests are the largest single source of municipal drinking water in the United States, and roadless watersheds consistently produce the highest-quality water precisely because they are unroaded. Road construction is a primary driver of sedimentation and watershed degradation on forest lands. Downstream communities did not consent to trade their water quality for remote logging access.
4. The recreation economy dwarfs the timber value at stake. According to the Bureau of Economic Analysis, outdoor recreation contributes more than a trillion dollars annually to U.S. GDP, and roadless backcountry—used for hunting, fishing, hiking, and camping—is a core input to that economy. This includes veterans like me, for whom access to intact public land is part of how we come home. The remote stands this rescission would open are, in general, the least commercially valuable timber in the system. The economics do not support the trade.
5. The process owed to the public. The 2001 rule was built on one of the largest public-engagement records in the history of federal rulemaking—hundreds of public meetings and approximately 1.6 million comments—and it has been upheld through years of litigation. Wholesale rescission of a rule with that public mandate, based on a rationale contradicted by ignition science, would be arbitrary and capricious. If specific forests present specific management needs, the appropriate vehicle is the existing state- and forest-level planning process, not nationwide revocation.
I am 22 years old. I served, I ran 911 calls, and I am raising my son a short drive from a national forest that I want him to know as I knew the waters and woods of this state growing up. Roadless backcountry is one of the few American inheritances that passes to every child equally, regardless of what their parents earn. I ask the Department to withdraw this proposed rescission, retain the 2001 Roadless Area Conservation Rule in full, and direct its wildfire resources to the wildland-urban interface, where the science shows that lives and homes can actually be saved.
Respectfully submitted,
Todd F. Cowley
Sergeant, U.S. Army (Retired) · NRP, SC Medic
Charleston, South Carolina