Opposes rescissionA0 noneSubstance 6/24Posted September 4, 2026 On Regulations.gov
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SUBMITTED VIA REGULATIONS.GOV
Date: Sep 3, 2026
U.S. Department of Agriculture – Forest Service
Attn: Public Comments Processing / Proposed Rule Rescission
Docket No. FS-2025-0001 (Document: FS-2025-0001-223869)
Subject: Formal Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule
Dear Forest Service Leadership and Rulemaking Committee,
I am writing in strong opposition to the U.S. Department of Agriculture and Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001). For nearly a quarter-century, the Roadless Rule has provided a balanced, durable framework that safeguards 44.7 million acres of inventoried roadless lands nationwide, including approximately 2 million acres across Washington State.
Rescinding this rule to open fragile, backcountry lands to industrial road construction and commercial timber extraction is ecologically harmful, fiscally irresponsible, and fundamentally unnecessary for active forest restoration. I urge the agency to withdraw this proposal and maintain full Roadless Rule protections based on the following substantive grounds:
1. Expanding the Road Network Exacerbates Wildfire Ignition Risks
The proposal suggests that road-building is required for wildfire mitigation. However, peer-reviewed fire science and regional data demonstrate that forest roads serve as primary vectors for human-caused wildfire ignitions. In Washington State, approximately 85% of all wildfires are caused by human activity. Expanding road access into remote backcountry dramatically increases ignition vectors in steep, dry, and fire-prone terrain where containment is most difficult.
2. Forest Health and Fuels Reduction Are Already Permitted Under the 2001 Rule
The premise that the 2001 Roadless Rule prevents necessary forest health management mischaracterizes existing regulatory flexibilities. The current rule explicitly permits ecological restoration thinning, small-diameter hazardous fuels reduction, and prescribed fire within roadless areas. What the rule restricts is industrial commercial timber harvest and road construction. Hauling heavy commercial timber out of steep, rugged backcountry is constrained by topography and market economics—not forest health regulations.
3. Deepening an Existing $10.8 Billion Road Maintenance Backlog Is Fiscally Irresponsible
The Forest Service currently manages an expansive infrastructure network of over 380,000 miles of existing roads, while facing a documented, persistent deferred maintenance backlog exceeding $10.8 billion. The agency receives annual appropriations sufficient to maintain only a small fraction of its existing road inventory. Constructing new roads across steep, erosion-prone terrain will generate long-term liabilities, increase culvert blowouts, accelerate sedimentation into fish-bearing streams, and drain vital resources away from existing road maintenance priorities.
4. Severe Impacts on Habitat Connectivity, Fisheries, and Municipal Headwaters
Roadless areas are vital reservoirs of biodiversity and ecological connectivity. In Washington, areas such as the Dark Divide (Gifford Pinchot National Forest), Liberty Bell (Okanogan-Wenatchee National Forest), and Abercrombie-Hooknose (Colville National Forest), along with roadless landscapes across the Cascades, Kettles, Selkirks, Olympics, and Blue Mountains, provide crucial contiguous corridors for wide-ranging species including the Canada lynx and wolverine.
Furthermore, these untouched watersheds provide clean, cold, naturally filtered drinking water to downstream municipal communities and protect essential spawning beds for threatened salmon, steelhead, and bull trout from damaging road runoff and sedimentation.
5. Cultural, Subsistence, and Backcountry Economic Values
Roadless national forests sustain essential cultural and traditional subsistence practices, while anchoring a vibrant backcountry recreation economy. Hunters, anglers, hikers, and local outfitters depend directly on undisturbed, intact wildlands. Industrial development in these areas degrades the very qualities that draw visitors and sustain rural economies.
Conclusion
The 2001 Roadless Area Conservation Rule is one of the most successful, widely supported conservation policies in American history. Rescinding it would cause generational ecological degradation while compounding the Forest Service's infrastructure deficit. I respectfully request that the Forest Service cancel this proposed rulemaking and retain the 2001 Roadless Rule in its entirety.
Sincerely,
M. David Conrad
Angler, Outdoorsman, Voter
Burien, WA