Opposes rescissionA0 noneSubstance 6/24Posted September 12, 2026 On Regulations.gov
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I’m writing to voice my OPPOSITION of the proposed rescinding of the Roadless Rule. This rule has served to protect intact forests and other lands from development for a quarter century.
I live in Santa Fe, NM. Here in the desert, water is our most precious resource. In fact, it could be argued that water is the most important resource to all life. Like many cities across the western United States, Santa Fe’s water supply is dependent upon forest health.
Much of our drinking water comes from the Santa Fe River Watershed which is a sub-basin of the Rio Grande Watershed with its headwaters located within the Sangre de Cristo range. If one looks at a map of this area, it is a patchwork of land uses with very few areas that are untouched, around 10%. (https://www.fs.usda.gov/sites/default/files/roadless-map-inventoried-areas-newmexico-santafe-fsmrs-072526.pdf)
While living here, I have witnessed two large wildfires in our area; the largest fire in New Mexico’s history, 2022 Calf Canyon/Hermits Peak Fire and this year the Frijoles Fire. I know that rescinding the Road Rule will enable not only more roads into our wilderness, but also increased mining, logging and other human behavior that is detrimental to the health of our forest systems and have an effect on the quality and quantity of our water.
The concerns I hold for where I live, can be extrapolated to the entire 44.5 million acres that the Roadless Rule has protected.
My concerns are three fold:
1. The roads themselves; the mere creation of them and the “opportunities” they open up for mining, logging and general human activity in these areas.
“…the presence of roads is highly correlated with changes in species composition, population sizes, and hydrologic and geomorphic processes that shape aquatic and riparian systems...Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering habitats, stressing native species, and providing movement corridors. Roads also promote increased hunting, fishing, passive harassment of animals, and landscape modifications.” Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities; Stephen C. Trombulak, Christopher A. Frissell; published 24 December 2001; (https://conbio.onlinelibrary.wiley.com/doi/10.1046/j.1523-1739.2000.99084.x)
2. Degradation of the water supply. Not only my own water supply but the water supply for 354 municipal watersheds around the country.
“…it is widely accepted that forest roads may alter the hydrologic response of the watersheds, because of the alteration of the landscape and its hydrologic functioning, morphology, land uses, and hydrologic characteristics.” Impact of Forest Roads on Hydrological Processes; Aristeidis Kastridis; published 14 November 2020; (https://www.mdpi.com/1999-4907/11/11/1201)
3. Human activity increases the possibilities of fire and additional issues with watersheds and water quality. Roads allow and even invite people to travel on them. Fires occur more often near roads and most fires are caused by human activity, accounting for roughly 80% to 85% of all wildfires in the United States.
It has been shown that there are more fires nearer to roads than in wilderness/roadless areas: “From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha).” Three-decade Record of Contiguous-U.S. National Forest Wildfires Indicates Increased Density of Ignitions Near Roads; Gregory H. Aplet, Phil Hartger & Matthew S. Dietz; published 29 January 2026; (https://link.springer.com/article/10.1186/s42408-026-00450-2)
“…fires impact watershed characteristics that control surface runoff, including reducing vegetation cover and altering soil properties such as water repellency.” Longitudinal Propagation of Aquatic Disturbances Following the Largest Wildfire Recorded in New Mexico, USA ; Justin Nichols, Eric Joseph, Asmita Kaphle, Paige Tunby, Lina Rodríguez, Aashish Khandelwal, Justin Reale, Peter Regier, David J. Van Horn & Ricardo González-Pinzón; published 21 August 2024; (https://www.nature.com/articles/s41467-024-51306-9)