FS-2025-0001-429065

I am submitting this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule and in support of keeping the Rule, and the roughly 58 million acres of Inventoried Roadless Areas it protects, fully intact. I grew up in New England, in forests my family has hiked, camped, fished, and hunted in for generations. Growing up in Southern Maine, I've watched what happens to a woodland once a road goes through it: the understory changes, the streambanks erode, and the deep quiet that lets wildlife actually live there disappears and it is urbanized for good. As an adult, hiking in the White Mountain National Forest and the Green Mountain National Forest has become essential to my own declining health, giving me a clean and wild place to escape the noise, congestion, and industrial pollution of urban New England, the causes of cancer and disease, and clean air to breathe. Without our intact and healthy national forests, I would no longer be alive today. I'm submitting this comment because I want the roadless backcountry that still exists in this country to still exist for my family’s and friends' kids, their grandchildren, and public health. Roadless forests reduce wildfire risk — they don't cause it. Proponents of this rollback frame it as a wildfire-prevention measure. The peer-reviewed evidence says the opposite. An analysis of two decades of federal wildfire records found that human ignitions account for 84% of all U.S. wildfires and are concentrated near roads and other human infrastructure (Balch et al., 2017). A newly published analysis found that Inventoried Roadless Areas have among the lowest wildfire ignition densities of any Forest Service lands, precisely because they lack the roads that bring ignition sources — vehicles, equipment, roadside debris burning, invasive flammable vegetation — deep into the forest (Mildrexler et al., 2026). Opening these areas to road-building would predictably increase fire ignitions, not reduce them. Roadless areas protect the drinking water millions of us depend on. National forests are the largest single source of municipal water supply in the country, and Inventoried Roadless Areas contain or contribute to hundreds of municipal watersheds serving tens of millions of Americans. This isn't incidental — roads are consistently identified as one of the most significant drivers of degraded water quality and aquatic habitat, through sedimentation, altered hydrology, and chemical runoff (Trombulak & Frissell, 2000). Once roads are built into intact watersheds, that water quality doesn't come back without expensive treatment infrastructure that ratepayers, not industry, end up funding. Roadless areas are irreplaceable habitat for imperiled species. Because they aren't fragmented by roads, these areas support wide-ranging and sensitive species — from salmon and trout runs in the Pacific Northwest to grizzly bears and wolves in the Northern Rockies to migratory songbirds in Appalachian hardwood forests like the ones I grew up in. Roads are a well-documented driver of habitat fragmentation, direct wildlife mortality, and the spread of invasive species, all of which erode the ecosystem integrity these species depend on (Trombulak & Frissell, 2000). Roadless forests are a climate asset we cannot afford to degrade. Older, undisturbed forest stands sequester and store significant amounts of carbon. Road construction and the logging it enables remove exactly the large, older trees that do this work best, converting a long-term carbon sink into a source of emissions at the moment we can least afford it. This is also a fiscal issue. The Forest Service already maintains a 380,000-mile road system it cannot afford to properly maintain, with a multibillion-dollar deferred maintenance backlog. Building new roads into currently roadless backcountry adds cost with no demonstrated benefit, while degrading forest values that, once lost, cannot be restored. For these reasons — reduced wildfire risk, protected drinking water, intact wildlife habitat, and climate stability — I urge the Forest Service to withdraw this proposal and keep the Roadless Rule fully in place. References Balch, J. K., Bradley, B. A., Abatzoglou, J. T., Nagy, R. C., Fusco, E. J., & Mahood, A. L. (2017). Human-started wildfires expand the fire niche across the United States. Proceedings of the National Academy of Sciences, 114(11), 2946–2951. https://doi.org/10.1073/pnas.1617394114 Mildrexler, D. J., Berner, L. T., Law, B. E., & Booth, M. S. (2026). Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation. https://doi.org/10.1016/j.biocon.2026.111950 Trombulak, S. C., & Frissell, C. A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology, 14(1), 18–30. https://doi.org/10.1046/j.1523-1739.2000.99084.x