Opposes rescissionA0 noneSubstance 6/24Posted September 17, 2026 On Regulations.gov
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My name is Richard Mitchell, I live in Coconino County in Flagstaff, AZ, right up against the Coconino National Forest.
I firmly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. This rule has protected roughly 58.5 million acres of national forest for twenty five years from new road construction and commercial logging. That’s nearly a third of the entire National Forest System. Repealing it would open an estimated 45 million acres to development and logging (which is similar in size to the state of Washington). I recreate on this land throughout the country. Frequently. From my own backyard around the Coconino forest, to dispersed camping in Utah, hiking in Washington, backpacking in Colorado, and soaking in hot springs in New Mexico, I find therapy and refuge in these spaces. Friends I know fill their freezers for their families through hunting in these areas. And my native siblings strongly oppose this proposal out of principle and respect for their culture and roots. Repealing the Roadless Rule would make my life considerably worse and I am quite upset and appalled at this continual threat to the land that We The People have a right to.
Highlighted below are the main reasons why I disagree with repealing the act, along with evidence-based information.
Increased wildfire risk: This repeal has been framed as a wildfire-safety measure, but the evidence does not support that claim. The vast majority of wildfires in the United States are started by people, with over 90% of fires starting within half a mile of a road. Research from the Pacific Biodiversity Institute and more recent analysis from The Wilderness Society covering 1992–2024 shows that roads bring more vehicles, more campfires, more equipment sparks, and more human traffic into forests that are currently among the least fire-prone in the system precisely because they are hard to reach. Opening these areas to road-building will very likely increase the number of human-caused ignitions.
Harm to wildlife and ecosystems: Roadless areas make up only about 2% of land in the lower 48 states but they provide habitat for an estimated 60% of the nation's vulnerable terrestrial wildlife. This rescission would affect more than 7 million acres of critical habitat and put more than 300 protected species at risk. Roads are a huge blockage to habitat, disrupt migration corridors, introduce sediment, invasive species, and cause disturbance into some of the only remaining wild landscapes we have left.
Threats to drinking water: National forests are the single largest source of municipal drinking water in the country, supplying an estimated 60 million people across 33 states, with roughly 20–25 million people relying specifically on water that originates in currently protected roadless areas. Rolling back these protections risks degrading water quality at the source for millions of downstream communities that have no comparable substitute for these watersheds.
The cost of new roads: This proposal is also fiscally hard to justify. The Forest Service already manages more than 380,000 miles of road — enough to circle the globe over fifteen times — and carries a maintenance backlog estimated between $7 billion and $10 billion on the roads it already has. The agency currently receives only a fraction of the annual funding needed to maintain its existing network. Building new roads into roadless areas would add to that unfunded liability rather than relieve it.
Indigenous impact and opposition: Tribal nations have been clear and consistent in their opposition to this rescission. Dozens of Tribes submitted formal comments and requested consultation during the initial comment period, and USDA's own tribal summary materials acknowledge that most Tribes consulted oppose the repeal. Roadless areas often overlap with lands of deep cultural, spiritual, and subsistence significance.
A better path forward? If the Department's genuine goal is wildfire resilience and forest health, there are more targeted, less destructive tools already available. The current Roadless Rule already permits road construction for public health and safety needs, and it does not block fuel reduction, prescribed burns, or other active forest-health work. I would encourage USDA to instead invest in: (1) prescribed burning and mechanical thinning focused on the wildland-urban interface, where it does the most good for actual communities at risk; (2) fully funding the existing road maintenance backlog before creating new liabilities; and (3) continued, good-faith consultation with Tribal nations on management of these lands, rather than a blanket nationwide repeal.
I urge you to take this comment and those of my peers submitting similar comments to heart. The health of our environment, wildlife, and resources is counting on you to make the right choice.
Sincerely,
Richard Mitchell