FS-2025-0001-509807

I oppose the Roadless Area Conservation proposal for the following reasons, which are all quoted. "The most decisive data point comes from a 2026 study in Fire Ecology by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz of The Wilderness Society. The authors analyzed 32 years of contiguous-U.S. wildfire records across all eight Forest Service regions. Their finding: 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). That is roughly a fourfold difference. Ignition density decreased steadily as distance to roads increased — from about 6 fires per 1,000 ha within 250 m of a road to fewer than 2 fires per 1,000 ha beyond 2,000 m. The pattern holds for human-caused, natural, and undetermined fires alike. As the authors conclude: "building roads into roadless areas is likely to result in more fires." A separate national analysis (Balch et al., Proceedings of the National Academy of Sciences, 2017) explains why. Human-started wildfires accounted for 84% of all U.S. wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Roads are the primary vector through which human ignitions reach previously remote landscapes. What about fire severity? Bradley, Hanson, and DellaSala (Ecosphere, 2016) found that forests with higher levels of protection burned at lower severity, not higher, even though they generally carry the highest biomass and fuel loads. Johnston et al. (Environmental Research Letters, 2021) confirmed that while roadless areas saw greater fire extent over three decades, there was no significant difference in fire severity after accounting for biophysical conditions — and suggested the greater extent of fire may even confer ecological resilience. The Wildland-Urban Interface claim doesn't hold up either Forest Service Chief Tom Schultz testified to the Senate Energy and Natural Resources Committee that 24.5 million acres of inventoried roadless areas sit within one mile of the Wildland-Urban Interface (WUI), calling that figure "our primary concern." The Wilderness Society performed a straightforward GIS analysis using the Forest Service's own WUI dataset. The actual figure is 2.8 million acres — a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not the 42% Schultz implied. Even if every acre near the WUI mattered, the Forest Service already has 23.3 million acres of non-roadless forest land available near communities for fuel reduction. There is no operational need to build new roads through pristine backcountry to address the genuine fire risk facing homes and infrastructure. What this means for the rescission The wildfire rationale is the only public-facing justification USDA has offered for rescinding the Roadless Rule. The actual Federal Register notice tells a different story: it cites Executive Orders 14192 (deregulation), 14225 (timber production), and 14154 (energy unleashing), and states the goal is to facilitate domestic production of "timber, energy and mineral production... to the maximum possible extent." Wildfire is the cover story. Industrial access is the policy. Anyone responding to the rulemaking should know that the empirical case for the wildfire rationale collapses on contact with the published science. Roads bring fire. Roadless areas are not the problem. They are part of the solution." I am quoting the sources used for the above as well: Sources Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, article 8. doi.org/10.1186/s42408-026-00450-2 Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. doi.org/10.1073/pnas.1617394114 Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10), e01492. doi.org/10.1002/ecs2.1492 Johnston, J. D., et al. (2021). Does conserving roadless wildland increase wildfire activity in western US national forests? Environmental Research Letters, 16(8), 084040. doi.org/10.1088/1748-9326/ac13ee The Wilderness Society (2025). Forest Service Chief Grossly Exaggerates Roadless Rule Concern: WUI Analysis. PDF