I am writing as a concerned citizen and public land steward to strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule across 44.7 million acres of National Forest System lands. Decades of peer-reviewed wildlife biology and road ecology research demonstrate that roads—regardless of size or surface—exert widespread, irreversible negative impacts on wildlife, habitat connectivity, and ecosystem integrity. It is scientifically impossible to mitigate these cumulative impacts at a national scale. I urge the Forest Service to select the No Action Alternative and maintain the 2001 Roadless Rule in full.
I. Scientific Evidence: Universal Road Impacts on Wildlife
Extensive literature confirms that roads severely degrade ecosystems and disrupt wildlife behavior:
Universal Ecological Degradation: Trombulak & Frissell (2000) reviewed decades of research and documented seven pathways of negative road impacts on terrestrial and aquatic species, including direct mortality, behavior disruption, invasive species spread, and microclimate alteration—with no net ecological benefits.
The "Road-Effect Zone" & Edge Effects: Forman & Alexander (1998) and Forman et al. (2003) showed that road impacts extend hundreds to thousands of meters into adjacent forests, converting interior habitat into degraded edge habitat.
Habitat Loss & Fragmentation: Haddad et al. (2015, Science Advances) demonstrated that global fragmentation reduces biodiversity by 13% to 75% and impairs ecosystem function. Ibisch et al. (2016, Science) highlighted contiguous roadless areas as vital buffers against biodiversity loss.
Wildlife Movement & Mortality: Studies on ungulates and carnivores (Sawyer et al. 2013; Northrup et al. 2012) show animals actively avoid roads, severing migration corridors and causing functional habitat loss. For wide-ranging species like grizzly bears and wolverines, road density directly predicts displacement and human-caused mortality (Boulanger & Stenhouse 2014; Mowat et al. 2019).
II. Specific Ecosystems at Risk
Rescinding this rule threatens irreplaceable landscapes across the country:
Tongass National Forest (AK): Over 9 million acres of Inventoried Roadless Areas (IRAs) protecting world-class Pacific salmon spawning streams, coastal brown bear foraging, and Alexander Archipelago wolf habitat.
Greater Yellowstone Ecosystem (Custer Gallatin & Beaverhead-Deerlodge NFs, MT/WY): Critical connectivity corridors for grizzly bears, elk calving grounds, and lynx habitat.
Northern Rockies (Clearwater & Idaho Panhandle NFs, ID): Pristine watersheds providing cold, sediment-free water for ESA-listed bull trout and westslope cutthroat trout.
Pacific Northwest Old-Growth (Mt. Baker-Snoqualmie & Olympic NFs, WA): Mature forest stands providing nesting habitat for the ESA-listed marbled murrelet and northern spotted owl.
III. NEPA/FEIS Questions Requiring Response
To comply with NEPA and ESA standards, I request explicit responses in the FEIS to the following:
-What peer-reviewed studies prove that road impacts on wildlife can be successfully mitigated across 44.7 million acres?
-How will the agency enforce scientifically defensible road-density thresholds (e.g., <1 mile per square mile for large carnivores) without national prohibitions?
-How did the agency analyze cumulative interior habitat loss resulting from road-effect zones across all impacted IRAs?
-How will the agency prevent sedimentation in spawning streams from new road construction?
-How can the USFS justify authorizing new roads in roadless areas while carrying a multi-billion-dollar deferred maintenance backlog on its existing ~370,000-mile road system?
IV. Conclusion
The 2001 Roadless Rule protects our most intact, resilient public lands. I request that the USFS reject this rescission proposal and maintain full protections.