I am writing to strongly oppose rescinding the 2001 Roadless Rule in its entirety.
I live in Portland and spend much of my year in the Clackamas River Ranger District of Mt. Hood National Forest, where I hunt and forage in the Roaring River Wilderness and the country around it. I also camp, backpack, and ski the backcountry, and I volunteer in habitat restoration and forest defense. I know this ground because I feed my family from it and depend on it for clean drinking water.
The wilderness is only as intact as the land around it. The Salmon-Huckleberry inventoried roadless area borders the Roaring River Wilderness and holds headwaters of the upper Clackamas. These upper tributaries are among the last strongholds of wild fish in the lower Columbia, and the basin holds the last significant run of wild late-winter coho in the entire Columbia Basin. Above North Fork Dam, the river has been managed as a wild fish sanctuary since 1999. That work means little if the cold, clean water feeding it is degraded upstream. Roads deliver sediment to spawning gravel, warm streams by stripping shade, and fragment habitat. [Add the runs or places you know firsthand.] Designated wilderness can't protect a watershed if the land upstream and alongside it is opened to roads and logging. More than a million Oregonians, including me and my family, drink water that comes off Mt. Hood National Forest.
As a hunter and forager, I've seen what roads do. Elk avoid road corridors, and new roads bring more traffic and less of the secure, quiet habitat that makes backcountry hunting worth doing. The same intact ground produces some of the best mushroom foraging I know, and those grounds are lost once roads and landings cut through them.
The fire rationale doesn't hold up. USDA says rescission will reduce fire risk, but most wildfires are human-caused and most ignite near roads. Recent research finds fires are about four times more likely to start in roaded areas than in unroaded ones. The 2001 Rule already allows road building and small-tree cutting where needed to reduce fire risk and protect public safety, so full rescission isn't necessary for that. It's also hard to take the argument seriously when the FY26 budget zeroes out wildland fire management funding.
The agency can't afford the roads it has. The national forest system carries a $10.8 billion maintenance backlog, and Mt. Hood's own 2015 Travel Analysis Report recommended decommissioning roads, not building them, citing water quality and aging, unsafe infrastructure. Forest revenue now comes mainly from recreation, and more roads would degrade what visitors come for.
This is not what the public wants. The 2001 Rule drew 1.6 million comments, over 95% in favor of protection, and a 2019 Pew survey found 75% of Americans support it and only 16% oppose it. The Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest, have voiced strong support. Rescinding the most popular rule in USDA's history would ignore the people the agency says it serves.
I ask that, before moving forward, the agency:
* Conduct a thorough environmental analysis of road building's impacts on roadless areas, including the upper Clackamas headwaters;
* Guarantee that no watershed or wild fish habitat, including upper Clackamas coho spawning and rearing streams, will be negatively affected by rescission;
* Publish a detailed plan for addressing the existing road maintenance backlog;
* Commit to transparency, including a full account of how public comments were considered.