Comment Analysis · Docket FS-2025-0001

FS-2025-0001-529881

Opposes rescissionPosted October 1, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Wildlife Habitat
    • “leading causes of permanent habitat fragmentation”
    • “preserve wildlife habitat and biodiversity”
    • “displacing wildlife and increasing soil erosion”
    • “puts these species and their protected habitats in harm's way”
  • Water Quality Quantity
    • “protect drinking water watersheds”
    • “Stormwater and road runoff are increasingly recognized forms of pollution”
    • “linked the presence of 6PPDQ in waterways to premature deaths in native coho salmon populations”
    • “increase the surface area of watersheds containing this harmful chemical”
  • Forest Management Wildfire
    • “78% of human-caused wildfires originated within half of a mile of a road”
    • “increasing the number of roads in these areas will proportionally increase the number of forest fires”
    • “allow for a wider range of hazardous fuels treatments rather than the construction of more roads”
    • “limited mechanical thinning options and some fire control tactics”
  • Environmental Protection Biodiversity
    • “preserve remaining wild areas”
    • “large-scale logging operations negatively impact forest health”
    • “number of noxious weed species drastically increases”
    • “preserve and protect the habitat for numerous species”

What it names

National Forests
Black Hills National Forest
Roadless areas
Ponderosa Pine

The comment

Prior to 2001, several studies had identified road construction and commercial logging activities to be the leading causes of permanent habitat fragmentation. In an effort to preserve remaining wild areas, the Roadless Area Conservation Rule – also known as the Roadless Rule – was proposed by the U.S. Department of Agriculture and eventually passed. The specific goal of the Roadless Rule was to protect drinking water watersheds, preserve wildlife habitat and biodiversity, protect threatened and endangered species, maintain and preserve scenic areas and recreation opportunities, and to reduce recurring controversy over the management of roadless areas, but the primary purpose was to prohibit the construction of new roads while the agency already had a large maintenance backlog. The proposed rescission of the Roadless Rule states “the 2001 Roadless Rule's prohibitions have limited mechanical thinning options and some fire control tactics in inventoried roadless areas. Substantial acreage within potentially affected inventoried roadless areas has a relatively high likelihood of burning under high intensity conditions that are difficult to manage or could pose a risk to communities, infrastructure, or drinking water sources.” If the objective of federal government is to reduce the risk of wildfires in roadless areas of national forests, the only approach that should be entertained is an amendment to the existing Roadless Rule to allow for a wider range of hazardous fuels treatments rather than the construction of more roads. Currently, about 2 million acres (14%) of Inventoried Roadless Areas have received hazardous fuels treatments to reduce fire risk. Since 78% of human-caused wildfires originated within half of a mile of a road, increasing the number of roads in these areas will proportionally increase the number of forest fires. According to the U.S. Geological Survey, “Stormwater and road runoff are increasingly recognized forms of pollution that can contain chemicals harmful to fish and other aquatic animals.” Car tires contain a chemical known as 6 p-phenylenediamine (6PPD) that is integral to the life of car tires; however, 6PPD readily reacts with air to form a variant known as 6 p-phenylenediamine-quinone (6PPDQ) that is released into the environment as tires wear down from driving. Runoff and stormwater carries this compound into nearby bodies of water where fish and other aquatic animals are exposed to it. Two recently published studies have linked the presence of 6PPDQ in waterways to premature deaths in native coho salmon populations. Genome analysis suggests that 6PPDQ may cause arteries, veins, and the barrier between the blood and brain of the fish to be more permeable. Rescinding the Roadless Rule will increase the surface area of watersheds containing this harmful chemical and will further increase the likelihood of negatively impacting native fish populations. As any environmentalist would be quick to point out large-scale logging operations negatively impact forest health in both the near and long-term. During the life of a logging operation, forests are cleared, displacing wildlife and increasing soil erosion. After the operation has concluded, several studies – including a study on Exotic plant responses to large-scale commercial logging in ponderosa pine forests of the Black Hills National Forest – found that the number of noxious weed species drastically increases in the years following large-scale commercial logging operations. Many people remember the predatory and aggressive logging practices of the 1900s that decimated much of the remaining old-growth forests in the contiguous United States. Since its formation, the National Forest System has worked to preserve and protect the habitat for numerous species at have been or would be affected by large-scale commercial logging efforts. The rescission of the roadless rule potentially puts these species and their protected habitats in harm’s way. America is one nation, under God and we have been appointed with the stewardship of His creation. Preserving the natural beauty and resources of these roadless areas is our God-given duty, a duty that should not be left to the whim of corporate lobbying and greed; therefore, a firm, all-encompassing rule must remain in effect to continue to protect these lands from further habitat destruction. Do not rescind the Roadless Area Conservation Rule.

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