Public Comment Opposing the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001, RIN 0596-AD66)
Dear Director, Ecosystem Management Coordination,
I am writing to voice my firm opposition to the U.S. Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. I advocate for the permanent preservation of all 44.7 million acres of Inventoried Roadless Areas (IRAs) nationwide. The current federal baseline ensures a unified, robust standard of ecological integrity that localized forest plans simply cannot replicate.
While I care about the protection of all national forests across every state, this proposal strikes incredibly close to home. I live in Arizona, where I have hiked and backpacked through the Tonto National Forest and around Mount Lemmon in the Coronado National Forest numerous times. I know firsthand how vital these unroaded spaces are to preserving the delicate desert-to-mountain ecosystems, protecting local municipal watersheds, and offering wild landscapes for quiet recreation. If the Roadless Rule is rescinded, the iconic backdrops of the Arizona National Scenic Trail which winds directly through IRAs in these forests could be forever scarred by industrial road construction and commercial logging.
Furthermore, my personal connection to our national forests spans the country. I have had the privilege of creating beautiful memories hiking in the Deschutes National Forest in Oregon, the George Washington National Forest in Virginia, and public lands near Ogden, Utah. Most deeply, I proposed to the love of my life in the Snoqualmie National Forest in Washington. These are not merely administrative parcels of land to be exploited; they are the irreplaceable geography of our lives.
The impacts of this rescission also extend directly to my loved ones. I have family and friends who rely on the intact backcountries of Washington and Montana for hiking, hunting, and fishing. Millions of outdoor enthusiasts depend on the primitive habitats protected by the 2001 Rule to maintain healthy big game populations and native trout streams.
I strongly reject the agency's primary justification that rescission is required for localized forest management, and I urge you to consider the following substantive points regarding wildfire and watershed degradation:
- Increased Wildfire Risk and Human-Caused Ignitions: The Forest Service's own DEIS data confirms that repealing the 2001 Roadless Rule actually increases the probability and frequency of wildfire ignitions. Historically, inventoried roadless tracts have up to four times fewer wildfire starts than heavily roaded forest areas. Carving new road networks into remote backcountry provides vehicle access that introduces a primary source of human-caused ignitions. Furthermore, commercial logging operations open up the canopy, altering local microclimates by drying out understory vegetation, creating wind tunnels that accelerate fire spread, and introducing highly combustible fine fuels.
- Severe Degradation of Watersheds and Drinking Water Resources: Roadless areas safeguard the headwaters of vital municipal watersheds that provide clean, unfiltered drinking water to over 25 to 60 million Americans. Roads inherently disrupt natural hydrology. Constructing new roads, culverts, and stream crossings triggers severe soil erosion and mass wasting events. The resulting sedimentation and toxic runoff empty directly into pristine headwater streams, choking aquatic habitats, decimating native trout and salmon spawning grounds, and threatening down-river municipal water supplies. This structural damage will force local communities to bear millions of dollars in skyrocketing water treatment and infrastructure costs.
The Forest Service already possesses the administrative flexibility under the 2001 Rule to execute targeted hazardous fuel reductions and handle emergencies without stripping protection from 44.7 million acres of pristine public land. Adding more roads when the agency already faces an $8.6 billion deferred road maintenance backlog is environmentally and fiscally irresponsible.
Our national forests are an interconnected legacy belonging to all Americans and future generations. I urge the U.S. Forest Service to reject the proposed rescission and maintain the 2001 Roadless Area Conservation Rule in its entirety.
Sincerely,
James Le
Gilbert, AZ 85296