FS-2025-0001-550957

Dear USDA, As a steward to our public lands, USFS is responsible for caring for and maintaining our National Forests. These are PUBLIC LANDS, and in 2001 the Roadless Rule was established with vast public support because Americans value wild places. Over 1.6 million comments and more than 15 months of development led to the original creation of the Roadless Rule, and that public support persists 25 years later. In 2019, a Pew Charitable Trust survey found that 75% of surveyed Americans supported the rule (regardless of political party or urban/rural residency) (Pew, 2019). Last year, you received over 220,000 public comments, and ~99% of them opposed the proposed change. I strongly oppose the rescission of the Roadless Rule. US National Forests are “Lands of Many Uses." The USFS already manages over 265,000 miles of roads for recreation, wildlife viewing, and timber harvest purposes. These roads allow people of all backgrounds to get outside, but not every scenic area needs roads. Over half of USFS land is already managed without the restrictions of Wilderness or Roadless Rule regulations (OnX, 2026), so it is in the public’s best interest to keep roadless areas set aside. Roadless areas attract outdoorspeople explicitly because they lack new road construction. These are scenic, quiet, natural places, often with abundant wildlife and clean air and water. They are places without roads for logging or mineral extraction and mining. They are also places with huge networks of existing trails. For a recreationist, roadless areas strike the perfect balance between wild and accessible. According to analysis by OnX, roadless areas contain over over 13,000 miles of trails accessible to motorized vehicles such as snowmobiles, motorbikes, and 4x4s, over 19,000 miles of hiking, biking, and ski routes, and over 3000 rock climbing areas (OnX, 2026). These are not empty wasted areas, and implementing further road construction would degrade the wilderness-like experience of outdoor recreationists who seek these areas out. Along with their inherent value to recreationists, these areas have strong economic value. A 2018 economic analysis assigned over $9 billion in economic benefits just from passive and recreational use, with the added benefit to local economies with strong outdoor industries (Hjerpe and Aldrich 2018). This summer, I had the wonderful experience of exploring a roadless section of Sequoia National Forest. In that subalpine meadow, I hiked through a relatively unfragmented ecosystem, encountering birds and wildlife that would be negatively impacted by roads. Even forest roads are a threat to wildlife. One of the biggest threats to biodiversity is habitat degradation and destruction, including fragmentation. A 2006 study in Nantahala National Forest found that even narrow, unpaved logging roads with relatively low usage had a negative impact on salamander abundance, and that impact extended outward from the roadway by at least 35 meters. Further, once roads have been built, it is nearly impossible to unbuild them, and the fragmentation and negative impacts to biodiversity can continue for decades after a logging road is decommissioned (Semlitsch et al. 2006). Multiple peer reviewed studies cast doubt on the argument that adding roads will improve fire management (Aplet et al. 2026, Kilbride et al. 2026, Johnston 2021, Healey 2020, Narayanaraj and Wimberly 2012). Healey (2020), synthesized 20 years of monitoring data, and found that the USFS had actually conducted more fuel management activities per unit area in roadless areas than in other parts of the National Forest System. Further, he found that forests with roads and roadless areas burned at similar rates over 31 years. Johnston et al. (2021) concurred, noting that fire severity was the same across both classifications of land. Finally, several authors have noted that human caused wildfire ignitions are higher in areas closer to roads (Narayanaraj and Wimberly 2011, Aplet et al. 2026). They note that there is a trade-off between higher ignition rates and ability to fight fires, leading to negligible overall impact. Increasing wildfire management is not a strong argument for rescinding the roadless rule. I come to this comment wearing many hats. I am a biologist. I am a hiker and runner and birder. I gravitate towards natural areas all over the country. I have had the privilege of exploring roadless areas in Utah’s Manti La Sal National Forest, California's Sequoia National Forest, Montana's Custer-Gallatin, and Wyoming's Medicine-Bow National Forest. I grew up walking seemingly endless boardwalks that veered in and out of the roadless portion of Croatan National Forest in North Carolina, and learning from my grandparents about the creatures that lived there. I love public lands, wildlife, and outdoor recreation. I firmly oppose the rescission of the Roadless Rule, and support Alternative 1, No Action. Thank you, Caroline sources attached