My name is Mary Grace Lemon and I live in in Minneapolis Minnesota. I have recreated in National Forests all across the United States including several National Forests in Minnesota such as Superior National Forest and Chippewa National Forest and Kisatchie National Forest in my home state of Louisiana. I also have a PhD in hydrology and spent 5 years working for the United States Fish and Wildlife Service as a hydrologist. I am writing to comment on the USDA Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule.
I am against repealing this rule for several reasons. First, repealing this rule will not help with fires. Rather, the repeal of this rule will likely lead to increased ignitions and fire intensity due to several factors. Second, roadless areas are critical for ecosystems. Habitat fragmentation causes significant harm to wildlife populations. Lastly, this rule change will waste taxpayer money and reduce recreation opportunities.
Wildfires are 4x more likely to start near roads (Aplet et al. 2026). Cars can cause sparks and are sources of ignition. In addition, roads are a pathway for fire-prone invasive plant species to invade the forest interior. Roads also cause hydrological changes that can lead to vegetation community changes and reduce soil moisture, increasing the vulnerability of a forest to fire. In fact, I worked for five years on restoration projects that overwhelming involved removing roads within National Wildlife Refuges to restore hydrologic connectivity and increase the water table within forested areas to reduce the vulnerability of the forest to fire.
Roads are a major cause of habitat fragmentation, breaking continuous landscapes into smaller, isolated patches. By acting as barriers to movement, roads prevent animals from reaching food, mates, and new territory, while traffic adds direct mortality (Seiler, 2001). Over time, this isolation shrinks populations and limits genetic exchange, making them more vulnerable to local extinction (Forman & Alexander, 1998; Trombulak & Frissell, 2000). A review of 79 studies found that negative effects of roads on animal abundance outnumbered positive effects five to one (Fahrig & Rytwinski, 2009).
While working at USFWS, I helped to remove many roads to restore ecosystem function and habitats. All of these roads were built with taxpayer money and then removed with taxpayer money after rarely being used. This represented a massive waste of taxpayer money that could have easily been avoided if large investment decisions were not left to local managers and rather decided at a higher level. In the end taxpayer money was wasted and ecological damage was done because a restored ecosystem takes decades to function as effectively as one that has never been modified. Repealing the roadless rule will lead future wasteful and ecologically damaging uses of taxpayer money that will require additional taxpayer money to be corrected.
Roads are some of the most disruptive human modifications that exist for effective ecosystem function. For all of the above reasons and more I strongly oppose rescinding the 2001 Roadless Rule and taking the no action alternative. We should absolutely be doing everything that we can to reduce the number of roads within our federal and managed forests and wilderness areas. Before moving forward, I ask that the agency:
1.Conduct a full environmental review of the impact of rescinding this rule on roadless areas;
2.Commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed.
comments were considered and concerns addressed.
References
•Aplet, G.H., Hartger, P., & Dietz, M.S. (2026) Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(8).
•Fahrig, L., & Rytwinski, T. (2009). Effects of roads on animal abundance: An empirical review and synthesis. Ecology and Society, 14(1), 21.
•Forman, R. T. T., & Alexander, L. E. (1998). Roads and their major ecological effects. Annual Review of Ecology and Systematics, 29, 207–231.
•Seiler, A. (2001). Ecological effects of roads: A review (Introductory Research Essay No. 9). Swedish University of Agricultural Sciences, Uppsala.
•Trombulak, S. C., & Frissell, C. A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology, 14(1), 18–30.