I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule.
My name is Darshan Ahluwalia, and I am president of the Warriors of the Santa Anas, a nonprofit organization that maintains trails and works to preserve recreational access in the Cleveland National Forest’s Trabuco Ranger District in Southern California. I spend considerable time in this forest recreating and volunteering, and I want to explain what the Roadless Rule means on the ground in our community.
The Trabuco Ranger District contains roughly 50 miles of official Forest Service trails and about 100 miles of forest roads outside San Mateo Canyon Wilderness. It is a large, contiguous backcountry landscape between millions of people in Orange and Riverside counties. Unlike our regional parks, which are largely islands surrounded by development, the Santa Ana Mountains allow people to travel for hours through connected public open space.
Inventoried Roadless Areas are a major part of that landscape. In the district, they cover approximately 38,500 acres—about 40 percent of federally owned non-wilderness land. Approximately 37 of our roughly 50 miles of official Forest Service trail pass through these areas, including Holy Jim, West Horsethief, Trabuco Canyon, Los Pinos, San Juan, Viejo Tie and Chiquito. These are not remote places with little public use; they are where our community hikes, bikes, runs, volunteers and explores.
The most important value here is not any single trail, but the continuity of the landscape. I have personally completed a 54-mile, one-way ride across the Santa Ana Mountains with roughly 12,500 feet of climbing, and we have proposed an 85-mile Santa Ana Mountains Traverse connecting nearly all of the district’s major Forest Service trails. Experiences like these are possible because the landscape remains large and connected. Additional roads and development could fragment that backcountry character even if individual trails remain open.
I recognize the need for the Forest Service to manage wildfire risk and protect communities, but wholesale rescission of the Roadless Rule is not necessary to do that. The existing rule already allows road construction when needed to protect public health and safety from an imminent threat such as fire, and it allows certain timber removal to restore ecosystem conditions and reduce the risk of uncharacteristic wildfire effects.
Road construction also involves its own wildfire tradeoffs. A 2026 peer-reviewed Fire Ecology study examining National Forest fires from 1992 through 2024 found ignition density of 7.99 fires per 1,000 hectares within 50 meters of roads, compared with 1.97 in Inventoried Roadless Areas. The largest 2 percent of fires were similar in size regardless of where they started. The study concluded that building roads into roadless areas is likely to produce more ignitions, even while recognizing that roads can provide strategic firefighting access.
We have experienced this risk firsthand. The 2024 Airport Fire burned 23,526 acres in and around the Trabuco Ranger District. It was accidentally ignited by heavy equipment being used by an Orange County Public Works crew to place large boulders along Trabuco Creek Road to prevent vehicles, particularly motorcycles, from entering a dry-brush area considered at high fire risk. In other words, the fire was itself started during road-access work intended to reduce fire risk. Two years later, our trail system and recreational infrastructure are still recovering.
This does not mean roads have no role in wildfire management. It means that more roads should not automatically be treated as a fire-safety benefit. Management should be strategic and location-specific, while recognizing that increased road access can also increase opportunities for human-caused ignition.
The Roadless Rule provides an important national baseline while retaining exceptions for legitimate management needs. In the Santa Ana Mountains, it protects a substantial portion of one of Southern California’s largest connected backcountry landscapes and most of the trails our community uses.
I urge USDA not to finalize the proposed rescission and to retain the 2001 Roadless Area Conservation Rule. If additional management flexibility is necessary, it should be addressed through targeted measures rather than eliminating nationwide roadless protections.