To the Department of Agriculture and the Forest Service:
As an outdoor enthusiast, I am entering the record to observe that the 2001 Roadless Area Conservation Rule represents a considered administrative judgment that the public interest in roadless national forest — ecological, recreational, and watershed-related — outweighs the interests served by road-building authorization, and that the Department's proposed rescission has not offered a sufficiently developed basis for overturning that judgment.
Regarding the Coconino Rim in the Kaibab National Forest, Arizona:
Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior.
Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)
Rescinding the Roadless Rule would open the Coconino Rim, Kaibab National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary.
Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole.
The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress.
“Although roadless areas tend to be cooler, moister, and higher elevation, they experienced greater fire extent than roaded areas over the past three decades. Critically, however, there was no significant difference in fire severity after accounting for biophysical differences. The authors suggest the greater extent of fire in roadless areas "may confer resilience to these landscapes in the face of climate change." — Johnston et al., 2021 (https://doi.org/10.1088/1748-9326/ac13ee)”
Rescinding the roadless rule will create greater fire risk
Keep the Roadless Rule. Don't rescind.
Yours truly,
CommentID: RLC-20261005-VOX7I2