Re: Docket No. FS-2025-0001 / RIN 0596-AD66 — Proposed Rescission of the 2001 Roadless Area Conservation Rule (36 CFR 294, Subpart B)
I oppose the proposal to rescind the 2001 Roadless Area Conservation Rule, in whole or in part, and urge the Department to select the No Action alternative and retain 36 CFR 294 Subpart B.
1. Roads increase wildfire ignitions; they do not reduce them.
The proposal cites wildfire risk as a primary justification, but the research points the other way. Balch et al. (2017, PNAS) found humans ignited 84% of U.S. wildfires from 1992–2012. Narayanaraj and Wimberly (2012, Applied Geography) found human-caused ignitions on national forest lands are concentrated near roads, and Syphard et al. (2007, Ecological Applications) found fire frequency is strongly tied to proximity to human infrastructure, including roads. Building roads into roadless areas expands the very access that drives ignitions. The proposal itself concedes that greater access can increase human-caused ignitions. Moreover, the existing rule already permits cutting small-diameter timber to reduce wildfire risk (36 CFR 294.13(b)(1)), so fuel treatment does not require rescission.
2. Roads fragment intact wildlife habitat.
Trombulak and Frissell (2000, Conservation Biology) documented the broad ecological harms of roads: mortality, habitat fragmentation, altered animal behavior, invasive species spread, and chemical and sediment pollution. Research at the Starkey Experimental Forest (Rowland et al. 2000, Journal of Wildlife Management) showed elk consistently avoid areas near open roads, reducing effective habitat. Roadless areas provide secure big-game habitat and backcountry hunting opportunity that roaded forests cannot replace.
3. Roads degrade clean water and native trout habitat.
The Forest Service’s own synthesis, Forest Roads: A Synthesis of Scientific Information (Gucinski et al. 2001, PNW-GTR-509), identifies roads as a major source of sediment delivery to streams. Assessments in the Interior Columbia Basin (Lee et al. 1997, PNW-GTR-405) found strong native salmonid populations associated with areas of low road density. Roadless areas are among the last strongholds for native cutthroat and bull trout and protect source waters for downstream communities. Once sediment and road crossings degrade these streams, recovery takes decades.
4. The Forest Service cannot maintain the roads it already has.
The proposal itself acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. Every new road adds a long-term maintenance liability to an asset base the agency already cannot fund. The proposal’s own estimate of $5.2–11.4 million per year in timber revenue to the Treasury and Forest Service would take over 600 years to retire the existing backlog, even at the high end and with every dollar applied to it. Meanwhile, the agency estimates about $6.1 million per year in lost recreation benefits, largely offsetting projected revenue. From a cost-benefit standpoint, rescission adds liabilities without a credible funding source.
5. Logging and extraction are not needed here.
The proposal describes management opportunities as “modest and localized” and anticipates no net change in domestic oil, gas, and coal production. If rescission produces no meaningful energy gain and limited timber, it offers little benefit in exchange for the permanent loss of intact forest. These areas are worth more standing, as habitat, watershed protection, and backcountry recreation, than cut.
6. Roadless areas buffer and connect designated wilderness, such as Citico Creek.
The Citico Creek Wilderness in the Cherokee National Forest shows what protected, unroaded land can become. The Forest Service acquired this cut-over land in the 1930s and let natural processes heal it, producing a mature second-growth deciduous forest along Citico Creek with remnant old growth still present. Citico adjoins North Carolina’s Joyce Kilmer-Slickrock Wilderness, forming one of the largest blocks of intact forest in the Southern Appalachians. But wilderness boundaries alone cannot sustain these values. Wildlife ranges and watershed processes do not stop at a boundary line, and inventoried roadless areas provide the connected habitat, buffers, and travel corridors that keep wilderness from becoming an isolated island. Citico demonstrates that eastern forests recover when left unroaded; rescinding protections on similar roadless lands throughout the Cherokee and other national forests would forfeit that recovery.
7. Local planning is not an adequate substitute.
Forest plans can be amended project by project, which invites the incremental degradation the 2001 Rule was designed to prevent. A consistent national standard provides durable protection that piecemeal planning cannot.
For these reasons, I urge the USDA to withdraw the proposed rescission and keep the 2001 Roadless Rule in place.