I oppose the proposal to rescind the 2001 Roadless Area Conservation Rule, and I urge the Forest Service to select the no-action alternative and retain the rule as written.
I am a wildlife biologist on the Payette National Forest in McCall, Idaho, where I lead wildlife monitoring and management for threatened, endangered, and sensitive species across two ranger districts. I hold an M.S. in Ecology and have spent more than a decade in the field on species from wolverine to woodpeckers to sage-grouse. I have written biological evaluations and assessments and contributed to the wildlife sections of EAs and EISs under NEPA, ESA, and NFMA. These comments are my own and do not represent the position of the Forest Service or the Department of Agriculture.
Roadless areas are some of the last intact refugia for sensitive wildlife.
Early in my career I worked on a multi-year wolverine study examining how winter recreation affects home range use and reproduction. I trapped, collared, and tracked wolverines, and I attended the USFWS public hearing on the species' listing. Wolverines need large, connected, lightly disturbed landscapes with persistent deep snow, and they respond to human access. The same is true of Canada lynx, fisher, grizzly bear, and gray wolf. Roads bring motorized access, development, and disturbance into the remote country these species use for denning and dispersal. The 2001 rule is the main safeguard keeping that habitat intact.
Roads are among the most reliable predictors of habitat degradation.
The research on roads and wildlife is consistent. Road density reduces effective habitat for elk and other big game, raises mortality and harvest vulnerability, and fragments movement corridors that carnivores need to maintain genetic connectivity. Roads deliver sediment to streams, harming bull trout and other native fish, and they are a primary pathway for invasive plants. Their effects persist for decades, long after use declines or maintenance stops. Few management decisions are as hard to reverse.
Climate change raises the value of these lands.
Species will need large, connected, minimally disturbed landscapes with elevation gradients and cold-water refugia to shift ranges and persist. Roadless areas provide that. Removing their protection now would foreclose options that managers and the public will need in the decades ahead.
The rule already allows needed management.
I work daily with fire, fuels, timber, and planning staff, and I support active management where it is needed. The 2001 rule already allows fuels reduction and restoration activities in appropriate circumstances. The agency has not shown that the rule, rather than funding, workforce capacity, and prioritization, is what limits fuels treatment near communities. Nationwide rescission would remove protection from millions of acres where no such need exists.
Case-by-case management is a poor substitute for a national standard.
Wide-ranging species cross forest and state boundaries and cannot be conserved through disconnected plan-level decisions. Forest-by-forest management is also more exposed to shifting local pressures and offers far less certainty for wildlife populations. A decision of this magnitude deserves a public process proportionate to the one that produced the rule, which drew more than a million comments, most in support. In the 2025 scoping period, more than 99 percent of comments opposed rescission.
The Roadless Rule has served wildlife, water, and the public for 25 years. I urge the agency to retain it in full.
Respectfully,
Dylan Hopkins
Wildlife Biologist
McCall, Idaho