To the USDA Roadless Rule Rulemaking Team:
In my experience as an outdoor enthusiast who has used roadless national forest as a recreational and restorative resource for many years, I have come to regard the 2001 Rule as one of the few administrative instruments capable of holding the line against the gradual conversion of interior forest to roaded and managed landscape.
I have been enjoying roadless areas since I was a child. I took them for granted as a restorative place. I realize now they need to be protected against those who are driven only by greed & special interests. Once these areas are destroyed, they are gone forever. We must protect them.
Roads bring noise & exhaust. I love breathing clean air & hearing only wildlife.
Regarding the South Mills River in the Pisgah National Forest, North Carolina:
Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer.
The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests.
“A foundational, frequently-cited review documenting seven categories of negative road effects: mortality from construction, vehicle collisions, modified animal behavior, alteration of physical and chemical environments, spread of exotic species, and increased human use. Establishes the scientific rationale for keeping roadless areas roadless and is cited extensively across the roadless-rule literature. — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)”
“A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)”
“Foundational environmental analysis documenting 58.5 million roadless area acres and comprehensive effects on soils, water, fish/wildlife, and socioeconomics. Core scientific record behind the Roadless Rule. — (2000/2001) (https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5057900.pdf)”
“Even-aged stands took on average 30 years to recover to pre-harvest buffering state after clear-cutting. Clear-cuts led to full coupling with open-air temperatures, eliminating microclimate buffering entirely. It can take decades for a clear-cut stand to reach the same buffering capacity as a forest with continuous tree cover. From biodiversity perspective, continuous tree cover can create more temporally stable microclimatic conditions and can thus aid in maintaining microrefugia and mitigate climate warming impacts. — ScienceDirect / Agricultural and Forest Meteorology, 2025 (https://doi.org/10.1016/j.agrformet.2025.110434)”
My ask is simple: keep the 2001 Rule.
Gratefully,
CommentID: RLC-20261005-P0VG8F