The views expressed in this comment are my own. I am submitting as an individual and do not speak for or on behalf of the University of Maryland Center for Environmental Science. I am a doctoral candidate at the University of Maryland Center for Environmental Science, Appalachian Laboratory in Frostburg, Maryland, where my research focuses on migratory bird conservation. I live in western Maryland and spend much of my recreational time in the forests and protected areas of neighboring West Virginia, including Monongahela National Forest.
I ask that the environmental impact statement (EIS) examine the following issues:
1) Wildfire risk, the stated basis for this proposal. The Forest Service has justified rescission as a way to reduce wildfire risk, but the claim should be rigorously tested. A 2026 peer-reviewed analysis of national forest wildfires from 1992-2024 found ~8 ignitions/1,000 hectares within 50m of roads, compared with ~2/1,000 hectares in Inventoried Roadless Areas, roughly 4x as many. Ignition density fell with distance from roads (1). The authors conclude that building roads into roadless areas is likely to result in more fires due to increased human access and ignition sources (e.g., campfires, cigarettes, vehicle sparks). The EIS should weigh access benefits for suppression against increased ignition risk and road maintenance costs. It should also analyze eastern forests separately because central Appalachian fire regimes and fuels differ from those of western forests.
2) Habitat fragmentation and forest-interior birds. The central Appalachians hold breeding habitat for Birds of Conservation Concern, including Cerulean Warbler and Wood Thrush (7). Roads cause habitat loss, fragmentation, disturbance, mortality, invasive species spread, and changes to adjacent environments (5, 6). Traffic and industrial noise can reduce reproductive and pairing success in songbirds and alter bird communities near roads (2-4). The EIS should quantify how road construction, logging, or development in currently roadless areas would reduce interior forest habitat and affect declining species.
3) Migratory and flyway-scale effects. Large, intact Appalachian forests provide breeding and stopover habitat for birds moving along the Appalachian ridge corridor. The EIS should assess cumulative impacts on migratory birds protected under the Migratory Bird Treaty Act and how habitat loss on National Forest lands would compound pressures elsewhere in their ranges.
4) Headwater water quality. Monongahela National Forest contains headwaters of rivers that supply drinking water downstream (i.e., Potomac and Ohio River basins). Roads are a source of sediment and altered stream hydrology (6). The EIS should evaluate effects on cold-water streams, sensitive aquatic species, and source water for downstream communities, including those in Maryland.
5) Threatened and endangered species. Please assess impacts on federally listed Appalachian species, including Cheat Mountain salamander and Indiana bat, whose habitats depend on intact forests and clean water.
Please include a “no action” alternative that keeps the 2001 Rule in place, along with alternatives that keep roadless protections at the state or regional level rather than rescinding them nationwide.
Thank you for considering my comment.
References:
Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2
Francis, C. D., Ortega, C. P., & Cruz, A. (2009). Noise Pollution Changes Avian Communities and Species Interactions. Current Biology, 19(16), 1415-1419. https://doi.org/10.1016/j.cub.2009.06.052
Habib, L., Bayne, E. M., & Boutin, S. (2007). Chronic industrial noise affects pairing success and age structure of ovenbirds Seiurus aurocapilla. Journal of Applied Ecology, 44(1), 176-184. https://doi.org/10.1111/j.1365-2664.2006.01234.x
Halfwerk, W., M. Holleman, L. J., Lessells, M., & Slabbekoorn, H. (2011). Negative impact of traffic noise on avian reproductive success. Journal of Applied Ecology, 48(1), 210-219. https://doi.org/10.1111/j.1365-2664.2010.01914.x
Kociolek, A. V., Clevenger, A. P., St. Clair, C. C., & Proppe, D. S. (2011). Effects of Road Networks on Bird Populations. Conservation Biology, 25(2), 241–249. http://www.jstor.org/stable/27976457
Trombulak, S. C., & Frissell, C. A. (2000). Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology, 14(1), 18-30. https://doi.org/10.1046/j.1523-1739.2000.99084.x
U.S. Fish and Wildlife Service (2024). USFWS Bird Species of Concern [fact sheet]. https://www.fws.gov/media/usfws-bird-species-concern