Subject: Strong Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket ID: FS-2025-0001) – Support for the No Action Alternative
Dear Secretary Rollins:
I am writing to express my strong opposition to the proposed total or partial rescission of the 2001 Roadless Area Conservation Rule. I strongly urge the agency to select the No Action Alternative and preserve this critical nationwide conservation policy.
My opposition is rooted in deep personal and professional experience, including my time as an outdoor recreation and tourism professional in Alaska, and as a former wildland firefighter on the Bridger-Teton National Forest in Wyoming. Having lived and worked in several states directly benefiting from the Roadless Rule—including Wyoming, Colorado, Alaska, and California—I understand both the operational realities of wildland fire management and the irreplaceable ecological and economic value of intact backcountry ecosystems.
I refute the fire suppression myth. The primary administrative justification for this rescission is that the 2001 Roadless Rule creates regulatory burdens that hinder effective wildfire risk reduction and fire suppression. As a former wildland firefighter, I know this insinuation is factually incorrect and misrepresents actual emergency operations.
The 2001 Roadless Rule has never prevented wildland firefighters from effectively suppressing active wildfires. During an incident, fire management personnel possess the clear administrative authority to construct handlines, establish containment zones, and utilize heavy equipment—including bulldozers and chainsaws—on an as-needed basis to protect life and property. Emergency fire suppression actions do not require permanent road infrastructure, nor do they require the complete repeal of a foundational national conservation rule.
In fact, constructing a permanent web of timber and resource roads into these pristine backcountry areas often increases wildfire risks. Roads act as primary corridors for human activity, significantly elevating the likelihood of human-caused ignitions.
Rescinding the 2001 Roadless Area Conservation Rule threatens nearly 400 threatened and endangered species (along with nearly 3,500 sensitive species identified in Forest Service reviews) across nearly 45 million acres of national forests. Carving up these 44.7 million acres of Inventoried Roadless Areas (IRAs) will fragment vital contiguous habitats and directly threaten fragile, specialized ecosystems. Based on my time living across the American West and Alaska, I am deeply concerned about the specific species that will suffer if these protections are stripped away:
•Wyoming & Colorado: Fragmentation of critical winter range and migration corridors for elk, mule deer, and the Greater Sage-Grouse.
•Alaska (Tongass National Forest): Destruction of old-growth canopies vital to the Alexander Archipelago wolf and the nesting habitats of Bald Eagles.
•Pacific Northwest & California: Degradation of pristine watersheds necessary for the survival of wild runs of spring Chinook salmon (such as those in the Klamath River Basin), Bull trout, and Steelhead, and all five species of Pacific Salmon.
•Regional Apex Predators: Encroachment into core security habitats needed for the recovery of Grizzly bears and Lynx
My conclusion is that the 2001 Roadless Rule is an incredibly successful, broadly supported policy that safeguards clean drinking water, native biodiversity, and remote recreation economies. Handing these wild spaces over to localized, piecemeal forest plans under the guise of fire safety is an operational mistake and an ecological tragedy.
Protect our wildlands, support our firefighters with factual management practices, and maintain the 2001 Roadless Area Conservation Rule by selecting the No Action Alternative.
Sincerely,
Nick Horras
Frankfort, Illinois
(Former Bridger-Teton National Forest Wildland Firefighter, former resident of Colorado, Alaska, and California)