I would like to strongly urge the USDA & USFS to retain the 2001 Roadless Area Conservation Rule. The USDA may believe that rescinding the rule is necessary for wildfire prevention but current research rejects this notion. Instead, research from the USFS itself has indicated that forests with and without roads have burned at similar rates ever since the roadless rule came into effect (Healey, 2020).
Given the neutrality of roads upon wildfire impact in Inventoried Roadless Areas (IRAs), it is then important to address the immense benefits of retaining IRAs in contrast to their other heavy downsides. IRAs have tremendous public recreation demand for activities like hunting and fishing. Rescission of the rule would risk destroying these opportunities against the public’s interest (Olden et al., 2026). Moreover, IRAs have been a triumph in protecting species of conservation concern (SCCs). Research shows that IRAs contain critical wildlife habitat across taxa with 57% of SCCs in the contiguous United States having suitable habitat in at least one or more IRAs.
As for what we stand to lose, research suggests that increased road construction in IRAs will result in increased spread of invasive plants and damage to the watersheds that 25 million Americans rely on for clean drinking water (Healey, 2020 & Olden et al., 2026). Vehicles will bring in seeds of invasive species to IRAs that were previously undisturbed while increased industrial activity and sediment from road construction will pollute watersheds (Olden et al., 2026).
Worst of all though, is that this proposed rule rescission is not fiscally sound. If the USDA truly wanted to mitigate the issues land managers and wildland firefighters face, then it would secure and commit funding resources to its already heavily backlogged maintenance requirements for the existing National Forest Road System. As of FY2023, the total cost for the USFS deferred maintenance is already at a whopping $8.6 billion. Instead the USDA is choosing to completely jeopardize all of the benefits IRAs bring us so that commercial logging can swiftly overcome this administrative hurdle for short term profit from irreplaceable old growth resources at exorbitant public expense.
So, I ask once again that the USFS & USDA abandon this attempt to rescind the 2001 Roadless Area Conservation Rule. Instead, I urge them to see the tremendous cultural, social, economic, and conservation value in IRAs and the heavy threats people and ecosystems alike will face from the reckless increased road construction. I also urge the USDA & USFS to instead more closely collaborate with local land managers and state governments for the existing exceptions to IRAs backed by science and to fund the already underfunded National Forest Road System.
Works Cited:
Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32, e01943. https://doi.org/10.1016/j.gecco.2021.e01943
Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15(10), 104023. https://doi.org/10.1088/1748-9326/aba031
Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), e0000538. https://doi.org/10.1371/journal.pwat.0000538