Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
I strongly oppose the Forest Service’s proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I support Alternative 1, No Action.
I live in Seattle, Washington and spend most of my weekends recreating outdoors in many of Washington State's 139 roadless areas. As an avid hiker, backpacker, trail runner, skier, and climber, I am incredibly grateful and in awe of the many unique, beautiful areas that I am able to recreate in because they have been federally protected with the intent that they remain minimally or undisturbed for the enjoyment of all citizens. The rescission of the Roadless Rule would cause me to lose that peaceful experience in some of my favorite places in Washington State, such as the Alpine Lakes Adjacency (Wenatchee National Forest, Washington) where I recently hiked with a friend to see the larches glow golden in the early morning Fall sunshine. Western larches are just one of many species that are only found in specific ecological habitats and elevation bands, and are likely to further narrow their ranges due to warming climate trends. Roadless areas are critical to maintain such species: "77% of inventoried roadless areas have the potential to conserve threatened, endangered, or imperiled species" (Loucks et al., 2003 https://doi.org/10.5751/ES-00528-070205). The Roadless Rule constrains road construction specifically (while allowing for other mulit-uses like grazing) because road construction is the enabling condition for nearly every documented threat to the lands — fragmentation, sedimentation, invasive species, fire ignition, extractive activity (Trombulak & Frissell 2000, https://conbio.onlinelibrary.wiley.com/doi/10.1046/j.1523-1739.2000.99084.x), all of which would harm my ability to recreate in these wild, gorgeous regions of my home state.
As both an avid outdoors person, and a constituent, I'm greatly concerned by any potential for increased wildfire risk and air quality impacts from the smoke. Unfortunately, evidence from studies suggest that rescission of the Roadless Rule would make wildfires worse, not better. A 2026 study of three decades of National Forest System wildfire data found that wilderness and Inventoried Roadless Areas (IRAs) have the lowest ignition densities of any land category studied (Aplet et al. 2026). Furthermore, wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest, and most ignitions near roads are human-caused (Narayanaraj & Wimberly 2012). Thus, it's reasonable to conclude that introduction of additional roads into current IRAs could to lead to an increase in wildfires.
As a constituent in Washington State, I am also acutely aware that my access to ample, clean water is directly tied to the continued presence of undisturbed natural ecosystems, such as those that are currently protected by the Roadless Rule. If the Roadless Rule is rescinded, there will be impacts on the quality of the water available to us, which is especially concerning as Washington faces more frequent droughts: "When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes" (DellaSala et al., 2011, https://doi.org/10.2489/jswc.66.3.78A). I am further concerned that the recission of the Roadless Rule will lead to higher costs of water in many regions of Washington State, due to higher water treatment expenses. Municipalities are actively decommissioning roads as an effective way to reduce water treatment costs: Seattle, Washington, where I am a resident, was able to defer "a $150 million filtration plant expenditure through an intensive watershed rehabilitation program that will decommission 480 km (300 mi) of roads over a 10-year period" (DellaSala et al., 2011, https://doi.org/10.2489/jswc.66.3.78A).
For the reasons listed above, I oppose the proposal to rescind or alter the Roadless Rule under Alternatives 2 or 3. Instead, I request USFS take Alternative 1, the No Action alternative.
Sincerely,
M.T.
Seattle, WA