Dear Ms. Rollins,
As a marine environmental researcher, I have studied how habitat connectivity sustains populations and ecosystems. The same principle applies on land, and it is the reason I oppose rescinding the 2001 Roadless Rule and urge the agency to select Alternative 1, No Action.
As a Marylander, the closest national forest is the George Washington National Forest in Virginia and West Virginia. Connectivity is very important within this forest, as it allows for genetic exchange and therefore healthier populations, demographic rescue, which allows recolonization after local disturbance; and seasonal migration to reach dispersed resources. 19 species rely on this connection, include the American Chestnut (G3), which once dominated northeastern forests before being practically wiped out in the first half of the 20th century (Dalgleish & Swihart 2011, https://doi.org/10.1111/j.1526-100X.2011.00795.x), the Rusty-patched Bumble Bee (G2), the tricolored bat (G3), and the Virginia big-eared bat (T3) (G2 = globally imperiled, G3 = globally vulnerable, T3 = vulnerable subspecies; NatureServe ranks.)
Roads undermine each of these functions. Globally, about 80% of the terrestrial surface is still roadless, but it is broken into roughly 600,000 patches, more than half of them only about 1 km² and just 7% larger than 100 km². Limiting road expansion into roadless areas may be one of the most cost-effective ways to meet biodiversity and sustainability goals (Ibisch et al., 2016, https://doi.org/10.1126/science.aaf7166). Within 1 km of roads, forests show about 18.6% lower forest cover, 2.7 m shorter canopy, reduced net primary productivity, and 23.0 more patches per km² of fragmentation. These impacts extend up to 5 km with a clear distance-decay pattern, and they are tied to roads opening wilderness to logging, hunting, mining, and colonization (Zhou et al., 2026, https://doi.org/10.1038/s41467-026-69150-4).
Roads also change the habitat itself. In natural secondary forests, species richness, density, and the proportion of invasive species all decline with distance from the road, with invasives concentrated along roadsides. Roads raise soil moisture, soil disturbance, nutrients, sun exposure, and soil temperature, all of which promote plant invasions (Dai et al. 2025, https://doi.org/10.1111/ddi.70002).
Additionally, as the argument for rescission is wildfire prevention, the recent study by Aplet at al. 2026 (https://doi.org/10.1186/s42408-026-00450-2) found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied.
Instead of breaking up habitat, and making new roads where not needed by the public, and increasing wildfire risk, perhaps first consider addressing the backlog of road repair of $6.9 Billion, a number that has no clear source or clear sampling methodology.