Re: Docket FS-2025-0001, RIN 0596-AD66, proposed rescission of the 2001 Roadless Area Conservation Rule
I oppose the proposed rescission and urge the Department to select the no-action alternative, keeping the 2001 Roadless Rule in full.
The stated rationale is wildfire and active management, but the peer-reviewed evidence points the other way. A 19922024 analysis of all eight contiguous Forest Service regions found 7.99 ignitions per 1,000 hectares within 50 meters of roads, against 1.97 in inventoried roadless areas, and concluded that building roads into roadless areas is likely to produce more fires (Aplet et al. 2026). The existing rule already has exceptions that allow timber projects aimed at reducing wildfire risk, so rescission is not needed to treat fuels where it matters.
Rescission would also put water supplies at risk. Roadless areas are the primary protection for more than 100,000 km of streams and rivers, and watersheds they influence supply drinking water to at least 25 million Americans (Olden et al. 2026). Road construction and logging raise sediment loads and treatment costs for downstream communities.
The final EIS should address these findings directly and explain how more roads would reduce, not increase, fire starts.
I am a lifetime beneficiary of the services derived from US roadless areas. The water supply in my hometown is partly derived from roadless areas in George Washington National Forest. I have hiked the Appalachian Trail through roadless areas in Virginia, North Carolina and New Hampshire. I have benefited from the wildlife habitat services of roadless areas in Colorado, Wyoming, Montana, Alaska, Utah, Oregon, and California, and surely more that I can't even remember. Roadless areas are a uniquely American invention. No other country in the world has had the foresight to protect wildlands such as these for future generations. It is inconceivable to me that we would forgo the benefits of these uniquely productive areas on such flimsy grounds as those proposed.
Sincerely,
William M. Shobe, Charlottesville, VA 22901
References:
Aplet, G.H., Hartger, P., & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22:8. https://doi.org/10.1186/s42408-026-00450-2
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