Opposes rescissionA0 noneSubstance 5/24Posted October 7, 2026 On Regulations.gov
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“Roadless areas provide recreational activities and promote the physical and mental health”
“outdoor recreation generates $1.2 trillion and relies on intact landscapes”
“Recreational activities have a direct economic impact on local communities”
The comment
As a professional ecologist, I have worked in the forests of northeastern Washington State, and have expertise in forest ecology around the globe. I co-authored the State of the World’s Forests, recently published by the UN Food and Agriculture Organization. The consequences of human activities on forests that modify ecological, social, and economic systems are a primary focus of my work. I write to strongly oppose the proposed rescission of the federal 2001 Roadless Rule, which prohibits road construction and logging on 30 percent of United States Forest Service (USFS) land across 42 states.
A justification of rescission is better management of wildfires due to more flexibility to take swift action to reduce wildfire risk (Secretary Rollins, press release). Multiple studies show that roads actually increase wildfire risk. Morrison (2007; Roads and Wildfires. Pacific Biodiversity Institute, Winthrop, WA) reported 88% of all wildfires nationwide are caused by humans and 95% of these occurred within 0.5 mile of a road. Over 90 percent of wildfires from all causes occurred within 0.5 mile of a road.
Other evidence indicates that forest management can occur in roadless areas, and that absence of roads supports forest health. Healey (2020; Environmental Research Letters. 15: 104023) used long-term USFS forest management records to assess the impact of roadlessness on forest health. Absence of roads in USFS roadless areas has not hindered management activities and has not stopped fire prevention measures. Indeed, fuel management activities in roadless areas were more numerous on a per-area basis than elsewhere in the National Forest System. But, Healey’s analysis of 15,000 forest inventory plots shows that roads are detrimental to other aspects of forest health. Significantly, roads increase spread of invasive plant species. He concludes that “Speculation that eliminating road prohibitions would improve forest health is not supported by nearly 20 years of monitoring data.”
Another justification is to boost resource extraction, usually timber harvest. Many areas are designated as roadless because the costs of road construction and resource extraction from remote areas were greater than the value of the timber. Moreover, operating in these areas increases soil erosion.
Healthy forests support healthy populations of plants and animals. The 2000 Roadless Area Final EIS states: “Inventoried roadless areas provide large, relatively undisturbed blocks of habitat for a variety of terrestrial and aquatic wildlife and plants etc. Many inventoried roadless areas function as biological strongholds and refuges for a number of species, and they play a key role in maintaining native plant and animal communities and biological diversity.” This was considered an important role of roadless areas at the inception of the Roadless Rule and is even more important today.
Roadless areas are important in providing clean water, critical for human health. The 2000 Roadless Area Conservation Final EIS by the USDA estimated that USFS lands provide 14% of the total water flow in the US and 33% of water flow in the West. Many of these watersheds occur on inventoried roadless areas, and are sources of drinking water for millions of Americans. The role of roadless areas in providing clean water was true in 2000 and is today.
Roadless areas provide recreational activities and promote the physical and mental health of people who participate in these activities. Recreational activities have a direct economic impact on local communities. A Forbes report (Randall, September 17 2025) indicates that outdoor recreation generates $1.2 trillion and relies on intact landscapes. The cultural and spiritual significance to our national well-being is harder to measure, but equally important.
The 2020 Final EIS for the 2021 Roadless Rule examined the socioeconomic and ecological ramifications of four alternatives for management of USFS roadless areas. The conclusion supporting Alternative 3: “Prohibit Road Construction, Reconstruction, and Timber Harvest Except for Stewardship Purposes Within Inventoried Roadless Area” was based on review of current data, following the guidelines/timelines of the National Environmental Protection Act (NEPA). It is imperative that the EIS to evaluate the rescission of the 2021 Roadless Rule be equally rigorous and adhere to NEPA. This EIS must consider the data that the current Roadless Rule promotes forest health, enables resource extraction where economically feasible, protects clean water for millions of people, sustains viable populations of native plants and animals, and provides recreational activities that benefit physical/mental health and local economies.
In sum, the reasons put forward by Secretary Rollins to rescind the 2001 Roadless Rule are unsupported by data and there are many more compelling reasons to reject the rescission, ensuring that roadless areas are maintained for future generations.