FS-2025-0001-600968

The Roadless Rule is essential is preserving biodiversity in the United States. Study after study demonstrate that our current protected areas, including national parks, wilderness areas, and wildlife refuges, are simply too small and fragmented to adequately preserve biodiversity. However, the addition of the roadless areas that are not directly impacted by humans make a big difference by extending the size and reducing isolation of fully protected areas. As an example, I suggest you review the study of Crist et al (2005), which shows that in the northern Rocky Mountains, roadless areas add 2.6 million hectares of additional protected land. This additional land increased all land cover types, including increasing 15 types by more than 40%, which demonstrates the diverse ecosystems that the roadless areas protect. The paper also shows that landscape connectivity was improved in terms of area, isolation, and aggregation. I'll provide the citation at the end of this comment for closer review. The National Forest Service manages approximately 193 million acres of land and only about 58 million of which are protected by the Roadless Rule. This leaves 135 million acres to be managed in the typical way, which allows for road construction, road reconstruction, and timber harvesting. That is an ample amount, and the costs associated with conducting these activities in roadless areas is simply too much. Losing biodiversity reduces the ecosystem services that this land can provide and jeopardizes the persistence of species. Resending the Roadless Rule will have a tremendous negative impact on these ecosystems and on the United States. Let us be thoughtful and good stewards and not make this mistake, which will have long lasting negative impacts. Reference: Crist, Michele R., Bo Wilmer, and Gregory H. Aplet. “Assessing the Value of Roadless Areas in a Conservation Reserve Strategy: Biodiversity and Landscape Connectivity in the Northern Rockies.” Journal of Applied Ecology 42, no. 1 (2005): 181–91. https://doi.org/10.1111/j.1365-2664.2005.00996.x.