The following comment refers to Special Areas; Roadless Area Conservation at 91 FR 53827. This commentary is in oppostion of rescinding the 2001 Roadless Area Conservation Rule by removing and reserving 36 CFR part 294, subpart B.
The 2001 Roadless Area Conservation Rule represents one of the most significant conservation achievements in American history, and its protection should be maintained in full.
Roadless areas are among the last remaining intact forest ecosystems in the contiguous United States. They provide clean drinking water to approximately 60 million Americans, serving as natural filtration systems whose value no engineered alternative could replicate at comparable cost. They provide critical habitat for hundreds of threatened and endangered species, including grizzly bears, wolves, and bull trout, whose survival depends on large, connected wilderness corridors that roads fragment irreparably. They store carbon at rates that make them meaningful contributors to climate mitigation — a function that, once destroyed by road construction, requires decades to restore and in many cases cannot be restored at all.
The economic argument for the Roadless Rule is as strong as the ecological one. Intact forests generate substantial and sustained economic returns through recreation, tourism, hunting, and fishing — industries that depend on the very wildness that road construction eliminates. A 2023 analysis found that outdoor recreation contributes over $780 billion annually to the US economy. The communities adjacent to roadless areas benefit disproportionately from this economy, and they are disproportionately harmed when extraction-driven road building degrades the landscapes that draw visitors and support local businesses.
The argument that roadless protections foreclose economic opportunity misreads the evidence. The timber and mineral resources accessible only through new road construction in currently roadless areas represent marginal economic returns compared to the sustained, renewable economic value of intact ecosystems — while imposing permanent, irreversible costs: erosion, watershed damage, wildlife displacement, and the loss of the solitude and wildness that no restored landscape fully recovers.
Roads, once built, are permanent interventions. The Roadless Rule preserves optionality — future generations retain the choice of what to do with these lands. Removing the rule eliminates that choice permanently, in exchange for short-term extraction value that accrues to few and at cost to many.
The Roadless Rule should be maintained, strengthened where possible, and treated as the settled conservation consensus it has become over more than two decades of bipartisan public support.