FS-2025-0001-602185

I am writing to oppose dropping the 2001 Roadless Rule and to ask you to choose Alternative 1, No Action, to retain that rule. I am a wildlife biologist, an outdoor recreation enthusiast, and someone who lives on a family farm that relies on clean water and functioning ecosystem processes for economic production. North America is a hotspot of global biodiversity for many freshwater species. Roads have both short and long-term negative effects on our native freshwater species. They can lead to both pulse and chronic sediment input through erosion, can permanently isolate populations where they cross streams when hanging culverts, extensive shading, or loss of natural substrate occur. A recent review documents the effects of roads on freshwater biodiversity, and these factors should have been given serious attention (Algera et al. 2026). There are many other aspects of ecosystem function and biotic integrity that are at risk with increased roads, as documented in a review by Midlrexler et al. (2026). Important ecosystem processes such as nutrient cycling and water cycling are driven by complex interactions among native plants, microbes, insects, and salamanders (often the most abundant vertebrates and major components of biomass) on the forest floor. When invasive plants spread in our forests and grasslands, there are cascading effects on leaf litter decomposition and soil chemistry, drastically changing the ability for our native species, including some of our important timber trees and medicinal plants, to grow and survive (Liebhold et al. 2017, Jones and Grenz 2023). Forest roads and skid trails are a major source of the spread of invasive plants (Buhaly et al. 2025, Dai et al. 2025). This spread creates risks and costs to forest industry, one of the most important economic drivers in many regions of our country. The costs of invasive species to the forestry and agriculture industries in Canada has been estimated at over $7.5 billion per year and in the US costs of damage from invasive plants has been estimated at $21 billion per year, with $700 million of that being costs to forestry operations (Jones and Grenz 2023). Until we develop much improved practices for reducing the spread of invasive plants, we would be wise to continue to restrict road-building and protect healthy forests. The proposed rule contradicts current scientific understanding of the effects of roads on wildfire risk in our national forests (Kilbride et al. 2026). High risk to humans from wildfires occurs at the interface of residential development and forests, not in large expanses of roadless areas. Legitimate concerns among the public about wildfire danger should not be used as an excuse to rescind the Roadless Rule, when other approaches should be prioritized. Knowing how popular recreation is in roadless areas, I was surprised by the statement in the Summary of Potential impacts that “Losses in economic benefit to recreationists are most likely to be associated with the operable areas of current IRAs and could be an estimated $6.1 million annually.” Then in a subsequent section on Minerals and Energy, the summary states “Under this proposed rule, there is additional flexibility for potential future leasable mineral development (primarily oil, gas, and coal) opportunities and it is reasonably foreseeable that some development could occur in potentially affected inventoried roadless areas, resulting in associated costs and benefits. . . . Although the estimated annual economic effects span a wide range, the additional impacts associated with the proposed rule could exceed $100 million. Some industries, including recreation and tourism, could experience trade-offs as a result of the proposed rule.” If eliminating the roadless rule would allow an additional $100 million in economic activity from mineral and energy extraction, certainly that would have a negative impact on recreation, but only the roads themselves, not the extraction that would follow, were accounted for in your estimate of costs to recreation. It is unreasonable to calculate costs to recreation from the roads alone, and not the increased mining and energy development, but then to compare that to the economic benefits of mineral and energy development. The value of healthy forests for clean water, recreation, and as seed and soil microbial banks and reserves for a healthy forest industry, seem to be undervalued. I did not see any of the literature cited above (references in attached document or below) included in the Draft Environmental Impact Statement. The Draft EIS glossed over some of these concerns, but did not thoroughly evaluate the severe negative consequences of building roads in forests that have been protected in recent decades. It appears that both the environmental and economic analyses are flawed. Please take the no action alternative and continue the 2001 Roadless Rule.