FS-2025-0001-604566

My name is Ryan Williams, and I am a conservation biologist from Massachusetts. As a lifelong New Englander, I cherish what little public land we have in the northeast. Our landscape was rapidly deforested in the centuries following European settlement and it has taken generations for our forests to rebound. Inventoried Roadless Areas (IRA) protected by the 2001 Roadless Area Conservation Rule are some of the few remaining wildlands left in the northeast. I vehemently oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. It would be an environmentally and socially irresponsible act to needlessly log some of our few remaining public wildlands. Therefore, I am writing in support of "Alternative 1", the "no action alternative", which would maintain the 2001 Roadless Rule. Roadless Areas are a bastion of biodiversity, providing critical habitat for innumerable wildlife species. A recent study found that 308 of 537 species of conservation concern in the United States have habitat contained within our Inventoried Roadless Areas (Dietz et al., 2021). What measures will the Forest Service take to minimize impacts to biodiversity associated with the proposed action? Wide-ranging species, like the federally threatened Canada lynx, require large core habitat areas connected by corridors throughout the landscape. Many of the existing large forest blocks required by these species are comprised of Inventoried Roadless Areas. A study by Forest Service researchers found that maintaining unfragmented forested corridors from source populations in Canada with lynx habitat in their southern range periphery is critical (Squires et al., 2013). This study was focused on lynx populations in the Northern Rockies. However, in the northeast we have our own population of this threatened species. How does the proposed action by the Forest Service account for any impacts to the Canada lynx specifically in northeastern states? Will the proposed action impact lynx recolonization into previously occupied habitat in northeastern states? Inventoried Roadless Areas provide countless opportunities for passive wildland recreation. In my own “backyard”, the Forest Service recognizes 25,000 acres of IRA’s in the Green Mountain National Forest (Vermont) and 241,000 acres in the White Mountain National Forest (New Hampshire and Maine) that fall under the protection of the Roadless Rule. This is over 20% of the national forest in New England. Many of these areas contain some of the region’s most popular hiking trails and access to iconic mountains and ridgelines. Areas that local hikers hold sacred include Franconia Ridge (Pemigewasset IRA), the Presidential Range (Presidential-Dry River Ext IRA), and the extensive trail network maintained by the Randolph Mountain Club in the northern Presidentials (Great Gulf Ext IRA). How will the proposed action impact trail use in these IRA's? How will potential road building and logging projects in these areas impact their scenic and recreational values? One of the main justifications for the proposed action is the reduction of wildfire risk. However, this proposal would do little to prevent national forests from burning. A recent study found that the density of wildfire ignitions increased as distance from roads decreased. That is, there were more fires started on and near roads than within intact forests. Furthermore, wildfire ignition density was lowest in Wilderness and Roadless Areas (Aplet et al., 2026). How might the proposed action increase the risk of wildfire ignition due to an increase in roads on our national forest lands? Is there any research in northeastern forests showing that more road building and logging would successfully prevent wildfires? For the reasons above, I strongly oppose the proposal to fully or partially rescind the Roadless Rule.