Comment Analysis · Docket FS-2025-0001

FS-2025-0001-606074

Opposes rescissionPosted October 7, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Wildlife Habitat
    • “Roadless areas are critical habitat”
    • “308 species, or 57%, had suitable habitat within Inventoried Roadless Areas”
    • “Roads also fragment habitat and disrupt ecological connectivity”
    • “prevent animals from moving between feeding, breeding, and seasonal habitats”
  • Water Quality Quantity
    • “Road construction also has consequences for water and soil”
    • “alter drainage, destabilize slopes, and increase erosion and sediment delivery to streams”
    • “degrade aquatic habitat and water quality far downstream”
    • “Protecting forests is also protecting the watersheds they sustain”
  • Forest Management Wildfire
    • “The argument that more roads will necessarily reduce wildfire risk is also not supported by the evidence”
    • “Ignition density generally declined as distance from roads increased”
    • “Expanding roads should not be treated as an automatic wildfire solution”
    • “Protecting roadless areas does not prevent responsible wildfire management”
  • Public Opinion Support
    • “The public has also demonstrated strong support for the Roadless Rule”
    • “75% of Americans supported it”
    • “more than 625,000 public comments were submitted, with approximately 99% opposing repeal”

What it names

Works cited
10.1016/j.gecco.2021.e0194310.1146/annurev.ecolsys.29.1.20710.1186/s42408-026-00450-2Healey 2020Healey 2020

The comment

I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Our national forests are public lands held in trust for all of us. Once intact forests are opened to new roads and development, the ecological damage can extend far beyond the pavement. I urge the Forest Service to protect these landscapes rather than weaken one of the few safeguards that keeps them intact. Roadless areas are critical habitat. Dietz et al. (2021) examined 537 wildlife species of conservation concern and found that 308 species, or 57%, had suitable habitat within Inventoried Roadless Areas. These areas therefore provide meaningful protection for vulnerable wildlife. Roads also fragment habitat and disrupt ecological connectivity. Forman and Alexander (1998) documented road impacts including habitat fragmentation, barriers to wildlife movement, erosion, and altered hydrology. A road is not simply a line through a forest. It creates disturbance and access that can change how wildlife use an entire landscape. Fragmentation can prevent animals from moving between feeding, breeding, and seasonal habitats and can isolate populations that need connected habitat to survive. The argument that more roads will necessarily reduce wildfire risk is also not supported by the evidence. Aplet, Hartger, and Dietz (2026) analyzed more than three decades of national forest wildfire data and found approximately 1.97 fires per 1,000 hectares in Inventoried Roadless Areas, compared with 7.99 fires per 1,000 hectares within 50 meters of roads. Ignition density generally declined as distance from roads increased. Roads can improve firefighter access in some circumstances, but they also increase human activity and opportunities for ignition. Expanding roads should not be treated as an automatic wildfire solution. Road construction also has consequences for water and soil. Roads can compact soil, concentrate runoff, alter drainage, destabilize slopes, and increase erosion and sediment delivery to streams (Forman & Alexander, 1998). These impacts can degrade aquatic habitat and water quality far downstream. Protecting forests is also protecting the watersheds they sustain. Roads can further increase the spread of invasive plants. Healey (2020), using more than 15,000 forest inventory plots, found non-native plants were approximately twice as common within 152 meters of roads than farther away. Once invasive species become established, restoration can be difficult and expensive. I strongly oppose weakening the Roadless Rule because the burden of proof should be on those seeking to disturb intact public lands, not on those asking to preserve them. We already have roads and developed areas where infrastructure can be placed. We cannot recreate an old-growth forest, restore lost wildlife connectivity, or reverse decades of ecological change simply by deciding later that a road was a mistake. Protecting roadless areas does not prevent responsible wildfire management. Targeted actions can be evaluated where there is a demonstrated need without broadly opening protected landscapes to additional roads and development. The public has also demonstrated strong support for the Roadless Rule. A nationally representative 2019 survey found that 75% of Americans supported it, including majorities of Democrats, Independents, Republicans, and rural respondents (Pew Charitable Trusts, 2019). During a previous consideration of repeal, more than 625,000 public comments were submitted, with approximately 99% opposing repeal (Pew Charitable Trusts, 2026). Scientific evidence and public input point in the same direction: intact roadless forests are worth protecting. Public lands are a legacy we inherit and a responsibility we pass forward. I ask the Forest Service to reject the proposed rescission and retain the 2001 Roadless Area Conservation Rule. We should not sacrifice irreplaceable ecosystems for roads that can be built elsewhere. References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology. doi:10.1186/s42408-026-00450-2 Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32, e01943. doi:10.1016/j.gecco.2021.e01943 Forman, R. T. T., & Alexander, L. E. (1998). Roads and their major ecological effects. Annual Review of Ecology and Systematics, 29, 207–231. doi:10.1146/annurev.ecolsys.29.1.207 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. doi:10.1088/1748-9326/aba031 Pew Charitable Trusts. (2019). Americans Support “Roadless Rule” to Protect Remarkable Forests. Pew Charitable Trusts. (2026). U.S. Department of Agriculture Proposes Eliminating the Roadless Rule.

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