I am writing to ask that the USFS does not rescind the 2001 Roadless Rule. Inventoried Roadless Areas (IRAs) protect drinking-water supplies for more than 25 million Americans, provide economic benefits through recreation, and can reduce water-treatment costs by protecting high-quality watersheds. The record does not indicate that rescinding the Roadless Rule would reduce wildfire activity.
IRAs protect more than 130,000 km of streams and rivers and are the primary protection mechanism for more than 100,000 km of rivers. These protections influence drinking-water supplies for at least 25 million Americans (Olden et al., 2026). Inventoried Roadless Areas in and near Ashley National Forest protect headwaters in the Upper Green River Basin, a major tributary of the Colorado River. Because Colorado River water supports communities and agricultural users throughout the basin and is delivered to Southern California, protecting these headwaters has downstream importance far beyond the forest’s boundaries.
Degradation of watersheds leads to degradation of water quality through the loss of forest vegetation, which moderates streamflow and serves as a barrier to water-polluting land uses such as agriculture, development, and logging. Keeping forested areas intact helps keep streams cold, supports aquatic life, and keeps rivers clean, reducing costs to water-treatment facilities and, ultimately, consumers.
IRAs overlap substantially with high-demand hunting and fishing areas and support aquatic and terrestrial biodiversity. They also provide connected habitat, summer and winter range, and travel corridors for wildlife.
In a peer-reviewed study, Sean P. Healey of the Rocky Mountain Research Station found that IRAs burned at rates broadly similar to the rest of the National Forest System. Contrary to the implication that roadless areas prevent fire mitigation, the study found that IRAs contained about 21% of National Forest System tree cover but accounted for 34% of fuel-treatment activities between 2001 and 2019. The study also found significantly fewer human-caused fires in IRAs. Human activity is responsible for a large share of wildfire ignitions nationwide (Healey, 2020).
To prevent severe wildfires throughout the West, it is imperative to sustain resilient ecosystems rather than fragment them with roads. Invasive species such as cheatgrass and other grasses and woody vegetation can outcompete native plants and often contribute to increased fire activity.
Just this year, I have been denied access on existing and open Forest Service roads well over a dozen times because of washouts and downed trees. That is in addition to the trees I was able to cut and move to the side of the road to allow travel, which has happened even more often. Why would we build more roads if we cannot maintain the roads we already have?
A fiscally conservative approach would focus on maintaining the roads we have rather than building new ones. A 2026 technical white paper estimated deferred maintenance for the National Forest road system at more than $9 billion (WildEarth Guardians, 2026). It does not make sense to spend money building new roads—or arguing for the opportunity to build new roads—when the existing road system has such substantial maintenance needs.
Our goal should not be to increase roads. Rather, it should be to maintain the roads we have, prevent the spread of invasive species, protect water quality, and protect wildlife habitat. Roads fragment habitat for both aquatic and terrestrial wildlife.
Every deer, elk, and bear I have been lucky enough to take has been in either a wilderness area or an IRA. Roadless areas generally, and IRAs specifically, are islands of connected habitat, summer and winter range, and travel corridors for wildlife. I have had the opportunity to live near and explore several of these exceptional places. I have shared hunting and fishing experiences with my children in these places. My family is fed and watered by IRAs, and I ask, as a citizen in this great republic: please protect roadless areas.
“The ‘greatest good of the greatest number’ applies to the number within the womb of time, compared to which those now alive form but an insignificant fraction. Our duty to the whole, including the unborn generations, bids us restrain an unprincipled present-day minority from wasting the heritage of these unborn generations.”
— Theodore Roosevelt, A Book-Lover’s Holidays in the Open (1916)