I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. As a lifelong enjoyer of forests and all our nation’s beautiful natural areas, and as someone who has worked in local conservation and restoration for over a dozen years, I care deeply about our national forests and am intimately familiar with their benefits for recreation, the economy, wildlife habitat, and maintaining clean air and water.
I strongly oppose rescinding the 2001 Roadless Rule for many reasons, among them because:
• The Forest Service itself was founded to protect forests and watersheds from logging and development. We have scientific proof that roads fragment the landscape, causing myriad issues that taken all together are even more harmful than clearcuts
• Road building disrupts wildlife, impair watersheds and makes adjacent stands much more vulnerable to fire. In fact, wildfires are four times as likely start in areas with roads. Roads also accelerate the spread of disease and highly damaging invasive pests that kill trees
• Roadless areas protect habitat for over 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests that are hundreds of years old
• The current rule in place now already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore completely unnecessary.
• Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks.
• The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog.
• Here in my local region, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure.
• The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private and Tribal Forestry. USDA’s stated rationale for rescission— supposedly addressing wildfire risk and giving states more decision-making power—rings as hollow and absurd when no funding is allocated to meet those goals.
• Forest revenues today come mostly from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line.
• The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. These comments were over 95% in support of keeping roadless protections.
• Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants.
• Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it.
For all these reasons above, I strongly oppose rescinding the 2001 Roadless Rule. Before the agency moves forward, I ask that the agency:
• Conduct a complete and thorough environmental analysis of roadless areas to assess the impacts of additional road building;
• Guarantee that no watersheds will be negatively affected by rescission;
• Develop and share out a detailed plan for addressing its existing backlog in road maintenance and repairs;
• Commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed.
• Commit also to acting in accordance with the will of the public the agency works with and for. If the public opposes the rescission of the Roadless Rule, it should do the same.
Please protect America’s remaining roadless areas for current and future generations.