FS-2025-0001-608153

When I was little my favorite children's book was called The Dead Tree by Alvin Tresselt. It is a story about a long lived oak tree that gives life and resources to all the other species as it lives and dies. While it is alive it is a shelter to the birds in its branches, the chipmunks in its trunk, the fox in its roots; it lives over a hundred years, longer than any human lifespan. When it eventually falls to wind and old age it is decomposed by small creatures like termites, who eat it and break it down and as they do the mother skunk can raise her babies in the hollowed out log. When the remains of the tree eventually become part of the soil they provide nutrients that the acorns it dropped on its way down use to grow strong, so that they can take the dead tree's place in the cycle of things. I am a student of environmental science and policy and it is stories like this that fueled my love and wonder for the natural world and my desire to understand and protect it. I will be commenting on the rescission of the roadless rule’s threats to biodiversity, like that seen in the story of The Dead Tree, as well as its needs in regards to wildfire management, timber production and rural job opportunities. The Roadless Rule protects old growth ecosystems throughout the United States and territories. Rescinding it will result in a loss of biodiversity in these places through increased logging, which is explicitly a goal of the rule's rescission in alignment with Executive Order 14225, Immediate Expansion of American Timber Production. Increased deforestation is known to reduce biodiversity of species through loss of habitat and old growth forests are home to some of the highest biodiversity of any terrestrial ecosystem (8,9). With timber production being a goal of the proposed rescission, old growth forests that are already fire resilient will be the target of this logging instead of areas that are prone to wildfire because the lumber in at-risk areas is usually small and not economically valuable for timber production (6). This means that the long-lasting trees in these robust and biodiverse forests will be the first to go, increasing habitat loss and therefore species loss. A main motivator behind executive order 14225 is that importing timber goods exports timber related jobs to other countries instead of adding jobs into our rural communities. However this rescission will put opportunities into new road creation when our Forest Service already has a backlog of $6 billion in road maintenance needs, while being understaffed and underfunded from recent cuts (6,7). Instead of opening up valuable and threatened environments to the possibility of habitat and biodiversity loss we should be focusing on maintaining the roads we already have which provide access to our already established timber operations. Additionally, the rescission claims to support increased flexibility for wildfire risk management options within roadless areas. However we do not need to open up these roadless areas to engage in proper wildfire management and in doing so we will not decrease fire risk. Roadless areas can already be managed to reduce fire risk without adding new roads and there are already exceptions written into the rule that allow fire risk management for “unnaturally intense wildfires”(5). Roads themselves additionally correlate with increased rates of fire ignitions due to increased human activity (3). Human activity increases the rates of fire ignition and although not all of these ignitions cause widespread wildfires, the increased frequency means that the benefits of greater access to prevent wildfire actually increase the potential fires. References: https://www.fs.usda.gov/managing-land/planning/roadless https://www.usda.gov/about-usda/news/press-releases/2026/08/18/usda-acts-remove-roadless-rule-restrictions-exacerbate-rising-wildfire-risk https://link.springer.com/article/10.1186/s42408-026-00450-2 https://research.fs.usda.gov/treesearch/61251 https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa https://www.eenews.net/articles/economic-realities-cut-into-trump-timber-plans/ https://www.pnt.org/roadless-rule-how-you-can-help/ https://www.sciencedirect.com/science/article/pii/S0006320723002276 https://www.sierraclub.org/massachusetts/importance-old-growth-forests https://www.govinfo.gov/content/pkg/DCPD-202500316/pdf/DCPD-202500316.pdf