Opposes rescissionA0 noneSubstance 6/24Posted October 7, 2026 On Regulations.gov
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Scorecard
Each dimension is scored 0–3; the eight sum to the substance score out of 24.
Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
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EvidenceBacks claims with specific facts, data, or research.
RequestMakes a specific, actionable request of the agency.
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As a professional ecologist, researcher and educator, I am writing to most strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule).
I urge the Forest Service to retain the current Roadless Rule by selecting Alternative 1 and for the Forest Service to reject the proposed nationwide rescission under Alternative 2 as well as any alternative that substantially weakens protections.
I am deeply concerned about the false claim that removing the Roadless Rule is necessary to reduce wildfire risk. On the contrary, 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). It is clear that more roads mean more fires, and my studies of areas opened to roads show that among other things, all of this equipment being brought in spreads non-native plants which have no part in the ecosystem to manage them, which takeover and suffocate the diversity of native flora and create massive amounts of highly flammable ground fuels.
Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of pristine, roadless wildlands.
I am also very concerned about the proposed rescission emphasizing greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning process to maintain ecological, cultural, and public values of roadless areas to an adequate level across the National system.
Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. Returning these decisions to entirely local planning processes should not be treated as a substitute for consistent nationwide protection measurements.
Putting these forests under local control would have immense impact on the land managers' ability to protect undeveloped wildlands put wildlife habitat and connectivity, biodiversity, endangered and threatened species and clean water which emerges from the headwaters in many of these roadless areas at grave risk. We must keep all roadless wildlands under protection at the National level.
As a researcher on biodiversity preservation on National Forest lands, I have an intimate knowledge of roadless areas in the Flathead National Forest as well as the Allegheny National Forest and have conducted biodiversity surveys in both locations as well as in non-roadless areas on both these National Forests. It is profoundly clear from all the studies that the the way lands are managed in non-roadless areas results in a far less biodiverse ecosystem that includes huge numbers and in some areas, monocultures of invasive, shallow rooted flora which create highly flammable ground fuels, decreasing water retention in dry soils, increasing wildfire risk and suffocating the diversity of native flora which support the entire ecosystem of flora, fauna and fungi.
The 2001 Roadless Area Conservation Rule should be kept intact as is with no changes whatsoever. We cannot afford to lose any more of the scant amount of pristine wildlands we have remaining to hold ecosystems intact - for the wellbeing and sustenance of nature and therefore humankind.