I strongly oppose the USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule. The Roadless Rule has been a cornerstone policy in protecting U.S. wild lands from industrial development, and according to countless peer-reviewed studies, it is a vital component in the protection of numerous species from encroaching habitat degradation as well as the provision of drinking water and recreational activities for local communities. Removing this policy would be devastating for both wildlife and communities that depend on these areas for their essential needs, and, antithetical to what the USDA proposes, this action could increase the risks that the USDA is attempting to prevent.
Inventoried roadless areas (IRAs) are critical to the protection of vulnerable/endangered species and the biological diversity of U.S. wildlife. Many protected areas of wild lands serving as refuges for vulnerable species are bordered by IRAs, which increase the size of these protected areas and provide a vital buffer between protected areas and external stressors like commercial development and other human land use activity (Talty et al., 2020). These areas are of particular importance for species that require large areas free of human disturbance, and many species with conservation concern depend disproportionately on IRAs for their habitat needs, with eighty-six of these species having over 5% of their total suitable habitat in IRAs despite IRAs covering only 2% of the contiguous U.S. (Dietz et al., 2021). Wild protected areas often maintain their typical ecological processes and have fewer local extinctions and are thus more likely to sustain their biodiversity in the future (Talty et al., 2020). IRAs are also critical to maintaining the area of conservation reserves in ecoregions. When considering designated wilderness areas alone, without including IRAs, 40% of ecoregions have greater than 12% of their total area in conservation reserves. However, when including IRAs with designated wilderness, this jumps to 71% of ecoregions that exceed the 12% threshold. Additionally, the size of a conservation reserve positively correlates with biological diversity, so preserving these areas, again, is essential to keeping the biological diversity of U.S. species high and protecting species that may be sensitive to human activity. (DeVelice & Martin, 2001). Ultimately, fragmenting IRAs with roads and construction activity would massively offset the ecological benefits of these areas and endanger the protections of vulnerable species residing in these areas.
In addition to wildlife conservation, roadless areas have a substantial role in decreasing the ignition of wildfires. Rather than being more likely to burn under high-intensity conditions, Inventoried Roadless Areas (IRAs) in all of the 8 contiguous-U.S. Forest Service regions have demonstrated the second-lowest wildfire-ignition density between 1992 to 2024 of 1.97 fires/1000 ha when compared to the wildfire-ignition densities in wilderness areas, “national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas,” and “lands within 50 m of roads,” only surpassed by the wildfire-ignition density in designated wilderness areas. Conversely, the highest wildfire-ignition density of 7.99 fires/1000 ha was seen in lands within 50 m of roads, more than four times the density seen in IRAs (Aplet et al., 2026). Allowing the construction of roads within roadless areas would greatly increase ignition frequency and the risk of wildfires within these regions due to greater opportunity for recreational negligence and arson, and this could subsequently affect nearby communities and be difficult to mitigate.
I urge the USDA to reconsider this proposal and take no action to change or rescind the 2001 Roadless Rule.
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, 22(1). https://doi.org/10.1186/s42408-026-00450-2
DeVelice, R. L., & Martin, J. R. (2001). Assessing the extent to which roadless areas complement the conservation of biological diversity. Ecological Applications, 11(4), 1008–1018. https://doi.org/10.1890/1051-0761(2001)011[1008:atetwr]2.0.co;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), e01943. https://doi.org/10.1016/j.gecco.2021.e01943
Talty, M. J., Mott Lacroix, K., Aplet, G. H., & Belote, R. T. (2020). Conservation value of national forest roadless areas. Conservation Science and Practice, 2(11). https://doi.org/10.1111/csp2.288