FS-2025-0001-611003

Dear Secretary Rollins, I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. For the past 250 years, the cultural belief has been that the earth is an endless resource created for our own use. A belief that the wood, sand, and soil have no soul. That the land stands solely for the benefit of the American people. I’ve grown up in this period of imbalance, when waves of caterpillars strip summer trees to winter branches and ocean currents rise to take back stolen artifacts. It has always been clear to me that our constant movement and development are the root causes of catastrophes that occur all too frequently. Reading through the proposal to rescind the Roadless Rule left me drained and sad. The language wielded in the document was a shameful bastardization of the words used by the front lines trying to save nature. Hidden in the rhetoric of community autonomy and protection, I saw the real motivation for this change. It wasn’t hard to do so when a selection of Trump’s degrading Executive Orders calling for more consumption, more extraction, and more feeding of the American machine stood front and center – the same motivation for reducing protection of inventoried roadless areas. Wildfires have indeed increased in frequency and severity (Davis et al. 2024), and prolific species pose serious risks to ecosystem homeostasis (Langmaier and Lapin 2020). However, we must ask why these changes are occurring, and if developing infrastructure in these protected areas will mitigate or exacerbate risk. We must also remember that the 2001 Roadless Rule does not prevent management or intervention; it is access to funding and resources that does. Many studies over the last two decades have clearly shown that the key to reducing wildfire severity and increasing forest resilience is using prescribed burns (Stephens et al. 2023, Davis et al. 2024). Mechanical trimming improves outcomes, but it is not necessary for a meaningful impact. Building more roads will cost money that could instead go to training and employing forest managers who can perform prescribed burns. In fact, research shows that roads are direct vectors of increased wildfires. Roads bring people, and people ignite 84% of wildfires (Balch et al. 2017). Most wildfires start within 50 m of roads, with inventoried roadless areas and protected wildlands experiencing 3.5 times fewer fire ignitions (Aplet et al. 2026). If anything, the best way to reduce wildfires is to reduce road access and use. Interestingly, the 50 m distance from roads has the highest densities of prolific species (Hansen and Clevenger 2005). Prolific, or invasive, species impact ecosystems by outcompeting diverse native plants and animals, which ultimately decreases biodiversity. When an ecosystem is diverse in its residents, it can respond better to stress, similar to how a body builds up a library of immune responses. Established roads benefit prolific species in several ways. Roads themselves change soil composition and density, while sedimentation, salt use, and chemical pollutants create harsher environments where invasive species thrive. Construction and road use kill plants and animals, reducing ecosystem viability and resilience. Additionally, roadways can unpredictably alter aquatic environments by changing water flow and composition (Trombulak and Frissell 2000). Roads not only alter the landscape, but the passage of cars and the wind corridors they form also extend the distance invasive plant seeds disperse (Hansen and Clevenger 2005, Von Der Lippe and Kowarik 2007). The best way to manage prolific species has not been determined, and many of the ways we choose to do so now are more harmful than good. I also doubt that management would be appropriately funded with or without the Roadless Rule in place. All in all, the arguments made in the proposed change to the rule seem silly to me. The primary goal is clearly resource extraction for private profit. If this were not the case, the Roadless Rule would stand because it is not a sweeping nationwide restriction. It is a long-standing protection of 7.2% of the country's national forests. What will it take for us to leave even small fractions of nature to be left for itself? 600,000 comments from the American people opposing rescinding the rule? Probably not. You won’t be convinced because there’s no check attached to each comment. We know the motive is profit. We know who is pushing for the change. We know what they stand to gain – holding dollars until they die. We know what we stand to lose – areas of peace and prosperity for the balance of the world as we know it. We are moving to lose the world as we know it. Will those dollars be food? Will those dollars be clothes? Will those dollars be friends? Maybe you believe they will; I can promise you they won’t. Please adopt the No Action alternative for the Final Rule.