I am writing on behalf of Friends of Allegheny Wilderness, a Warren, Pennsylvania-based non-profit organization dedicated to protecting wilderness under the Wilderness Act of 1964 here in the Allegheny National Forest.
We and our hundreds of thousands of supporters strongly oppose rescinding the 2001 Roadless Area Conservation Rule. This landmark directive has helped to protect roadless areas, and adjacent designated wilderness areas, on national forest lands for a quarter-century now.
If anything is to be done with the Roadless Rule, it should be strengthened to eliminate logging and roadbuilding loopholes, and to provide better protection to roadless areas and adjacent designated wilderness areas.
Roads fragment wildlife habitat, dividing contiguous ecosystems and creating harsh 'edge effects' that introduce invasive species and human disturbance. Existing roadless areas preserve large, uninterrupted tracts of high-quality interior forest habitat essential for sensitive, threatened, and endangered native species.
By maintaining unbroken habitat, roadless areas serve as vital migration corridors, allowing wildlife to safely travel, forage, and adapt across broader natural landscapes.
Roads threaten streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and other aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers.
Over long periods, as normal background amounts of soil and rock naturally break down and travel downstream, hydraulic abrasion wears down sharp edges. The particles become smoothed, rounded, and sorted by size over decades and centuries.
By stark contrast, logging roads and other forest roads are built by crushing bedrock and exposing fresh, unweathered parent material. Traffic grinds this rock into fine dust, and storm runoff washes it into nearby streams. Because these particles have not undergone long-term aquatic transport, they are characterized by extremely sharp, angular, jagged edges.
Fish breathe by drawing water across delicate filaments and lamellae in their gills. Rounded natural sediments simply slide off or cause minimal friction. Angular logging road particles act like microscopic shards of glass—scratching the gill tissues, causing lacerations, triggering excessive mucus production, and prompting cellular thickening. This drastically reduces the fish's ability to absorb oxygen and filter out waste.
Beyond the sharp shape, logging roads generate an overwhelming volume of fine sediment. In natural stream systems, rounded gravel creates interstitial spaces where aquatic insects live and fish lay eggs. High-volume logging road runoff fills these gaps with fine, sharp silt, suffocating fish eggs and burying macroinvertebrates.
One of the most glaring falsehoods surrounding efforts to rescind the Roadless Rule is the claim that we need to build more roads into roadless areas in order to prevent forest fires.
In fact, more roads will result in more human-caused fires. Research shows that more than 60 percent of human-caused fires in national forests in the lower forty-eight states are ignited within one-eighth of a mile of the nearest road, and 95 percent are ignited within one-half of mile. You punch roads into a roadless area, you are going to wind up with more fires, not fewer. Roads bring people in their vehicles, and these people inevitably bring fire.
Roadless areas provide for recreation like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities. Large sections of the North Country, Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas.
With more than 380,000 miles of existing roads—a vast network that dwarfs America's entire highway system—the U.S. Forest Service faces a deferred maintenance backlog exceeding $8.6 billion. Rather than cavalierly expanding upon this costly footprint, the focus should be on closing and decommissioning roads wherever possible, in order to restore natural landscapes and ensure fiscal responsibility.
In the Allegheny National Forest, we have about 25,000 roadless acres, including the largest inventoried roadless area on federal public lands in the Commonwealth — the 9,705-acre proposed Tracy Ridge Wilderness Area. We must retain protections brought by the Roadless Rule for all 25,000 roadless acres in the Allegheny National Forest to help protect these last special areas here in what is otherwise the most densely-roaded national forest in the country.
We must continue to grow America's 111 million-acre National Wilderness Preservation System. An important component of doing that is to keep all national forest roadless areas completely intact, so that with time they too may all ultimately be designated as wilderness areas under the Wilderness Act of 1964.
Kirk Johnson, Executive Director
Friends of Allegheny Wilderness