“wildfire ignition density within 50 meters of roads is roughly four times higher”
“Wilderness and Inventoried Roadless Areas had the lowest ignition densities”
What it names
Works cited
Haddad et al. 2015
The comment
Dear Mr. Schultz,
I'm writing as a wildlife observer to register my opposition to the rescission, with reference to the rule's actual field record rather than its sponsors' framing.
One night on a backpacking trip in a roadless area, I was hanging my bear bag when I heard a rock tumble behind me. I turned to see not one, not two, but an entire pack of gray wolves crossing the steep mountain side near the creek. I watched in awe as they deftly navigated the rocky terrain and edged closer to the ridgeline, their gray and black bodies powerful yet supple. Not long after they disappeared into the mountain's own majesty, they began to howl. Better than magic, this was nature without roads.
Roadless areas preserve some of the best parts of this world. The arguments for rescinding the Roadless Rule are unfounded, and the evidence for keeping it is overwhelming.
Roads increase wildfire risk. A 2026 study of three decades of National Forest System wildfire data found that wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest. Wilderness and Inventoried Roadless Areas had the lowest ignition densities of any land category studied (Aplet et al. 2026).
Roadless lands benefit local economies. Counties with substantial protected federal lands have grown faster in population, employment, and per-capita income than counties without them, with growth concentrated in lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). Wilderness recreation generates an estimated $574 million annually in economic value, while Western wilderness has an estimated passive-use value of roughly $168 per acre (Loomis 2000).
Roads create an enormous financial burden. The Forest Service has an $8.4 billion deferred-maintenance backlog across its existing road network—an obligation the agency has acknowledged it cannot resolve. Expanding roads into currently roadless areas would only compound this burden (USDA Forest Service 2001 EA).
Roads fragment wildlife habitat. Habitat connectivity allows animals to move across landscapes, reach new habitat as conditions change, and maintain the gene flow necessary for healthy populations. Roads disrupt that movement: some species avoid them, others are killed crossing them, and for many species roads function as barriers.
A meta-analysis found that wildlife movement between connected habitat patches was roughly 50% higher than movement between unconnected patches (Gilbert-Norton et al. 2010). Road fragmentation can create smaller, more isolated populations with reduced genetic diversity, diminished resilience, and greater risk of local extinction (Christie & Knowles 2015).
Roads fragment aquatic ecosystems, too. Road-stream crossings create potential passage barriers, usually through culverts. A poorly designed culvert can function like a small dam, preventing fish passage. The cumulative effects of small barriers such as culverts can equal or exceed those of large dams simply because there are so many more of them; some North American watersheds have 24–38 times more culverts than dams. Roadless watersheds preserve continuous headwater habitat for cold-water fish such as bull trout, cutthroat trout, and native brook trout (Lehrter et al. 2024; Sliger et al. 2026).
Roads also eliminate critical forest-interior habitat. A 2024 meta-analysis found that nest success for eastern North American forest birds rises steadily from the forest edge to roughly 250 meters, after which it levels off. Species such as Wood Thrush, Cerulean Warbler, Ovenbird, and Acadian Flycatcher depend on these interior-forest conditions (Akresh et al. 2024). Roads do not merely remove the narrow strip of forest they occupy—they create edge habitat on both sides.
The broader consequences are substantial. Fragmentation reduced biodiversity by 13–75% across studied ecosystems and impaired ecosystem functions including biomass production, nutrient cycling, and carbon storage (Haddad et al. 2015).
The roadless condition is not what makes these lands vulnerable to disturbance. It is what makes them resilient to it.
The Roadless Rule constrains road construction—the infrastructure that enables many documented threats, including fragmentation, sedimentation, invasive species, increased wildfire ignition, and extractive activity (Trombulak & Frissell 2000). It does not prohibit grazing, dispersed recreation, or other non-commercial uses, and it operates alongside existing forest plans rather than replacing them (USDA Forest Service 2001).
Once roads fragment intact forests, the ecological benefits they provide are difficult or impossible to restore.
Let the Roadless Rule stand. Protect the roadless lands that protect and inspire us.
Sincerely,
J. Harris