September 19, 2025
Brad Kinder
Acting Director
Ecosystem Management Coordination
U.S. Department of Agriculture
201 14th Street SW, Mailstop 1108
Washington, DC 20250-1124
Re: Notice of Intent to Rescind the 2001 Roadless Area Conservation Rule; FR Doc # 2025-16581
Dear Mr. Kinder:
Thank you for the opportunity to comment on the Notice of Intent to rescind the 2001 Roadless Area Conservation Rule (66 FR 3244, 36 CFR Subpart B (2001)). We respectfully urge the Forest Service to maintain meaningful and durable conservation safeguards for the nation’s 45 million acres of Inventoried Roadless Areas while also addressing the need for effective management to reduce wildfire risk and restore ecosystem health. We request a collaborative, transparent process to identify potential changes to the 2001 Rule to achieve these goals. We object to a full rescission of the rule. Further, we request a 30-day extension to the original 21-day comment period to enable meaningful, constructive input on this important rulemaking.
AFS is the world’s oldest and largest professional society of fishery and aquatic scientists and managers. The society seeks to improve the conservation and sustainability of fishery resources and aquatic ecosystems by advancing fisheries and aquatic science, promoting the development of fisheries professionals, and advocating for the use of best available science in policy-making.
Roadless areas in our national forests—often referred to as backcountry—supply clean drinking water to Americans, protect downstream communities from flooding, maintain abundant and healthy fish and wildlife populations, serve as habitat for threatened and endangered species, and provide unparalleled outdoor recreation. Roughly 70 percent of roadless areas contain habitat for native fish, underscoring their irreplaceable value.
In the face of more intense fires, earlier flooding, prolonged drought, and increased vulnerability to invasive species, it is critical that we take a landscape-scale approach to conservation. It is imperative to maintain biological diversity and increase habitat to make ecosystems more resilient. A full rescission of the 2001 Roadless Rule would undermine these important tools for fish and wildlife management when we should actively and aggressively work to protect and restore resiliency for the full range of fish and wildlife habitats and also ensure their connectivity to adjacent or downstream habitats on public and private lands.
Roadless areas sustain coldwater fisheries, particularly native trout and salmon populations that are prized by anglers. Timber roads and clearcutting can increase sedimentation, degrade water quality, fragment habitat, and increase high temperature regimes. Sedimentation alone has caused salmon productivity to decline in numerous studied watersheds.
A full rescission of the rule threatens fish, wildlife, and the outdoor recreation of millions of Americans who rely on these lands for hunting, fishing, and other activities. We urge you to conduct a full analysis of the potential social, economic, and environmental programmatic effects resulting from a rescission of the rule, as well as analysis of an additional alternative that would allow for reasonable flexibility for responsible active management to effectively reduce wildfire risk, restore healthy ecosystems, protect communities, and maintain consistent and durable safeguards for intact habitat and backcountry values.
Thank you again for the opportunity to comment.
Sincerely,
Jeff Kopaska
Executive Director
