Stanislaus National Forest
Sierra Sun Times file photo
September 23, 2025 - On Monday, the Coalition to Protect America’s National Parks released the following:
EIS Planned on Possible Repeal of the 2001 Roadless Rule
Brad Kinder
Acting Director, Ecosystem Management Coordination
U.S. Forest Service
201 14th Street SW
Mailstop 1108
Washington, DC 20250
September 19, 2025
Re: Notice of Intent to Prepare an Environmental Impact Statement on Potential Rescission of the 2001 Roadless Area Conservation Rule, Docket No. FS-2025-0001
Dear Acting Director Kinder:
On behalf of the National Parks Conservation Association (NPCA) and the Coalition to Protect America’s National Parks1we write to express our strong opposition to any proposal that rescinds or weakens the U.S. Forest Service’s (USFS) Roadless Area Conservation Rule (Roadless Rule) — a widely supported management tool that has maintained the integrity of key ecosystems while allowing timber management to prevent wildfire for nearly a quarter century. Rescinding the Roadless Rule would literally pave the path towards increased oil and gas leasing, industrial logging, and other harmful development on public lands that provide clean water, wildlife habitat and protect the connected ecosystems of nearby national parks. All of these impacts need to be carefully and fully assessed in an environmental impact statement and should guide USFS to keep the rule in place.
Since 1919, National Parks Conservation Association (NPCA) has been the leading voice of the American people in protecting and enhancing our National Park System. NPCA along with our more than 1.6 million members and supporters works to conserve national parks and the broader landscapes upon which parks rely for future generations. From the Appalachian Trail to Yosemite, the health of many of America’s national park sites is directly tied to the health of the ecosystems that surround them, including intact national forests.
Roadless Rule Overview
The Need for a National Roadless Policy
Established in 2001, the Roadless Rule was designed and implemented to provide lasting protection for the last remnants of vast, substantially undisturbed, yet unprotected, largely roadless landscapes within the National Forest System for their unique ecological, social, and economic values. The Roadless Rule was created to mitigate the fragmentation of national forest habitat, stem the almost $8 billion USFS road maintenance backlog, and balance the multiple uses of the USFS lands under the agency’s multiple use mandate. For 24 years, the Roadless Rule has succeeded in doing so — conserving roughly 58.5 million acres of Inventoried Roadless Areas (IRAs) from most new road construction and commercial timber harvest, with limited exceptions.
The Roadless Rule came in response to several findings. First, the USFS found local land management planning efforts were failing to recognize the regional and national cumulative impacts of road construction beyond the individual forest planning area. Second, the USFS identified that over 50-percent of its lands already provided the full spectrum of management opportunities, including extractive and development use. Third, unfettered road development and timber authorizations within IRAs were accumulating at an unsustainable rate, creating a cumulative net loss to the overall quality and quantity of IRAs and the values they provide including watershed health, fish and wildlife habitat, air quality, recreation experience, fire resilience, and more.
The Forest Service road system consists of over 371,000 miles of roads,2 enough mileage to circle the earth at the equator more than 14 times. The USFS is responsible for the management and maintenance of 265,000 of these road miles.3
During the development of the Roadless Rule, the USFS found the majority of forest-level IRA management prescriptions permitted additional road building. This dynamic existed despite deep budget constraints limiting the agency’s ability to effectively manage the USFS road system. Road construction and timber harvest within IRAs were found to come with heightened development difficulties and costs, lower timber suitability, and a greater likelihood of significant environmental impact. The Roadless Rule therefore provided significant cost saving opportunities for the agency, conserved important fish and wildlife habitat, and secured crucial ecosystem services for neighboring communities dependent on watershed health.
The Roadless Rule created a national network of IRAs and instituted management prescriptions specifically for road construction and timber harvest – the two activities deemed to have the greatest likelihood of degrading roadless characteristics. The Roadless Rule largely retained IRA management and their allowed uses within the jurisdiction of local forest planners. Outside of road construction and commercial timber harvest, the management of activities within roadless areas was left to the supervisors and district rangers, this includes things like motorized recreation, fuels reduction and fire mitigation, and watershed management.
Though IRAs represent just 2-percent of the nation’s land base, these lands are crucial in providing public benefits like clean water for communities and agriculture, vital aquatic habitat, air quality, viewsheds and scenic quality, immense opportunity for outdoor recreation, large undisturbed and connected landscapes to support biodiversity, climate change mitigators, increased wildfire resilience, and cultural resources preservation including archeological and Tribal cultural sites. In contrast, the development of roaded forest land is shown to cause: disruption of natural watershed processes, increased likelihood of geologic hazards including erosion, landslides and debris flows, slope failure, and increased sedimentation in waterways, increased likelihood of human-caused fire, habitat fragmentation and connectivity impairment, increased invasive species, and endangerment to watershed health.
Recission of the Roadless Rule would not only introduce the threats related to roadways to IRAs, but these threats would be compounded by the impacts from increased industrial development. The 2025 Notice of Intent (NOI) indicates the need for road development in IRAs to support increased extractive and development activities, including timber harvest and mineral and energy development presenting an additional layer of negative effects from road construction within IRAs both for the USFS and downstream land managers, owners, and users.
The negative effects of rescinding the Roadless Rule for USFS lands are immense and extend far beyond USFS lands. The loss of the Roadless Rule would dramatically impair public lands managed by the National Park Service (NPS). Nearly one third of IRAs lie within 30 miles of a national park system unit4 making IRA management decisions profoundly consequential to the values and resources protected within and by the national parks. IRAs shield national parks from incompatible development, sustain and connect national park wildlife, preserve park viewsheds, air, and water quality seen and experienced 4 from within the parks, and protect access to park-adjacent public land recreation opportunities. Dismantling these protections could invite industrial development to the doorstep of national parks, fragment habitat connectivity, and permanently diminish the ecological integrity of our public lands.
Public Engagement
Development of the 2001 Roadless Rule involved extensive public outreach and engagement with over 1.6 million comments submitted, of which 95-percent supported conserving the last remaining intact portions of our nation’s forests. Support for public land protection remains strong two decades later. A 2019 poll by the Pew Charitable Trust found that three-fourths of the public supports the Roadless Rule.5 In a 2023 NPCA poll conducted by Harris Poll, 87 percent of Americans expressed support for restoring or preserving wildlife habitat connectivity and improving migration corridors on lands and waters within and beyond park borders. In a 2023 NPCA poll conducted by Harris Poll, 87 percent of Americans expressed support for restoring or preserving wildlife habitat connectivity and improving migration corridors on lands and waters within and beyond park borders.6
Development of the 2001 Roadless Rule included a 60-day comment period on the Notice of Intent with nearly 200 listening sessions drawing the attention of more than 16,000 participants and 500,000 comments. Identifying relevant public issues and concerns warrants a greater level of outreach and opportunity to provide meaningful public comment than the 21-day comment period offered on the 2025 NOI. We encourage the USFS to offer a much lengthier comment period once the Draft Proposed Rule and Draft Environmental Impact Statement (DEIS) are released publicly, as was done during the development of the 2001 Roadless Rule. Meaningful public engagement at the local and national level is essential for the USFS to understand public sentiment of the Roadless Rule and the public’s willingness to remove this highly successful policy. Given the 2025 NOI listed local land management discretion as a core basis for the proposal to rescind the Roadless Rule, the USFS must engage local communities and those who use these public lands. USFS should include public meetings at the local, regional, and national levels as a component of the DEIS comment period.
Roadless Rule is Multiple Use in Action and Driven by Local Forest Directives
The 1960 Multiple-Use and Sustained-Yield Act (MUSYA) directs USFS to manage the national forests for a variety of uses and purposes to best meet the needs of the public and with flexibility to respond to changing needs and conditions. Specifically, the MUSYA directs the USFS to manage the forests for “outdoor recreation, range, timber, watershed, and wildlife and fish purposes” and clarifies national forest management of resources, values, and uses should occur “without impairment of the productivity of the land” and “not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output.” Of the roughly 193 million acres of USFS lands roughly 50 percent are managed as general management areas where uses like timber production and road building can occur under the relevant forest plan.values, and uses should occur “without impairment of the productivity of the land” and “not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output.” Of the roughly 193 million acres of USFS lands roughly 50 percent are managed as general management areas where uses like timber production and road building can occur under the relevant forest plan.7
Since 1964, Congress has designated roughly 35 million acres of Wilderness pursuant to the Wilderness Act where land use is highly restricted. The remaining 58.5 million acres of USFS lands are designated as IRAs. These broad management categories, created by both Congress and the agency, demonstrate the key role of the Roadless Rule within the multiple use framework.
The rescission of the Roadless Rule is proposed partially to provide supposedly greater management discretion of IRAs to the forest plan level, claiming the Roadless Rule is a “one-size fits-all” approach. However, the Roadless Rule provides lasting protection for IRAs in the context of multiple-use management through a combination of national direction and local discretion.8
The national policy limits timber harvest and road construction but does not require local land managers to achieve any management results. The local planning process supports integration of local values to determine the remaining multiple-use management prescriptions, uses, and protections for IRAs including motorized, mechanized, and quiet-use recreation, range, and watershed, and wildlife and fish health. The Roadless Rule also offers local regulatory flexibility for active and passive forest management to increase the resilience of forests within the wildland urban interface to wildfire, management of wildlife habitat for Threatened and Endangered Species, and for providing access to areas requiring action under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Notably, IRAs do not preclude mineral development on valid mining claims, nor do they prevent leasing these lands for oil and gas development.
Roadless Rule is Fiscally Responsible
Responses to growing budgetary concerns over management constraints and costs of the rapidly growing National Forest Road system were a major driver for the Roadless Rule. Road construction and management is expensive and building more roads in roadless areas without sufficient agency funding to maintain its existing system was, and remains, fiscally irresponsible. During the establishment of the Roadless Rule, the USFS documented a growing $8.4 billion maintenance and reconstruction backlog, noting the agency receive only 20-percent of the annual funding required to maintain the agency’s vast 380,000-mile road system.9
The USFS budget has not changed dramatically since adoption of the Roadless Rule, with the agency identifying an agency wide maintenance backlog of $8.6 billion in FY23.10 Coupled with the current wholesale staffing loses, the proposed closure of USFS Regional Offices, and the proposed cuts to the USFS budget, the USFS faces struggles to manage the current Forest Service road system, let alone the construction and maintenance of new roads in IRAs.
The effects of rescinding the Roadless Rule would be fiscally irresponsible, environmentally dangerous, and negatively impact neighboring communities and adjacent public lands managed by the NPS. The DEIS must include updated information on the status of the USFS road system including current number of road miles, new road construction, and decommissioning of miles since 2001, agency spending on the road system since 2001, and current deferred maintenance levels. USFS must also analyze what the upfront and maintenance costs of new roads could be if the Roadless Rule is rescinded.
Impact of Roadless Rule Rescission for National Park Landscapes
America’s national park system cannot be managed in isolation. The management of the lands and resources that lay within broader national park landscapes directly impacts our national parks’ lands and resources. Under the National Environmental Policy Act (NEPA), federal agencies must examine the “reasonably foreseeable environmental effects of the proposed agency action,” consider a “reasonable range of alternatives” including a no-action alternative, evaluate any unavoidable adverse environmental effects, and identify “irreversible and irretrievable commitments of Federal resources” that would result from the project.11 With nearly one third of IRAs within 30 miles of a national park system unit12 the USFS must fully analyze the impact the rescission of the Roadless Rule could have on the lands and resources of the national park system.
The following outlines the areas the USFS must fully evaluate in the draft EIS and proposed rule with an eye to the impacts on nearby national park sites.
Under the revised USDA NEPA regulations, it states that “In accordance with NEPA section 107(a)(3), 42 U.S.C. 4336a(a)(3), the lead agency may, with respect to a proposal, designate any Federal, State, Tribal, or local agency that has jurisdiction by law or special expertise with respect to any environmental impact involved in a proposal to serve as a cooperating agency”.13 Special expertise is defined to mean “statutory responsibility, agency mission, or related program experience”14 The USFS must invite the National Park Service to serve as a cooperating agency due to the special expertise the National Park Service holds in relation to the impact the rescission of the Roadless Rule could have on the ability to uphold its mission and statutory mandate to protect national parks from impairment.
Roadless Areas Integral to National Park Landscapes
Managed under a dual mandate of protecting against impairment and ensuring visitor enjoyment, the national park system is world renowned for its expansive natural resource conservation. However, national parks are not islands of conservation; their health is reliant on the surrounding landscapes. There are 76 national park sites across the country that share a management boundary with USFS managed lands. To conserve park resources, including wildlife and water resources, clean air, and visitor and recreation experiences, land management agencies must plan and manage at a landscape scale through coordination and collaboration. Working within the multiple use framework to manage adjacent public lands to establish large, disturbance-resilient habitat blocks is essential to the long-term conservation of park resources and our ability to leave them unimpaired for future generations. IRAs play a crucial role in securing large, disturbance-resilient habitat blocks, as 74 percent of all IRA acreage, across the lower 48, is physically connected to another protected area.https://doi.org/10.1111/csp2.288." role="button" aria-pressed="false" aria-describedby="mfn-content-00000000000008070000000000000000_48440-15" style="box-sizing: border-box; background-color: transparent; text-decoration: none; transition: 0.5s; color: blue;">15
Development permitted beyond park boundaries can have direct, indirect, and cumulative impacts on national parks and park resources. Commercial logging, oil and gas development, and road building and construction can negatively impair park viewsheds, water and air quality, watershed functionality, cultural resources, recreation experiences, and fragment wildlife habitat and movement corridors. When these resources are impaired, it can negatively impact the park experience, drive down visitation, and negatively impact gateway community economies. Rescinding the Roadless Rule would open important park adjacent habitat to road building and extractive industries, thus impairing national park resources and experiences.
National parks provide a protected core of some of our nation’s most iconic landscapes from the Greater Yellowstone, the Smoky Mountains, or North Cascades. IRAs are a key land designation that furthers the conservation of these landscapes with nearly one third of IRAs within 30 miles of a national park system unit. The attached maps illustrate two examples of the interconnectedness of USFS and NPS lands.16 In the Greater Yellowstone Ecosystem, the surrounding IRAs enlarge Yellowstone’s protected core by a full 29 percent. Meaning the IRA designation helps support the wildlife movement, expanded recreation opportunities, wildlife fire resilience, and watershed health of our nation’s first national park by 29 percent. In the North Cascades Ecosystem anchored by North Cascades National Park, the surrounding IRAs expand the protected core by 31 percent. The same holds true with IRAs increasing the protected core by 12 percent in the South Sierra landscape with Yosemite National Park and 32 percent for the Crown of the Continent with Glacier National Park.17
The USFS must evaluate how rescinding the Roadless Rule could effect the 76 park sites that share a boundary with USFS land and national park sites that lay within 30 miles of an IRA. The USFS must also determine how the rescission could impact NPS’s ability to meet its statutory obligations under the Organic Act and individual park enabling acts.
National Park Air Quality
Recognizing the special importance of national parks and wilderness areas to America, Congress afforded 156 of these places a higher air quality protection status – Class I designation – when it created the Clean Air Act (CAA) in 1970 and amended it in 1977. The CAA establishes a statutory obligation and “…declares as a national goal the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory class I Federal areas which impairment results from manmade air pollution”.18 Class I areas include 48 national parks reaching from Great Smoky Mountains in Tennessee and North Carolina, to Yellowstone in Wyoming to Mount Rainier in Washington. The USFS manages over half of the Class I protected areas and must engage in state and federal planning processes to ensure progress towards the national goal of natural visibility in Class I areas. In rescinding the Roadless Rule, the USFS must ensure that doing so will not increase manmade air pollution problems that would otherwise harm Class I protected areas.
Despite these protections, air pollution remains one of the most serious threats to national parks. Dirty air can ruin scenic landscapes and it also damages plants, harms fish and other wildlife, and can affect the health of visitors and park staff. National park air quality is directly affected by pollution sources both nearby and far away including vehicles, industrial development, coal-fired power plants, oil and gas development, and agricultural sources. A 2024 NPCA report, Polluted Parks: How Air Pollution and Climate Change Continue to Harm America’s National Parks found that 97 percent of national parks are still experiencing air quality conditions with significant or unsatisfactory levels of concern and roughly half of national parks are at high risk from at least one high-impact vulnerability factor from climate change.19
Moreover, NPCA’s August 2025 report Driving Dirty Air: How U.S. Vehicle Pollution Harms National Parks found that over 60 percent of our national parks are located in counties with high levels of vehicle emissions that contribute to air quality issues in those parks.20 NPCA identified 12 urban areas around the country that are causing problematic air pollution “hot spots” that disproportionately diminish air quality in national parks. And nationwide, heavy-duty vehicles (including construction vehicles and logging equipment) already account for 41 percent of total nitrogen oxide (NOx) emissions and across the 12 regions analyzed in the study, heavy-duty vehicles are responsible for an average of 60 percent of regional NOx emissions. The outsize contribution of NOx pollution in these 12 regions versus nationally is particularly striking and underscore just how much large engines drive dirty air, given that heavy-duty vehicles make up a much smaller share of the total vehicle numbers and are far less common on the road compared to light duty vehicles. These disproportionate heavy-duty vehicles emissions are largely due to greater fuel consumption and engine size and underscore just how problematic increased heavy duty vehicle traffic would be in areas that are currently protected by the Roadless Rule.
Rescinding the Roadless Rule could worsen air quality in and around national parks and other Class I protected areas by increasing activities using heavy duty vehicles, which introduce localized air pollution. Existing restrictions on timber harvests and road construction in IRAs protects the air quality both within and beyond the IRAs, while the prohibition of road construction and reconstruction ensures dust and vehicle emissions do not degrade these landscapes. The Roadless Rule therefore most likely positively contributes to regional air quality for USFS lands within and beyond IRA boundaries as well as neighboring public lands managed by fellow land management agencies, including the NPS.
Theodore Roosevelt National Park already has unsatisfactory levels of concern for the air quality conditions of visibility, unhealthy air and harm to nature. Visitors to Theodore Roosevelt experience visible air pollution that limits visibility and detracts from their experience. The USFS lands surrounding the park contain numerous IRAs. Rescinding the Roadless Rule could open these lands up to activities that could compound the degraded air quality issues this park is already experiencing. This is one example of a national park that is already experiencing air pollution that could see an increase if the Roadless Rule is rescinded.
The USFS must evaluate how rescinding the Roadless Rule will affect air quality, visibility and ecosystem health from air and climate pollution in federally protected Class I areas. The USFS must specifically analyze the potential increases in each type of emission source and consider the impacts it will have on human and ecosystem health as well as the tourism industry.
National Park Watersheds and Water Quality
A hallmark principle in the establishment of the national forest and grassland system was to “secure favorable conditions of water flows. ” The Roadless Rule provides meaningful contribution to this directive by protecting watershed health and overall water quality from the harmful impacts of timber harvest and road building, mainly erosion, sedimentation, and disruption of water flows. Though IRAs comprise just 2-percent of the United States land base, IRAs are found within a third of the nation’s major watersheds.21
Because IRAs minimize ground disturbance, they are far more capable of filtering water and reducing pressures on rivers and streams and delivering clean water to downstream communities and buffering against destructive flooding, debris slides and erosion, and sedimentation that impacts flows. This makes IRAs important to the protection of watershed health, water quality, and the viability of fish and wildlife populations in an era of more extreme rain-on-snow and dust-on-snow events.
In 2011, the USFS did the first nationwide assessment of National Forest Watersheds. The Wilderness Society analyzed the results of the watershed health framework for IRAs and found most watersheds within IRAs were considered “properly functioning” while the inverse was true for other USFS lands not designated as IRAs or Wilderness.https://www.wilderness.org/sites/default/files/media/file/Report- WatershedHealthinWildernessEtc_2012.pdf" role="button" aria-pressed="false" aria-describedby="mfn-content-00000000000008070000000000000000_48440-22" style="box-sizing: border-box; background-color: transparent; text-decoration: none; transition: 0.5s; color: blue;">22 Based on the USFS’s own findings, watershed conditions tend to be better off in areas protected from road construction and development. The knowledge and information retained by the USFS makes it abundantly clear: the Roadless Rule is good watershed health and water quality policy.
Rescinding the Roadless Rule could result in greater levels of road construction and timber harvest in IRAs leading to increased levels of sediment producing activities, such a mineral and energy development, upstream of drinking water intakes and streams and rivers upstream of national park sites.
Many communities rely on water that originates in national parks and surrounding IRAs. Billings, MT, the state’s largest city, relies on the Yellowstone River for its municipal water supply. The Yellowstone River originates high in Yellowstone National Park. The river, and its many tributaries flow along multiple IRAs before reaching Billings. The USFS must evaluate how rescinding the Roadless Rule, and the subsequent increase in timber harvest and road building, could impact watershed health. This must involve evaluating increases in runoff, erosion, sedimentation, and disruption of water flows.
Outdoor Recreation and National Park Visitation
IRAs provide a unique recreational setting away from highly developed areas, without the typical blanket restriction on vehicle usage as is the case with Wilderness designation. Analysis by Trout Unlimited found that across western states there are over 9,000 miles of trails open to off-highway vehicles in IRAs.https://storymaps.arcgis.com/stories/4d9978ecdfb246e4a53b8a5681b631cb Accessed 16 September 2025." role="button" aria-pressed="false" aria-describedby="mfn-content-00000000000008070000000000000000_48440-23" style="box-sizing: border-box; background-color: transparent; text-decoration: none; transition: 0.5s; color: blue;">23 Quiet use, mechanized, motorized, and hunting and fishing are all permitted within IRAs at the discretion of local forest managers. IRAs generally provide recreation opportunities in the Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive Motorized classes of the Recreation Opportunity Spectrum (ROS), which offer diverse and unparallel backcountry recreation opportunities. In making such allocations, USFS land managers seek to balance recreation demands alongside other key values preserved within IRAs including viewsheds, watershed health and water quality, wildlife and biodiversity, and cultural resources and sacred sites.
National parks, local communities, and regional economies benefit from the presence of IRAs as they enhance economic development conditions and the recreation experience within and beyond park boundaries. IRAs provide visitors with a wider range of opportunities, including uses like motorized and mechanized backcountry travel, hunting, and fishing that may not be permitted within the park. For national park gateway communities who rely heavily on tourism and visitation, neighboring public lands offering additional recreation opportunities outside the park is yet another economic driver. The USFS must evaluate how rescinding the Roadless Rule could directly and indirectly impact National Park gateway communities reliant on tourism and recreation and dispersed recreation.
Increasing the ability of USFS and NPS to address the impacts of growing recreation pressures and increase the resiliency of these public lands to these pressures has long required agencies to participate in cross-jurisdictional, landscape-level planning and adaptive management efforts with local and state governments, Tribal Nations, and other federal entities. To the detriment of NPS and USFS lands, the effects of rescinding the Roadless Rule worsens this rapidly growing problem by decreasing certainty for recreation planners and further diminishes the USFS’s ability to provide sustained yield of the various renewable resources without impairment of the productivity of the land.
Cultural Resources in National Park Landscapes
The 2001 Final Rule for the Roadless Rule identifies “traditional cultural properties and sacred sites” as one of the features that are often present in and characterize inventoried roadless areas”. The Final Rule goes on to note that “Traditional cultural properties and sacred sites may be eligible for protection under the National Historic Preservation Act. However, many of them have not yet been inventoried, especially those that occur in inventoried roadless areas.”
Section 106 of the National Historic Preservation Act (NHPA) requires federal agencies to “take into account” the effects any federal undertaking, such as the rescission here, will have on “any historic property” around it.24 In doing so, an agency must make a “reasonable and good faith effort to carry out appropriate identification” and “identify issues relating to the undertaking’s potential effects on historic properties.”25 Similarly, NEPA requires federal agencies undertaking major federal projects to analyze the impacts that the project may have on “important historic [and] cultural . . . aspects of our national heritage.”26
IRAs are important to the preservation of cultural resources, sacred sites, and Traditional Cultural Properties. These resources often extend across large swaths of land and are often protected by nearby national park sites. These areas and resources require management actions necessary across land management boundaries to preserve the full story of these cultural landscapes. In addition to Traditional Cultural Properties and sacred sites, IRAs also preserve additional social, cultural, and historic characteristics including ceremonial sites, places for local gatherings, areas utilized for non-timber forest products, and hunting and fishing opportunities.
Saguaro National Park in southern Arizona conserves archeological sites that span more than 8,000 years of prehistoric and historic-period occupation. The Rincon Mountain District of the park is adjacent to the Coronado National Forest and multiple IRAs. These IRAs including the Upper Rincon IRA have important cultural and sacred sites. Examining Saguaro National Park and the park adjacent IRAs provides clear evidence of cultural resource connection between parks and IRAs.
Pursuant to Section 106 of the NHPA27, the USFS must identify all historical properties that might be impacted by the potential rescission, including those of religious and cultural importance to Tribes, and analyze the potential impacts that roads and development could have on these historical and/or sacred places. Specifically, 36 CFR § 800.2(c)(2)(ii) requires consultation with any Indian tribe that attaches religious and cultural significance to historic properties potentially affected by an undertaking, regardless of the property’s location. Executive Order 13175 further affirms the federal government’s obligation to engage in consultation that respects Tribal sovereignty and ensures Tribal perspectives are integrated throughout the planning and decision-making process.
The USFS must complete inventories of designated IRAs for these resources and values of cultural significance in coordination with the NPS and in formal government-to-government consultation with affected Tribal Nations. Additionally, the USFS must assess the potential adverse effects that road construction and other forms of development may have on historic and sacred sites. This process should be conducted in accordance with the NHPA and NEPA.
National Park Viewsheds and Soundscapes
Scenic vistas and expansive views are a hallmark of the national park experience. Surveys of park visitors show a consistently high value placed on viewshed preservation.28 Along with conserved viewsheds of undeveloped landscapes comes the preservation of natural soundscapes and dark night skies – two additional components seen as integral to the national park experience. NPS manages viewsheds at the park-level where neighboring land-uses like energy development and other land uses can negatively impair views seen from within the parks. The NPS preserves these areas by identifying visible areas important to the visitor experience and through the agency’s Visual Resource Program, which guides local park managers in stewarding these viewsheds, while assisting in the advocacy of viewshed protection from neighboring land use developments. In managing park viewsheds it is essential to evaluate the entire landscape seen beyond the park as visitors cannot see park boundaries.
The Roadless Rule references two desirable elements of scenic quality: landscape character and scenic integrity. Landscape character represents geological, biologic, and cultural features providing landscapes with an identity and sense of place, while scenic integrity represents the degree to which these features deviate from the landscape character. IRAs tend to have higher levels of scenic integrity by offering natural-appearing landscapes. Bryce Canyon National Park provides outstanding evidence of viewshed and scenic integrity connection between parks and IRAs. Rescinding the Roadless Rule directly threatens this experience, and area soundscape as a side effect. The USFS must evaluate how rescinding the Roadless Rule could impact NPS viewshed and soundscapes.
Reference Landscapes
The Roadless Rule provides outstanding examples of reference landscapes – a collection of knowledge and studies on the effects of management activities over long periods of time on large landscapes. As noted, in many instances IRAs connect to areas managed by the NPS making the management decisions within IRAs and neighboring USFS lands essential to the ability of the NPS to achieve its mission. We encourage the USFS to engage the NPS in the development of the proposal to rescind the Roadless Rule to enumerate the research completed to date in these reference IRA-NPS landscapes since the establishment of the Roadless Rule in 2001, to demonstrate the knowledge gained from studying these areas and their ability to positively impact the missions of both agencies. Has the USFS engaged with NPS since the adoption of the Roadless Rule to collaboratively study the value of IRAs as reference landscapes for national park landscape conservation? Has the USFS studied and measured key values of ecosystem health in IRAs and compared them to other USFS general management areas with road construction and timber harvest? How do greater levels of ecosystem health provide increased landscape and resource resilience, productivity, and renewal?
The USFS must address the effects of removing national protections for IRAs as reference landscapes for long-term resource management for resilience, productivity, and renewal, specifically in those areas where IRAs abut or are connected to national park sites through additional protected areas.
Impacts to National Park Biodiversity
As habitat loss, degradation, and fragmentation rises on developed lands, IRAs remain critically important to countering the loss of biodiversity and retaining strongholds for terrestrial and aquatic species diversity. IRAs support proven methods for retaining biodiversity at the landscape and regional scale including minimizing habitat fragmentation, conserving large habitat blocks close together, maintaining habitat corridors between habitat blocks, and securing habitat for species across more of their range. The scientific community has long recognized landscape intactness as one of the most important and reliable indicators of ecosystem health.http://www.jstor.org/stable/2385928." role="button" aria-pressed="false" aria-describedby="mfn-content-00000000000008070000000000000000_48440-29" style="box-sizing: border-box; background-color: transparent; text-decoration: none; transition: 0.5s; color: blue;">29
During the adoption of the Roadless Rule, the USFS cited multiple research studies listing habitat loss and degradation as the most significant threat to biodiversity loss in the United States.30 IRAs, alone and in combination with other protected areas like national parks, serve as strongholds for biodiversity as these areas are not exposed to habitat degradation and loss at the same rate as developed landscapes. IRAs also directly support aquatic habitat by eliminating the disturbances caused by roads and their associated activities. With biodiversity strongholds comes greater landscape and ecosystem resilience and the conservation of air, land, and water quality and the provision of both game and non-game species making the Roadless Rule good forest resiliency and biodiversity policy.
The NPS plays an integral role in providing strongholds for biodiversity, creating a clear connection between the stewardship of these strongholds across land management boundaries. Diversity of plant and animal communities is an integral component for both the NPS and the USFS and protecting and maintaining biodiversity supports the directives of the NPS to conserve these values both for today and tomorrow’s generation of park visitors. The USFS must evaluate the impact the rescission of the Roadless Rule could have on the biodiversity value of not only the directly impacted USFS lands, but also the broader ecosystem.
Habitat for Imperiled Species
Lands managed by the USFS play an important role in the recovery and conservation of threatened and endangered species as well as species the USFS has identified as species of conservation concern. Habitat loss has been implicated in the decline of approximately 85 percent of federally listed threatened and endangered species.31 IRAs play an outsized role in preventing habitat loss and conserving habitats such as coldwater fisheries. Despite making up just 2 percent of the lower 48’s land area, IRAs provide habitat for over half (57 percent) of all vulnerable species.32 These are species that are often sensitive to habitat disturbance, depend on large intact landscapes, or are endemic to a limited range.
On average each IRA contains habitat for 10 species of conservation concern — from lynx to native trout.33 Many of these habitat types, including mid to low elevation habitat such as ponderosa pine forests are absent or underrepresented in other federal lands.34 An analysis of land in Montana, Wyoming, and Idaho found that “roadless areas, when added to existing federal-protected areas in the northern Rockies, increase the representation of virtually all land-cover types, some by more than 100 percent, and increase the protection of relatively undisturbed lower elevation lands, which are exceedingly rare in the northern Rockies. In fact, roadless areas protect more rare and declining land-cover types, such as aspen, whitebark pine, sagebrush and grassland communities, than existing protected areas.”35
The USFS must complete a full inventory of all the federally listed threatened and endangered species and USFS species of conservation concern in the IRAs protected under the Roadless Rule. This analysis should be done in consultation with the U.S Fish and Wildlife Service.
National parks conserve habitat for more than 600 threatened and endangered species protected by the Endangered Species Act (ESA). Many of the species that national parks are helping to conserve and recover also rely on habitat beyond park borders. For example, Tumacacori National Historic Site in Arizona is home to threatened and endangered species such as Yellow-billed Cuckoo or Willow Flycatcher. The nearby Tumacácori IRA provides critical habitat for up to 62 imperiled species. In the southeast Great Smoky Mountain National Park’s role in the conservation of threatened and endangered species such as the Indiana Bat or Carolina Northern Flying Squirrel relies on the management direction of the surrounding national forest lands including multiple IRAs. The ability of the NPS to play a role in the conservation of imperiled species is often directly tied to the managed of adjacent habitat.36 The USFS must analyze how the rescission of the Roadless Rule could impact the recovery of threatened and endangered species across the broader landscapes that contain IRAs. This evaluation should be done with consultation from the NPS and the U.S Fish and Wildlife Service.
Wildlife Movement and Habitat Connectivity
From big game migration across the west, to seasonal movement of amphibians in the east, species need to be able to move across habitat to survive. Conserving wildlife corridors and movement areas is more important than ever, especially as habitat fragmentation drives biodiversity loss. Wildlife populations that depend on national parks require secure ways to move to habitat beyond park boundaries to thrive. Whether it’s migrating to seasonal habitats or simply moving beyond boundaries in search of food or mates, species need the ability to move across broader park landscapes to maintain healthy park wildlife populations. IRAs play a critical role in increasing connectivity for wildlife across landscapes. On average IRAs are located at higher elevations across the Sierra Nevada, Cascade, Rocky, and Appalachian Mountains then the surrounding landscape.37 These higher elevation undisturbed habitats will play an even more important role in species ability to move across the landscape in a changing climate.
Considerable efforts have been taken over the last decade to conserve the habitat and migration routes of big game such as elk, mule deer, and pronghorn antelope including state efforts to identify corridors and federal initiatives such as Secretarial Order 3362, “Improving Habitat Quality in Western Big Game Winter Range and Migration Corridors”. Many of these species migrate through IRAs or have important seasonal habitat secured in IRAs. This includes pronghorn antelope, elk and mule deer that travel from Grand Teton National Park, through numerous IRAs to the southeast or mule deer that move through the IRAs of the national forests around John Day Fossil Beds National Monument in Oregon.
The USFS must, in consultation with the U.S Fish and Wildlife Service, evaluate how many species could become threatened or endangered due to the loss of connectivity from a rescission of the Roadless Rule and how many species were not listed under the ESA due, in part to, the connectivity created by the IRAs. USFS must consider the impacts this rescission could have on each species and create a timeline for their reassessment.
Climate Change, Carbon Storage, and Mature and Old Growth Forests
The Roadless Rule is a natural asset in our fight against the number one threat facing the national parks and public lands: climate change. IRAs conserve some of the few remaining vestiges of our nation’s mature and old growth forests and provide immense opportunity for the long-term preservation and recruitment of these stands. These forests can store vast amounts of carbon, further bolstering the role of IRAs as one of our greatest natural allies in the fight against climate change as IRAs can be managed in ways to maximize carbon accumulation from the reduction of timber harvest and road development. A 2024 analysis by NPCA found that of the 92 million acres of mature and old growth forest stands, roughly a quarter (27 million acres) are located within 30 miles of national park sites – 3-percent of which are located within the parks themselves.38 The health of old growth stands within the parks is heavily dependent on the health and management of these stands outside of park boundaries and rescinding the Roadless Rule could negatively affect the old growth stands found within the parks. Given the scale of this threat, it is essential that the public lands be managed as part of the climate solution and not directly contribute to worsening the problem. The USFS must engage with the Environmental Protection Agency (EPA) on the impact this potential rescission could have on carbon dioxide emissions and fully analyze these potential impacts on the draft EIS.
Wildfire Resilience
Wildfire risk reduction and fire suppression are listed as a primary purpose in the 2025 NOI to rescind the Roadless Rule. However, studies show roadless areas, especially those with a large presence of mature and old growth forest stands, are far less likely to ignite into dangerous wildfires than areas already developed with roads.https://www.wilderness.org/sites/default/files/media/file/Summary%20NFS%20roads%20fire%20paper%20- %202025.pdf" role="button" aria-pressed="false" aria-describedby="mfn-content-00000000000008070000000000000000_48440-39" style="box-sizing: border-box; background-color: transparent; text-decoration: none; transition: 0.5s; color: blue;">39 There is a deep field of science behind wildfire suppression and the negative long-term side-effects, which show wildfire suppression leads to worsening long-term fire risk conditions and nets an overall decrease in forest resilience. Wildfire suppression maintains its value in the wildland urban interface (WUI) and the Roadless Rule provides regulatory flexibility to manage these areas for fuel reduction to safeguard these communities with IRAs existing within the WUI.
Large, destructive wildfires come with a host of lasting immediate and long-term effects including compromised precipitation interception, transpiration, soil ability to absorb and retain water, expedited spring run-off from snowmelt leading to increased levels of erosion, landslides, and sedimentation. These effects directly impact watershed health and local and regional air quality, particularly for areas managed by the NPS. We need to retain the last remaining IRAs protected by the Roadless Rule as climate change brings on larger and more intense wildfires. The Roadless Rule is one of the nation’s strongest forest resilience and wildfire policies on the books. The USFS must engage with NPS in the long-term monitoring of fire activity in IRAs adjoining NPS managed lands to understand how fire impacts differ from these IRA-NPS areas to general forest management areas.
Extractive Uses
Contrary to language within the 2025 NOI, the Roadless Rule does not prevent mineral extraction. Save for valid claims for locatable mineral extraction, the Roadless Rule merely requires development be done without the construction or reconstruction of roads. IRAs already support most of the principal forest uses, while providing enumerable social, economic, and environmental benefits. Timber harvest and energy and mineral development often require additional road construction and as noted previously these uses negatively impact the values conserved within IRAs and create lasting, downstream side-effects for neighboring communities and adjacent public lands managed by the NPS. Relying on the purported energy emergency announced in multiple 2025 executive and secretarial orders to justify rescission of the Roadless Rule is baseless.
Timber Harvest
Rescinding the Roadless Rule immediately exposes IRAs to road building for timber harvest, which would directly counteract the positive gains achieved over the past 25 years for these watersheds and national park landscapes. The Roadless Rule still permits timber activities within IRAs to restore vegetative conditions, improve forest health, reduce excessive fuels and wildland fire risk, and improve habitat for wildlife. At the time of the Roadless Rule’s adoption, the USFS noted that roughly 47 million acres of USFS land were suitable for timber production.
In the development of the DEIS, the USFS should analyze the following questions related to timber harvest:
- Across forest plans, how many acres are deemed suitable for timber production today?
- How has the Allowable Sale Quantity changed across forest plans since the adoption of the 2001 Roadless Rule?
- What trends in USFS timber harvest and timber sales have emerged since the adoption of the Roadless Rule?
- What other factors impact the demand for National Forest timber IE: current market forces, rules against international exports?
- What milling capacity exists to handle an increase in timber production?
Hardrock Mineral Mining
The Roadless Rule does not prevent mining activity or access to valid mining claims for the extraction of locatable minerals, provided exploration and development activities follow federal and state environmental regulations. However, the mining industry already maintains a significant sum of public lands under mining claims and active development. A 2024 study by NPCA found public land mining claims have increased 25 percent over the past five years and of the nearly 500,000 mining claims across the west, nearly 30 percent are within 30 miles of national parks and monuments.40 All told, the mining industry holds about 10 million acres of mining claims of which 1 million acres are under some form of production activity. Easing the burden to mine in more areas is simply unnecessary given the large quantity of holdings already held by the mining industry.
Oil and Gas Leasing and Development
The Roadless Rule also does not prevent development of pre-existing mineral leases within IRAs and it does not prohibit future oil and gas leasing or development – it merely requires future leasing and development activities to be done without building new roads. In 2023, the BLM sold leases within the Fish Lake IRA in southern Utah and the expectation is for technological drilling advancements to make exploration and development of this site possible without new road construction. Management of oil and gas resources atop Colorado’s Roan Plateau provides another example of oil and gas resource development without road construction and access.
Suggesting rescinding the Roadless Rule in the name of an energy emergency flies in the face of reality: the oil and gas industry maintains a significant number of leases – over 20,000 – yet produces only half of them. The NOI’s claim that IRAs are necessary to address the energy emergency is false. Domestic oil production is at all-time high and the US is a net exporter of petroleum. The US is also the world’s top producer of oil and natural gas. In March of 2024, the US was producing more crude oil than any other country in the world, ever. In 2023 and early 2024, the US produced more than 13 million barrels of oil per day. Industry operators currently sit on more than 6,000 approved, yet unused drilling permits.
The USFS must examine how many acres are considered open in some fashion for oil and gas leasing across all USFS managed lands. What could the direct, indirect, and cumulative impacts be to allowing road access to these areas considered open to leasing for oil and gas development?
Conclusion
The Roadless Rule has proven itself to be an effective tool that balances the multiple use mandate of our national forests while supporting wildlife habitat, hunting, fishing, outdoor recreation, and traditional uses, protecting drinking water for millions, and allowing forestry where necessary to reduce wildfire risk. It protects landscapes that safeguard national parks, promote biodiversity, store carbon, shelter wildlife, supply clean water, and anchor recreation economies.
Without Roadless Rule safeguards, logging, mining, and oil and gas leasing could further push right up to park boundaries, threatening iconic sites under threat include Capitol Reef, Dinosaur, Carlsbad Caverns, Badlands, Theodore Roosevelt, Rocky Mountain, Grand Teton, and Sequoia national parks.
Rescinding the Roadless Rule would be a step backward, leaving our public lands weaker, less connected, and more vulnerable at a time when climate change and biodiversity loss demand stronger safeguards. All these potential impacts, including impacts to national park sites, must be carefully analyzed and considered during the NEPA process. We urge the USFS to stand with the American people and retain the 2001 Roadless Rule in full.
Sincerely,
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National Parks Conservation Association |
Coalition to Protect America’s National Parks |
The Coalition to Protect America’s National Parks represents over 3,400 current, former, and retired employees and volunteers of the National Park Service, with over 50,000 collective years of stewardship of America’s most precious natural and cultural resources. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service. More information can be found at https://protectnps.org
Source: Coalition to Protect America’s National Parks
