What former Forest Service leaders say about repealing the Roadless Rule

The public comment period on the Department of Agriculture’s intention to rescind the Roadless Rule ends Friday, but one significant submission was obtained by E&E News and published this week.

Four former U.S. Forest Service chiefs wrote a letter urging the USDA to abandon its plan to unwind the rule and to seek alternatives that “would require a collaborative, transparent process.”

“We believe a total repeal of the rule will result in many more problems than it fixes and be more costly in the long run,” the former chiefs wrote. “Turning the clock back to the 1990s will reignite the onerous issues, divisive controversies and costly litigation associated with that era.”

The four chiefs worked in Democratic and Republican presidential administrations, and served from the inception of the rule, through the contentious period of serious litigation and public debate, and into the years where it was settled as the established means of forest management.

The signatories are Michael Dombeck, who served from 1997 to 2001, during the Clinton administration and the formation of the rule; Dale Bosworth who was chief during the George W. Bush presidency from 2001 through 2007; Tom Tidwell, who served from 2009 to 2017 under President Barack Obama, and Vicki Christiansen, who served from 2018 to 2021 in the first Trump administration.

“The rule was developed or administered during our tenure in Forest Service leadership positions including as chief,” they wrote. “We are very familiar with both the rule and associated issues. Hopefully our perspective, comments and suggestions will be useful and carefully considered.”

Why the Roadless Rule was adopted

The former Forest Service leaders wrote that they agree that it might be time for a review of the rule, but said statements made by USDA officials neglected to highlight the benefits or the reasoning for why the rule was implemented in the first place.

“Yes, much has changed over the past nearly quarter century,” the letter reads. “But much also remains unchanged. More important, much has improved.”

Referring back to the preamble of the 2001 decision, the chiefs reminded the USDA of several key arguments for why it was considered a good idea and held such significant public appeal.

“Although the inventoried roadless areas comprise only 2% of the land base in the continental United States,” the preamble reads. “They are found within 661 of the over 2,000 major watersheds in the nation and provide many social and ecological benefits.”

It was a necessary response to the development and urbanization of the American landscape, the amount of which doubled from the 1980s to the 1990s. That paving over of American wild spaces ultimately diminishes access to natural resources, impacting the environment in ways that are crucial for society.

“Inventoried roadless areas provide clean drinking water and function as biological strongholds for populations of threatened and endangered species,” reads the decision’s preamble. “They provide large, relatively undisturbed landscapes that are important to biological diversity and the long-term survival of many at risk species.”

Namely, they are areas of healthy and clean air, soil and water, which provide clean drinking water for millions of Americans and healthy environments for native fauna and flora to survive.

Often, too, those spaces are beautiful, diverse landscapes that are excellent for recreation while also providing a stable reference for forest and land management. Roadless forests, according to the preamble, “serve as a barometer to measure the effects of development on other parts of the landscape.”

“The values and importance of these remote back country places have increased in the past 25 years as more of this nation’s private forest and farmland is developed and urbanized,” the chiefs wrote.

Has the Roadless Rule worked?

Regarding the arguments about wildfires, the chiefs say that the means to address those threats are built into the rule.

“The 2001 rule allows hazardous fuel reduction, livestock grazing, off-highway vehicle (OHV) riding, energy development including oil and gas leasing, hard-rock mining, and the entire spectrum of back country recreation,” they wrote.

“Are there changes in the past 25 years that require additional allowances or exceptions?”

As for the economic benefits to local communities, they suggested the USDA do greater due diligence on the economic potential of the roadless areas. The majority of the areas are within rugged, mountainous terrain that would be costly to attempt to log or develop, they wrote, which is part of the reason they were protected in the first place.

Not only are the high-value, old-growth forests and timber mostly gone, they wrote, the value those lands provide ecologically today far outweighs their potential extractive, commodity value.

“We need to face reality. The easy to access timber has been cut,” they wrote. “The primary role of the Forest Service should be in stewardship and restoration activities that protect human communities from fire and restore the health of the land.”

Regarding the transfer of control to local managers, they reminded the USDA that this was attempted in the past and failed.

“The issues simply could not be resolved at the forest plan or district project level,“ the chiefs wrote. ”This was a key reason we decided a national rule was needed. Even Congress was unable to reach consensus on resolution of the future of roadless areas.”

“Overall,” the chiefs wrote, ”the 2001 rule has been successful.”

What’s next

As of Thursday, nearly 160,000 public comments have been submitted to the USDA. It will next conduct an environmental impact analysis, review the comments and determine a plan by March 2026. The plan will also have a public comment period. Following that and by the end of 2026, the USDA intends to publish a final decision.

Within those considerations, the chiefs wrote that they hope the current USDA finds their perspective and experience helpful.

“We remain convinced,” they wrote, “that repealing the 2001 rule will not be in the long-term interest of the American people, Forest Service employees, and the communities they serve.”