The federal government is considering removing the Roadless Rule which was adopted in the final hours of the Clinton Administration in 2001. That rule, designed to protect wilderness areas, is now making it difficult to treat unhealthy federal forests and fight wildland fires. Currently, there are fires in at least four of the inventoried roadless areas in Washington state.
Here is the comment we filed in support of rescinding the roadless rule and providing local forest managers more flexibility to address the increasing risk of catastrophic wildfire.
You can add your comment here.
I am writing in support of the proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule) in RIN 0596-AD66 and adopt Alternative 2. Washington state’s 2026 fire season provides a good example of why the rule needs to be modified so local foresters can have the flexibility to address the forest health risks across the West.
The largest wildland fire in Washington state, the Little Giant Fire, which has burned more than 162,000 acres thus far, is in two inventoried roadless areas (IRAs) and is a good example of the risk that needs to be addressed in federal forests.
Like every public policy, there are tradeoffs and using the flexibility offered by rescinding the Roadless Rule wisely will require local foresters, biologists, engineers and officials to prioritize limited resources. The information provided in the draft EIS demonstrates that targeted treatment of forests in some existing roadless areas is likely to reduce the severity of catastrophic wildfires in areas that are important to wildlife, watersheds and communities.
In the Pacific Northwest, the draft EIS notes that more than half of roadless areas are in zones considered to have high or very high wildfire hazard potential and 43 percent of the acres in roadless areas are in “high priority firesheds” important to communities, infrastructure and drinking water. As the draft EIS notes, recent assessments “indicate that substantial acreage within potentially affected IRAs has a relatively high likelihood of burning under high‑intensity conditions that are difficult to manage or that could expose communities, infrastructure, or drinking‑water sources. These areas may therefore represent priority opportunities for hazardous fuel reduction.”
Rescinding the Roadless Rule and adopting Alternative 2 would allow the Forest Service the flexibility to increase the use of mechanical thinning and controlled burns to reduce the risk of catastrophic wildfire, like the Little Giant Wildfire in North-Central Washington state this year. I agree with the assessment of the draft EIS which notes, “Alternative 2 would provide the most local management flexibility for wildfire risk mitigation. This flexibility is essential for identifying, prioritizing, implementing, and maintaining treatments that address key drivers of wildfire risk, as well as for adapting strategies to changing conditions.”
Several objections have been raised to rescinding the Roadless Rule. Fundamentally, the objections do not represent a difference in scientific assessment of the impacts of the rule. Instead, they stem from a difference in risk tolerance. Some are more willing to risk the damage from catastrophic wildfire, especially fires caused by lightning, than risk from human-created roads and thinning. Additionally, because rule implementation is uncertain, weighing potential tradeoffs between the risk of fire and the risk of road disturbances is based largely on personal biases and priorities.
For example, the draft EIS notes that adding roads and using mechanical thinning could negatively impact the areas of contiguous habitat that some birds and wildlife prefer. It is difficult to say, however, whether that risk is greater than the risk from large wildfires that move through these areas.
The growing threat of catastrophic wildfire calls for more serious efforts to protect wildlife habitat, as well as communities.
The draft EIS notes that “IRAs in the Pacific Northwest and Northern Rockies often contain habitat for species sensitive to high-severity fire, such as the northern spotted owl and bull trout.” Between 1984 and 2024, nearly half of the acres in the IRAs were impacted by wildfire, with 22 percent impacted by moderate or high severity fire. With the increase in fire activity across the West, it is likely that a quarter of these areas will again see high or moderate severity fires in the next 40 years, which represents a real risk to wildlife habitat.
During a fire in Washington state where I was a public information officer, a designated spotted owl circle was destroyed and the owl likely with it. The risk of wildfire across the West to wildlife and protected species is real and growing.
Some have argued that adding roads to these areas would increase the risk of fire by allowing the public to access these areas. This doesn’t have to be the case. As the draft EIS notes, “not all roads constructed under alternative 2 would be open for public access,” limiting or eliminating the risk of additional human-caused fires.
Roads would also help quickly stop human- or lightning-caused fires in these areas, potentially reducing the total area burned. The draft EIS provides several pieces of evidence that support this hypothesis.
For example, the average time to contain escaped fires on NFS land is 27.4 days but 46.6 days in the potentially affected IRAs. Additionally, the average fire size in IRAs is more than double the size of other NFS lands – 659 acres compared to 302 acres. Even where roads are public, fires are more likely to be successfully attacked and contained quickly.
Roads are not appropriate in all existing IRAs. Building, maintaining and removing roads is expensive. In Washington state, and elsewhere, the distance between roadless areas and timber mills, as well as the poor quality of the wood makes commercial use of timber in the IRAs very limited. The market for “old growth” timber is also much smaller than during the 1990s because mills have re-tooled for smaller-diameter logs. And there is already a backlog of forest health work to be done in other lands managed by the Forest Service and other agencies that competes for agency attention and resources.
These limitations mean removing the Roadless Rule is unlikely either to result in major improvements in forest health or timber production.
Adopting Alternative 2 will, however, provide local forest managers the ability to address problems more quickly and effectively than the current rule allows.
Considering the growing prevalence and increased risk of catastrophic wildfire in federal forests, rescinding the Roadless Rule is a necessary step to counteract the damage those fires do.
If you have questions, please contact me at tmyers@washingtonpolicy.org.