PERC appreciates the opportunity to comment on the U.S. Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule. That rule prohibits road construction and forest management across nearly one-third of the national forest system. Roadless areas may provide important wildlife habitat, improve water and air quality, and offer opportunities for recreation. However, inflexible management restrictions can also impose costs, such as increased fire risk and fire-suppression challenges.
Importantly, these benefits and costs vary considerably across the landscape. The top-down Roadless Rule can’t easily accommodate this variability. Rescinding the rule and returning to bottom-up management decisions could. So too might reforms that retain national direction encouraging roadless area conservation while giving local foresters more flexibility than the current rule does to weigh local tradeoffs.
PERC
PERC is the national leader in market solutions for conservation, with more than 45 years of research and a network of respected scholars and practitioners. Through research, law and policy, and innovative field conservation programs, PERC explores how aligning incentives for environmental stewardship produces sustainable outcomes for land, water, and wildlife. Based in Bozeman, Montana, we are intimately familiar with the worsening wildfire crisis and the pressing need to reduce fuel loads on the national forests across the West. PERC has examined federal forest management in depth, with particular attention to how federal rules can either enable or encumber forest restoration work.1See Holly Fretwell & Jonathan Wood, Fix America’s Forests: Reforms to Restore National Forests and Tackle the Wildfire Crisis, PERC (Apr. 12, 2021) (documenting how environmental review, litigation, and other procedural obstacles delay fuel treatments and other restoration projects on national forests). Across our work, we have consistently argued that conservation means active stewardship, rather than passive preservation, and succeeds when those closest to the resource have the flexibility to make decisions and are held accountable for the results.2See, e.g., Temple Stoellinger, Wildlife Issues Are Local—So Why Isn’t ESA Implementation?, 44 Ecology L.Q. 681 (2017); Sophie Gilbert et al., Fast Conservation, PERC (Sept. 17, 2026).
Research Summary
This comment aims to inform the agency’s decision by examining the relationship between roadless areas and wildfire. The attached analysis finds that the Roadless Rule’s conservation trade-offs vary substantially across landscapes. Key findings include:
- Ignitions are more likely in roaded areas;
- Fires that ignite in roadless areas are larger on average and more likely to escape containment;
- Fires that ignite in roadless areas are substantially more expensive to suppress, costing about 25 percent more per acre;
- While roadless areas tend to be remote and contain few structures, the Roadless Rule covers 7.3 million acres in the “wildfire transmission zone,” the area where fires are more likely to spread into populated areas;
- Fires in roadless areas create about 33 percent more PM₂.₅ emissions per acre than fires in roaded areas.
Our analysis does not provide a single solution to these problems. Instead, it shows that the costs and benefits of the Roadless Rule vary across the landscape, a fact that the rule’s rigid road and forest-management prohibitions cannot easily address. Rescinding the rule and restoring flexible, bottom-up management could address this variability. But so too could more modest reforms, such as reducing the Roadless Rule’s scope, softening its prohibitions, or making its exceptions more flexible. Whichever path the Forest Service chooses, however, we recommend that local managers have flexibility to authorize roads where active stewardship requires them and encouragement to decommission roads that no longer serve a management purpose. The goal should be healthier, more resilient forests, for which roads are sometimes a necessity and sometimes an obstacle.
