SOCAN Comments on the USDA Proposal to Terminate the Roadless Rule

Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
August 25^th 2025

Comments regarding Repeal of the 2001 Roadless Rule RIN 0596-AD66,
Document ID: FS-2025-0001-223869; Docket (FS-2025-0001)

Secretary of Agriculture Brooke Rollins
U.S. Department of Agriculture
1400 Independence Ave., S.W.
Washington, DC 20250

Secretary Rollins:

I write as cofacilitator of Southern Oregon Climate Action Now, the oldest grassroots climate organization in Southern Oregon representing some 2,000 Southern Oregonians who understand and accept the scientific consensus regarding climate change and are concerned about the climate crisis. We seek federal, state, and local action to address it and oppose proposed actions that contribute to the crisis.  We are rural and coastal Southern Oregonians who live on the frontlines of the warming, reducing snowpack, heatwaves, drought, rising sea level and the increasing wildfire risk that climate trends conspire to impose on us.  Because of our concern, we pay close attention to efforts nationally, statewide, and locally that influence our collective efforts to address the serious climate crisis.  As our logo above indicates, the focus of SOCAN is to promote action through science while encouraging that action be undertaken through a social justice lens.

We understand that some members of the current Administration deny data, evidence, and reality.  They deny, for example, that tariffs constitute a tax on the American consumer (Gore 2025), they deny that Bureau of Labor Statistics data on jobs and inflation indicated, when released, an economic downturn (Aitken 2025), and they deny that mRNA vaccines exhibit considerable potential for curtailing many critical diseases (Scott 2025). We are also well aware that there are those in the current administration who, in addition to rejecting science and evidence generally, specifically reject climate science. Not only do they deny the consensus among climate scientists but also, they seek to suppress government sites that increase our understanding how greenhouse gases are contributing substantially to the climate crisis we are experiencing (e.g. LSE 2025). 

In order to undertake a rational assessment of the proposal to repeal the roadless rule, it is imperative that those evaluating this proposal undertake an objective review of the climate science literature rather than accept, for example, the flawed report written by the Department of Energy team of science deniers (Christy et al. 2025) that was used by the EPA to repeal  justify repealing the 2009 Greenhouse Gas endangerment finding, and justify suppressing and defunding climate research.  It is transparently obvious to even the most casual objective observer that, as has been reported many times (e.g. Tandon et al. 2025; Voosen 2025, Dessler & Kopp 2025), the report by Christy et al. (2025) that was never peer-reviewed, is substantially flawed in its misrepresentation of climate science and its misrepresentation of the work of climate science authors and their published peer-reviewed findings.

In responding to the proposed repeal of the 2001 Roadless Rule, we note the Federal Register claim that “Management flexibility is needed for the Agency to achieve its multiple use conservation mission, including timber production, recreation, wildfire suppression, and fuel reduction treatments (Federal Registry 2025). We first note the federal hypocrisy of claiming in this effort a need to maintain flexibility that includes serving the conservation mission while the DOI, as reported by Beamer (2025), is simultaneously seeking to terminate conservation as a goal in the management of public lands (DOI 2025). If the U.S. Forest Service leadership doesn’t even know what the Department of the Interior is proposing with regard to eliminating conservation from the multi-purpose management goals of DOI public lands when it writes its justification for proposals such as this, how are members of the public to find anything they offer credible?

In terms of our effort to counter global warming and its climate change consequences, we are acutely aware that forests across the globe provide us with among the greatest natural climate solutions. This is because forests are responsible for the sequestration (capture and storage) of carbon dioxide from the atmosphere (e.g., Ruiz 2024).  This is especially the case for forests of the Pacific Northwest (USDA undated) which states: “Forests in the Northwest Climate Hub region have some of the highest carbon densities in the United States.” However, contrary to the graph in that discussion depicting a reduction in productivity and thus sequestration as forests age, there is now abundant evidence that forests continue sequestering carbon well into old age (e.g., Anderson 2021, Stephenson 2014). This last citation indicates that knowledge of the ongoing sequestration of carbon by forests as they age is not new.

As noted above, among the claims justifying the effort to repeal the roadless rule is wildfire suppression, based on the claim that roads are valuable for allowing forest personnel to fight fire. This might have been a reasonable argument if the current administration had not terminated a vast percentage of the very forest service personnel designated for firefighting (Olalde 2025).   Rather than enhancing the forest service’s ability to fight fires, this Administration is systematically eliminating the capacity of the forests service to address this threat.

A critical additional problem with this firefighting justification for the repeal of the roadless rule is the reality that constructing roads into our forests allows ever more easy access by humans to those forests.  Not only do forest roads themselves create conditions that increase fire risk (e.g., Browning et al. 2024), but according to the National Interagency Fire Center (NIFC updated), 85% of U.S. wildfires are human-caused.  Globally, meanwhile, the percentage of fires caused by humans has been placed at 90% (Cyfoeth Naturiol Cymru undated). Alarmingly, in California, the percentage of forest fires initiated by humans is reportedly as high as 95% (Braxton Little 2023). Nearly two decades ago, Morrison (2007) undertook an analysis of wildfire causes. Despite conventional wisdom suggesting that roads are crucial in fighting fires (e.g., OFIC undated), he reported that 88% of all fires nationwide are caused by humans and of these, 95% occur within ½ a mile of a road.  Since most forest fires seem actually to be initiated by humans and these generally occur within close proximity to a road, allowing more humans into the forests seems likely only to increase the frequency of fire ignitions even if roads may subsequently hasten the ability of firefighters to reach and extinguish those fires. Ultimately, is it easier to extinguish a forest fire or prevent its initiation? The evidence suggests adding roads to our forests will increase fire risk not decrease fire risk.

Forest research reveals that old growth forests continue sequestering greenhouse gases throughout their lives. Logging not only results in the release of carbon dioxide from the harvested trees but also precludes those harvested trees from continuing to sequester the gas.  Given that many of the roadless areas are designated in order to protect old growth forests (Earthjustice 2025). Abandoning the Roadless Rule is clearly designed to undermine our old growth forest and expose them to logging and desecration.

A far more likely justification for repealing the roadless rule is the clearly stated goal of increasing logging, likely especially targeting old growth forests.

We are also well aware of the data that reveal logging in Oregon contributes substantial carbon dioxide (Law et al. 2018).  Indeed, logging results in more emissions annually even than the transportation sector (DEQ undated).  In addition, as Plotkin and Boan (3034) conclude: “…decades of clearcut logging, conifer planting, and extensive fire suppression have more likely exacerbated wildfire risk to communities than diminished it.”  To understand how logging affects free risk, it’s important to appreciate that fires are stimulated more by the smaller branches and twigs than the larger trunks (e.g. Cowan 2023).  Some three decades ago, it was well understood as Fernandes & Rego (1998) stated: “Large surface area-to-volume ratios increase the rates of energy and mass exchange with the gaseous phase, leading to lower ignition delays and higher rates of fire spread” This means smaller branches and twigs with large surface to volume rations will burn more rapidly than large branches or trunks. Loggers seek the larger timber not the branches and twigs. Thus, they frequently remove the trunks and

 leave the smaller highly flammable debris. Figures 1 and 2 illustrate the problem where the slash piles left after a local logging operation clearly demonstrate that logging can increase fuel and the fire risk.

Any effort to manage wildfire risk should take climate change into account.  As Levine et al. (2025) state: “….there is widespread agreement that climate change will raise high-severity fire risk by fostering more extreme weather conditions.” Interestingly, the same authors also point out that “the odds of burning at high severity were 1.8 times higher in private industrial forests than on public land.”

The claim that logging our forests will decrease fire risk is not supported by the evidence. Rather, the evidence suggests that non-commercial thinning of forests combined with imposing a controlled fire regime is the best approach to reduce fire risk (e.g., TNC undated; Davis et al. 2024; NAFSR 2021; Brodie et al. 2024).

Rather than accept what the timber industry urges (e.g. Cornell 2025; Hoffman 2025), and what the ignorant Trump administration urges (e.g. TWH 2025; Hoffman 2025; Shirvell 2025; Dezember 2025; Brown 2025; Cornwall 2025) all seeking to increase logging without regard to forest health or any other forest value, we urge proponents of repealing the roadless rule to review the current science regarding what is required in relation to fire in order to maintain healthy forests.  In particular, the team should review the study undertaken by the US Forest Service itself (USDA 2020) that concluded: “Historical fire maps indicate that forests with and without roads have burned at similar rates since the Rule took effect.” They also reported “higher rates of human caused ignition near roads” and “…roads are strongly associated with the spread of invasive plant species in national forests.” Finally, and probably most convincingly: “…a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System, although activities in areas with roads cover larger areas.” Clearly the Forest Service itself has argued convincingly against the arguments employed to justify the roadless rule repeal proposal.  If Forest Service leaders refuse to accept the evidence presented to them by their own staff, it’s difficult to imagine what argument could possibly influence the current preconceived and obviously uninformed opinions and decisions of current Forest Service Leadership.

For the plethora of reasons discussed above, Southern Oregon Climate Action Now vehemently opposes the effort on the part of the Forest Service to repeal the roadless rule.

Respectfully Submitted

Alan Journet Ph.D.

7113 Griffin Lane

Jacksonville
OR 97530-4182

alan@socan.eco
541-500-2331
541-301-4107

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