On August 20, the U.S. Forest Service (USFS) published a proposed rule in the Federal Register that would rescind the 2001 Roadless Area Conservation Rule (Roadless Rule).

Background

The Roadless Rule limits road construction, road reconstruction, and timber harvesting on specified inventoried roadless areas (IRAs) on National Forest System lands, subject to certain exemptions. The rule covers approximately 44.7 million acres of National Forest System (NFS) land across 38 states and Puerto Rico, with more than 95% located in Western states and Alaska’s Tongass National Forest. (The 2001 Roadless Rule is not in effect in Colorado or Idaho, which have a combined 13.5 million acres of IRAs, because those states have state-specific roadless rules.)

During the first Trump Administration, roadless protections were removed in the Tongass National Forest through the 2020 Alaska Roadless Rule and then reinstated by the Biden Administration in 2023. In June 2025, the Administration announced its intentions to fully repeal the 2001 Roadless Rule—not just in the Tongass. The notice of intent was issued in August 2025 and the formal proposed rule issued August 2026.

Proposed Rule: Full Rescission

The USFS analyzed three alternatives: no changes, full recission, and a modified roadless rule. USFS selected Alternative 2, full recession.

Alternative 1 would maintain the Roadless Rule, keeping it fully intact.

Alternative 2 would repeal the entirety of the Roadless Rule, removing roadless rule prohibitions and IRA designations on all 44.7 million acres.

Alternative 3 would modify the Roadless Rule, removing roadless rule prohibitions and IRA designations on 31.7 million acres:

• 5 million acres of non-NFS lands and congressionally designated areas
• 9 million acres within 0.5 mile of roads and/or within the wildland-urban interface (WUI)
  • 1 million acres within WUI, defined as areas in an existing Community Wildfire Protection Plan and an up to 1.5-mile buffer around at-risk communities and their evacuation routes
  • 3 million acres within 0.5 miles of existing roads
  • 7 million acres that are both within the wildland-urban interface and within 0.5 miles of existing roads
• 3 million acres of IRA within the Tongass National Forest

Taxpayer Impacts

For more than two decades, our national forests have been governed by the Roadless Rule and its full repeal carries significant consequences for American taxpayers. A closer read of USFS’ own analysis of the proposed rule’s impacts reveals that full repeal would increase taxpayer costs and liabilities through increased road subsidies, revenue losses from timber sales, and increased wildfire risks. While the USFS stated the goals to reduce regulatory burden, increase resource production, and increase local management flexibility to allow for active management where necessary in response to increasing wildfire risk, a full repeal may have the opposite impact.

Increased Opportunity for Roadbuilding: There are approximately 17,000 miles of roads within IRAs. About half of IRAs are within 1 mile of a road and 31 percent are within 0.5 miles of a road. USFS reports that while the proposed rule would increase the “potential for added mileage to the NFS road system,” it is “not reasonable to anticipate specific mileage changes.” The cost of any roadbuilding is likely to fall to taxpayers—$80,000 to $100,000 per mile for just dirt roads, according to USFS—and will add to the USFS’s already $6.9 billion in deferred maintenance for passenger car-suitable roads. USFS states that any benefits of additional road building would be related to improving access for timber harvest and wildfire risk reduction, which are discussed below.

Potential Increase in Annual Timber Production: USFS expects the proposed rule to open 4.8 million acres to timber production, which could result in a maximum 5-10% increase in annual sawtimber harvest on NFS lands, generating $5.2-$11.4 million in revenue for taxpayers if annual harvest is carried out in all areas. However, this maximum increase is unlikely to occur due to “budgets, unforeseen limits on operability, and market conditions”. USFS also notes that it is hard to predict potential impact of the rule on timber production due to the small number of operable areas within IRAs and that any efficiency gains are expected to be limited by “road costs, maintenance funding gaps, and the $6.9 billion deferred maintenance backlog”.

Unquantified Wildfire Risk Reduction: While the proposed rule would provide increased opportunities for wildfire risk mitigation, USFS anticipates a modest overall increase in treatment due to the high cost of road building and declining budgets for road construction and maintenance. Despite being a substantial argument in defense of the proposed rule, USFS does not quantify wildfire risk reduction in their analysis. Although the proposed rule acknowledges “there could be increased hazard from human-caused ignitions”, it does not quantify the potential cost of wildfire suppression, damages, and natural resource loss that may arise from increased risk of ignitions. The proposed rule also severely understates this risk compared to the agency’s draft environmental impact statement, which highlights that “ignition density is approximately four times greater on other NFS lands compared to the potentially affected IRAs and wilderness.”

Millions in Annual Economic Losses in Outdoor Recreation: USFS anticipates a minimum of $6.1 million in annual losses to recreationists and $9 million in lost recreation visitation expenditures. These costs are both short-term impacts from noise, visible infrastructure, and temporary closures, and long-term decreased opportunities for “quiet, remote and self-reliant recreation”. USFS notes that the proposed rule could expand recreation opportunities that require roads or accessibility improvements but are impacts are “uncertain and anticipated to be limited.”

Potential Threats to Commercial Fishing and Seafood Processing: The USFS anticipates no significant impacts to commercial fishing and seafood processing industries due to the small number of operable areas for timber harvest in current IRAs, but notes that commercial fisheries could experience long term effects if resource conditions are affected. Any impact will most likely be felt in Southeast Alaska near the Tongass National Forest.

Social, Environmental, and Other Harms from Increased Roadbuilding: Road construction and use can “degrade the unique characteristics of roadless areas” – aka the very fact that they are, by definition, undeveloped. USFS estimates $5.3 to $11.5 million annually in socio-economic loss in “non-commodity values” from the proposed rule. USFS does not quantify costs relating to air and water quality, wildlife, the spread of nonnative invasive species, and general ecosystem health.

The Taxpayer Takeaway

Conditions have undeniably changed since the rule was first promulgated 25 years ago; national forests face increased threats from extreme temperatures, wildfire, invasive species, and disease outbreaks. It is good governance to regularly evaluate longstanding policies and closely examine what is and isn’t working. But a rushed, full abandonment of the Roadless Rule without a thorough examination of policies that have worked for the last two decades puts taxpayers at risk.

The USFS’s own analysis fails to make that case that full repeal of the rule is in the best interest of taxpayers, communities, and our national forests. Not only is USFS’s justification unsupported, but the proposal leaves critical questions on taxpayer impacts, risks, and costs unanswered.

Roadless areas in our national forests directly impact federal taxpayers and local communities. That’s why the 2001 rule was built on more than a year of public engagement—USFS held 440 public meetings across the country, with roughly 25,000 total participants, and received 1.6 million comments. This time around, the public will only have 30 days to comment on the proposed rule before full rescission could be finalized.

Targeted improvements to the Roadless Rule, identified through careful analysis and public consultation, make sense. Blindly instituting full repeal would expose taxpayers to billions in subsidized road construction and maintenance, exacerbate taxpayer losses from money-losing timber sales, potentially increase wildfire risks and the associated costs borne by taxpayers, and weaken the health of roadless areas that provide important commercial and recreational benefits to the American public.