Federal Register Public Comment: 2001 Roadless Area Conservation Rule
September 19, 2025 — Verdani, LLC (DBA Verdani Partners) hereby submitted the following comment in strong opposition to the USDA's proposed rule to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244, 36 CFR Subpart B (2001)). Verdani Partners is a sustainability consulting company specializing in commercial real estate and provides biodiversity, resilience, and decarbonization services, and is therefore well positioned to comment on the proposed rule.
Federal Register: Special Areas; Roadless Area Conservation; National Forest System Land
The Roadless Rule protects nearly 58 million acres of National Forest land nationwide, including about 6 million acres in Montana and over 9 million acres in Alaska’s Tongass National Forest. These areas are an American treasure, irreplaceable for clean water, wildlife, recreation, and climate resilience. For nearly a quarter century, the Roadless Rule has proven its worth. It protects our last remaining undeveloped public lands while allowing flexibility for responsible forest management
Since 2001, Montana alone has seen nearly 190,000 acres of active forest management projects inside roadless areas, proving that conservation and stewardship can coexist. Rescinding the Roadless Rule would dramatically increase risks to our forests, communities, and climate. The vast majority of wildfires, over 85%, are human-caused, and most ignite within a half-mile of a road. Building new roads will not prevent wildfires; it will multiply ignition points. Meanwhile, cutting more big, old trees removes the most resilient, fire-resistant part of the forest. Once these old-growth trees are gone, it takes centuries for ecosystems to recover
Rolling back the Rule is also fiscally reckless. The Forest Service already faces a multi-billion-dollar road maintenance backlog. Adding new roads would further strain taxpayer resources, degrade water quality, reduce safe public access, and create more hazards instead of solutions. Forests are not a crop to be exploited for corporate profit. They sustain fish, birds, and wildlife; filter drinking water for millions of people; provide extraordinary recreation opportunities; and absorb and store vast amounts of carbon?helping us fight climate change. Older trees are especially critical, as they store exponentially more carbon than young trees. To cut them now would be to squander one of our strongest tools in the climate crisis
The Roadless Rule is extremely popular with the American public because it protects what we value most about our National Forests: wild places, clean water, wildlife, and a stable climate. These lands belong to all Americans, not industry lobbyists. Rolling back the Roadless Rule would hand over our shared natural heritage to short-term profit seekers at the expense of future generations.
Verdani Partners’ headquarters and many of our employees are located in California. For Californians, already living with the compounded threats of climate change, mega-fires, and water scarcity, this proposal is more than misguided. It is dangerous. Weakening the Roadless Rule will jeopardize the safety, health, and well-being of our communities while worsening the climate crisis for everyone. Verdani Partners urges you to keep the Roadless Rule intact and protect our forests, for Montana, for Alaska, for California, and for every community that depends on clean water, healthy forests, and a livable climate.
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