Policy Statements » Letters from the President:

October 20, 2004

Attn: Roadless State Petitions
Content Analysis Team
USDA Forest Service
P.O. Box 221090
Salt Lake City, UT 84122

Dear U.S. Forest Service:

The Ecological Society of America (ESA), the nation’s professional organization of ecological scientists, would like to respond to the proposed changes to Title 36, Code of Federal Regulations, Protection of Inventoried Roadless Areas. The replacement of the existing rule with a state petitioning process has the potential to have a very broad negative impact on the nation’s federal lands. The changes are particularly worrisome because the proposal provides no guarantee that the federal government will protect inventoried roadless areas. ESA is concerned that if a state fails to file a petition or if a petition is rejected, many roadless areas would be subject to roadbuilding, logging, mining, and other commercial activities.

ESA supports the nationwide protection of U.S. roadless areas as determined by the Roadless Area Conservation Rule of January 2001. Roadless areas play a vital ecological role as refugia for sensitive species and as providers of ecosystem services, such as high quality drinking water. Sustaining these areas will benefit the U.S. public as well as the many other species with which we share our resources.

Direct effects of roads on ecosystems are well documented. The current state of scientific knowledge about effects of roads includes:

Water Degradation—Roads contribute sediments to water bodies such as streams which can degrade water quality, damage aquatic life, and spoil drinking water available for human consumption. Roads can also bring about changes to water volume, speed, and temperature which can negatively affect a host of animals including trout and salmon.

Biological Invasion—Roads can enable invasive plants and animals, many of which are non-native, to expand their ranges. Exotic species often thrive in the environments created by roads and can also be inadvertently transported by vehicles. Roads create open edges to forests which can make species more vulnerable to pest epidemics, invasion by nonnative species, and nest parasitism. Examples include: weeds, such as spotted knapweed; aggressive brood parasites, such as the brown-headed cowbird; and pathogens, such as Port-Orford cedar root rot.

Habitat Fragmentation—Roads break up local populations of smaller animals and plants, in some cases bringing about local extinctions. Roads can alter the behavior and movement patterns of large animals, such as elk, wolves, and bears, who may avoid suitable habitat because of its proximity to roads.

Human-caused fire—Most fires are caused by people and over half of these begin in the vicinity of roads. While fire is a natural process, the frequency and timing of fires plays an important role in how the landscape responds.

The Ecological Society of America and its members would be happy to provide the agency with any additional information that may be helpful. Thank you for considering our comments.


Jerry M. Melillo