Roads Not Taken: The Trump Administration’s Roadless Rule Reversal
Written by Drew Collins and Professor Ross Jones
For over two decades the Roadless Area Conservation Rule protected 58.5 million acres of national forest land in 39 different states.[1] The Roadless Rule prohibits road construction, road reconstruction, and timber harvesting in these areas.[2] Lands protected by the Rule include 80,000 acres in Vermont’s Green Mountain National Forest.[3] However, the Roadless Rule is now subject to reversal through massive deregulation efforts made by the Trump Administration to disempower the Forest Service.[4] This article will discuss the history and purpose of the Roadless Rule before jumping into the Trump Administration’s rescission of the Rule, public response, and the future of the Rule.
History of the Roadless Rules:
The Roadless Rule originated from decades of unsustainable logging practices that resulted in an $8.5 billion deficit in road maintenance.[5] Unsustainable logging required the construction of extensive forest road networks to access remote timber stands. These roads were costly to build, often poorly engineered, and left the Forest Service responsible for long-term upkeep after timber revenues declined.[6]
After World War II, the Forest Service entered the business of large-scale logging.[7] Timber production surged nationwide to fuel the post-war boom.[8] By the 1980s, annual harvests peaked at more than 12 billion board feet.[9]Â This level of production continued through the Clinton Administration, until Mike Dombeck, the Former Chief of the U.S. Forest Service, declared a temporary moratorium on new road construction in roadless areas in 1999.[10] Dombeck recognized this level of production was unsustainable, prompting a shift toward a new, ecosystem-based approach to forest management. In response to the moratorium, President Bill Clinton instructed the Forest Service to begin rulemaking to protect our forests.[11]
The Final Rule was promulgated in 2001 after two nationwide efforts to inventory roadless areas for their wilderness potential.[12] Many of the tracts targeted for protection lay high in watersheds, where soils were thin and highly prone to erosion.[13] Other tracts protected were already contentious sites for proposed timber sales.[14] The agency received over 1.8 million public comments on the proposed rule, most of which were in support of the rule or wanted to further expand its protections.[15]
Since its promulgation, the Roadless Rule survived several attempts to truncate it, particularly from the Bush Administration.[16] Despite these challenges, the Rule remained successful in conserving natural habitat and water quality.
Purpose of the Roadless Rule:
The United States Department of Agriculture (USDA) is the agency responsible for managing the National Forest System’s resources “to sustain the health, diversity, and productivity of the nation’s forests and grasslands to meet the needs of present and future generations.”[17] The Roadless Rule furthers these efforts by conserving forests, preserving water quality, and protecting habitats of endangered species.
As mentioned, the conservation benefits of the Roadless Rule stem from preserving forested areas and preventing large-scale logging.[18] However, the Rule also indirectly mitigates the effects of climate change. Currently, forests in the nation’s roadless areas are estimated to contain 445 million tons of sequestered carbon.[19] Many roadless areas contain the nation’s old-growth forests.[20] Old-growth forests are “areas [that] absorb and store climate-warming carbon dioxide at a large scale”.[21] These forests are prime examples of carbon sinks, areas on the earth that remove more carbon dioxide from the atmosphere than they produce. Carbon sinks are crucial to combatting climate change because they absorb vast amounts of atmospheric carbon dioxide, slowing global warming.[22]
The Rule preserves water quality by limiting development near headwaters that provide much of the nation with freshwater.[23] Over 60 million Americans rely on water sources originating from national forests.[24] As droughts intensify, preserving water sources in these areas becomes even more critical. Logging and construction degrade freshwater streams by increasing erosion and removing the natural filtration provided by trees and vegetation.[25]
By preserving large, unfragmented tracts of land, the Rule protects habitats for many species, including threatened and endangered species.[26] The Defenders of Wildlife, a conservation nonprofit, estimates the Roadless Rule protects over 220 different species listed under the Endangered Species Act.[27] The presence of roads can fragment habitats and have potential to disrupt migration patterns for some species.[28] Additionally, salmon and trout rely on undammed, unlogged streams for their very survival. As a result, some of the most productive fisheries in the country are found in roadless forest lands.[29]
The Rule also promotes the outdoor recreation industry. In 2023, the outdoor recreation industry generated $1.2 trillion of goods and services in the U.S. This represents 2.3 percent of the nation’s GDP and 3.1 percent of all jobs.[30] Roadless areas protect 11,337 climbing routes, 1,000 whitewater paddling runs, and more than 43,826 miles of trails, including 20,298 miles of mountain biking trails.[31] Without the Roadless Rule, these areas would be subject to development or logging operations.
The USDAs Plan to Reverse the Roadless Rule:
The Trump Administration’s Secretary of Agriculture, Brooke Rollins, announced plans to rescind the Roadless Rule in June 2025.[32] This plan aligns with three executive orders passed by the President in Spring 2025.[33] Executive Order 14192 titled “Unleashing Prosperity Through Deregulation”, directs the executive branch to “alleviate unnecessary regulatory burdens placed on the American people.”[34] Secretary Rollins argued the Roadless Rule is unnecessary, describing it as an “outdated administrative rule” that undermines the Forest Service’s duty “to sustain the health, diversity, and productivity of the nation’s forests and grasslands.”[35]
The USDA also justifies recession of the Rule by conformance with Executive Order 14225, titled “Immediate Expansion of American Timber Production”.[36] This Executive Order directs the Chief of the United States Forest Service to strategize ways to improve the speed of approving forestry projects and set targets for timber production.[37] Rescission of the Roadless Rule would lift the prohibition on timber harvesting across nearly 59 million acres of the National Forest System, aligning the agency’s regulatory framework with the Executive Order’s directive to expand timber production.[38]
Finally, President Trump issued Executive Order 14308, titled “Empowering Commonsense Wildfire Prevention and Response”, directing the Secretary of Agriculture to make wildfire programs more efficient.[39] Over 25 million acres of land protected by the Roadless Rule is categorized as “high or very high risk of wildfire”.[40] Secretary Rollins claims rescission of the Roadless Rule will reduce wildfire risk in high risk areas because land will be managed at the local forest level, which will provide greater flexibility to take action against fires.[41]
Opposition to the Rescission and Agency Response:
The USDA opened a 22 day truncated comment period for their rescission of the Roadless Rule starting on August 29, 2025.[42] During this time, more than 600,000 Americans commented on the proposed rescission, demonstrating substantial public concern for the Rule’s withdrawal.[43] The Center for Western Priorities, a conservation group, completed an analysis of comments and found that 99 percent of commenters disfavored rescission of the Rule.[44] In a day and age when Americans can’t agree on much, such overwhelming consensus underscores the public’s strong commitment to preserving roadless protections. It’s worth mentioning when Mike Dombeck first promulgated the Roadless Rule in 2001, the Rule drew over 1.8 million comments with 90 percent approval.[45] Based on these statistics, it’s fair to suggest Americans prefer the Rule in place, but does near-unanimous discontent mean the USDA will reverse course? The short answer is probably not.
The overwhelming public opposition for rescission of the Rule does automatically stop the rulemaking process. However, under the Administrative Procedures Act (APA), the USDA must address the major issues raised by commenters, explain why it disagrees, and provide evidence for that reasoning.[46] An unreasoned decision exposes the agency to potential litigation under the APA. If the agency cannot provide evidence to support its decision to rescind the Rule, then the rescission may be considered an arbitrary and capricious abuse of agency discretion and overturned in the court system.[47] Public comment alone is not enough to overturn an agency rulemaking, but it can certainly increase pressure on the agency to provide a reasoned explanation and the opportunity for a successful challenge under judicial scrutiny.
What’s Next? The Future of the Roadless Rule:   Â
The USDA must undertake more administrative steps before promulgating a Final Rule. At the end of August 2025, the USDA published a notice in the Federal Register to prepare an Environmental Impact Statement (EIS).[48] An agency must prepare an EIS when it undertakes a major federal action significantly affecting the quality of the human environment in accordance with the National Environmental Policy Act.[49] The EIS is expected in March 2026; it will address the potential environmental impacts of the rescission, alternatives to the decision, and possible mitigation measures.[50] If the EIS identifies significant adverse impacts or practicable alternatives, the USDA may be required to modify the proposed action or provide additional justification for proceeding. After the EIS is complete, the agency will promulgate a Final Rule based on their findings. The Final Rule is expected in late 2026.[51]
As the USDA moves towards rescinding the Roadless Rule, millions of acres of habitat, critical watersheds, carbon-rich old-growth forests, and countless recreation opportunities are at stake. The future of the Roadless Rule will test how the Trump Administration balances ecological stewardship, public participation, and administrative discretion. Whichever route the USDA pursues will represent a pivotal moment for the nation’s national forest lands and the importance of conservation as a pillar of the USDAs mandate.
Author Bio:
Drew Collins is a third-year law student at Vermont Law and Graduate School and serves as an Articles Editor for the Vermont Journal of Environmental Law. He intends to pursue a career in business law and family law following graduation. Drew holds a B.A. in Philosophy, Political Science, and Economics from Denison University. Outside of his academic and professional pursuits, he enjoys skiing, mountain biking, and spending time outdoors. These interests directly inspired the focus of this piece.
[1] Juliet Grable, Trump Wants to Rescind the Roadless Rule. What Does That Mean?, Sierra (Jul. 27, 2025), https://www.sierraclub.org/Sierra/roadless-rule-trump-wants-rescind-what-does-that-mean.
[2] Id; See Special Areas; Roadless Area Conservation, 66 Fed. Reg. 3244, 3244 (Jan. 12, 2001).
[3] Grable, supra note 1.
[4] See Special Areas; Roadless Area Conservation; National Forest System Lands, 90 Fed. Reg. 42179 (Aug. 29, 2025); see also Press Release, U.S. Dept. of Agric., Secretary Rollins Rescinds Roadless Rule, Eliminating Impediment to Responsible Forest Management (Jun. 23, 2025).
[5] Grable, supra note 1.
[6] Road Woes at the Forest Service, Taxpayers for Common Sense (Mar. 29, 2002), https://www.taxpayer.net/article/road-woes-at-the-forest-service/.
[7] Grable, supra note 1.
[8] Id.
[9] Id.
[10] Regarding the Promulgation of Regulations Concerning Roadless Areas Within the National Forest System, Hearing before Subcomm. on Forests and Pub. Lands Mgmt. Comm. on Energy and Nat. Res. U.S. S., 106th Cong. (1999) (statement of Mike Dombeck, Chief of U.S. Forest Serv.).
[11] Grable, supra note 1.
[12] Id.
[13] Id.
[14] Id.
[15] Id.
[16] Id; see Press Release, The PEW Charitable Trusts, Statement on the Bush Administration’s Plan to Remove Protections for Idaho’s Roadless Areas (Dec. 20, 2007); see also Timeline of the Roadless Rule, Earthjustice (Aug. 27, 2025), https://earthjustice.org/feature/timeline-of-the-roadless-rule.
[17] Meet the Forest Service, U.S. Dept. of Agric., https://www.fs.usda.gov/about-agency/meet-forest-service (last visited Nov. 23, 2025); see Mission Areas, U.S. Dept. of Agric., https://www.usda.gov/about-usda/general-information/mission-areas (last visited Nov. 23, 2025).
[18] Roadless Areas, U.S. Dept. of Agric., https://www.fs.usda.gov/managing-land/planning/roadless (last visited Nov. 23, 2025).
[19] DellaSala et. al., Hope in an Era of Climate Change: Roadless Areas in National Forests 5 (2011).
[20] Adel Alamo, What is the Roadless Rule and Why is it Important?, Dogwood All. (Aug. 10, 2025), https://dogwoodalliance.org/2025/08/what-is-the-roadless-rule/#:~:text=Why%20is%20the%20Roadless%20Rule,%2C%20fires%2C%20and%20strong%20storms.
[21] Id.
[22] What is a Carbon Sink?, ClientEarth (Dec. 22, 2020), https://www.clientearth.org/latest/news/what-is-a-carbon-sink/.
[23] Grable, supra note 1.
[24] Id.
[25] Id.
[26] Alamo, supra note 20.
[27] USDA Moves to Repeal Roadless Rule, Reigniting Fight for Public Lands, Defs. of Wildlife (Aug. 27, 2025), https://defenders.org/newsroom/usda-moves-repeal-roadless-rule-reigniting-fight-public-lands.
[28] Id.
[29] Grable, supra note 1.
[30] Alamo, supra note 20.
[31] Id.
[32] See Press Release, U.S. Dept. of Agric., Secretary Rollins Rescinds Roadless Rule, Eliminating Impediment to Responsible Forest Management (Jun. 23, 2025).
[33] Id.
[34] Exec. Order No. 14192, 90 Fed. Reg. 9065 (Jan. 31, 2025).
[35] See Press Release, U.S. Dept. of Agric., Secretary Rollins Rescinds Roadless Rule, Eliminating Impediment to Responsible Forest Management (Jun. 23, 2025); see Mission Areas, U.S. Dept. of Agric., https://www.usda.gov/about-usda/general-information/mission-areas (last visited Nov. 23, 2025).
[36] Exec. Order No. 14225, 90 Fed Reg. 11365 (Mar. 6, 2025).
[37] Id. at § 2.
[38] Grable, supra note 1.
[39] Exec. Order No. 14308, 90 Fed Reg. 26175 (Jun. 18, 2025).
[40] See Press Release, U.S. Dept. of Agric., Secretary Rollins Rescinds Roadless Rule, Eliminating Impediment to Responsible Forest Management (Jun. 23, 2025).
[41] Id.
[42] See id.; Special Areas; Roadless Area Conservation; National Forest System Lands, 90 Fed. Reg. 42179 (Aug. 29, 2025).
[43] Special Areas; Roadless Area Conservation; National Forest System Lands, 90 Fed. Reg. 42179 (Aug. 29, 2025) (noting receipt of 625,931 public comments); Comment analysis finds over 99% opposition to repealing 2001 Roadless Rule, Ctr. For Western Priorities, https://westernpriorities.org/2025/09/comment-analysis-finds-over-99-opposition-to-repealing-2001-roadless-rule/ (last updated Sep. 23, 2025).
[44] Comment analysis finds over 99% opposition to repealing 2001 Roadless Rule, Ctr. For Western Priorities, https://westernpriorities.org/2025/09/comment-analysis-finds-over-99-opposition-to-repealing-2001-roadless-rule/ (last updated Sep. 23, 2025).
[45] Milton Brown, Public Support For Roadless Rule Is Nearly Unanimous, Sierra News Online (Oct. 3, 2025), https://sierranewsonline.com/public-support-for-roadless-rule-is-nearly-unanimous/#:~:text=The%20Roadless%20Rule%2C%20a%20federal%20rule%20that,comments%20opposed%20the%20rescission%20of%20the%20rule.
[46] 5 U.S.C. § 553(c).
[47] 5 U.S.C. § 706(2).
[48] Special Areas; Roadless Area Conservation; National Forest System Lands, 90 Fed. Reg. 42179 (Aug. 29, 2025).
[49] 42 U.S.C § 4332(c).
[50] Special Areas; Roadless Area Conservation; National Forest System Lands, 90 Fed. Reg. 42179 (Aug. 29, 2025); 42 U.S.C § 4332(c)(i–iii).
[51] Special Areas; Roadless Area Conservation; National Forest System Lands, 90 Fed. Reg. 42179 (Aug. 29, 2025).