Read PCEC's Comments on the Roadless Rule

Much of the Crazy Mountains are currently protected by the Roadless Rule

To Secretary Brooke Rollins:

I am submitting this comment on behalf of Park County Environmental Council (PCEC), and our  500+ members, and 2400 supporters. PCEC is a grassroots conservation group serving Park County Montana. We stand in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). 

Since 1990, PCEC’s mission has been to protect the wildlife, critical habitat, public lands, water resources, and community resilience that define our region and the people who call Park County home. This proposed rule change directly threatens the natural resources and economic foundations of Park County and the Greater Yellowstone Ecosystem.

The Roadless Rule is an essential protection for the 1.6 million acres of Inventoried Roadless Areas within the Custer Gallatin National Forest surrounding our community. For us, this policy is not an abstraction; it is a tangible safeguard for the places we cherish and which our lives depend on. The Crazy Mountains, for example, with its checkerboarded ownership, are highly vulnerable to new road construction for industrial-scale logging, mining, and recreation development. 

Rescinding the Roadless Rule would directly contradict the spirit and precedent of recent conservation efforts, like the 2024 East Crazies Inspiration Divide Land Exchange, opening these critical lands to permanent alteration.

The threat extends to other invaluable areas in and around our county, including Mill Creek, West Pine, and Hidden Lakes. These headwaters of the Yellowstone and Shields Rivers are vital for our clean drinking water, agriculture, fish spawning habitat, and local economy, and each are protected by the Roadless Rule. Our community's well-being and economic viability is directly tied to the health of these watersheds, which would be harmed by increased road construction and logging.

Park County is situated in the northern Yellowstone ecosystem, and serves as the only vehicular entrance to Yellowstone National Park year-round. The areas in the Park County and adjacent to Yellowstone National Park protected by the Roadless Rule provide a relative seamless connection of landscape and habitat critical for both wildlife, but also the people who live here and the many millions who visit here to experience what wildlands and wilderness truly are, an increasingly rare experience in the modern world.

Arguments for repealing the Roadless Rule are often presented as a solution for catastrophic wildfires. However, this assertion is not supported by peer reviewed scientific consensus. We are concerned that the stated shift in federal priorities toward timber harvest is a clear step toward logging previously designated critical habitat. This is a move that many fire ecologists and forestry experts argue can actually increase wildfire risk. The 2003 Cooney Ridge fire in western Montana offers a crucial lesson, as studies have shown that heavily logged areas burned more severely than adjacent unlogged forests (Stone, C., et al., 2004). We believe that protecting intact, roadless forests is a more effective fire resilience strategy for our local forests that also protect people.

The claim that repealing the Roadless Rule would boost our local economy is outdated and ignores current economic realities devoid of meaningful public consultation. As an organization that works on community resilience, we know that the timber industry's importance in the West has been in a long and steep decline due to automation and other market shifts. A 2017 report by Headwaters Economics, "The Transition from Western Timber Dependence: Lessons for Counties," shows that the number of lumber mills in the West plummeted from 950 in 1970 to just 160 in 2011. 

In contrast, our local economy is built on recreation and tourism, both of which depend on the pristine, unfragmented public lands that the Roadless Rule protects. The 2023 Institute for Tourism and Recreation Research (ITRR) data shows that non resident spending in Park County was over $262.8 million. Tourism supported directly and indirectly over 2,400 jobs in Park County.

In 2023, non-resident visitors spent $5.45 billion in Montana, supporting over 66,550 jobs statewide (Montana Department of Commerce, 2024). The tourism industry is a major economic engine, generating $414 million in state and local taxes. This spending is particularly vital in our region, with visitors to Yellowstone and Glacier National Parks alone generating $716 million in nearby communities in 2023 (ITRR, 2024). These numbers demonstrate that the economic vitality of our region is intrinsically linked to preserving the natural amenities that draw visitors and support local businesses.

This push to build more roads for logging is a fiscally irresponsible proposal. The U.S. Forest Service already faces a massive and growing $8-10 billion road maintenance backlog for its more than 382,000 miles of roads. The agency’s annual funding is not even sufficient to maintain a fraction of its current road network, much less the millions of dollars in new roads that would be required to access these roadless areas. Subsidizing the construction of more logging roads with taxpayer dollars would only add to this unsustainable financial burden, shifting costs from private timber companies onto the public.

Research indicates that many logging operations and associated road construction can increase sediment and negatively affect water quality. The health of these headwaters is not just a local concern; the Yellowstone River is a major tributary of the Missouri and Mississippi Rivers, connecting our watershed to millions of people and ecosystems in states far downstream. The degradation of these headwaters would have far-reaching negative consequences for agriculture, drinking water, and aquatic habitats across the greater watershed.

The repeal of this rule would fragment crucial wildlife habitat, disrupt migration corridors, and increase human-wildlife conflict. This is especially concerning for the Gallatin Range, which includes the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area, the areas adjacent and connected to the Absaroka Beartooth Wilderness area. All are critical areas for wildlife and serve as vital migration corridors for elk, and a core habitat for one of the densest grizzly bear populations outside of Yellowstone National Park.

Over 20 federally-listed, threatened, endangered, or "Species of Concern" depend on the health of Montana’s roadless forest systems. This includes large mammals, birds, fish, amphibians, and insects, demonstrating that the threat spans the entire food chain. The repeal threatens keystone plant species like the Whitebark Pine, which provides a crucial food source for a variety of wildlife, including Grizzly Bears and Clark's Nutcrackers. This single species' decline impacts a wide range of other animals. 

Large mammals like Grizzly Bears, Canada Lynx, and Wolverine require vast, interconnected tracts of undisturbed habitat to maintain genetic diversity and a healthy population. The construction of new roads would fragment these habitats, disrupting critical migration corridors and increasing human-wildlife conflict. This pressure could push these populations into unlivable habitat or land management zones that lead to direct human encounters.

A significant number of species at risk are tied directly to water resources. Bull Trout and native cutthroat trout depend on the cold, clean water that originates from high-elevation, roadless headwaters. Similarly, endangered insect species like the Meltwater Lednian Stonefly and Western Glacier Stonefly are sensitive indicators of water quality and habitat integrity. Road construction and logging increase sediment runoff and pollution, directly threatening these foundational aquatic species and the broader food web. 

The health of these ecosystems is deeply interconnected. The Black-backed Woodpecker, a species of concern, relies on the standing dead trees that remain after a fire, while the Northern Goshawk requires large, mature forest stands for nesting. Logging for fire prevention removes these essential habitats, while a hotter, drier landscape creates conditions that can eliminate the very species needed to maintain a healthy forest.

By protecting roadless areas, we are not just preserving scenic views; we are safeguarding the intricate and life-sustaining connections that support a diversity of wildlife, from the smallest insect to the largest bear and the people of our Montana. The repeal of the Roadless Rule would initiate a chain reaction of ecological degradation, with devastating ripple effects across the entire Greater Yellowstone Ecosystem.

For these reasons, the Park County Environmental Council urges the U.S. Department of Agriculture to maintain the integrity of the Roadless Rule. It is a proven, forward-thinking policy that protects the very resources—our clean water, our wildlife, and our wild places—that form the foundation of our community.

Sincerely, 

Park County Environmental Council


List includes both federally-listed species and those identified as "Species of Concern" by Montana state agencies that would be negatively impacted by this decision.

Federally Listed Wildlife in Montana Forests Systems

  • Canada Lynx (Lynx canadensis): Threatened

  • Grizzly Bear (Ursus arctos horribilis): Threatened

  • Northern Long-eared Bat (Myotis septentrionalis): Endangered

  • Bull Trout (Salvelinus confluentus): Threatened

  • Meltwater Lednian Stonefly (Lednia tumana): Threatened

  • Western Glacier Stonefly (Zapada glacier): Threatened

  • Monarch Butterfly (Danaus plexippus): Candidate for listing

Montana Forest Wildlife Species of Concern

  • Wolverine (Gulo gulo)

  • Fisher (Pekania pennanti)

  • Northern Goshawk (Accipiter gentilis)

  • Great Gray Owl (Strix nebulosa)

  • Bighorn Sheep (Ovis canadensis)

  • Harlequin Duck (Histrionicus histrionicus)

  • Black-backed Woodpecker (Picoides arcticus)

  • Flammulated Owl (Psiloscops flammeolus)

  • Pacific Wren (Troglodytes pacificus)

  • Boreal Chickadee (Poecile hudsonicus)

  • Idaho Giant Salamander (Dicamptodon aterrimus)

  • Rocky Mountain Capshell (Acroloxus coloradensis)

  • Rocky Mountain Duskysnail (Colligyrus greggi)

Federally Listed Plants in Montana Forests Systems

  • Whitebark Pine (Pinus albicaulis)

  • Water Howellia (Howellia aquatilis)

  • Spalding's Catchfly (Silene spaldingii)

  • Ute Ladies'-tresses (Spiranthes diluvialis)

Montana Forest Plant Species of Concern

  • Arctic Sweet Coltsfoot (Petasites frigidus var. frigidus)

  • Hiker's Gentian (Gentianopsis simplex)

  • Hollyleaf Clover (Trifolium gymnocarpon)

  • Howell's Gumweed (Grindelia howellii)

  • Idaho Barren Strawberry (Waldsteinia idahoensis)

  • Lackschewitz' Fleabane (Erigeron lackschewitzii)

  • Mission Mountain Kittentails (Synthyris canbyi)

  • Oregon Bluebells (Mertensia bella)

  • Sandweed (Athysanus pusillus)

  • Scalepod (Idahoa scapigera)

  • Sapphire Rockcress (Boechera fecunda)

  • Peculiar Moonwort (Botrychium paradoxum)

  • Columbia Crazyweed (Oxytropis campestris columbiana)

  • Columbia Wild Onion (Allium columbianum)

  • Mealy Primrose (Primula incana)

  • Bristly Sedge (Carex comosa)

  • Giant Helleborine (Epipactis gigantea)

  • English Sundew (Drosera anglica)

  • Slenderleaf Sundew (Drosera linearis)

  • Macoun's Gentian (Gentianopsis macounii)

  • Marsh Felwort (Lomatogonium rotatum)

  • Flatleaf Bladderwort (Utricularia intermedia)

  • Alpine Meadowrue (Thalictrum alpinum)

  • Autumn Willow (Salix serissima)

  • Primrose Monkeyflower (Mimulus primuloides)

  • Creeping Sedge (Carex chordorrhiza)

  • Beaked Spikerush (Eleocharis rostellata)

  • Hudson's Bay Bulrush (Trichophorum alpinum)

  • Slender Cottongrass (Eriophorum gracile)

  • Simple Kobresia (Kobresia simpliciuscula)

  • Tufted Club-rush (Trichophorum cespitosum)

  • Water Bulrush (Schoenoplectus subterminalis)

  • Loesel's Twayblade (Liparis loeselii)

  • Pod Grass (Scheuchzeria palustris)

  • Crested Shieldfern (Dryopteris cristata)

Erica Lighthiser