09/09/2026
RMEF ROADLESS RULE & TRAVEL MANAGEMENT RULE STATEMENT
ROADLESS RULE & TRAVEL MANAGEMENT RULE STATEMENT
The 2001 Roadless Rule has been in effect for 25 years placing management restrictions across 44.7 million acres of public land. Unfortunately, even before the draft environmental impact statement and its three alternatives were released in August, the discourse on this topic from special interests on all sides has been hyperbolic and polarizing. The Rocky Mountain Elk Foundation (RMEF) has resisted
initial pressure to take an immediate or reactive position on the proposal. Rather, to fulfill our obligation to RMEF members and supporters, we are evaluating the proposal through the lens of our
mission; which is to ensure the future of elk, other wildlife, their habitat and our hunting heritage.
Over the past 25 years big game habitat conditions on National Forests, including the Inventoried Roadless Areas (IRAs), have degraded. Elk and other big game rely on quality habitat to thrive. The four pillars of quality habitat include food, water, security, and space. Too much of one, or not enough of another, results in degraded habitat conditions. While the blanket Roadless Rule has played a key role in providing wildlife security and space, it has also in many cases worsened forage (food) conditions and water development.
Elk and other big game may also be negatively impacted by disturbance. The proliferation of roads and trails that reduce elk and big game security have negative impacts on reproduction and distribution. Both motorized and non-motorized recreation on trails and roads cause elk and other big game to move, often to lower quality habitats or to less disturbed private land. If the disturbance is on calving and fawning grounds, or on winter range at critical times, the population can be significantly impacted.
The evaluation of the Roadless Rule and the scoping of potential changes to the 2005 Travel Management Rule are directly related. The fundamental big game question is how the interplay between active forest habitat management and ongoing recreational disturbance will be balanced against elk and big game security.
Our conclusion is that over the past 25 years, despite the Roadless Rule, many elk and other big game populations have shifted from National Forests to private lands. RMEF is skeptical of one-size-fits-all policies like the Roadless Rule and places a greater emphasis on localized management of forests for sustainable habitat. The four pillars of quality habitat require balance, localized prescriptions, and
common sense.
Entering the public comment process, we were particularly interested in nearly one quarter of Inventoried Roadless Areas that today lie in the Wildland-Urban Interface (WUI). Upon reviewing the
details of the proposed rule, alternative 3 appears to address these specific areas. Alternative 3 presents several items we support, including:
• Increased opportunities for hazardous fuel treatments in the Wildland-Urban Interface, where 9.8 million acres (or 24 percent) overlap with IRAs, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure
• Expanded scope and applicability with the addition of boundary modifications. This supports local assessment and decision-making on the remaining 13 million acres that would be retained as roadless
• Expanded opportunities for active forest management and improved big game habitat
• Retention of remote recreation opportunities
Alternative 3 also presents some items that are of concern or require greater detail, including:
• RMEF would seek clarity as to why the mapping analysis used WUI as defined by Healthy Forests Restoration Act of 2003. The data source used may significantly alter the acreage removed from - or remaining in - roadless boundaries
• Modification to USFS Chief authority under §294.14 Scope and applicability. As currently written, the Chief may make roadless boundary modifications to conform with new 'statutory or regulatory requirements’. Modifications under these situations should follow typical processes to ensure compliance with the National Environmental Policy Act (NEPA) and other relevant laws and regulations.
It is important to understand that, despite rhetoric and talking points, rescinding the Roadless Rule does not allow unregulated logging or road building on National Forests. Activity on these lands is subject to the National Environmental Policy Act (NEPA), Endangered Species Act (ESA), the Clean Water Act, and locally crafted forest management plans. These plans can and should include seasonal closures of roads and trails to protect big game during critical periods. These plans must additionally address wildfire threats, proactive forest/habitat management, and reasonable hunter access. As the Forest Service undertakes revisions to, or recission of, the Travel Management Rule, RMEF will advocate that wildlife impacts must be of significant consideration and decision-making must lie with individual Forest Service Units.
RMEF members and supporters have varied and strong opinions on the Roadless Rule. Public comments on the proposed Roadless Rule draft environmental impact statement are being accepted until September 21, 2026. RMEF strongly encourages our members and supporters to submit their comments through the established public comment process.
