Several Key Problems with the Forest Services’ Proposed Repeal of the Roadless Area Conservation Rule

Nature & Climate Perspective

**The proposed repeal of the Roadless Area Conservation Rule places 58. 5 million acres of intact public forest ecosystems at immediate risk, compromising critical North American carbon sinks and high-integrity biodiversity corridors.**

• Road construction and commercial timber harvesting threaten to fragment contiguous interior forest biomes, driving severe habitat loss, edge effects, and degradation of vital cold-water aquatic ecosystems.
• Industrial access exposes extensive old-growth and mature standing stocks to harvest, undermining national LULUCF carbon reservoirs and reversing decades of accumulated terrestrial biogenic carbon sequestration.
• The potential degradation of natural disturbance buffers elevates structural vulnerability to catastrophic wildfire and pest outbreaks, directly defying the ICVCM Core Carbon Principles (CCPs) regarding permanence and ecological integrity safeguards.

Market & Policy Outlook

**Dismantling federal roadless protections destabilizes jurisdictional LULUCF baselines, impairs US compliance credibility, and introduces severe Scope 3 supply chain exposure for forest products under SBTi criteria. **

• The regulatory shift fundamentally weakens the baseline additionality assumptions required for compliance and Article 6.4-aligned crediting mechanisms, challenging federal forestlands' eligibility for high-integrity carbon mechanisms.
• Market confidence in domestic nature-based solutions is disrupted, as the loss of durable federal protection creates baseline confusion, higher buffer pool requirements, and potential pricing downgrades for neighboring carbon projects.
• Corporations working under SBTi Forest, Land, and Agriculture (FLAG) guidance face increased Scope 3 deforestation and land-use-change risks within domestic timber and wood-fiber supply chains, complicating B Corp and green procurement commitments.