Read the comments.

Continued: 4. Fire is a part of the ecosystem. To the extent that the rationale is reducing fire, the rationale is wrong, as other commenters have pointed out and as the rationale points out, that more roads lead to more fire activity. But also the entire proposal is misplaced — because the most effective way to address fires of increasing intensity is to address climate change. That is the real national priority that needs to be addressed that the government is completely failing to address. Roads in forests are not a recognized wild-land fire management policy, as other commenters have pointed out. *** Put simply, the repeal of the Roadless Rule is a step backwards in public lands management. It effectively takes public lands out of the hands of the people they are set aside for — the American public — and hands them to special interests who are willing to pay for them. This is not the mandate that the USFS has been given by Congress. The mandate is the manage these lands for multiple uses. Creating new roads in forests prioritizes only one use, timber harvesting, over all others. *** My experience in this comment is drawn from recreating at the following USFS properties: Little Missouri National Grassland; Buffalo Gap National Grassland; BigHorn National Forest; Chequamegon-Nicolet National Forest; Hiawatha National Forest; Ottawa National Forest; Huron-Manistee National Forest; Superior National Forest; Chippewa National Forest; Shoshone National Forest; Custer-Gallatin National Forest; Flathead National Forest; Bridger-Teton National Forest; Caribou-Targhee National Forest; Gifford Pinchot National Forest; Olympic National Forest; Okanogan-Wenatchee National Forest; Mount Baker-Snoqualmie National Forest; Colville National Forest; Medicine Bow-Routt National Forest; Arapaho National Forest; White River National Forest; Black Hills National Forest; Thunder Basin National Grassland; Unit-Wasatch-Cache National Forest; Sierra National Forest; Stanislaus National Forest; Lincoln National Forest; and Shawnee National Forest. My major takeaway from all these experiences is that these Forests already have more roads than most people could explore in a lifetime. There is quite simply no practical or logistical need, from a recreational perspective, for more under the rationales that the USFS has proposed in this rule change.

Dear Acting Director White: We are writing as members of the National Parks Conservation Association’s (NPCA) Midwest Regional Council to urge the U.S. Forest Service to keep the Roadless Rule in place to protect the water, air quality, climate resilience, and wildlife that sustain our national parks. For nearly a quarter century, the Roadless Rule has protected the integrity of key national park ecosystems while allowing appropriate timber management to reduce wildfire risk. Rescinding these protections would leave some of our last intact forests vulnerable to increased logging, mining, oil and gas development, and other harmful uses. In the Midwest, roadless areas are not abstract federal designations. These areas are upstream forests, watersheds, wildlife corridors, and recreation landscapes that support local economies and the national parks people travel from across the world to experience. The Council advises NPCA’s Midwest regional staff and includes business and community leaders committed to securing the future of our national parks. We work with communities and businesses to support national parks in Illinois, Indiana, Kansas, Michigan, Minnesota, Missouri, Nebraska, Ohio, South Dakota, and Wisconsin. Healthy national parks depend on healthy forests, clean waterways, and intact public lands beyond their boundaries, including many places protected by the Roadless Rule. More than 45 million acres of national forest lands are designated as roadless, and nearly 30% of those acres are within 30 miles of national park sites. Across the Midwest Region, the Roadless Rule protects public lands connected to national park landscapes, from Badlands National Park in South Dakota to the wild woods and waters near Voyageurs National Park in Minnesota and Apostle Islands National Lakeshore in Wisconsin. These protections include: Roadless areas in Superior National Forest that help sustain the biodiversity and clean water of Voyageurs National Park, Grand Portage National Monument, and the North Country Scenic Trail. The 5,951-acre Flynn Lake roadless area, 5,510-acre Tea Lake roadless area, and 6,161-acre Moose roadless area in Chequamegon-Nicolet National Forest near Apostle Islands National Lakeshore, which support federally listed species, contain the Moose River headwaters, and offer outdoor recreation opportunities such as hunting, hiking, and paddling. More than 26,000 acres of roadless area in Buffalo Gap National Grassland along the borders of Badlands National Park, protecting important hydrological features that support biodiversity in this semi-arid region. If Roadless Rule protections are rescinded, these lands—and more than 45 million acres of public lands nationwide—could be opened to roadbuilding, large-scale logging, mining, and oil and gas development, putting nearby national parks, gateway communities, clean water, and wildlife at risk. As national park advocates and community leaders from across the region, we urge you to choose the No Action alternative and keep the Roadless Rule in place to protect roadless forests and the national park landscapes they sustain. Thank You, Nicole Barker LaPorte, IN Wendy Bennett Minneapolis, MN Donté Gibbs Peninsula, OH Peter Gove White Bear Lake, MN David Hackett Chicago, IL Jennifer Manville Traverse City, MI Laura Merriam Saint Paul, MN Neil Mortine Worthington, OH Kathleen Schneider Hart, MI Cheryl A. Schreier Custer, SD Dave Walter Edina, MN Michelle Wang Chicago, IL

The elimination of the Roadless Rule threatens 45 million acres, much of which is wilderness, that are currently managed by the U.S. Forest Service. Among the precious areas which are protected by the rule are Sand Creek, Inyan Kara and Beaver Park in the Black Hills National Forest, and Indian Creek, Red Shirt, Cheyenne River, First Black Canyon and Jim Wilson Canyon in the Buffalo Gap National Grassland. The Black Hills National Forest, much loved by sportsmen and recreationists as well as local residents, already has over 7500 miles of forest system roads. The forest would actually be well-served if some existing roads were retired; degradation of our existing roadless areas would be a tragic mistake. The Black Hills are sacred to many Native tribes, including the Lakota, Nakota, Dakota, Cheyenne, Arapaho, Arikara, Hidatsa and Mandan peoples. In addition to providing areas for traditional religious ceremonies, the forest contains ancient (and fragile) rock art which would clearly be threatened by additional road construction. Eliminating protection for our roadless areas raises the threat of reckless over-logging, the destruction of wildlife habitat, popular recreation areas, and clean drinking water that much of western South Dakota and eastern Wyoming depends upon. Construction of additional roads will doubtless lead to more human-caused fires. The threat of off-highway vehicles (ATV’s, UTV’s, side-by-sides and dirt bikes) would inevitably increase conflicts among recreational users of the Black Hills. The Forest Service currently has difficulty enforcing necessary protections, and unauthorized OHV routes are already degrading the Black Hills with dust, noise, congestion and damage to existing trails. We do not need a regulatory change that significantly worsens these problems. There is an urgent need to protect clean drinking water at a time of increasing drought in our region. Groundwater in the Black Hills is an interconnected system, and the Madison and Minnelusa aquifers protect our environment and our quality of life. Undisturbed creeks in the Black Hills support our wild trout population. There is also a need to protect endangered species, and increased human access in motorized vehicles will threaten our elk, mule deer, mountain lion, bighorn sheep, wild turkey, northern goshawk and other vital species in our region. For all of these reasons, we implore our federal government to leave the Roadless Rule intact.