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Director, Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Re: Comments on Proposed Rescission of the 2001 Roadless Area Conservation Rule Docket No.: FS-2025-0001 / RIN: 0596-AD66 Dear Director, I am writing to submit substantive comments opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. As an active recreational user of inventoried roadless areas (IRAs) across the Sierra Nevada, Olympic, Okanogan-Wenatchee, and Huron-Manistee National Forests, I have direct experience with the vital ecological and public values these unroaded landscapes provide. I urge the agency to select the No Action Alternative and retain the 2001 Rule. The proposal to open IRAs to commercial road construction relies on flawed fire risk assumptions, ignores severe maintenance liabilities, and understates irreversible impacts to critical watersheds. My specific technical objections to the Draft Environmental Impact Statement (DEIS) are: 1. Inadequate Analysis of Human-Caused Ignitions vs. Mitigation The agency's premise that road construction reduces catastrophic wildfire risk through thinning is contradicted by fire science data. Road networks are primary vectors for human-caused ignitions. In drier ecosystems like the eastern Okanogan-Wenatchee and lower Sierra Nevada, surface disturbance from road building facilitates the spread of invasive fine fuels like cheatgrass, which significantly increases fire return intervals. Furthermore, the 2001 Rule already contains explicit exceptions (36 CFR § 294.13) for hazardous fuel treatments near wildland-urban interfaces. The DEIS fails to demonstrate why these existing exceptions are insufficient. 2. Failure to Account for Maintenance Backlogs and Lifecycle Costs The Forest Service currently carries a multi-billion-dollar deferred maintenance backlog on its existing 370,000-mile road network. Adding temporary or permanent routes in steep, unstable terrain—such as the high-precipitation zones of the Olympic NF—generates long-term erosion, culvert replacement, and maintenance liabilities. The DEIS lacks a comprehensive lifecycle cost-benefit analysis comparing the short-term economic yield of timber harvest against the long-term capital liability of road maintenance and decommissioning. 3. Cumulative Watershed and Hydrological Risks IRAs serve as high-integrity anchor watersheds. In the Olympic and Okanogan NFs, IRAs encompass headwaters vital to threatened salmonid species (e.g., bull trout, Chinook). Road construction and timber haulage increase stream sedimentation and degrade spawning gravels. In the Sierra Nevada, canopy disruption from road corridors alters snowpack retention, exacerbating late-season water scarcity. In the Huron-Manistee NF, fragile sandy soils and groundwater-dependent cold-water trout streams are exceptionally vulnerable to runoff and nutrient loading from unpaved corridors. 4. Degradation of Backcountry Recreation Economies Converting remote roadless tracts into industrial zones permanently degrades their primitive character. This violates the balanced multiple-use mandate by shifting economic value away from growing local outdoor recreation economies that rely heavily on quiet, non-motorized backcountry access. Requested Actions: Adopt the No Action Alternative, maintaining the uniform national protections of the 2001 Roadless Rule. Utilize existing administrative exceptions within the 2001 Rule to execute targeted, community-adjacent hazardous fuel treatments without permanent road construction. Address localized fuel concerns through site-specific NEPA analyses within existing forest plan revisions, rather than a sweeping national repeal. Sincerely, Albert Karl Henning, PhD Palo Alto, CA