“Docket No. FS-2025-0001 Special Areas; Roadless Area Conservation; National Forest System Lands I, T…”

Docket No. FS-2025-0001 Special Areas; Roadless Area Conservation; National Forest System Lands I, T Cartwright, strongly oppose the proposed rescission of the 2001 Roadless Area Conservation in this "Special Rule". As a resident, recreationist, and steward of the lands surrounding the Fremont-Winema National Forest and Sky Lakes Wilderness, I view this proposal not as a routine regulatory update, but as a serious threat to the public trust that prioritizes short-term corporate gain over long-term public interests. Technical and Factual Concerns: The 2001 Roadless Rule protects approximately 60 million acres of inventoried roadless areas (IRAs). Rescinding national-level prohibitions would remove protections from approximately 55 million of those acres. The USDA’s justifications are unpersuasive: “Flexibility”: The rule already operates alongside forest plans and site-specific review. Rescission would eliminate consistent national safeguards, leaving roadless lands vulnerable to piecemeal road construction, logging, and commercial development. “Regulatory Burden”: The rule is not an absolute ban. It contains limited exceptions and operates alongside the Clean Water Act, Endangered Species Act, and Wilderness Act. The burden being reduced is not administrative—it is the protection of irreplaceable public lands. Permanent Loss: Once roads, motorized use, or commercial logging are introduced, the wilderness character may be permanently destroyed. No future Congress can restore an ancient forest or replace a thousand-year-old tree after it has been logged. Personal, Community, and Economic Impacts: My family, neighbors, and community rely on these roadless areas for irreplaceable experiences and essential services. We canoe, hike, camp, and sail in this wilderness, and our wells depend on the watershed protections these lands provide. Roadless areas support an outdoor recreation economy contributing approximately $1.2 trillion nationally. Sacrificing these places for short-term extractive profits undermines the long-term, sustainable economic benefits rural communities depend on. These forests are among our last intact systems for storing carbon, mitigating climate change, protecting clean water, and maintaining connected habitat. Treating them as a “renewable commodity” ignores their ecological value and the consequences of industrial disturbance. Supported by over 1.6 million Americans at its inception, the Roadless Rule remains a highly popular conservation policy. Reversing it through omnibus legislation, land swaps, or processes avoiding meaningful professional and public scrutiny violates public trust. Recommendations for Genuine Stewardship: To balance stakeholder interests, the USDA and U.S. Forest Service should pursue reforms that strengthen stewardship rather than expand extraction: Provide full funding to address the ~$22 billion deferred-maintenance backlog and restore staffing for rangers, scientists, and land-management crews. Require fair-market-value payments for grazing, drilling, and timber, with revenues reinvested in restoration and public-land management. End privatization of core services, including campground and visitor operations, to preserve public accountability. Codify National Monument boundaries through Congress to prevent unilateral revocation. Permanently prohibit commercial logging of old-growth and mature forests on public lands. Restore and strengthen NEPA and Endangered Species Act review for development projects. Recognize conservation as a primary, enforceable use of public lands, taking precedence over extraction to protect ecological integrity. Create a permanent, year-round federal wildland firefighting service with full benefits. Establish a new Civilian Conservation Corps dedicated to planting trees, repairing trails, and restoring ecosystems. Conclusion: The agency has provided no adequate scientific justification for reversing decades of established protection. A change of this magnitude, made despite substantial public opposition and without a documented evidentiary basis, is arbitrary and capricious. I respectfully request that the USDA immediately withdraw the proposed rescission of the 2001 Roadless Rule and reject any “Special Rule” changes that weaken protections for wilderness study areas or roadless country. Our wild Public Lands are a finite inheritance and a national trust. They are not for sale. Keep and Expand the 2001 Roadless Rule.