“I am writing as a to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the…”

I am writing as a to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to retain the current Roadless Rule under Alternative 1 and reject the proposed nationwide rescission under Alternative 2 and any alternative that substantially weakens protections. The DEIS stated purpose of the proposed rescission emphasizes greater local decision-making authority in forest planning processes. Yet, the original Roadless Rule was established in part due to the failure of the local forest planning process to maintain ecological, cultural, and public values of roadless areas to an adequate level. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protective measures. I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk and that putting these forests under local control would have little adverse impact on the ability to protect their values as undeveloped wildlands. The DEIS recognizes that increased road construction can provide additional opportunities for wildfire response and fuels management, but it can also increase opportunities for unplanned human-caused ignitions. 96.2% of fires start within 800 meters of a road. It is clear that more roads mean more fires. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. The agency should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by an analysis of trade-offs026.08.25 of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks and hazards during suppression operations. Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System. Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, and other ecological values. The Roadless Area Conservation Rule was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the Roadless Rule is rescinded or revised under Alternatives 2 and 3. The Forest Service should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, and other culturally significant areas. I urge the Forest Service to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections. New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources. Future consultation on individual projects is not an adequate substitute for considering these impacts before nationwide protections are removed. For these reasons, I urge the Forest Service to retain the 2001 Roadless Rule under Alternative 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities. Thank you.