“I am writing as a public lands user to oppose the proposed rescission of the 2001 Roadless Area Conservation…”

I am writing as a public lands user to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RR). I urge the Forest Service (FS) to retain the current RR under Alt. 1 & reject the proposed nationwide rescission under Alt. 2 & 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 RR was established in part due to the failure of local forest planning process to maintain ecological, cultural, & 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 protection measurements. As a recreationalist, I am concerned about the claim that removing the RR is necessary to reduce wildfire risk & 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 & fuels management, but it can also increase opportunities for unplanned human-caused ignitions. 96.2% of fires start within 800m of a road (Pacific Biodiversity Inst.). It is clear that more roads mean more fires. Wildfire risk reduction should not be used as a blanket justification for expanding roads & 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 & firefighters, rather than broadly removing protections from remote landscapes. I urge the FS to explain how proposed road construction or vegetation management would demonstrably improve firefighter safety, & to fully account for the increased ignition risks & long-term maintenance burdens associated with new roads. The agency should also disclose & analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, & future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks & hazards during suppression operations. Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction & logging, mining, & drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, & other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected & biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction & timber harvest are reasonably foreseeable if the RR is rescinded or revised under Alt. 2 & 3. I am particularly concerned about wildlife habitat & connectivity. The FS 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 & fragmentation of roadless landscapes across the NFS. The DEIS recognizes that additional road construction & timber harvesting could have long-term negative effects on Tribal rights & interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, & other culturally significant areas. I urge the FS to ensure meaningful government-to-government collaboration & to fully incorporate Tribal knowledge & concerns before any decision is made to remove protections. Regarding Indigenous sovereignty, I am particularly concerned about increased unauthorized access. New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, & resource extraction. These consequences should be considered alongside direct impacts to culturally significant places & treaty-reserved resources. Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed. For these reasons, I urge the FS to retain the 2001 Roadless Rule under Alt. 1 & reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge & rights, & the long-term safety of firefighters & communities.