“I am a field biologist who regularly works on national forests containing inventoried roadless areas in…”

I am a field biologist who regularly works on national forests containing inventoried roadless areas in California that would be impacted from the rescission of the 2001 Roadless Rule including: Stanislaus NF, Sierra NF, Plumas NF, and Mendocino NF. I also regularly visit Coronado NF lands containing inventoried roadless areas in Arizona, including the Chiricahua Mountains, Dragoon Mountains, Santa Rita Mountains, and Catalina Mountains. These lands and the communities that inhabit and rely on them, some of which are threatened and endangered species, are sensitive to further fragmentation and degradation from development. Their watersheds (which humans also rely on) are sensitive to the erosion and sedimentation caused by construction and maintenance of new roads and/or other development. I strongly oppose the recission of the Rule and list objections to the rationale for the Proposal and to the draft EIS below. One of the main stated rationales for rescission of the Rule presented in the Proposal is the need to return control of inventoried roadless areas to local FS authorities because the national 2001 Roadless Rule was too restrictive and burdensome to locally adapt, specifically regarding active management for fire and fuels. Yet, on page 14 of the draft EIS, Table 1., 2001 Roadless Rule exceptions (alternative 1) (36 CFR 294.12(b) and 294.13(b) (2001)), states: “Road construction, reconstruction, including temporary road construction, is prohibited in inventoried roadless areas, except when: 1) A road is needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property” Fuel reduction projects on FS lands in California have been actively taking place since the Roadless Rule went into effect. I know this because I have worked on these projects. I also know this because there is published research documenting these activities: “The findings in our analysis are consistent with other studies, including research supported by the Forest Service’s Rocky Mountain Research Station, which evaluated nearly twenty years of monitoring data, concluding that “a lack of roads in IRAs [Inventoried Roadless Areas] has neither prevented fuel treatment nor led to substantially more fire” (Trout Unlimited 2026). On page 24 of the draft EIS, Table 3., which shows comparison of effects under alternatives 1-3 divided by resource/topic, under Fire and Fuels Management, it states “Currently, the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands. Under alternatives 2 and 3, if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads.” This statement, along with statistics from other published, peer-reviewed, and agency-accepted studies regarding the topic (see below), refute the argument that adding additional roads would reduce fire risk by any meaningful amount. “Analysis of information about ignition source and location from the Forest Service fire occurrence dataset (USA.FireOccurrence) shows the occurrence of human-caused wildfire ignitions is strongly correlated with roads. Seventy-eight percent of human-caused fires on NFS lands nationwide start within ½ mile of a road” (Trout Unlimited 2026). References: Trout Unlimited, 2026. Roadless: Active Management and Fire A GIS data analysis and research review. September 2, 2026. Accessed October 5, 2026, online at https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa.