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

"I am writing as a Civilian to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). As a Civilian, I am concerned about the claim that the proposed rescission emphasizes greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning process to maintain ecological, cultural, and public values of roadless areas at an adequate level across the National system. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protection measurements. 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. As a Civilian, I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk. 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). 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. I am particularly concerned about wildlife habitat and connectivity, sensitive/endangered/threatened species, invasive species, biodiversity, clean water, soil erosion, climate resilience, recreation access, firefighter risk, landscape fire restoration, solitude and landscape connectivity. The claim that putting these forests under local control would have little adverse impact on the land managers' ability to protect undeveloped wildlands puts these values at risk. I have an intimate knowledge of the Bridgeport (Mt. Hicks, Aurora Crater, Mt. Jackson, Hoover Areas etc.), Lee Vining (Mono Craters, Log Cabin Saddlebag, Tioga Lake etc.), Mammoth (Laurel McGee, Sherwin, San Joaquin, Rock Creek, Glass Mountain etc.), Bishop (Wheeler Ridge, Buttermilk, Coyote North and South, Boundary Peak, etc. ), Big Pine and Lone Pine (Soldier Canyon, Paiute, Tinemaha, Independence Creek etc.) roadless areas. I am particularly concerned about Climate change Keep the roadless rule by choosing the no action alternative."