FS-2025-0001-318857

Secretary of Agriculture Brooke Rollins,Comments for RIN 0596-AD66We, strongly, oppose the "U.S. Department of Agriculture" ’s proposal to repeal, or, weaken, the, landmark, Roadless Area Conservation Rule" that has protected wild, unfragmented, forests for more than a quarter century. The rationale offered for doing so is NOT supported by science, violates the, public, trust, doctrine, and, would unleash, irreparable, harm to our National Forests.Endangered Species: the recovery, and, long-term, survival of, many, imperiled, species are, highly, dependent upon, existing, roadless, areas. The Forest Service" ’s, own, biological, assessment determined that rescinding the "Roadless Rule" is “likely to adversely affect” 327 Threatened, and, Endangered, species, and, 71, designated, critical, habitats. Imperiled animals, and, plants, need, adequate, secure, habitats to survive, thrive, and, ultimately, recover to, sustainable, population, levels.Biodiversity: wild, nature is under assault both within the U.S., and, globally. Both the number of species, and, the abundance of animals are in, sharp, decline at a pace NOT experienced, on Earth, for, approximately, 60 million, years. A, sixth, mass, extinction, of life on Earth, is, clearly, underway, with, measured, extinction, rates of 100-1,000 times, normal, background, levels. Monitored, global, wildlife, populations, of, land, animal, populations, have declined by about 69 percent over the, last, 50 years (1970-2020). North American, bird, populations have declined by about 29 percent (~3 billion birds) since 1970, including, many, imperiled, species. A, major, cause of the decline is, habitat, destruction, and, fragmentation. With, more, species endangered, today, and, wildlands disappearing at a, rapid, pace, roadless, areas are, more, important than ever to address, ongoing, wildlife, decline, and, the, extinction, crisis. Roads serve as conduits for, invasive, species, which can out compete, native, species. Opening, existing, roadless, areas to, road, building, and, resource, extraction, activities, like logging, and, mining, will, further, exacerbate the decline of, wildlife, habitats and, the wildlife they support.Ecological Health and Services: healthy, ecosystems are critical to the, long-term, survival of both, wild, nature, and, human-dominated, landscapes. Benefits include, ample, secure, habitats for, both, imperiled, and, non-imperiled, species. Benefits to humans include, sustainable, supplies of freshwater to, 354, municipalities, compounds used in more than 50 percent of, modern, medicines, carbon, storage, and, climate, moderation, purification of water, and, air, soil, formation, nutrient, cycling, treatment of, both, mental, and, physical, health, conditions, and, outdoor, recreation. Once roads are built, habitat, fragmentation, and, ecosystem, impacts can persist for decades. At a time when, biodiversity, loss, and, habitat, degradation continue to threaten wildlife, across the U.S., the "Forest Service" MUST strengthen protections for, roadless, areas, NOT eliminate them!The U.S. Timber Supply: the, federal, timber, program has, never, been profitable. Over 40 years, logging, on National Forests, has resulted in $227 million, in revenue, while costing a, staggering, $1.96 billion to implement — a return of about $1 dollar for, every, $8 of, federal, investment! This is an, inexcusable, loss of, U.S., taxpayer, dollars, and, public, resources! National Forests produce, only, a, small, fraction of the, total, U.S., timber, production! The "U.S. Forest Service" admits that, private, forests supply more than 90 percent of, U.S., forest, products, mostly, from, large, timber, plantations.Too Many Roads Already: the "National Forest System", currently, has, approximately, 370,000 miles of roads, which the "Forest Service", already, cannot afford to, fully, maintain. The Agency’s, road, maintenance, and, reconstruction, backlog is $8.6 billion! Building, more, roads is NOT a, fiscally, responsible, idea given the, massive, backlog of, road, maintenance, needs that, currently, exists!Fire Risks: wildfires are, much, less, frequent in, protected, roadless, areas, which comprise about 30 percent of, National Forest, lands, but, account for, only, about, three, percent of, all, wildfires that start on, "Forest Service", lands. Wildfire-ignition density is lower in roadless forests (about 1.9 fires per 2,500 acres) compared to areas near roads, where the rate is up to, four, times higher. Fires in, remote, areas, which, often, are sparked by, lightning, strikes, tend to burn, far, fewer, acres. Approximately, 90 percent of, all, wildland, fires ignite within a half m