FS-2025-0001-448391

Secretary of Agriculture Brooke Rollins,Comments for RIN 0596-AD66Our fanily, strongly, opposes 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 should be strengthening protections for roadless areas rather than eliminating 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 mile of an existing road due to human activity like vehicles, campfires, and equipment. Fires started by people are about seven times more common on roaded national forest lands than in the roadless areas. Roads bring people, and people