2 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
Own letter
Own letter
The comment
Comments on the 2001 Roadless Area Conservation Rule
Docket number FS-2025-001
Executive Summary
Mitch Keiler, Environmental Programs Manager and former natural resources professional, submitted this formal comment strongly urging the U.S. Forest Service to adopt the No-Action Alternative and retain the 2001 Roadless Area Conservation Rule (Docket number FS-2025-0001). Drawing from a 40-year career in public land stewardship, Keiler argues that completely rescinding the national safeguards will trigger severe, irreversible degradation across distinct American ecosystems.
The letter attached as a separate file outlines critical, region-specific ecological and economic risks associated with the proposed rule rescission:
•Medicine Bow-Routt National Forest (CO): Road construction and commercial logging will cause severe forest fragmentation, disrupting vital migration corridors for big game (elk, mule deer, bighorn sheep). Furthermore, USFS data indicates timber roads will double the presence of invasive plants in subalpine zones, threatening Colorado's multi-billion-dollar outdoor recreation economy.
•Monongahela National Forest (WV): Developing steep, highly erodible Appalachian slopes will cause massive sedimentation in crucial headwater streams that feed the Ohio and Potomac River basins. This degradation will escalate municipal water treatment costs for millions of residents and decimate native brook trout habitats.
•Washington State: Opening remote, temperate rainforests and old-growth stands to road building will compromise powerful carbon sinks, undermining federal climate mandates. Additionally, proximity to roads is shown to quadruple wildfire ignition density, creating an unacceptable risk to local communities.
•Maine: Removing protections will fragment the last remaining intact blocks of northern hardwood and boreal transition forests. This isolation threatens vulnerable interior forest species, including the Canada lynx and pine marten.
Financial & Legal Conclusion: The letter concludes by pointing out that modest projected timber revenues do not offset the staggering capital costs of new road construction, especially given the agency's existing $7 billion road maintenance backlog. Keiler asserts that rescinding the rule shortchanges long-term ecological stability, clean water security, and tribal treaty rights for deficit-ridden, short-term extractive gains.
Enclosure: Letter for the Record