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The Upper Hondo Soil & Water Conservation District supports the rescission of the 2001 Roadless Area Conservation Rule and offers the following comments:
•Since 2001, the Roadless Rule—through centralized management and an extensive history of litigation—has proven ineffective and costly.
•The result has been widespread mismanagement and the loss of millions of acres of overgrown forests to wildfire, disease, and drought.
•These losses represent billions of dollars in natural resources, including timber that could have been used to build affordable housing to replace homes lost to wildfires and to address the severe housing shortages frequently highlighted in media coverage of homelessness in major urban areas.
Upper Hondo Soil & Water Conservation District supports rescinding the 2001 Roadless Rule because doing so decentralizes road management and places responsibility for creating, decommissioning, and maintaining roads with individual National Forest Supervisors.
•Each National Forest is unique, and local supervisors are far better positioned to understand the environmental conditions and management needs of their respective forests than staff located in Washington, D.C., thousands of miles removed from on the ground realities.
•Local decision making regarding road creation, maintenance, or decommissioning must consider multi use objectives such as recreation, grazing, forest thinning for fire mitigation, and overall forest health.
•Roads that were decommissioned under the Rule rarely received the funding necessary to address erosion issues either before or after decommissioning. Forest Supervisors should work directly with local Soil and Water Conservation Districts to resolve these problems.
•Each National Forest’s Land Management Plan should address road system needs based on local conditions and priorities.
•Roads identified as Potential Operational Delineation (POD) boundaries must be thinned and upgraded to standards that ensure safe ingress and egress during wildfire events.
•Individual National Forests must be adequately resourced—with both funding and personnel—to maintain existing roads and prevent the creation of illegal user built roads and illegal dumping on Forest Service lands.
•Individual National Forests should provide clear, detailed information in their Land Management Plans describing how they will manage the road system. Additionally, taking more than seven years to revise a Land Management Plan is unacceptable; for example, the revision of the 1986 Lincoln National Forest Plan, ongoing since 2019, has taken far too long with no clear end in sight.