FS-2025-0001-466351

The U.S. Department of Agriculture is proposing to rescind the 2001 Roadless Area Conservation Rule, which has protected approximately 44.7 million acres of National Forest System lands from road construction and timber harvest for more than two decades. The single most damaging flaw in the agency's analysis is that it relies on wildfire risk as the primary practical rationale for rescission while its own data in Table 26 shows that roads were associated with successful fire containment on only 23.5 percent of road miles that encountered large wildfires, and the agency simultaneously acknowledges that most new roads built under the action alternatives would be temporary timber-harvest spur roads rather than strategically placed, higher-standard roads designed for fire suppression. No fiscal analysis is provided showing how additional road mileage would be funded given the existing $6.9 billion deferred maintenance backlog and a 70 percent decline in appropriated road funding over the last 20 years. The draft EIS contains additional unresolved analytical gaps that require correction before a final rule is issued. First, the agency's preliminary biological assessment found 'may affect, likely to adversely affect' determinations for 327 ESA-listed species and 71 critical habitats, yet Section 7 consultation with USFWS and NMFS remains incomplete, meaning the public cannot evaluate the legal sufficiency of the proposed action (Biodiversity section). Second, the agency's own insect-and-disease risk data in Table 14 shows that IRA forests in most western regions have equal or lower mortality risk than already-roaded NFS forests outside designated areas, directly undercutting the forest-health rationale for rescission. Third, Table 35 documents that approximately 24 million people outside Alaska obtain drinking water from watersheds containing potentially affected IRAs, yet the document provides no quantitative estimate of increased sediment loading or municipal water-treatment cost increases under alternatives 2 and 3. Fourth, tribal consultation is incomplete: only 29 of 64 requested government-to-government consultations had been held at time of publication, and the Tribal Impact Summary Statement will not be available until the final rule, depriving Tribes of meaningful participation in the comment process (Agencies and Persons Consulted section). Based on the foregoing, I request that the agency take the following specific actions before issuing a final rule: (1) extend the public comment period until all requested tribal consultations are complete and the Tribal Impact Summary Statement is published for review; (2) complete and publish the USFWS and NMFS biological opinions and make them available for public comment before the comment deadline; (3) prepare and disclose a quantitative fiscal analysis of projected new road maintenance costs under alternatives 2 and 3 against available funding sources; (4) prepare a quantitative analysis of projected increases in sediment delivery and municipal water-treatment costs for the approximately 24 million downstream water users; (5) add to the final EIS a detailed alternative that allows temporary-road-based hazardous fuel treatment and selective harvest inside IRAs without authorizing permanent road construction, and provide a non-circular explanation of why such an alternative cannot meet the stated fire and forest-health objectives; and (6) identify which specific land management plan amendments are required to provide equivalent IRA protections before rescission takes effect, given the agency's own finding that most current plans lack adequate IRA-specific direction.