Secretary Brooke Rollins
U.S. Department of Agriculture
1400 Independence Ave. SW
Washington, DC 20250
Thomas Schultz, Chief
U.S. Forest Service
201 14th Street SW
Washington, DC 20250
Re: Docket No. FS-2025-0001: Opposition to Rescission of the 2001 Roadless Area Conservation Rule and Comments on the Draft Environmental Impact Statement
Dear Secretary Rollins and Chief Schultz:
I urge USDA to retain the 2001 Roadless Area Conservation Rule, select the No Action Alternative, and revise the Draft Environmental Impact Statement (DEIS) as described below.
I spend time in the Bridger-Teton National Forest near Jackson, Wyoming, most recently this September, including the Inventoried Roadless Areas along the Gros Ventre River east of town. I hike there and watch for elk, moose and other wildlife. What stays with me is how quickly the land beyond the Gros Ventre Road opens into quiet, unbroken forest and ridgeline, a short drive from a busy valley. Places like this provide clean water, wildlife habitat, recreation, solitude and some of the last intact forest in the country, and they stay that way only because no roads cut through them.
The Rule already permits substantial forest management, including prescribed fire and hazardous fuels reduction. USDA argues that rescission would lower wildfire risk, yet the DEIS cites research finding that the absence of roads has not impeded fire prevention or protection work. The DEIS also acknowledges that nearly 90 percent of wildfires are human caused and that fires are more than four times as likely to start near a road. New roads would add ignition sources, not remove them. If specific constraints on fuels work exist, USDA should identify and address them directly rather than remove protections nationwide.
The DEIS does not adequately assess the reasonably foreseeable national and regional effects of removing protections from 44.7 million acres of public land. Deferring NEPA review to future site-specific projects cannot fill that gap. Project-level reviews will not capture cumulative effects on landscape fragmentation, habitat connectivity, native plant communities, invasive species, interstate and cross-forest migration corridors, or regional watersheds. In the Greater Yellowstone Ecosystem, where elk, pronghorn and other wildlife move across multiple forests and state lines, those cumulative effects are the whole question. USDA should analyze now where rescission would most endanger intact habitat, wildlife movement and native plants, and where new roads and logging would most threaten watersheds and drinking water supplies.
Rescission would also remove protections from 9.3 million acres of the Tongass National Forest. USDA relies on the 2020 Alaska Roadless Rule Final EIS but has not shown that this earlier analysis adequately evaluates rescission. Tribal consultation is also incomplete. USDA should fully weigh Tribal concerns about subsistence, cultural resources, fish and wildlife, and intact landscapes before reaching a final decision.
I urge you to keep the Rule's national protections in place and to analyze the reasonably foreseeable effects of rescission now, before any final decision.
Sincerely,
Ryan McMorrow