Secretary Brooke Rollins
U.S. Department of Agriculture
201 14th Street SW
Washington, DC 20250
Thomas Schultz, Chief
U.S. Forest Service
1400 Independence Avenue, SW
Washington, DC 20250-0003
Re: Docket No. FS-2025-0001 — Comments on the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement (DEIS)
Dear Secretary Rollins and Chief Schultz:
On behalf of The Fairfield Garden Club, I strongly urge the U.S. Department of Agriculture (USDA) and the U.S. Forest Service to retain the 2001 Roadless Area Conservation Rule (Roadless Rule), select the No Action Alternative, and revise the Draft Environmental Impact Statement (DEIS) to provide a more complete assessment of the reasonably foreseeable environmental consequences of rescinding these nationwide protections.
Members of The Fairfield Garden Club value and enjoy the forests and roadless areas of the Northeast, including Vermont's Green Mountain National Forest, New York's Finger Lakes National Forest, and New Hampshire's White Mountain National Forest, among many other public lands. These areas provide opportunities for hiking, recreation, solitude, wildlife observation, and appreciation of intact natural landscapes. They also provide clean water, wildlife habitat, and connected ecosystems that benefit communities far beyond the boundaries of individual forests.
For our members and many other members of the public, the absence of roads is itself an important conservation value. Roadless areas provide places where people can experience forests with fewer disturbances while also maintaining habitat connectivity and protecting watersheds. These lands should not be treated simply as areas awaiting future road construction or timber development.
The existing Roadless Rule already permits important forest management
The current Roadless Rule does not prohibit all forest management or wildfire-prevention activities. It allows substantial management activities, including prescribed fire and other hazardous-fuels reduction measures under applicable circumstances.
The DEIS itself cites research indicating that the absence of roads has not prevented necessary fire prevention or fire protection measures. The DEIS cites research that 1) the lack of roads has not prevented fire prevention or protection measures, and 2) acknowledges that almost 90% of wildfires are human-caused and more than four times likely to ignite near a road. If specific constraints exist, USDA should identify and address those narrow constraints rather than remove the Rule’s nationwide protections.
USDA has not adequately assessed the reasonably foreseeable national and regional environmental effects of its decision to eliminate the Rule’s protections across 44.7 million acres of public lands. Deferring NEPA review to future site-specific individual projects will not address the regional and national consequences of rescission. While later reviews may evaluate individual projects, they would not address foreseeable programmatic impacts at scale from landscape fragmentation, habitat connectivity, native plants and invasive species. interstate or inter-forest migration corridors, or regional watersheds. USDA should assess now where national rescission would put intact habitat, wildlife movement, and native plant communities at greatest risk, and where added roads and timber harvest could most threaten watersheds and drinking-water sources.
Rescission would also remove protections from 9.3 million acres in the Tongass National Forest, relying on the 2020 Alaska Roadless Rule Final EIS, but it has not demonstrated the earlier environmental analysis adequately evaluates rescission. Tribal consultation remains incomplete. USDA should fully consider Tribal concerns about subsistence, cultural resources, fish and wildlife, and intact landscapes before making a final decision.
I urge you to keep the Rule's national protections in place and reassess the reasonably foreseeable effects now.
Regards,
Susan Bonner
Ann Franzen
Co-Presidents
The Fairfield Garden Club