Secretary Brooke Rollins
U.S. Department of Agriculture
201 - 14th Street, SW
Washington, DC 20250
Mr. Thomas Schultz
Chief, U.S. Forest Service
1400 Independence Ave., SW
Washington, D.C. 20250-0003
Dear Secretary Rollins and Chief Schultz:
Re: Docket No. FS-2025-0001 - Comments on the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement (DEIS)
I strongly urge USDA to keep the 2001 Roadless Area Conservation Rule (Rule) intact, select the No Action Alternative, and revise the DEIS as stated below.
Over the course of my life, I have spent considerable time in our nation's Roadless Areas, including George Washington Forest where I have enjoyed hiking, picnicking, and relishing the flora and fauna. These Roadless Areas provide a rebalancing of life's stresses, connection to our natural world, and provide clean water and protected wildlife habitat in our nation's increasingly rare intact forests. I would like yours and my grandchildren to similarly enjoy what you and I have been blessed with.
The current Rule already allows substantial forest management, including prescribed fire and other hazardous-fuels reduction. While USDA claims rescission would reduce wildfire risks, 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 impacts 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. Impacts would include landscape fragmentation negating habitat connectivity, damage to native plants and proliferation of invasive species. It would limit interstate or inter-forest migration corridors and impact 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 remove protections from 9.3 million acres in the Tongass National Forest. It would rely on the 2020 Alaska Roadless Rule Final EIS, which does not adequately evaluate rescission. 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 national protections of the Rule in place and reassess the reasonably foreseeable effects now.