Subject: Keep the 2001 Roadless Rule Intact (Docket FS–2025–0001 or RIN 0596-AD66)
I am writing to urge you to keep the Roadless Rule in place and oppose the proposed rescission. Instead of an overly broad repeal, the agency should pursue targeted improvements to the Roadless Rule that strengthen wildfire resilience and recreation access, while keeping its strong safeguards in place.
I have a great concern based on years of firefighting and prescribed fire use that building new roads or opening old roads will only add to fire problems not curtail them. My background; 34 years as a Forest Service employee (retired Forest Fire Staff, Type 1 Incident Commander, Operations Section Chief and Prescribed Fire Manager) 21 years as a California State Deputy Fire and Rescue Chief.
I will use the Eldorado National Forest as an example of fires and road access. There are about 3000 acres of current or disused roads that could be used to access the forest and where the large fires have started. Currently on the Eldorado NF and other Forests where there are no roads-the Roadless Rule areas- are either to steep or rocky, burned over or have nothing of commercial value that would justify the costs of building road.
The recent fire history of the Eldorado NF illustrates the proximity of roads and large fires is not an abstract concept.
1959 Ice House Fire 18600 acres burning logging slash off of Granite Springs Road
1959 Javbird Fire 7600 acres burning logging slash off of Ice house Road
1973 Park Fire 900 acres arson fire started on Camp Creek Road
1973 Pillikan Fire 10000 acres (1 firefighter fatality) started on the Mormon Emigrant Trail
1981 Wrights Fire 3600 acres vehicle fire highway 50.
1992 Cleveland Fire 24580 acres (2 airtanker pilots, killed 41 structures burned) Fire started on Ice House Road from driver throwing burning debris from vehicle.
2004 Power Fire 17000 acres Utility workers working on power lines accessed by the road to Salt Springs Reservoir.
2004 Freds Fire 7600 acres Utility workers working on power lines on highway 50.
2014 King Fire 91700 acres (80 structures destroyed 12 civilian injuries) arson started off of King Rd in Pollock Pines.
2021 Caldor Fire 221835 acres (1005 structures destroyed major damage to Sierra at Tahoe Ski area) human caused start off of road near Omo Ranch.
A scientific study, published by members of the Wilderness Society in Springer Nature’s Fire Ecology Journal, examined patterns of fire size in a nationwide dataset of U.S. Forest Service regions from 1992 to 2024.
The researchers found that the highest wildfire-ignition density among the lands studied was in lands within 164 feet of roads, at just under 8 fires per 2,471 acres, while the second highest wildfire-ignition density was in other national forest lands outside the 164-foot buffer, but not in wilderness or roadless areas, at 3.5 fires per 2,471 acres. Wildfire-ignition density was at its lowest in designated wilderness areas without roads, at 1.75 fires per 2,471 acres.
In my years of experience of wildland firefighting roads can be helpful for suppressing fires depending on fire intensity. All of the fires except the Park Fire burned over roads and dozer lines until either a change in fuels, topography and or weather reduced the spread of the fire.
Adding more roads in the current roadless areas is an invitation to human carelessness or intent to do damage to our national forests. In California, about 86% of wildfires are human-caused, with ignition risk four times higher near roads.
The lands protected by the Roadless Rule were identified for their critical role in safeguarding clean water, providing wildlife habitat, preserving Tribal cultural resources, and offering cherished backcountry experiences. They also sustain thriving recreation economies while supporting community safety through wildfire prevention, firefighting access, and road maintenance.
The Forest Service already manages roughly 380,000 miles of roads across the National Forest System, much of which it does not have the resources to maintain. The Forest Service since the 1980’s has reduced the capacity to maintain even the most used roads. More roads will increase forest fragmentation, erosion, invasive species, and wildfire risk.
The Roadless Rule strikes the right balance: it allows managers to reduce fuels and protect communities while maintaining a consistent national safeguard against unnecessary new roads.
Please reject this broad repeal and preserve the Roadless Rule.
Sincerely,
Scott Vail
240 Judy Drive Placerville, California 95667
530 748 5438vail.s@sbcglobal.net