Re: Docket No. FS-2025-0001 (RIN 0596-AD66) — Public Comment in Opposition to the Rescission / Amendment of the 2001 Roadless Area Conservation Rule
To:
Director, Ecosystem Management Coordination
U.S. Department of Agriculture, Forest Service
201 14th Street SW, Mailstop 1108
Washington, DC 20250-1124
I. Introduction
I am writing to express my strong opposition to the proposed rescission and amendment of the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001). As a resident and advocate for Teton County, Wyoming, I am deeply concerned about the potential impacts of opening Inventoried Roadless Areas (IRAs) within the Bridger-Teton National Forest to road construction, timber harvesting, and commercial development.
The roadless landscapes surrounding Teton County represent an irreplaceable resource. Removing federal roadless protections in favor of localized discretion risks permanent damage to our ecological health, local economy, and public resources.
II. Critical Wildlife Habitat and Ecosystem Integrity
The Inventoried Roadless Areas in Teton County serve as vital sanctuaries for western wildlife within the Greater Yellowstone Ecosystem.
Habitat Connectivity: These remote tracts provide core, contiguous habitat and critical movement corridors for species including grizzly bears, gray wolves, elk, moose, and bighorn sheep.
Fragmentation Threats: Road construction and commercial logging break up contiguous forest canopy, introduce edge effects, create disturbance corridors, and encourage human-wildlife conflicts that degrade ecosystem resilience.
III. Watershed Enhancement and Water Quality Protection
The forests of Teton County are key headwaters for the Snake River Basin, providing critical ecological functions:
Drinking Water & Quality: Roadless areas function as natural filtration systems, keeping sediment levels low and providing pristine drinking water for local communities downstream.
Aquatic Habitat: Native cold-water fish, such as Snake River fine-spotted cutthroat trout, rely on clean, cold, and silt-free water. Industrial activity and road building increase soil erosion and sedimentation, threatening critical fish habitat.
IV. Unsuitability for Commercial Logging
Commercial timber extraction in the roadless areas of Teton County is ecologically unsustainable and economically inefficient:
Steep Terrain & Soil Vulnerability: Much of the roadless terrain in the region is characterized by high elevation, steep slopes, and highly erodible soils, making road construction physically destructive and unstable.
Low Timber Value: These slow-growing, high-altitude forests lack the commercial timber yields necessary to justify the immense public expenditure required to build and maintain access roads.
Deferred Maintenance Deficit: Expanding road networks in remote areas creates long-term financial liabilities for the Forest Service, which already faces significant maintenance backlogs on existing national forest roads.
V. Conclusion and Recommendation
Rescinding or weakening the 2001 Roadless Area Conservation Rule threatens the water quality, wildlife habitat, and natural heritage of Teton County, Wyoming. The current national protections ensure that these high-value roadless lands remain intact for future generations.
I respectfully request that the U.S. Department of Agriculture and the Forest Service withdraw the proposed rule change and maintain full protections under the 2001 Roadless Area Conservation Rule for all Inventoried Roadless Areas in Teton County and nationwide.
Thank you for the opportunity to comment on this critical proposed action.
Sincerely,
David G Brown