Re: Special Areas; Roadless Area Conservation, Proposed Rule (RIN 0596-AD66) [Docket No. FS-2025-0001]
To the U.S. Department of Agriculture and U.S. Forest Service:
On behalf of YAMA Mountain Gear LLC, I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule.
YAMA Mountain Gear is a small, independent company that designs and builds lightweight shelters for backpackers. We are based in Bonner, Montana, surrounded by the Lolo National Forest. Much of the backcountry where we test our gear and spend our own time outdoors, including places like the Great Burn, is roadless country. Our customers carry our shelters into National Forests across the country, and the undeveloped landscapes they seek out are, in large part, the Inventoried Roadless Areas this rule protects.
The Roadless Rule is a modest and effective policy. It applies to specific, mapped areas of National Forest that were inventoried as still roadless. Within them, it prohibits new road construction and commercial timber harvest, which in practice also keeps out most new mining. It does this without designating Wilderness, closing existing roads or trails, or restricting hiking, hunting, fishing, or grazing. It simply keeps new roads and timber sales out of the last large, intact blocks of National Forest land.
Those areas matter far beyond their boundaries. Inventoried Roadless Areas provide habitat and migration corridors for wide-ranging wildlife, protect water quality at the headwaters of streams and rivers that downstream communities depend on, and preserve the backcountry recreation experiences that draw people to public lands. They are also inexpensive to manage. The Forest Service already faces a substantial backlog of maintenance on its existing road system; adding new roads in roadless areas would add new long-term costs to an agency that cannot keep up with the roads it has.
These lands are also an economic asset. They contribute to a national outdoor recreation economy of roughly $1.3 trillion, and to the rural communities, guides, outfitters, and small manufacturers like us that depend on it. Opening roughly 45 million acres still covered by the national rule to new roads, logging, and mining would trade durable, long-term value for short-term extraction.
We recognize that wildfire is the central justification offered for this proposal, and we take that concern seriously. Reducing fire risk to communities is important work, and we would welcome future rulemaking that improves the rule's ability to support fuels reduction and prescribed fire where it is genuinely needed. But the evidence on roads and fire cuts both ways: most wildfires are human-caused and tend to start near roads, and new road networks create new ignition points. A targeted, science-based approach to fire management in roadless areas deserves careful consideration. A wholesale rescission is not that approach.
That is the core of our objection. The choice presented here is not reform; it is removal. Rescinding the rule entirely would open tens of millions of acres to road building, logging, and mining without any national plan to protect the habitat, water, and recreational values that depend on these areas staying roadless. Shifting those decisions to individual forest plans would replace a consistent national standard with a patchwork that local units, already stretched thin, would struggle to administer.
When the Roadless Rule was adopted twenty-five years ago, more than 1.6 million public comments helped shape it, reflecting broad public support for protecting these lands. A decision to undo it deserves comparable public engagement. A 45-day comment period with no public hearings is not sufficient for a proposal affecting roughly 45 million acres across dozens of states. At a minimum, we ask the Department to extend the comment period to 120 days, hold in-person public meetings in affected regions, and complete full consultation with tribal nations before proceeding.
We respectfully urge the Department to withdraw the proposed rescission and retain the 2001 Roadless Rule. If changes are warranted, particularly regarding wildfire mitigation, we ask that the agency pursue targeted improvements, developed with the kind of public engagement described above, rather than eliminating protections for some of the most valuable public lands in the country.
Thank you for the opportunity to comment.
Sincerely,
Gen Shimizu
Founder/Member
YAMA Mountain Gear LLC
Bonner, MT