FS-2025-0001-550364

Subject: Docket Number: FS-2025-0001 I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule, options 2 or 3. In 2001, the Roadless Area Conservation Rule was adopted with massive public support to protect 58.5 million acres of roadless national forest land in 38 states and the Commonwealth of Puerto Rico, out of the 192 million acres of NFS land. The public comment period set a record with 1.6 million public comments submitted, indicative of the very strong public support for the Roadless Rule. The rule prohibits the logging of roadless areas in the National Forest System. (USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-ssummary.pdf) Fires: The Roadless Rule already allows for fire suppression, restoration, thinning, and fuel reduction, and wildfires are roughly four times more likely to start near roads than within roadless areas. Recent research found that wildfire-ignition density was the lowest in designated wilderness areas, followed closely by Inventoried Roadless Areas (IRAs). The highest wildfire-ignition density was in lands within 50 m of roads (Aplet, G.H., Hartger, P., &Dietz, N.S. (2026) (doi.org/10.1186/s42408-026-00450-2). A Wilderness Society review of the Forest Service’s Wildland-Urban Interface (WUI) dataset revealed less than 5% of inventoried roadless area acreage is in close proximity to the WUI. The Forest Service already has 23.3 million acres of non-roadless forest land available near communities for fuel reduction. There is no operational need to build new roads through pristine backcountry. Drinking Water: In the 48 contiguous states, 15 to 18 percent of the nation’s runoff is sourced from national forests, and roughly a third of that is derived from IRAs. Sedell et al. (2000) estimate that more than 3,400 communities in 33 states rely on national forest drinking water. The 2001 Roadless Rule is, among other things, a drinking-water policy. The 44.5 million acres it protects sit at the headwaters of rivers that feed municipal water supplies across two-thirds of the country. Repealing it would place those supplies-and the budgets of the cities that depend on them-directly in the path of new road construction. Roads are the single largest controllable input of sediment into forest streams. Erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest soils. That sediment impacts the storage capacity of reservoirs. (DellaSala, D.A. (2011) “Roadless areas and clean water.” Journal of Soil and Water Conservation, 66(3), 78A-79A. doi.org/10.2489/jswc.66.3.78A) (Sedell, J., Sharpe, M., Apple, D.D., Copenhagen, M., & Furniss, M. (2000). Water and the Forest Service, USDA Forest Service, FS-660.) Recreation: Roadless areas protect 43,826 miles of trails. Along with thousands upon thousands of Americans, my recreation takes place in the outdoors, in the forests, the lakes and rivers that flow thru the forests. I want future generations to have that option. The recreation that roadless areas provide works because access is dispersed, mechanized use is limited, and the landscapes have not been industrialized (USDA Forest Service 2016). The "amenity economies" of the rural West depend on the conditions roadless areas provide. Research describes a shift from an "Old West" economy dominated by extractive industries to a "New West" economy in which population, employment, and income growth are driven by environmental amenities, residential appeal, and recreational property. Counties with substantial protected federal lands have shown faster growth in population, employment, and per capita income than counties without — and the growth has been concentrated in service-based industries, including lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). The economic value also includes passive use — wilderness recreation generating an estimated $574 million annually in economic value (Loomis 2000). The 58.5 million acres inventoried as roadless are spread throughout 120 national forests located in 38 States and the Commonwealth of Puerto Rico (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-summary.pdf), A total of 50.3 million acres of protected wilderness areas, roadless areas, and designated critical habitat, as well as 2,300 miles of wild and scenic rivers are included in the emergency declaration map area, fast-tracking destructive projects in areas that were intentionally set aside to preserve their natural values and functions (Woodard et al., 2025). Once you build a road into a roadless area, you’ve opened it up to industrial extraction, and the wild character of that land is gone. New Mexicans, and Americans across the country, have fought to keep these forests roadless because our drinking water, our wildlife, our culture, and our way of life depend on it. Mary Needham New Mexico