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Re: Docket FS-2025-0001, Proposed Rescission of the 2001 Roadless Area Conservation Rule
I strongly oppose rescinding the Roadless Area Conservation Rule and urge the Forest Service to adopt the No Action alternative and keep the rule in full.
I am a painter of the plants, birds, and animals of America's wild public lands, and I work from direct observation in the places themselves. I have attached examples of that work.
On the Little Cherry Creek Trail in the Gila National Forest in New Mexico, I found a painted redstart, a small jewel of a warbler and one of many birds I saw for the first time in that forest. In Montana's Custer Gallatin National Forest, my husband caught a native Yellowstone cutthroat trout in a backcountry stream, and I painted it. I have also painted fish he caught on a daylong horseback trip into the Bob Marshall Wilderness. Native trout like these survive only where headwater streams stay cold, clear, and connected. New roads and logging send sediment into exactly those streams. Wilderness areas like the Bob Marshall also depend on the roadless lands around them, which serve as buffers and corridors that wildlife and clean water cross freely. In 1993, while my husband fished, I painted a backcountry stream in Alaska's Tongass National Forest. We hiked in to reach it, as we did to many places there. The Tongass has had its roadless protections removed and restored before, and the public spoke clearly then in favor of keeping them. On Mt. Blue Sky in Colorado, I drew a bristlecone pine more than 1,500 years old, which I call "Old Man of the Mountain."
I have also stood before a 3,000-year-old bristlecone in Great Basin National Park and touched it. That tree has lived through the rise and fall of civilizations, through humanity's greatest achievements and greatest sorrows. It survives because the land around it has been protected. Standing in the presence of something that ancient is awe-inspiring, but it is also a heavy responsibility. These trees, fish, and birds will outlast every one of us only if we decide to let them. The Roadless Rule is that decision, already made, and it has worked for twenty-five years.
The proposal argues that rescission will give local managers flexibility and improve forest health and wildfire response. The existing rule already allows fuel reduction and other necessary work, especially near communities. New roads into remote backcountry add human-caused fire ignitions, fragment habitat, and degrade the streams that supply clean drinking water and cold-water fisheries. Roads also cost money to build and maintain, and the Forest Service already has a large backlog of road maintenance it cannot afford. I ask that the final EIS explain how adding roads to remote areas reduces wildfire risk better than focusing fuel work near homes and towns.
The draft EIS must also fully account for the permanent nature of these losses. A road can be built in a season and an old forest cut in a day, but what they destroy took centuries or millennia to grow. No later policy can restore it on any timescale that matters to us or to our grandchildren.
These lands belong to all Americans, including the hunters, anglers, hikers, and artists who go to them to escape the noise of everyday life. I am one citizen, but these lands are mine as much as anyone's. Keep the Roadless Rule.
Attachments:
Field journal, May 5–7, 2023, including painted redstart and red-faced warbler, Little Cherry Creek Trail, Gila National Forest, NM
Native Yellowstone cutthroat trout, Custer Gallatin National Forest, MT
"Old Man of the Mountain," bristlecone pine, 1,500+ years, Mt. Blue Sky, CO
Watercolor study, backcountry stream, Tongass National Forest, Southeast Alaska (likely Wrangell Island), 1993
Kelly Leahy Radding
Connecticut