Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Dear U.S. Forest Service Officials,
I respectfully urge the Forest Service to retain the 2001 Roadless Rule and reject the proposed rescission. Roadless lands are not idle land. They supply clean water, wildlife habitat, and recreation to communities nationwide, and rescission would do far more harm than good.
WHAT IS AT STAKE (Forest Service roadless inventory)
- Deschutes NF, central Oregon: about 137,000 acres protecting the headwaters of the Deschutes and Metolius rivers. Oregon's roadless lands protect drinking water for about 800,000 people, including Bend.
- Wallowa-Whitman NF, northeast Oregon: about 515,000 acres. Its mountain streams supply Baker City, one of only two Oregon cities whose water is clean enough to go unfiltered.
- Gifford Pinchot NF, southwest Washington: about 213,000 acres. Its streams supply drinking water to communities and support threatened Chinook and coho salmon, steelhead, bull trout, and the northern spotted owl.
- Superior NF, northeast Minnesota: about 62,000 acres bordering the Boundary Waters, home to moose and threatened Canada lynx.
- White Mountain NF, New Hampshire and Maine: about 235,000 acres, including headwaters of the Pemigewasset River, which forms the Merrimack, a drinking water source for Manchester, Nashua, and Massachusetts towns.
- Bridger-Teton NF, western Wyoming: about 1.4 million acres at the headwaters of the Snake and Green rivers, feeding the Columbia and Colorado systems, with grizzly bears, wolverines, lynx, and native cutthroat trout.
Nationally, roadless watersheds supply drinking water to about 25 million Americans.
THE FOREST SERVICE'S OWN SCIENCE
The agency's report Forest Roads: A Synthesis of Scientific Information (PNW-GTR-509) found that roads contribute more sediment to streams than any other land management activity, and that most sediment from timber harvest is tied to roads. Forest Service research on Washington's Clearwater River found fine sediment making up 15 to 25 percent of spawning gravels in heavily roaded basins, smothering salmon eggs. That matters: the Columbia Basin once produced 10 to 16 million salmon a year, and logging and road building were among the causes of its decline, alongside dams. The current DEIS itself acknowledges that new roads and logging could bring more human-caused fires, sedimentation, harm to threatened and endangered species, and recreation losses.
WILDLIFE
Roadless areas cover about 2 percent of U.S. land but support roughly 25 percent of threatened and endangered species. In Idaho, 75 percent of Chinook salmon and steelhead habitat is in roadless areas. The U.S. Fish and Wildlife Service has called roads probably the most imminent threat to grizzly habitat. Roads also fragment migration routes and push elk out of secure cover: in Wyoming, hunters in mostly roadless country harvest about one bull elk per 2.4 square miles, versus one per 25 square miles in heavily developed areas.
THE COST OF ROADS
The proposed rule anticipates permanent roads could be built across 18.2 million acres now protected. Yet the Forest Service already manages over 370,000 miles of roads with a maintenance backlog the agency puts at about $6.9 billion, and fewer than one in five roads is fully maintained. Neglected roads wash out, plug culverts, and send sediment into streams, and deferred repairs grow costly. Former Chief Mike Dombeck noted that reconstructing five miles of one road cost $1.4 million when $100,000 in earlier upkeep would have preserved it. The DEIS projects just $5 to $11 million a year in new timber revenue and admits this would not cover the cost of building and maintaining new roads. Adding roads the agency cannot maintain shifts the bill to taxpayers and downstream communities.
WILDFIRE
The rule already allows thinning and road access to reduce fire risk, and areas near roads have recorded nearly four times as many human-caused ignitions as roadless areas.
I ask the Forest Service to keep the Roadless Rule in place and pursue any needed changes through targeted reform with full public input.
Thank you for considering my comments.
Sincerely,
Marguerite Nico
Allen, Texas