FS-2025-0001-576778

RE: RIN 0596-AD66, Docket FS-2025-0001 Thank you for the Forest Service's work to find ways to keep our national forests healthy, and for the chance to comment. I support Alternative 1 and ask the Department to keep the 2001 Roadless Rule in place. I agree with the Department's diagnosis. Decades of fire suppression have built up fuels and closed canopies. I study butterflies and moths in the field around Clackamas and Multnomah Counties, and I see meadows filling in and open forest closing over without fire. Prescribed burning, managed wildfire and thinning are critical. Where I disagree is the prescription. New roads would make the Department's job harder. The rule is not what stands in the way. It does not restrict prescribed fire, and it already allows small-diameter cutting to reduce wildfire risk and roads to meet imminent threats. The Forest Service's Rocky Mountain Research Station found there is already more fuel treatment per square kilometer inside roadless areas than elsewhere (Healey 2020). The limit is funding and crews. A bright line is the cheapest answer. Today everyone knows the answer in a roadless area before spending a dollar. Rescission replaces that rule with a case-by-case "maybe" across about 44 million acres, decided forest by forest and likely litigated project by project. A "maybe" invites spending on long-shot roads and timber sales in remote, low-value country, and the public pays to prepare them: in the Tongass, 45 percent of timber sales offered from 1998 to 2007 drew no bids. Water providers, outfitters and recreation businesses have also relied on this rule for 25 years, and the final EIS should account for those reliance interests. The agency cannot afford more roads. The draft EIS reports that appropriated funding for the road system has fallen almost 70 percent in twenty years. Every dollar spent on new roads is not spent on burning and thinning. Roads also add fire starts: the draft EIS's own data show ignitions concentrated near roads, and Oregon's own comments cite 53 percent more ignitions than expected within 200 meters of roads. At the road stubs I visit I find broken glass, trash, shotgun shells and long-term camps, a law enforcement and fire burden that new roads would carry into country that has none today. Roads also bring invasive plants. The same Forest Service study found roads strongly associated with their spread (Healey 2020). This is a problem for everyone, including firefighters: invasive grasses such as cheatgrass cure early, fill the gaps between trees and shrubs, and carry fire faster and more often than the native plants they replace. Every new road is a new corridor for them into country that is mostly free of them today. Alternative 3 is not a narrow fix. It drops 17.9 million acres because they lie near a road or in the wildland-urban interface, plus the entire Tongass and, by Oregon Wild's count, about three quarters of Oregon's roadless acres. The fire concern near communities is already covered by the rule's exceptions. I ask that the final EIS (1) identify fire or safety projects the existing exceptions actually blocked, (2) state maintenance costs and funding for any road it expects to build or reopen, (3) explain why its goals cannot be met on roaded national forest land and the 104,000 miles of stored roads it already has, and (4) respond to the State of Oregon's comments asking for less than full repeal. Please keep the Roadless Rule and put the resources new roads would take into prescribed fire capacity, crews and maintenance of existing roads. Thank you for considering these comments.