FS-2025-0001-577831

I welcome this opportunity to offer comment on the US Forest Service’s Draft Environmental Impact Statement (DEIS) and Proposed Rule to rescind the national Roadless Rule. The DEIS and Proposed Rule were released on August 20 for a one-month public comment period ending September 21. Summary As expected, the Proposed Rule would entirely rescind the 2001 Roadless Rule, removing protection from 44.7 million acres of Inventoried Roadless Areas (IRAs) currently covered by the 2001 Rule, including the 9.3 million acres in the Tongass National Forest. The Idaho and Colorado Roadless Rules would remain in effect. Our organization focuses on the Bighorn National Forest, which the Proposed Rule covers with more than 649,000 acres. The justification for rescission presented in the Proposed Rule and DEIS focuses on providing more local control and management flexibility. The Federal Register notice for the Proposed Rule states, “There is a need to increase local management flexibility and, where necessary, allow for active management to respond to changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface.” 91 Fed. Reg. 53828. The notice also cites recent Executive Orders to eliminate unnecessary regulations, expand domestic timber production, and maximize natural resource development in Alaska, including exempting the Tongass National Forest from the national Roadless Rule. The DEIS considers just three alternatives: Alt. 1 – No Action (keep the 2001 Rule), Alt. 2 - Full Rescission, and Alt. 3 – Partial Rescission. Alternative 3 would maintain Roadless Rule protection for 13 million acres of IRAs (29%), while removing protection from the Tongass, IRA considered to be in the Wildland-Urban Interface, and other IRA land within ½ mile of a road. I strongly advocate for Alternative 1- No Action, keeping the 2001 RCRA in place, without amendment.