Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Everyone deserves to have access to intact, beautiful landscapes; not just for recreation, but for the ecosystem services that these places provide. The implementation of the Roadless Rule has helped maintain these ecosystems by protecting intricate watersheds, swaths of forests, and a plethora of wildlife. The agency's proposal to remove the Roadless Rule will have long-lasting, negative consequences on unique ecosystems that bring so much enrichment to millions of Americans. I oppose the rescission of the 2001 Roadless Area Conservation Rule.
I fish for rainbow trout, bull trout, and cutthroat trout in the Salmon-Challis National Forest, including within the Frank Church-River of No Return Wilderness. Many of the places I fish are roadless or connected to roadless areas, and they boast relatively healthy streams because of it. The agency's own record states that roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and that sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout. Although this area is not at threat due to Idaho's Roadless Rule, this forest's ecosystem and waters rely on the health of surrounding national forests in neighboring states like Montana. I can't imagine how many places such as this one will be lost if the Roadless Rule is rescinded. I ask the agency to explain on the record what specific finding it relies on to conclude that expanded road access will not increase sediment loads in streams that currently support bull trout, cutthroat trout, and the other native species verified in that forest and other forests outside the state of Idaho.
I have hiked, camped, and photographed in the Bridger-Teton National Forest for a good portion of my life, since I grew up near it. I was there twice in the last 3 months. The Bridger-Teton is the western wall of the Greater Yellowstone Ecosystem, the largest intact temperate ecosystem in the world. It holds 19 inventoried roadless areas totaling 1,417,499 acres. The elk herds that winter in the National Elk Refuge depend on summer range in these roadless mountains. The forest creates the habitat connectedness that grizzly bear, gray wolf, cutthroat trout, trumpeter swan, and sage grouse need to survive and thrive. It also supports the national parks it surrounds; when overcrowding limits access to Grand Teton and Yellowstone, the Bridger-Teton is where people like me still go. I go there to see beautiful, unique landscapes and wildlife that people have spent decades restoring and protecting. The agency built Alternative 3 because commenters asked it to maintain protections for big game habitat, fisheries, and wildlife connectivity, then chose the alternative that protects none of it. The agency must explain why it discarded that public demand.
On wildfire, the agency's own text states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Most human-caused wildfires are started near roads. More roads means more wildfires, which means more taxpayer money spent fixing preventable problems. The proposal invokes wildfire management as a reason to rescind the rule. That reasoning runs directly into the agency's own data. I ask that the agency reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from its own prior findings on fire occurrence.
The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." We should maintain the roads we already have, not spend money on new roads with no guaranteed economic benefit to the agency or local communities.
Our public lands should be managed with the public's interests in mind. The agency held more than 600 public meetings and took 1.6 million comments to write the rule. It has held none to undo it. I mourn the places I never got to see because of poor decisions made by previous generations. I want my children and grandchildren to have the same opportunities I have had to enjoy these roadless areas. Clean water, intact habitat, and roadless country are not preferences of a special interest. They are what the public asked for, and the public has not changed that answer.
Sincerely,
Abbie Johnson
Moscow, ID