I am a veterinarian and lifelong Texas Panhandle resident, and I oppose rescission of the 2001 Roadless Area Conservation Rule (36 CFR 294, subpart B). My comments address the Department's wildfire rationale and the animal and public health consequences that the proposal and DEIS do not adequately weigh.
1. The existing rule already allows the fuels work the Department says it needs.
The Purpose and Need cites wildfire risk, insect and disease infestations, and protection of the wildland-urban interface. The 2001 Rule already permits road construction where it is needed to protect public health and safety from an imminent threat of fire, flood, or other catastrophic event (§294.12(b)(1)). It also permits cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire effects (§294.13(b)(1)(ii)). Before concluding that a nationwide rescission is necessary, the Department should quantify how many fuels or WUI projects these provisions actually blocked. If the barrier is narrow, the remedy should be narrow too.
2. New roads increase ignition risk.
Most U.S. wildfires are human-caused, and human ignitions have expanded both the fire season and the fire niche (Balch et al. 2017). Ignition density rises with proximity to roads (Narayanaraj & Wimberly 2012). Opening roadless backcountry to new road access in the name of fire-risk reduction may therefore increase the ignitions it intends to prevent. The final EIS should model the added ignition risk from new road access, not only the benefit of fuel reduction.
3. Animal and public health (One Health) impacts.
Land-use change and habitat fragmentation are recognized drivers of infectious disease emergence at the wildlife–livestock–human interface (Patz et al. 2004). Roads fragment habitat, alter where wildlife move and congregate, help invasive species and pathogens spread, and increase sediment delivery to streams (Trombulak & Frissell 2000). Many western grazing allotments border roadless areas. Changes in wildlife distribution and in contact rates with livestock carry disease-management consequences for producers and animal health officials. The DEIS should analyze wildlife disease, livestock–wildlife contact, and source-water impacts specifically, rather than treating them as incidental.
4. Roads the agency cannot maintain.
The Forest Service already carries a large deferred-maintenance backlog on its existing road system. Poorly maintained roads are a chronic source of sediment in the watersheds that downstream communities and livestock depend on. The Department should explain how new roads would be funded and maintained before authorizing them.
For these reasons, I urge the Department to withdraw the proposed rescission and retain the 2001 Roadless Rule. Any specific fuels-management barriers should be addressed through targeted amendments, not by removing protections from roughly 45 million acres.