I urge you to rescind the proposal discussed in FS-2025-0001-223869, Special Areas: Roadless Area Conservation, because of the irrevocable devastation it would cause. Once roads are built, there is no way to undo the damage. According to the analysis in the DEIS, elimination of the Roadless Rule across 45 million acres nationwide would result in a loss of up to $9 million a year from lowered visitor spending, especially hurting local communities, 327 ESA-listed species and 71 critical habitats would be negatively impacted, threaten Tribal sacred and archeological sites, exacerbate the Forest Service’s estimated maintenance backlog of over $8.6 billion covering the existing 370,000 miles of roads, and could actually increase fire risk.
When it was adopted in 2021, the Roadless Rule applied to forests containing habitat for approximately 25 percent of animal species and 13 percent of plant species listed as Endangered in the U.S. Roadless areas are critical habitat for 1,600+ threatened species. Many roadless areas are mature or old-growth forests—irreplaceable ecosystems that protect plant and animal diversity. Roadless areas also provide important migration corridors that are critical for numerous migrating species. Additionally, rivers flowing through roadless areas provide vital refuges for declining fish and wildlife species. A study conducted in the Sierras found that the biologically healthiest waters were in roadless areas including many existing Wild and Scenic Rivers such as the Middle Fork Feather, North Fork American, Tuolumne, Kings, and North Fork Kern and many recommended by the Forest Service for Wild and Scenic protection, including Deer and Mill Creeks and the Clavey River.
A spectacular example of what we have to lose without the Roadless Rule is the Tongass National Forest (9 of 17 million acres). It is the largest national forest in the country, spanning Southeast Alaska's islands, fjords, waterways, and mountains, the largest intact temperate rainforest in the world, and is the only public land in the U.S., if not the world, that still has intact water sheds.
The Tongass provides critical habitat for more than 400 species of fish and wildlife and for birds from across the globe, supporting approximately 350 bird species, including about 40% of all bird species found in North America. The forest contains the world's highest density of nesting Marbled Murrelets and Bald Eagles, and hundreds of thousands of migrating shorebirds stop here each spring before continuing north to Arctic breeding grounds. Unique subspecies—including the Queen Charlotte Goshawk and Prince of Wales Spruce Grouse—depend on the mature and old-growth forests that make the Tongass special.
Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. Roads result in other long-lasting harms such as fragmenting wildlife habitat, degrading habitat, increasing pollution, spreading invasive species, and are the single largest threat to bird species and the greatest driver of population declines.
It is imperative that at least 30% of all species and their habitats be preserved to have a livable future.
Given the widespread multifaceted harms repealing the Roadless Rule would cause it is imperative that it be improved by:
Eliminating the logging loopholes. Logging does not improve anything - it only causes degradation.
Instead of the 2000 EIS estimated ~ 1,400 acres of logging in roadless areas across the nation annually, on average from 2008-2018, there has been 3,200 acres of inventoried roadless logging annually in Montana alone. The majority of which was from using Roadless Rule loopholes.
Eliminating livestock grazing in our inventoried roadless areas. Livestock grazing spreads invasive grasses that exacerbate wildfires, displaces wildlife, destroys habitat, and pollutes clean water.
Despite being only four percent of livestock production in this nation, livestock grazing is pervasive on nearly 250 million acres of our public lands. The Forest Service is clandestinely restocking vacant grazing allotments with cattle, including in roadless areas and Wilderness, without public knowledge or participation.
Restricting motorized and mechanized use in our inventoried roadless areas. Research shows that motorized and mechanized access (on roads, trails, or over the snow) harm wildlife, from elk to grizzly bears.
Extend the provisions of this strengthened national rule to Idaho and Colorado, which currently have less protective rules.
Thank you