Special Areas: Roadless Area Conservation; Proposed Rule RIN 0596-AD66
Docket number FS-2025-0001-223869
My name is Karla Ward, a registered voter living in Whatcom County, Washington. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, documented in the Federal Register on August 20, 2026 (FR Doc. 2026-16965, Docket No. FS-2025-0001, RIN 0596-AD66).
The proposed rescission is a violation of treaty rights, trust responsibilities, and federal law (see USDA Departmental Regulation 1350-002, Executive Order 13175, and the Federal government’s trust responsibility to Tribal Governments). The proposed rescission is an unacceptable and illegal Indigenous-erasure-forward and ethnic-cleansing policy statement.
The EIS, cost-benefit analysis, and draft Biological Assessments available under Docket No. FS-2025-0001 are as clear as the water flowing from a protected and pristine watershed. It ain’t broke. Don’t fix it.
The DEIS analyzes three alternatives. The only alternative acceptable to this voter is Alternative 1 (No Action), retaining roadless policy on 44.7 million acres of inventoried areas, including 9.3 million acres on the Tongans National Forest.
The proposed rule reveals that the rescission “would have substantial direct effects on Indian Tribes”, and “warrants consultation under E.O. 13175”. The DEIS itself concedes: “Timber harvest and road construction in inventoried roadless areas could significantly alter Tribal access to treaty-reserved resources, sacred sites, and other culturally significant areas.” Both action alternatives acknowledge these activities “could have long-term negative effects on Tribal rights and interests.” Every alternative that Tribal governments put forward in good faith during scoping was screened out of detailed analysis in the DEIS.
Government-to-Government consultation is the standard, not a one-off. Re-defining ‘consultation’ to nothing more than a public comment option is dismissive and illegal. Tribal consultation is NOT advisory, nor is it just another check-off box item. Substantive, formal, robust and inclusive Tribal and Nation consultation and accordance-as understood by the Tribes-is non-negotiable and must not be diminished, period.
Roadless spaces preserve food security-such as salmon stocks and gathering territories-for many Indigenous communities. Roadless spaces sustain Indigenous cultural practices observed and protected for thousands of years. This artificially accelerated rescission will undermine existing co-management and co-stewardship agreements and Memorandums of Understanding between the USFS and many Indigenous governments. Case in point, proximate to me, the Roadless Rule protects 19,200 acres of the Mt. Baker-Snoqualmie National Forest, which includes at least 19 local areas that could be adversely affected by the proposed rescission. Every acre is traditional Indigenous homeland to multiple recognized Tribes and Nations, and has been since time immemorial.
The accelerated process coded in the proposed rescission of the Roadless Rule favors extraction over protection. What’s the reason for the hurry? Three words: GREED, POWER and CONTROL.
Ecosystems providing clean drinking water to 60 million US residents and 354 municipal watersheds, and wildlife habitats and foundational biodiversity, will be irrevocably and significantly compromised by incursions from motorized vehicles, expanded logging, drilling, fracking, mining, refining and distribution activities. Keystone species contributing to sustainability for all of us will certainly be harmed by invasive incursions and additional wildfire risk, as documented in the EIS that the rescission proposes to ignore.
The existing rule provides for management flexibility, including wildfire risk reduction and public safety response. The proposed rescission enshrines the ‘wildfire risk’ red herring. By increasing human activity in currently-protected roadless areas, wildfire risk is enhanced, not diminished. Concerns for wildfire in roadless areas are best addressed with robust USFS wildfire mitigation funding and interjurisdictional-including Tribal-involvement.
The American people overwhelmingly supported the establishment of the Roadless Rule and the values therein encoded, have opposed rescission during the intent process, and will continue to insist on its intact preservation during the DEIS process. The Federal Land Policy and Management Act of 1976 states ‘public lands are to be protected for future generations’. The federal government is responsible to manage these lands for ALL citizens, for the long-term, not for the benefit of short-term, exploitative, commercial interests.
The USFS was constituted for public service, not to enable outright, illegal corporate capture of public lands. Adopt Alternative 1(No Action).