Re: Docket FS-2025-0001, RIN 0596-AD66, Special Areas; Roadless Area Conservation
I live in Rapid City, South Dakota, and the Black Hills National Forest is my home forest. I ask the Forest Service to withdraw the proposed rescission of 36 CFR part 294, subpart B, and keep the 2001 Roadless Area Conservation Rule in full effect (the no-action alternative).
Roadless land is scarce here. The agency's own inventory lists about 80,000 roadless acres in South Dakota, under 4 percent of the National Forest System land in the state. The Black Hills is already heavily roaded and logged. These few remaining acres hold the intact habitat, quiet backcountry, and headwaters that the rest of the forest has given up. Rapid City draws its drinking water from Rapid Creek, which rises in this forest.
The economics in the proposed rule argue against the change. The agency estimates $5.2 to $11.4 million a year in new revenue to the Treasury and the Forest Service, against about $6.1 million a year in lost recreation benefits. The same agency reports a $6.9 billion deferred maintenance backlog for existing roads and bridges. New roads add to a system the agency already cannot afford to maintain.
The wildfire rationale also falls short. The 2001 rule already permits cutting small-diameter trees to reduce fire risk and building roads where public health and safety require it. Most wildfires start close to roads, so more roads mean more ignitions.
Forest plans change with every revision cycle. A national rule gives these areas durable protection, and it has done so for 25 years.
Please retain the 2001 Roadless Rule.
Megan Werpy
Rapid City, South Dakota