FS-2025-0001-583038

I am writing in favor of keeping the 2001 Roadless Area Conservation Rule as-is and in opposition to this proposed change that would rescind the 2001 Roadless Area Conservation Rule. Keeping roadless areas of our national forests is vital for long-term resource security, safety, and conservation. Rescinding the Roadless Rule and increasing the number and total length of roads will endanger our national forests by increasing the risk of wildfire and introduction of invasive species. Roads can increase the frequency of wildfires (eg, Narayanaraj and Wimberly 2012, Bowring et al 2024) - and even though fragmentation may reduce burn area, forest fragmentation is harmful to plants and animals in many ways and should not be viewed as an overall benefit or solution for wildfires. Similarly, roads (ie, human mediated travel) are a known dispersal pathway for invasive species (eg, Mortensen et al 2009, Ladin et al 2023, Solano et al 2021, Haubrock et al. 2026); many pest insects threaten our forests and to speed their spread into currently roadless areas could cause irreparable harm and economic loss (Lovett et al 2016). The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). Rescinding the roadless rule will be harmful to fish and wildlife by increasing forest fragmentation, destroying habitat, increasing soil disturbance and run-off into waterways, and increasing the likelihood of human-wildlife conflicts (Croke and Hairsine 2006, Robinson et al 2010, Boston 2016). These conflicts will be great in magnitude if the roads lead to more timber production and mining. Increased timber production and mining is harmful to fish and wildlife. Furthermore, increasing roads and areas where natural resources are extracted will reduce access for recreation and have a negative economic impact on the tourism industry. The Forest Service's own analysis shows economic losses from reduced tourism and recreation caused by rescinding the Roadless Rule. Our National Forests should remain intact and roadless so Americans can enjoy them now and for centuries in the future. Short-term gains from resource extraction are not more important that the long-term integrity and preservation of our natural areas and resources for all Americans and future Americans to enjoy. Finally The rule states that "local decision making would remain subject to the substantive requirements of the Endangered Species Act". However, current changes to the Endangered Species Act means that any roads, timber harvest, of mining that removes habitat and other resources necessary for endangered species to survive would not be a violation of the Endangered Species Act. Therefore, endangered species are at highest risk by rescinding the Roadless Rule. Species cannot survive if their habitats are destroyed, degraded, and fragmented. I urge the USDA to protect our natural resources and do NOT rescind the Roadless Rule. Narayanaraj and Wimberly 2012 - https://doi.org/10.1016/j.apgeog.2011.09.004 Bowring et al 2024 - https://doi.org/10.1038/s41467-024-53460-6 Mortensen et al. 2009 - https://doi.org/10.1614/IPSM-08-125.1 Ladin et al. 2023- https://doi.org/10.1038/s41598-022-25989-3 Solano et al. 2021 - doi: 10.1093/jee/toaa278 Haubrock et al 2026 - doi: 10.1002/brv.70121 Lovett et al 2016 - https://esajournals.onlinelibrary.wiley.com/doi/pdf/10.1890/15-1176 Croke and Hairsine 2006 - https://cdnsciencepub.com/doi/10.1139/a05-016 Robinson et al 2010 - doi:10.1139/A10-002 Boston 2016 - DOI 10.1007/s40725-016-0044-x