FS-2025-0001-585055

I respectfully oppose nationwide rescission of the 2001 Roadless Area Conservation Rule because of the consequences for clean water, trout fisheries, and the undeveloped headwater watersheds that support them. I say take Alternative 1 – No Action, and maintain the roadless rule in place. Ever since I was a child, I have camped, fished, hunted, and backpacked across some of the designated roadless areas in particularly in Middle Fork Roadless Area in Wyoming and Price Mountain in Virginia. I grew up as a Boy Scout and as the son of a U.S. Fish and Wildlife Service biologist, my favorite memories in the are hiking through the most beautiful stands of pine trees and catching the most beautiful brook trout. Nowhere have I experienced this more clearly than in Middle Fork Roadless Area . In my experience, it contains some of the finest trout fishing anywhere. On one trip to two lakes known as the Twin Lakes, I caught roughly 60 brook trout in only a few hours. What made that experience extraordinary was not simply the number of fish. It was fishing in a remote mountain watershed surrounded by an essentially undeveloped landscape. These fisheries are a treasure! My experience as an angler illustrates an important principle of watershed science: a trout stream or lake cannot be separated from the landscape draining into it. Forest roads can disturb soils, alter drainage, increase erosion and sediment delivery, and create barriers at stream crossings. Forest Service research has long identified increased sedimentation and obstruction of fish migration as important potential effects of forest roads on salmonid habitat (Yee & Roelofs, USDA Forest Service, 1980). USFS Research & Development The Forest Service's own environmental analysis has also found that road sediment can increase fine material in streambeds and reduce preferred fish-spawning substrates. Culverts can fragment aquatic habitat, while roads and stream crossings can alter channel form, substrate, pool depth, and other characteristics important to fish. US Forest Service This matters far beyond the physical footprint of a road. Roadless areas occur within hundreds of major American watersheds. US Forest Service Protecting relatively intact headwaters helps protect water quality and fisheries downstream. Sediment and altered runoff do not stop at an administrative boundary. I also question whether nationwide rescission is justified as a wildfire and forest-health measure. Forest Service researcher Sean Healey analyzed nearly 20 years of monitoring data and found that forests with and without roads burned at similar rates after the Roadless Rule took effect. Fuel-management activities still occurred in roadless areas and were actually more numerous per square kilometer, although treatments outside roadless areas covered larger areas. His analysis of more than 15,000 forest inventory plots also found non-native plants were twice as common within 500 feet of roads. He concluded that the monitoring evidence did not support speculation that eliminating road prohibitions would improve forest health (Healey, 2020, Environmental Research Letters 15:104023). USFS Research & Development I am not arguing that roads should never be built or that forests should never be actively managed. As a hunter, fisherman, camper, and backpacker, I recognize the need for wildfire mitigation, ecological restoration, responsible timber management, and access. Roads can be valuable management tools where there is a demonstrated need. But restraint is also a form of management. Some watersheds provide their greatest public benefit precisely because they remain relatively intact. Once a remote watershed is fragmented by permanent roads, restoring its hydrology, aquatic habitat, and undeveloped character can be difficult and expensive. The scientific response should therefore be targeted management based on local conditions, not elimination of a national conservation framework covering tens of millions of acres. I ask USDA to retain the 2001 Roadless Rule. Where legitimate wildfire, restoration, or public-safety needs cannot reasonably be addressed under the existing framework, USDA should use narrowly tailored, science-based exceptions rather than nationwide rescission. At minimum, strong protections should remain for important headwater watersheds, native and wild trout habitat, spawning tributaries, and watersheds supporting sensitive aquatic species. Future generations of Americans deserve the opportunity I had as a kid: to shoulder a backpack, hike beyond the end of a road, and find cold, clean water full of trout. These places provide clean water, wildlife habitat, hunting and fishing opportunities, and experiences that become increasingly valuable as truly undeveloped landscapes become harder to find. Please retain the 2001 Roadless Area Conservation Rule and protect the clean, cold headwaters upon which America's trout fisheries and downstream communities depend.