Dear Director,
I’m writing to oppose the full rescission of the 2001 Roadless Area Conservation Rule and to ask the Forest Service to pursue amendment instead of repeal.
[Optional: One or two sentences on personal connection — e.g., “I’ve hiked/hunted/fished in [forest/region] for [X years], and the roadless character of that land is why it still supports [wildlife, clean water, quiet recreation, etc.].”]
Amendment is the better tool. The state-specific roadless rules already in place for Idaho (2008) and Colorado (2012) prove the agency can address local management needs through negotiated rulemaking without eliminating baseline protections nationwide. The proposed rule itself notes that states, Tribes, and other parties can petition for tailored roadless provisions under 7 CFR 1.28 — that mechanism should be used instead of a blanket, one-time repeal of 25 years of settled protections across 44.7 million acres.
Old-growth and mature forest should be permanently off-limits. These stands cannot be replaced on any human timescale once logged or roaded. They:
•Hold the largest, most stable carbon stores of any forest condition class
•Provide habitat structure — large snags, downed wood, multi-layered canopy — that younger forest doesn’t have
•Protect water quality and intact watersheds far better than roaded, managed stands
•Represent some of the least-disturbed land left in the National Forest System, covering just a small fraction of the lower 48 yet supporting a disproportionate share of vulnerable species
If the Department’s real goal is wildfire risk reduction near communities, that can be achieved through targeted thinning in overstocked younger stands and wildland-urban interface zones — it does not require opening old growth to logging or new roads.
I ask the Forest Service to:
1.Withdraw the proposal to rescind 36 CFR Part 294, Subpart B in its entirety.
2.Pursue amendment through the existing petition process (7 CFR 1.28) to address specific, documented local needs.
3.Write an explicit, durable prohibition on road construction and timber harvest in old-growth and mature forest stands into any amended rule.
4.Retain a nationwide baseline of roadless protection rather than relying solely on individual, more easily revised land management plans.
Thank you for considering this comment.