FS-2025-0001-590006

Dear Director: On behalf of Gila County, Arizona, we appreciate the opportunity to comment on USDA's proposed rescission of the 2001 Roadless Area Conservation Rule. Gila County supports greater flexibility for local forest managers to address conditions on the ground, particularly where road improvements and active forest management are necessary to protect public safety. Gila County is home to extensive National Forest System lands, including the Tonto National Forest, so Forest Service decisions on roads, forest health, and access directly affect County residents. Two priorities stand out: emergency access across federal lands, and active forest management to reduce catastrophic wildfire risk. Public Safety and Forest Roads Gila County's mountainous terrain, wildfire exposure, and dispersed rural communities create significant challenges for fire suppression, emergency medical services, evacuation, and disaster response. Forest roads are critical public-safety infrastructure, not simply recreational amenities. Control Road (FSR 64) is a key corridor through the Tonto National Forest for residents, forest management, and emergency response. The Forest Service has previously funded improvements, and the County's long-term goal remains a paved Control Road. Because the road is on federal land and serves federal purposes, the Forest Service should have a significant role in bringing it to standard. Young Road (FSR 512/FH-12) presents an even more immediate need. Young is an isolated rural community surrounded by National Forest System lands, making reliable access essential for residents, emergency responders, and wildfire evacuation. The project is well advanced: ADOT's June 2026 Stage III estimate identifies 13.5 miles of paving, drainage, guardrail, and erosion-control improvements at the 60-percent design stage, at an estimated cost of approximately $25.1 million. Gila County urges USDA and the Forest Service to provide the federal funding necessary to move Young Road into construction. Forest Management Is Emergency Management For Gila County, forest management is emergency management. The 2021 Telegraph Fire burned more than 180,000 acres in Pinal and Gila Counties. Severe wildfire destabilizes soils and watersheds, leaving communities vulnerable to flash flooding and debris flows long after the fire is out. In September 2025, exceptionally intense rainfall caused catastrophic flooding in the Globe-Miami area. Pinal Creek rose approximately six feet in 30 minutes; floodwaters damaged businesses and infrastructure, swept away vehicles, and three lives were lost. Gila County therefore supports giving local Forest Service officials sufficient flexibility to undertake hazardous-fuels reduction, thinning, prescribed fire, fuel breaks, and watershed restoration. Roads needed to conduct those treatments and provide suppression and emergency access must be part of that strategy. Federal Lands Require Federal Investment Gila County recognizes the values protected by the National Forest System. Rescission of the Roadless Rule would not itself authorize individual projects; forest plans, environmental review, and other federal requirements would continue to apply. Gila County and the Tonto National Forest already operate under a Cooperative Forest Road Agreement covering the planning, construction, and maintenance of forest roads. But federal responsibility should be accompanied by federal investment. A rural county should not bear the primary financial burden of improving Forest Service roads needed to manage federal lands, protect communities, provide emergency access, and respond to wildfires. Accordingly, Gila County supports greater flexibility to address local forest-management and transportation needs while retaining applicable environmental review. The County urges the Forest Service to use that flexibility to improve public safety and actively manage forests, and to invest in the infrastructure to do so, including federal funding to pave Control Road/FSR 64 and to move Young Road/FSR 512 from design into construction. These roads are on federal land and serve federal as well as local purposes; the federal government should be a principal partner in bringing them to the standard both the National Forest System and surrounding communities require. Gila County looks forward to continuing its partnership with USDA and the Tonto National Forest. Thank you for your consideration of these comments.