FS-2025-0001-590242

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting means something to me. It encapsulates American freedom, something people in this country have done for centuries. Fishing is the same: my grandfather taught me, I fish with my wife, and I want to pass it on to my kids. We hike and camp all the time, going for solitude and to build memories. These are not abstract values. They are the reason I oppose the rescission of the 2001 Roadless Area Conservation Rule, and I ask this agency to take my comments seriously. The areas I care about sit inside the Gallatin and Beaverhead-Deerlodge National Forests in Montana. The Bridger unit at 45,059 acres, the Hyalite-Porcupine-Buffalo Horn Wilderness Study Area at 143,991 acres, the Madison at 127,859 acres, and the North Absaroka at 159,075 acres form part of the northeastern wall of the Greater Yellowstone Ecosystem. The Potosi unit at 5,194 acres in the Beaverhead-Deerlodge is part of that same landscape. The Gallatin Range fight has been one of the most contentious roadless battles in the country, pitting backcountry hunters and wildlife advocates against timber interests in grizzly bear habitat. I am one of those hunters. If you hinder hunting, you hinder freedom. America is not about hindering freedom. I have seen streams and trout populations change because of roads and logging. That experience is not abstract either. The agency's own record confirms what I saw. Roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Yellowstone cutthroat trout are verified species of the Custer Gallatin. Across the Northern Region, which includes Montana, 1,287 municipal water intakes sit in watersheds containing affected roadless areas. This decision directly impacts streams, where our water comes from, the water we need to drink, the water that fish live in, that cattle drink, the water that our crops depend on. I ask the agency to explain how opening these watersheds to new road construction can be squared with its own data on sediment loading and the public water supplies that depend on these drainages. The economics of this proposal do not hold up either. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency is already carrying a $6.9 billion road maintenance backlog against a road budget of roughly $73 million a year. Building more roads into country that has none, when the agency cannot manage the roads it already has, is straight up financial nonsense. Some of these places are not even worth logging, and if you have ever actually been in some of them you would know that. The agency must reconcile its own cost-benefit analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from negative $92 million to positive $199 million, and explain how that uncertain arithmetic justifies expanding a road system whose deferred maintenance is already a crisis. The agency also argues that rescission is needed for wildfire management. Its own record says otherwise: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must reconcile its proposal with that finding and explain why it departs from the ignition data in its own DEIS. The proposal argues that state-by-state approaches can replace a national rule. The record reflects that the agency itself once described its dissatisfaction with the rule's approach, quoting its own language about rejecting "inflexible 'one-size-fits-all' nationwide rulemaking." But the Ninth Circuit already found problems with the state-by-state replacement the agency tried before. The agency must address how this proposal avoids those same deficiencies. Public lands can host recreation, raw material extraction, farming and ranching, and gathering. All of these are good things, and they can occur without repealing the Roadless Rule. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres. That is a legacy worth keeping intact. Sincerely, Jacob Trausch Bozeman, Montana