Opposes rescissionA0 noneSubstance 3/24Posted October 6, 2026 On Regulations.gov
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Public Comment Submission
Docket ID: FS-2025-0001
Proposed Rule: Rescission of the 2001 Roadless Area Conservation Rule
To Whom It May Concern:
Please accept these comments on behalf of Bob and Diane Hutton, retired U.S. Forest Service (USFS) employees with 40 years of dedicated agency service each, who are also active sportsmen and Montana residents. Based on our combined 80 years of direct experience managing National Forest System lands across Oregon, Utah, Idaho, and primarily the Beaverhead-Deerlodge National Forest, we strongly oppose rescinding the 2001 Roadless Area Conservation Rule.
Our careers directly spanned the critical program areas at the center of this debate: timber, fire, range, invasive species, and trails. Having spent decades implementing these exact programs, we know rolling back roadless protections will cause severe fiscal, ecological, and operational harm to the agency and public lands.
1. The Road Maintenance Backlog and Staffing Collapse
Working in timber and trail management, we witnessed a continuous decline in agency staffing, equipment, and budgets. The USFS manages an unsustainable network of over 370,000 miles of road while facing a deferred maintenance backlog exceeding $8 billion.
• Operational Impossibility: The agency lacks the workforce and heavy equipment to maintain its existing footprint. Thousands of miles of road have already been downgraded or abandoned because the agency cannot service them.
• Fiscal Irresponsibility: It is managerially irresponsible to open Inventoried Roadless Areas (IRAs) to new road construction when the agency cannot safely manage current infrastructure. New roads strip resources away from existing, heavily used recreation roads and trails.
2. Lack of Capacity to Treat Road-Induced Noxious Weeds
Our experience in range and invasive species management highlights a stark reality: roads are the primary vectors for noxious weeds.
• The Vectors: Ground disturbances from road building rapidly colonize with invasive species like spotted knapweed and hound's-tongue. These weeds hitchhike on vehicles and spread deep into forest interiors, destroying native range forage and ruining critical winter range for elk and mule deer.
• The Workforce Deficit: Managing infestations requires multi-year monitoring and chemical or biological treatment. The USFS lacks the field employees and seasonal crews required to treat existing roadside weed corridors. Opening IRAs to road construction will create unmanageable weed highways that a depleted workforce cannot contain.
3. Roads Drive Human-Caused Wildfires
Working in fire management, we know that proponents often argue roads are necessary for wildfire suppression access. Our experience and historical data show the exact opposite: roads introduce the risk.
• The Ignition Risk: Over 90% of human-caused wildfires start within half a mile of a road. In Montana, human-caused ignitions on National Forest lands are eight times higher within 100 yards of a road than in roadless blocks.
• The Vulnerability: Building roads into pristine IRAs actively invites motorized human pressure and accidental ignitions into remote, high-risk areas, putting communities and our former wildland firefighting colleagues at greater risk.
4. Flawed Economic Projections: Recreation vs. Subsidized Timber
As sportsmen who hunt in Montana, we understand that the economic engine of the modern West is driven by intact habitats, not subsidized timber extraction.
• The Economic Reality: Outdoor recreation generates 4.9% of Montana’s GDP ($3.8 billion annually) and supports over 32,000 jobs. Pristine roadless areas are the exact backcountry spaces that draw hunters and anglers who fuel local economies.
• The Subsidy Trap: Conversely, building timber roads into remote terrain is heavily subsidized by taxpayers. With declining housing starts and deflated timber prices, the cost of building and decommissioning rugged timber roads far outpaces the commercial value of the timber retrieved. It represents a net-negative return on investment for taxpayers.
Conclusion
Based on our 80 years of collective service, we know the 2001 Roadless Rule is one of the most effective, fiscally sound conservation policies the agency has ever implemented. It protects the agency from taking on unmaintainable infrastructure liabilities while safeguarding intact habitats. We urge the Forest Service to withdraw this proposal and maintain the 2001 Roadless Rule in its entirety.
Sincerely,
Bob and Diane Hutton
Retired U.S. Forest Service Employees (80 Years Combined Service)
Specialized in Timber, Fire, Range, Invasives, and Trails
Montana Residents & Sportsmen