Dear Director,
My name is Birgit Graf, and I am writing in response to the proposed rescission of the Roadless Area Conservation Rule (Docket No. FS-2025-0001).
I have lived in Montana for decades, and feel very fortunate having had the opportunity to spend time in places like the Bob Marshall and Great Bear Wilderness, the Swan Range and the Badger-Two Medicine Area. I have enjoyed the beauty and serenity of these undisturbed, quiet places, which make Montana unique, as large intact connected landscapes are increasingly hard to find.
I am very concerned about the future impacts of the proposed rescission of the Roadless Rule. Whereas Glacier Park, the Great Bear Wilderness, the Bob Marshalls enjoy protections from industrial development due to congressional designations, the integrity of places like the Badger-Two Medicine, the Swan Range or the Crazy Mountains is only protected by the Roadless Rule. Without that protection the likelihood of industrial development with accompanying negative impacts is very high.
Therefore I strongly support the "No Action" alternative (Alternative !).
!.The negative ecological impacts resulting from road building include wildlife habitat loss and fragmentation, loss of important migratory corridors, decrease in species diversity, soil erosion and stream pollution, harm to threatened and endangered species, increase in invasive insects and weeds, also a significant increase in noise and air pollution.
2. The economic consequences include loss of revenue due to declining tourism, as many out-of-staters visit the State esp. because of its magnificent scenery and wild beauty, as do many Montanans (like me), who enjoy hiking, boating, fishing and other recreational activities, which support local businesses like outfitters, guides, tour operators etc.
3. While the proposal for rescission does not mandate road-building and timber production and other industrial activities, according to the USDA, it is alligning with Executive Order 14225 "Immediate Expansion of American Timber Production" and EO 14154 "Unleashing American Energy" of 2025. Considering the 2025 congressional OBB Act, which mandates yearly increases of timber production on USFS administrated land as well as on Bureau of Land Management land, the quota can only be met by industrial-scale operations, and road building in the currently inventoried roadless areas seems inevitable. Besides moving the USFS Wildland Fire Operations over to the Department of the Interior, creating a new US Wildland Fire Service, and proposing more widespread budget cuts and the elimination of several offices (like the Collaborative Forest Landscape Restoration Program), the released USDA FS proposed budget for FY 2027 seeks to refocus the Forest Service on its core land and ressource management mission through timber production. This goal is reflected in the fact that the line item for forest products is more than quadrupled. The result is very limited room for multi-use.
4. A major reason for the rescission of RR is, according to the USDA,
that the rule prevents efforts to improve forest health, by aiding over grown forests, and to effectively deal with increasingly severe and long lasting wildfire seasons. It has been well established that roads actually increase the likelihood of wildfires. According to the National Park Service almost 85% of wildfires are human- caused, and ignite in close proximity to roads. The challenges of community protection in the wildland-urban interface, fuel reduction, and strengthening the resilience of forest ecosystems can be and has been successfully met within the framework of the Roadless Rule. Furthermore, it is difficult for me to understand how the aim of improving the federal response to wildfires, as stated in 2025, can be achieved, considering the major budget cuts and reductions in wildfire-certified staff and other essential workers in the same year.
5. In 2024, a group of Montana researchers found that the common quick suppression of low and modest intensity wildfires actually leads to larger more intense fires. These scientific findings are in line with tradidional tribal fire management practices, based on the knowledge that frequent, low intensity fires on the landscape are not just important to reducing the risk of catastrophic wildfires, but are essential for forest health and resiliency. I am encouraged by the over 60 co-stewardships that were signed in 2024 between Tribal Nations and National Forests. Also in 2024 the Forest Service published a draft amandment to the Northwest Forest Plan, which manages 245 million acres across California, Oregon and Washington. Over half of the amendment involved tribal stewardship.
I hope very much that the new Wildland Fire Service at the BLM builds on these partnerships. And as we have great responsibilities, I pray that decisions will be made with the well being of the future generations in mind.
Thank you!