Re: Special Areas; Roadless Area Conservation, Proposed Rule (91 FR 53827), Docket FS-2025-0001, RIN 0596-AD66
As an avid naturalist, camper, hiker and supporter of our Natural Forests, I submit this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select the No Action alternative and keep the rule in place.
1. The rule works and has broad public support. For 25 years, the Roadless Rule has protected tens of millions of acres of National Forest from new road construction and industrial logging while still allowing recreation, hunting, fishing, and fire management. It was adopted after one of the largest public comment efforts in the history of federal rulemaking, and the public response to this rescission has been just as large. Nothing in the record shows that the public has changed its mind.
2. Roadless areas protect clean water. Intact forests filter and regulate the flow of drinking water for millions of Americans. Roads are a leading source of sediment, landslides, and stream damage. Rescinding the rule would put these watersheds at risk and shift costs to downstream communities and water utilities.
3. Roads are not a wildfire solution. The Department says rescission would reduce wildfire risk, but the rule already allows thinning and hazardous fuel treatment near communities, and the great majority of such work happens outside roadless areas. New roads open backcountry to human ignitions, the leading cause of wildfires, and they carry long-term maintenance costs. The Forest Service already has a multibillion-dollar road maintenance backlog. Adding more miles of road makes that problem worse.
4. Habitat and climate. Roadless areas are some of the last large, connected blocks of habitat for species such as grizzly bears, salmon, and elk. They also store large amounts of carbon. Fragmenting them is difficult or impossible to reverse.
5. Forest-by-forest planning is not an adequate substitute. The Department says forest plans would govern roadless areas after rescission. Plans can be amended, are subject to local political pressure, and vary widely in strength. A national rule gives consistent, durable protection and certainty for communities, businesses, and visitors who depend on these lands. Rescission also invites years of costly, piecemeal conflict and litigation.
6. The process has been rushed. Complex rules affecting tens of millions of acres warrant longer comment periods and more thorough environmental review. The Department should fully analyze the cumulative impacts of rescission, including effects on water, wildlife, climate, Tribal interests, and rural economies built on recreation and tourism, and it should respond to the substance of public comments.
Conclusion. The Department has not shown that the benefits of rescission outweigh the loss of protection for these lands. I urge the Forest Service to retain the 2001 Roadless Rule in full, including for the Tongass National Forest.
Respectfully,
Laverne Simoneaux
Baton Rouge, Louisiana