FS-2025-0001-603597

I live in Missoula, Montana, and can see Lolo National Forest from my home. I previously lived in the PNW just outside Mount Baker-Snoqualmie National Forest and grew up skiing in the White Mountains and Green Mountains of New England. Hanging on the wall behind my computer as I write this comment is a map naming all four of our national land management systems and their governing agencies, with colorful pushpins marking the national forests, parks, grasslands, refuges, and monuments I’ve been fortunate enough to visit. I spend much of my time hiking, climbing, skiing, boating, camping, and simply enjoying public lands across the country. National forests are some of the places where I feel most at ease, where I feel lucky just to be alive, and roadless areas are where I can step outside of the world we’ve built and return to the home we’ve always belonged to. I also previously worked for the National Forest Foundation on conservation and forest-management issues. That experience taught me that forest management is complicated and that active, science-based management can be appropriate, including to address wildfire risk. It also taught me to be skeptical of broad changes that remove protections across millions of acres without first demonstrating that the existing framework is failing. I strongly urge the Forest Service to retain the 2001 Roadless Area Conservation Rule and select Alternative 1, the No Action alternative. I have also attached a longer version of this comment with additional context and questions for the Forest Service, including more detail on the ecological value of roadless areas, wildfire and roads, road maintenance and watersheds, timber harvest, existing environmental safeguards, the history of Forest Service management, and the cumulative effects of other changes to public-land protections. I hope the Forest Service will consider the attached document as part of my comment as well. The wildfire rationale does not appear sufficient to justify rescinding the entire rule. The 2001 rule already allows certain fuels treatments and road construction when necessary to protect public health and safety from an imminent catastrophic event. Prescribed and managed fire are not prohibited. The agency’s own analysis also raises questions about whether the rule is preventing necessary wildfire management. Roads themselves deserve more scrutiny. Humans caused approximately 84% of U.S. wildfires from 1992–2012, and human-caused fires were heavily concentrated near roads. The Forest Service already has more than 370,000 miles of roads and an estimated $10 billion maintenance backlog. New roads create permanent maintenance obligations and can damage watersheds, fish habitat, and water quality. This proposal also cannot be considered solely a wildfire measure. It removes restrictions on both road construction and timber harvest, and the agency recognizes that vegetation management and timber harvest can create the need for roads. I am not arguing that all timber harvest is inappropriate. I am asking the Forest Service to acknowledge that permanent road access changes what becomes economically and practically possible in a landscape over time. Other environmental safeguards are not equivalent to the Roadless Rule. For species such as grizzly bears, lynx, and bull trout, habitat loss and fragmentation are major threats. Once an intact watershed or wildlife corridor has been fragmented, project-level environmental review cannot simply put it back. The Forest Service’s own history should encourage humility. Management assumptions that once seemed unquestionably correct have changed as the agency learned from experience and from Indigenous knowledge. A road can be built in a season; meaningfully evaluating its ecological consequences can take decades. I ask the Forest Service to retain the Roadless Rule, identify specific cases where its existing exceptions have prevented necessary management, quantify the expected new roads and timber harvest in currently roadless areas, analyze the potential increase in human-caused wildfire ignitions, quantify long-term maintenance and watershed impacts, and explain how habitat and connectivity will be protected under the remaining safeguards. I’m not asking the Forest Service to stop managing forests or give up on wildfire mitigation. I am asking it to recognize that roadlessness itself has value, and that some losses cannot simply be reversed later. A forest can be cut in a few years. A centuries-old tree cannot be replaced on any meaningful timescale. An intact watershed cannot simply be put back together. When the consequences are potentially irreversible, the burden of proof should be high. If specific problems with the Roadless Rule exist, address those problems directly and use the narrowest effective tools. Please retain the 2001 Roadless Area Conservation Rule and select Alternative 1.