FS-2025-0001-607244

Subject: Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule, 91 FR 53827 (Docket No RIN 0596-AD66) Dear Forest Service Rulemaking Team, I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to urge the Department to select the no-action alternative, which retains the Rule in full. Because i live in NYC, in part for work-related reasons, my greatest pleasures are escaping to wilderness, roadless areas for recreation. I am an active fly fisherman and have hiked, backpacked and fished in many roadless areas, my personal favorites include the Clark Fork Region in the Idaho Panhandle National Forest and in the Green Mountain National Forest in Vermont. To hoghlight my objections to changing the current rule: 1. The current rule protects irreplaceable forests at a modest cost, keeping out nearly 45 million acres of national forest free of new road construction and most industrial logging. These areas supply clean drinking water, provide core habitat wildlife and offer some of the last undeveloped and most spectacular areas for backcountry for hiking, hunting, fishing, and quiet recreation. Once a road is built, these qualities cannot be restored. 2. The wildfire justification is not supported by the agency's own analysis. The proposal is framed as a wildfire-risk measure. But I understand the Draft Environmental Impact Statement itself acknowledges that increased road density raises the likelihood and frequency of human-caused ignitions. The Rule already allows thinning and fuel treatments near communities, including road work needed to protect life and property. The agency has not shown that the Rule is what limits effective fuels work, particularly when [the Forest Service faces large maintenance backlogs on the roads it already has]. Adding new roads to a system the agency cannot currently maintain would worsen the problem. 3. The Forest Service cannot afford more roads. The agency already has a multibillion-dollar deferred maintenance backlog for its existing road network. Opening inventoried roadless areas to new construction would add long-term liabilities for taxpayers, along with erosion, sedimentation, and invasive-species spread that degrade water quality and fish habitat. 4. The public process has been rushed and not vetted sufficiently. A rule affecting about 45 million acres deserves a full, unhurried comment period. Draft EISs of this scale commonly receive 60 to 90 days, yet this one was offered only 30 before a brief extension. I also ask that the Department make the records of Tribal consultations publicly available in the docket so the public can evaluate how treaty rights and trust responsibilities were considered. 5. And most importantly, this proposal is out of step with public opinion. The 2001 Rule drew an unprecedented volume of public comment, and the overwhelming majority supported it. As a city dweller, my respite and relief has always been my ability to retreat into nature – these roadless areas represent one of America’s crown jewels. My hope is that the enormous pleasure these wild areas have provided my generation will be available to my grandchildren and even their grandchildren. I therefore urge the Department to abandon the proposed rescission and retain the 2001 Roadless Area Conservation Rule. If the Department believes specific management needs exist, they should be addressed through targeted, transparent amendments rather than wholesale repeal. I also ask that the Department respond substantively to the issues raised in these comments in the final rule and Final EIS. Thank you for considering my comments and concerns. Sincerely, JLS New York City, NY