FS-2025-0001-607700

Dear Director White, I am writing to state my opposition to the rescission of the 2001 Roadless Area Conservation Rule. I am a Wyomingite from Riverton, Wyoming, and I have spent many of the summers and falls of my adult life in part working in and next to roadless areas guiding pack trips, hunts and helping to run a cowcamp. I likewise recreate, hike, hunt and ride in Wyoming’s roadless areas frequently. What I value most from these areas includes both their solitude, wildlife and also their relative accessibility compared to wilderness. These are the places I, and other friends and colleagues, use as day trips that still allow for a backcountry experience. With the dramatic growth in populations in the rural west and increasing outdoor recreation, I believe roadless areas are worthy of increased protection, not weakening of existing protective frameworks. I urge the Forest Service to maintain the Roadless Rule and consider working with local communities, conservation organizations and other stakeholders in improving the Rule if necessary rather than scrapping or gutting it via Alternatives 2 or 3. Out of the three alternatives identified in the DEIS, I support the “no action,” Alternative 1. The proposed rule–analyzed as Alternative 2 in the DEIS -- would remove the Roadless Rule’s protections against commercial logging and road building from nearly 45 million acres of intact public forests, including over 3.2 million here in Wyoming. Alternative 3 is far from offering a meaningful alternative to a full rescission in that it removes roughly three fourths of lands currently listed as IRAs from protection via excessive and arbitrary methods. The Supplementary Information in the NOI stated “About 23 percent (10.2 million acres) of inventoried roadless areas managed under the 2001 Roadless Rule are within the Wildland-Urban Interface (WUI) areas … an additional 4.8 million acres are within one mile of the WUI, totaling about 35 percent of these inventoried roadless area acres.” Findings by The Wilderness Society, using the Forest Service’s own data, suggest that only 2.8 million acres of IRAs are located within one mile of the WUI, not 24.5 million. An additional analysis by the Property and Environment Research Center found that only roughly 74,000 roadless acres are within direct-exposure zones near developed areas, further suggesting that the 31.7 million acres removed from Roadless Rule protection under Alternative 3, and even more so the full rescission under Alternative 2, grossly exaggerate the geographic scope of benefit to community-wildfire protection. Wyoming’s roadless areas provide some of the best fish and wildlife habitat in the country, help supply one of five Wyomingites with clean water, and offer world class recreational opportunities. The loss of the Roadless Rule would put many of these values at risk, including in IRAs that I personally value. The Castle Rock Inventoried Roadless Area and Telephone Draw Inventoried Roadless Area are both IRAs facing incredible pressure from motorized vehicle use on their edges (much of the public land to the south is already incredibly accessible and well-roaded. This poses an issue to wildlife especially during hunting season when big game (elk, mule deer, bighorn sheep) species and other wildlife are heavily pressured and stressed. Telephone Draw has existing tribal and ancient Indigenous resources. Castle Rock IRA is likewise composed mostly of incredibly steep terrain that is incompatible with roadbuilding. The Middle Fork Inventoried Roadless Area is a prized recreational area for locals and visitors alike. The area is facing increased recreation pressure. The loss of the Roadless Rule protections would be damaging for wildlife, cultural resources and recreational experience in each of these IRAs as in other roadless areas across Wyoming and the nation. Thank you for your consideration of these comments, I urge the Forest Service to choose the “no action” Alternative. Thank you, Gabby Yates