Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The Absaroka and Beartooth Mountains in Montana are some of the most wild country in the US. They are humbling and beautiful, and they allow the wildlife of the Greater Yellowstone Ecosystem to thrive. I hike, backpack, and camp there and in the Pioneer Mountains and the Mission Mountains of western Montana to ground myself, to reset my nervous system from the manic pace of the modern world. These places have shaped how I think about public land management. I oppose the rescission of the 2001 Roadless Area Conservation Rule in Docket FS-2025-0001.
Public lands should be managed for every being, from humans to animals, insects, fish, and plants. All of them deserve to be protected. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres. The Custer Gallatin Forest accounts for 848,000 acres, forms the northeastern wall of the Greater Yellowstone Ecosystem. Grizzly bear, Yellowstone cutthroat trout, wolverine, elk, and bighorn sheep all depend on that country staying intact. I have backpacked in the West Pioneer roadless area within the Beaverhead-Deerlodge for years. It is peaceful and wild and deserves to remain so. In the Mission Mountains, the western flank carries the first Tribal Wilderness, managed by the Confederated Salish and Kootenai tribes to protect natural and cultural resources, and the adjoining national forest sustains grizzly bear habitat and Native food plants. The Kootenai National Forest, which borders this landscape, holds 48 inventoried roadless areas totaling 638,470 acres and is home to the Cabinet-Yaak grizzly population, one of the most endangered in the country, with fewer than 50 bears surviving there. Every road opened is a mortality risk for that population.
The agency's own record is clear on what roads mean for bears. The DEIS quotes the federal grizzly recovery plan to state that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. I ask that the agency address, specifically and in writing, how the proposed rescission can be squared with its own grizzly recovery record and with the documented mortality risk that attaches to road access in Cabinet-Yaak and Greater Yellowstone grizzly habitat.
The west is arid. I regularly recreate in the Forest that supplies my city's water, and I know we need to protect the clean water we have left like our lives depend on it, because they do. Across the Northern Region alone, which includes Montana, 1,287 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must explain what it intends to say to the communities whose intakes draw from these watersheds, and it must do so on the record.
The agency justifies rescission in part on wildfire grounds, but its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must explain why the proposal departs from these findings and reconcile the claimed fuels rationale with its own ignition data.
The economic case for rescission is not established by the agency's own numbers. The agency's Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, and the existing road system already carries a $6.9 billion maintenance backlog. The agency must explain in plain terms how a proposal whose own analysis cannot establish a net benefit justifies adding to that backlog.
The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than assessing the permit holders actually operating in the affected areas. The agency must withdraw that certification and assess the impact on the small businesses actually holding permits inside the potentially affected roadless areas.
Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such an interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken.
Sincerely,
Nicki Jimenez
Bozeman, MT