he Road Rule should remain in place. Removing the protection will be a detriment to our forests, wildlife, waterways and commerce. Studies have shown that wildfires start near roads. Careless people throwing stuff out the windows and such.
Black Butte roadless area in Los Padres National Forest is the kind of place the 2001 Roadless Area Conservation Rule was written to protect, and I am filing this comment to oppose its rescission under Docket FS-2025-0001.
California holds 381 inventoried roadless areas totaling 4,389,760 acres. Black Butte, at 5,116 acres, is one of them. The rule has stood for more than two decades as the legal foundation protecting that landscape from road construction and the cascade of consequences roads bring. Rescinding it without a credible substitute is a detriment to our environment. It is not necessary for any additional roads to be built. They also require additional maintenance.
The forests should remain pristine.
The agency advances wildfire management as a justification for rescission, but its own prior findings directly undermine that argument. The agency already found: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. Noting that a human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially roadless lands." That finding did not vanish because the agency changed administrations. The agency’s current reliance on wildfire management therefore appears inconsistent with its earlier recognition that increased road access can itself heighten the risk of human-caused wildfire.
Why is agency departing from its own prior findings on fire occurrence and fuel treatment in roadless areas? Why would you want to rescind in spite of the ignition data its own draft environmental impact statement contains? Doesn't make sense.
Seems the only reason these protections are being rescinded so they can be extorted and logged and mined. Once a road is in place easier access to destroy.
Extending roads will mean more car traffic and cars killing animals, struck while crossing the road. Rescinding the rule would put wildlife at risk.
Timber and mining make the land unstable so remaining trees could have ill effects and definitely the soil erosion would present a problem.
The quality of our air and water would also be effected by building roads in the currently protected forest. We also have an environmental industry that this would adversely effect.The protection of those watersheds has supported not only ecological integrity but also the outfitters, guides, and recreation businesses that depend on intact, unroaded landscapes. 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 is reached by spreading estimated losses across every small firm in the sector nationally rather than examining the businesses that actually hold permits in the areas at risk. The agency concedes that some firms may lose those receipts entirely. A certification that reduces the effects on individual small entities to a national average does not fulfill the purpose of a regulatory flexibility analysis. The agency should withdraw the certification and instead evaluate specific impacts on small entities operating within the roadless area that would be affected.