I write today in support of the “no action” alternative and to keep the 2001 Roadless Rule intact. The Roadless Rule successfully safeguards the critical streams and rivers that provide clean drinking water for millions of Americans, preserves vital wildlife migration paths, and protects mature forests that serve as critical carbon sinks—an environmental buffer that is uniquely vital in light of increasingly hotter and drier weather trends here in Utah.
Complete rescission of the rule is a flawed approach to wildfire mitigation.
Particular notes of concern regarding the proposed changes:
Watershed Protection: Across the country, roadless forests feed watersheds that supply clean drinking water to about 24 million Americans. The agency's own DEIS indicates that a full repeal risks severe environmental degradation, including increased erosion, localized landslides, and heavy sediment loads introduced directly into these municipal water supplies.
Biodiversity: The DEIS also notes that shifting away from national roadless protections may adversely affect up to 327 threatened and endangered species by fragmenting critical habitats and disrupting migration corridors.
Tribal Sovereignty: Tribal nations overwhelmingly oppose the repeal of the Roadless Rule, citing direct threats to sacred sites and treaty-protected hunting and fishing rights. Notably, the Secretary of Agriculture and the USDA announced the proposed rule- a large-scale, sweeping shift in environmental policy- without the mandatory advance consultation of affected tribal governments, bypassing Executive Order 13175, the Administrative Procedure Act, and the USDA's own Departmental Regulation 1350-002. Attempting retroactive consultation during an open public comment window fails the legal standard for "prior" or "meaningful" government-to-government consultation.
Disrupting these vast, intact ecosystems will impact human communities far beyond what appears in the short term. A full repeal of the 2001 Roadless Rule strips all environmental protections and bypasses the collaborative, state-specific approach previously achieved in places like Idaho and Colorado. The cutting of mature trees will disrupt local water cycles, destabilize forest ecosystems, and fragment critical habitats. Introducing new road networks into these pristine spaces creates greater opportunities for human and machine caused ignitions. The 2001 Roadless Rule already allows for the proactive thinning of small-diameter trees to reduce wildfire risk; therefore, this total rescission is unnecessary for public safety and disregards the cumulative ecological damage that will be incurred.
I strongly encourage the USDA to consult with a balanced, independent panel of conservation biologists, ecologists, forest management specialists, and local tribal leaders to fully grasp the long term impacts of this measure. Furthermore, as established in NCAI Resolution #SEA-25-102, Tribal governments need to be treated as cooperating agencies, ensuring they have equitable standing with states in determining management priorities for areas that directly affect Tribal resources, treaty rights, and cultural landscapes.
If the rule is rescinded contrary to my primary recommendation, I urge the agency to implement a "Restoration Only" framework as the sole allowable policy direction.
Limit road infrastructure to temporary networks permitted solely for urgent forest health and public safety, while prohibiting commercial logging.
Restrict all cutting to sub-merchantable fuels using strict, science-based diameter caps.
Codify ecological priority zones.
Utilize non-commercial stewardship and continuous maintenance contracts focused solely on removing small-diameter ladder fuels while maintaining the closed canopy of ancient trees.
Thank you