FS-2025-0001-612334

Re: Comments on Proposed Rescission of the Roadless Area Conservation Rule, RIN 0596-AD66 Dear Secretary Rollins and U.S. Forest Service, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain these protections. I am a California resident, and I understand firsthand the urgency of wildfire and the need for responsible forest management. But that urgency makes it especially important that wildfire policy be based on evidence rather than assumptions. The claim that eliminating roadless protections will meaningfully reduce wildfire risk is not supported by the available evidence—including the Forest Service's own analysis. The Forest Service's draft environmental analysis found little difference in the proportion of land burned or in fire intensity among wilderness, inventoried roadless areas, and other National Forest System lands. It also found that wildfire ignitions are approximately four times more common on other National Forest System lands than in inventoried roadless areas and wilderness. Other Forest Service research has found that forests with and without roads can experience similar fire rates and that the absence of roads has not prevented appropriate fuel-management activities in roadless areas. Roads are not simply neutral tools for fighting fire. They facilitate human access, and human activity is a significant source of wildfire ignitions. Roads also fragment habitat, alter drainage, increase erosion and sedimentation, facilitate invasive species, and create a continuing footprint in landscapes that are otherwise relatively intact. Nor does the argument for increased timber production adequately justify repeal. Inventoried roadless areas contain some of our nation's least-disturbed forests and provide public benefits that cannot be reduced to the value of timber: clean water, wildlife habitat, carbon storage, recreation, scenic value, and ecological resilience. Many roadless areas are remote and steep, making road construction and timber harvest expensive while creating long-term costs for taxpayers. The economic value of extracting timber should therefore be weighed against both those costs and the substantial value of keeping these forests intact. California's national forests are particularly important as watersheds and as habitat for wildlife. They are part of the natural infrastructure on which communities depend. Protecting intact headwaters and forest ecosystems is a form of long-term stewardship, not an obstacle to responsible forest management. I also question the premise that retaining the Roadless Rule prevents the Forest Service from addressing genuine wildfire or forest-health concerns. The Rule contains exceptions and existing authorities allow appropriate emergency response and management. The relevant question is not whether forests should ever be managed, but whether eliminating nationwide protection for millions of acres of intact landscapes is an effective wildfire strategy. The evidence presented thus far does not establish that it is. The Roadless Rule has protected these lands for 25 years. Once a road enters an intact landscape, its ecological consequences cannot simply be reversed. Before removing a longstanding national protection, the Forest Service should be able to demonstrate clear, evidence-based public benefits that outweigh the permanent costs of increased fragmentation and development. I do not believe the current proposal meets that standard. I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule in its entirety. Wildfire is a serious threat, but it should not be used to justify a policy whose wildfire benefits have not been demonstrated. We should use the best available science to protect communities while also protecting the intact forests, watersheds, wildlife habitat, and ecological resilience that are among our most valuable public resources. Thank you for considering my comments. Sincerely, Louisa Squires Santa Cruz, CA