3 files. Counts as 1 — Counts as one: The attachments enclose no one else's submissions; the comment counts as one.
Own letter
Own letter
Own letter
The comment
My comments are specific to the Bighorn National Forest. I worked on the Bighorn National Forest for 31 years of my 39-year career with the US Forest Service. I believe the situation on other National Forests is like the Bighorn National Forest.
The 2005 Bighorn National Forest Plan revision set a goal of reducing the miles of roads on the Forest by forty (40) miles. In 2015 the Travel Analysis Report (TAR) which took a detailed look at every road on the Bighorn National Forest. It again recommended reduction in the miles of roads on the Forest. I was on the review team for that effort. In 2004 a Mr. Wolf, Fellow, Society of American Foresters, authored a detailed white paper concerning roads on National Forests and the recent Roadless Rule implementation. In his report he explained that the National Forests were in serious need of reducing roads on National Forests due to lack of maintenance funding. Over this period these three studies have shown that National Forests cannot maintain the current miles of road let alone add additional miles.
Any improvements, including roads built are a liability, not an asset! The National Forest has enough liability with the current road miles.
Other public responses focus on the value of the current roadless areas in National Forests. I agree totally with them. Watershed protection, wildlife security, non-motorized recreational opportunities and not conducting money losing timber sales in the roadless areas. Over the last 70 to 80 decades if there was merchantable timber in these areas the Forest Service would have already constructed roads into the current roadless areas.
I have also attached two files detailing the documents I mentioned in my comments. They provide in much greater detail the need to maintain current NFS roads. Not build new ones in roadless areas! And my more detailed comments from March 2026.