Re: Special Areas; Roadless Area Conservation - proposed rescission, 91 FR 53827 (Aug. 20, 2026) | RIN 0596-AD66 | Docket FS-2025-0001
I oppose rescinding the 2001 Roadless Rule and ask that the Department withdraw the proposed rule, or at minimum adopt an alternative that retains the national baseline and requires site-specific NEPA before any road construction or commercial harvest in inventoried roadless areas.
I am a U.S. military veteran and an America the Beautiful Military Lifetime Pass holder. I live in San Francisco, and these areas are where I actually spend my time - the San Gorgonio Wilderness (San Bernardino NF), the Cucamonga Wilderness and the San Gabriel high country around Mount Baldy (Angeles NF), the Mount Pinos country in Los Padres NF, and the eastern Sierra out of Mammoth. The reason those places are still quiet is the 2001 rule. I also drive SR-38 to the Vivian Creek trailhead, which has washed out repeatedly since the 2020 El Dorado Fire - a reminder of what these steep headwater drainages do after fire, and why road density and ground disturbance in them matter.
Four specific comments:
1. The stated problem does not require this remedy. USDA keeps the Idaho (subpart C) and Colorado (subpart D) roadless rules and notes that any state, tribe, or entity may petition under 5 U.S.C. 553(e) for tailored management. If place-based roadless rules are workable - and USDA is retaining two - then "one-size-fits-all" is not a justification for repealing the baseline everywhere else. The Department already has the mechanism it says it needs.
2. "Returning decisions to land management plans" is a plan of absence. The notice states the rule "does not require or compel the amendment or revision of any land management plan." For forests whose plans do not independently prohibit road construction and harvest in roadless areas, rescission leaves a gap with no protection until a plan is revised - years, for many units. The final EIS should state, acre by acre, how much of the 58.5 million acres retains equivalent protection on day one and how much does not. The notice asserts effects are "bounded by existing land management plan direction" without demonstrating what that direction is.
3. The economics are close to a wash; the losses are not. USDA's own figures: timber-industry gain of $4.6-10.6M/yr, recreation loss estimated at $6.1M/yr - against a $6.9 billion deferred-maintenance backlog on the existing forest road network. Building new roads you cannot afford to maintain, for revenue the same order as the recreation value displaced, is not a net-benefit case. The road-maintenance liability of new permanent roads is missing from the analysis.
4. Wildfire. The notice concedes greater access "can increase human-caused ignition potential." If road construction is justified as fire-risk treatment, the EIS should quantify treatment acreage actually achievable within operability and budget over ten years, and compare it against the acres each new road puts at higher ignition risk. The 9.8 million WUI acres overlapping roadless areas deserve a spatially explicit alternative, not blanket repeal.
Alternative I support: No Action, or a targeted-WUI-treatment alternative permitting fuels reduction and temporary access within a defined distance of at-risk communities while retaining the prohibition on new permanent roads and commercial harvest in the interior of inventoried roadless areas.
As a veteran, I value these lands for the quiet, self-reliant recreation they provide, and I ask the Department to keep the protection that makes them what they are. Please withdraw the proposed rule.
Brian Mauck - San Francisco, CA