Secretary Brooke Rollins
U.S. Department of Agriculture
201 14th Street SW
Washington, DC 20250
Thomas Schultz Chief, U.S. Forest Service
1400 Independence Ave.,
SW Washington, D.C. 20250-0003
Re: Docket No. FS-2025-0001 - Comments on the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement (DEIS)
Dear Secretary Rollins and Chief Schultz:
I strongly urge USDA to keep the 2001 Roadless Area Conservation Rule (Rule) intact, select the No Action Alternative, and revise the DEIS as stated below. The North Country Garden Club of Long Island, New York is deeply committed to conservation and environmental stewardship and has advocated for the protection of forests, flora, fauna, and biodiversity for well over a century, which is why we strongly oppose a rollback that would threaten ancient botanical carbon sinks, fragment vital wildlife corridors, and put at risk pristine watersheds supplying clean drinking water to more than 24 million Americans.
Our members of the NCGC a Garden Club of America Member Club, appreciate the U.S. Forest Service (USFS) Inventoried Roadless Areas (IRA’s)—hiking, camping, fishing, horseback riding, birdwatching, backpacking, skiing, hunting, and viewing wildlife and the beautiful scenery in these largely undisturbed landscapes. Rescinding the Roadless Rule would irreparably harm these stunning landscapes, and, in turn, the well-being of our members who cherish and depend upon them.
NCGC members spend time in and deeply value Inventoried Roadless Areas. These places matter to our organization as they provide clean water, wildlife habitat, recreation, solitude, and increasingly rare intact forests.
The current Rule already allows substantial forest management, including prescribed fire and other hazardous-fuels reduction. While USDA claims rescission would reduce wildfire risks, the DEIS cites research that 1) the lack of roads has not prevented fire prevention or protection measures, and 2) acknowledges that almost 90% of wildfires are human caused and more than four times likely to ignite near a road. If specific constraints exist, USDA should identify and address those narrow constraints rather than remove the Rule’s nationwide protection.
USDA has not adequately assessed the reasonably foreseeable national and regional environmental effects of its decision to eliminate the Rule’s protections across 44.7 million acres of public lands. Deferring NEPA review to future site-specific individual projects will not address the regional and national consequences of rescission. While later reviews may evaluate individual projects, they would not address foreseeable programmatic impacts at scale from landscape fragmentation, habitat connectivity, native plants and invasive species. interstate or inter-forest migration corridors, or regional watersheds. USDA should assess now where national rescission would put intact habitat, wildlife movement, and native plant communities at greatest risk, and where added roads and timber harvest could most threaten watersheds and drinking-water sources.
Rescission would also remove protections from 9.3 million acres in the Tongass National Forest, relying on the 2020 Alaska Roadless Rule Final EIS, but it has not demonstrated the earlier environmental analysis adequately evaluates rescission. Tribal consultation remains incomplete. USDA should fully consider Tribal concerns about subsistence, cultural resources, fish and wildlife, and intact landscapes before making a final decision.
I urge you to keep the national protection of the Rule in place and reassess the reasonably foreseeable effects now.