Read the comments.

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit Sam’s Knob near my home in Asheville, NC. Protecting these unfragmented landscapes is deeply personal to me because I hike the backcountry trails and I value the pristine wildlife habitat. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Esther Hales Omission of Invasive-Species Establishment and Treatment Cost from the Quantified Cost Column of Cost Benefit Analysis Table 1 The Comparison of Alternatives table states that “Forest Service data indicates less than one percent of the affected environment has mapped invasive plant populations,” and that where activities increase under alternatives 2 and 3, “they could potentially increase the extent or the number of invasive plant species, especially if they create ground disturbance” (DEIS p. 32). The invasive plant species effects discussion repeats that conclusion (DEIS p. 116) and adds the agency’s own cost finding for alternative 2: “there would also likely be an increased cost associated with detecting and treating new invasive plant populations.” Neither passage projects an acreage, a spread rate, or a dollar figure for any alternative. The only acreage given is the existing 270,787 acres of invasive plants within the alternative 3 affected area, which is a baseline, not an effect. This is not a general objection to qualitative analysis. Table 1 of the Cost Benefit Analysis (p. 5) monetizes the benefit side of this rule at $9.9 to $22.0 million per year in timber benefit to society, and it monetizes two cost categories: lost recreation benefits at -$6.1 million and forgone passive use values at -$5.3 to -$11.5 million. Invasive-species establishment and treatment appears nowhere in that table, although the Cost Benefit Analysis states at p. 27 that road construction “contributes to soil erosion, sedimentation, risk of invasive species and habitat fragmentation,” and although the DEIS states that detection and treatment costs would likely rise. The agency has identified the effect, identified the cost, and then left it out of the only table in which costs are quantified. The stated reason for qualitative treatment does not reach this category. The Cost Benefit Analysis explains that “the rulemaking would not compel, require, or authorize any site-specific activities” and that “it is difficult to predict quantitative changes in costs or benefits” (p. 20). But lost recreation benefits and forgone passive use values are equally non-site-specific, and the agency monetized both across the same acreage on the same programmatic assumptions. Whatever method supported those two lines is available for this one. If it is not, the analysis should state why this category alone is different. Deferral to project-level analysis does not answer this either. The rescission itself fixes the acreage in which the prohibitions on road construction, reconstruction, and timber harvest no longer apply; the exposure follows from that rule-level determination, not from any later project decision. In Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), a programmatic EIS was held inadequate for deferring analysis of the spread of Port-Orford-cedar root disease to the site-specific stage where the programmatic decision governed the exposure. The invasive plant species discussion here rests on “future project design features and management requirements to mitigate invasives species introduction and spread” (DEIS p. 116) without disclosing what those measures are, what they cost, or what residual spread they leave after mitigation. The quantification direction is one the agency invoked itself. The Cost Benefit Analysis records at p. 4 that this rule was determined significant for purposes of Executive Order 12866 and requires OMB review, and that Executive Order 13563 “emphasizes the importance of quantifying both costs and benefits, reducing costs, maximizing net benefits.” A regulatory analysis prepared under those orders that monetizes the benefit side and two selected cost categories, while omitting a cost the agency’s own effects analysis says will rise, gives no reasoned basis for the omission and does not permit a reasoned comparison of alternatives.

I am opposed to rescinding the roadless rule for the following reasons. Fire danger: Intact forests that have not been logged have uneven-aged stands, larger trees farther apart, and more moisture-absorbing ground cover. They are not as prone to dangerous crown fires as logged areas that have grown up as even-aged stands and are choked with small trees and brush. Roads bring people, vehicles and activity, which bring sources of ignition. When you talk about forest management for fire prevention, you may be hoping that we imagine brush clearing or managed burns. But in fact, what usually happens is that areas are clearcut, leaving even-aged stands to grow up and be more fire-prone. You quote President Trump as saying, “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” Timber production is not the same as “targeted fuels treatments.” In fact, it can be the opposite. Many areas, especially in the west, have fire-adapted ecosystems that naturally burn and re-grow when ignited by lightning, for example. In a roadless area that is far from human settlement, fires can be allowed to take their course. Once there are mines, oil wells and lumber camps, there will be more infrastructure and people to protect and a greater need for fire suppression. Ecosystem Services: To some people, an intact forest produces nothing unless it is logged or mined. But in fact, it produces services of great value: clean water, clean air, fish and wildlife, natural beauty, soil formation, erosion prevention. Development: Even though you say that rescinding the rule only provides flexibility and doesn’t actually require road building, logging or mining, it’s obvious that exploitation is the goal. You mention the income that could be produced for timber companies and the federal government if logging is allowed. But it’s well known that the government subsidizes logging on federal land, so it would be a money loser for the taxpayer. Predictability: “EO. 13563 reaffirms the principles of E.O.12866 while calling for improvements in the Nation’s regulatory system to promote predictability, to reduce uncertainty, and to use the best, most innovative, and least burdensome tools for achieving regulatory ends.“ The best way to promote predictability is not to change the rule! Uncertainty will be magnified when each forest service unit creates its own plans. I feel like I’ve spent my whole adult life trying to keep roadless areas from being opened up. When is this going to stop? Just leave them alone.