“I am submitting these comments regarding the effect that rescission of the 2001 Roadless Rule could have on…”

I am submitting these comments regarding the effect that rescission of the 2001 Roadless Rule could have on the Ashley National Forest, Flaming Gorge National Recreation Area, Manila, Utah, and Daggett County. I request that USDA retain the protections of the 2001 Roadless Rule, or at minimum maintain equivalent or greater protections for inventoried roadless areas in and around Daggett County and Flaming Gorge National Recreation Area. I spend significant time in and around Manila and Flaming Gorge and have personally observed that the undeveloped character of the surrounding National Forest is one of the area's defining qualities. Visitors come here for Flaming Gorge, fishing, hunting, wildlife, camping, hiking, scenery, and access to relatively undeveloped public lands. For a small rural community like Manila, these scenic and recreational resources are economic infrastructure. Their long-term value should be weighed against any projected short-term benefit from additional timber, mineral, development, or road access. The lands surrounding Manila and Flaming Gorge derive substantial value because large portions remain undeveloped, scenic, intact, and connected. Forest Service planning documents recognize approximately 119,511 acres of inventoried roadless areas within Flaming Gorge National Recreation Area and recognize the area's scenery and recreation as important drivers of tourism and the local economy. Roadless areas of particular concern include Sheep Creek West, Sheep Creek East, Hideout Draw, Bare Top, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge. USDA should evaluate the cumulative effects of losing roadless protections across these adjoining areas rather than considering future roads only one project at a time. Roads can fragment wildlife habitat, increase erosion and sedimentation, spread invasive species, change recreation patterns, increase opportunities for human-caused wildfire ignition, and permanently alter scenic and undeveloped landscapes. This is particularly important around Flaming Gorge Reservoir, Sheep Creek, Carter Creek, Goslin Creek, and their tributaries. Protecting intact watersheds should remain an important preventative management tool for maintaining water quality, reducing erosion, and protecting vegetation and wildlife habitat. Wildfire risk does not justify eliminating roadless protections. The existing Roadless Rule already allows appropriate management actions, including certain vegetation treatments and exceptions addressing imminent threats involving wildfire, flooding, public health, and safety. USDA should distinguish between targeted fuels treatment needed to protect communities and infrastructure and substantially broader road construction, reconstruction, timber access, or development. Those are very different management decisions. Greater road access can also increase human-caused wildfire ignition and reduce the quiet, remote recreational character that makes these lands valuable. Around Manila, recreation associated with Flaming Gorge, the Green River, hunting, fishing, wildlife viewing, camping, hiking, and scenic landscapes is an important part of both the community's identity and economy. Permanent fragmentation could exchange a long-term renewable recreation asset for short-term development benefits. The economics of new roads should also be fully considered. The Forest Service already faces substantial deferred maintenance needs for existing roads and infrastructure. Before allowing additional roads USDA should evaluate who will pay to construct, maintain, repair, and ultimately decommission them. Roadless protection should also not be confused with Wilderness designation. Disagreement over formal Wilderness designation should therefore not be used as justification for eliminating roadless protections. If USDA determines that additional local flexibility is necessary, a better approach would be to retain roadless protections while allowing narrowly tailored exceptions. At minimum, I request that USDA retain existing protections for roadless areas surrounding Manila, Flaming Gorge Reservoir, Sheep Creek, Bare Top, Hideout Draw, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge unless a location-specific analysis demonstrates that removing those protections would provide benefits exceeding the long-term costs to scenery, recreation, wildlife habitat, watershed integrity, wildfire risk, road maintenance, and Daggett County's recreation-based economy. Once these landscapes are fragmented by permanent roads, their roadless character is difficult or impossible to restore. That irreversibility warrants continued protection. I request that USDA retain the 2001 Roadless Rule or establish equivalent or heightened protections for the Ashley National Forest and Flaming Gorge National Recreation Area in Daggett County, Utah.