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Own letter
The comment
I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge USDA and the Forest Service to withdraw the proposal and retain the Rule’s nationwide protections for inventoried roadless areas.
I am a 36-year backpacker and hiker based in Sedona, Arizona, a certified site steward and trail patrol volunteer for the Coconino National Forest, a photographer who documents public lands, a board member of an environmental nonprofit focused on watershed protection, and an attorney with more than a decade of complex litigation experience. I have personally recreated in inventoried roadless areas in Arizona and Alaska, including along the Salt and Verde Rivers and in the Chugach National Forest. My attached PDF comment provides my complete factual, economic, environmental, and legal analysis, along with supporting authorities and citations.
My comment raises several principal concerns with the proposed rescission.
First, inventoried roadless areas provide a distinct recreational and ecological resource that cannot simply be replicated elsewhere in the National Forest System. Their undeveloped character supports primitive and semi-primitive recreation, wildlife habitat, watershed integrity, and water quality. Once roads and associated development are introduced, those characteristics may be permanently altered.
Second, the proposal does not adequately account for the economic importance of outdoor recreation and undeveloped public lands. This omission is particularly significant in Arizona, where outdoor recreation is a substantial and growing component of the state economy. The attached comment discusses national and Arizona-specific economic data and explains why the economic value of recreation, watersheds, tourism, guiding, photography, hospitality, and related industries should be meaningfully considered before eliminating protections across 58.5 million acres.
Third, forest-by-forest planning is not an adequate substitute for a uniform national baseline. Forest plans are revised infrequently and may be subject to differing local priorities, budgets, and political pressures. Replacing a national standard with separate management decisions across the National Forest System also makes it more difficult for recreational users, communities, and businesses to understand whether particular roadless areas will remain protected. The Forest Service should also address its substantial existing road-maintenance backlog before facilitating construction of additional roads into currently protected lands.
Fourth, I question the proposal’s reliance on wildfire management as a justification for rescission. Research discussed and cited in my attached comment demonstrates a strong relationship between roads and human-caused wildfire ignitions, including Arizona-specific data showing that human-caused fires disproportionately occur near roads. If additional flexibility is necessary for hazardous-fuels treatment, USDA should consider narrowly tailored modifications to existing exceptions rather than eliminating national protections across ecologically diverse roadless areas.
Finally, my attached comment identifies significant legal and procedural concerns under the Administrative Procedure Act and National Environmental Policy Act. These include whether the agency has adequately explained the reversal of a policy in place for approximately 25 years; meaningfully considered reliance interests; taken the required “hard look” at environmental, watershed, wildfire, recreation, and cumulative impacts; and provided an adequate opportunity for public participation given the scope of the proposed action and the abbreviated comment period.
For these reasons, I urge USDA to withdraw the proposed rescission and retain the 2001 Roadless Rule. At minimum, the agency should extend the comment period, conduct additional public hearings, address the existing road-maintenance backlog, and revise its analysis to meaningfully consider recreation-economy impacts, watershed effects, wildfire ignition data, and reliance interests before taking final action.
Please see my attached PDF comment for my complete comments, supporting factual analysis, legal arguments, authorities, data, citations, and personal stakeholder perspective. I respectfully request that USDA and the Forest Service consider the attached PDF in its entirety as my formal comment on the proposed rule.