Dear Chief Tom Schultz,
As a freshwater ecologist, I understand the importance of intact and undisturbed ecosystems. Rescinding the 25-year-old Roadless Rule would put those untouched forests in jeopardy and would be a true loss for the American people.
Pre-European settlement, Michigan was once home to 10.7 million acres of wetlands. Since 1978, that number has dropped to 6.47 million acres. Bear Swamp in the Huron-Manistee National Forest is an intact wetland protected by the Roadless Rule. Bear Swamp is home to federally protected species such as the Eastern Massasauga rattlesnake and Blanding's Turtle. Additionally, Bear Swamp is home to the Brook Trout, a species I studied in college and is an indicator of high water quality.
“Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)”
If this rule is rescinded, we lose the pristine headwaters of Muckwa and Black Creek that feed into the larger Big Sable River system. These waters protect important and imperiled cold-water species such as the brook trout. Building roads leads to disconnects in rivers that make fish migration difficult and alters the temperatures of those rivers. Additionally, roads are huge sediment polluters, especially when crossing critical stream/ river habitat.
Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan:
Communities downstream of the Bear Swamp IRA, Huron-Manistee National Forest, receive clean water because this watershed has no roads. Municipal water supplies, agricultural irrigation, and recreational fisheries all depend on the sediment-free, thermally stable flows that the roadless condition delivers. Road construction transfers the cost of degraded water quality to every downstream user.
The Bear Swamp IRA, Huron-Manistee National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently.
The DEIS must evaluate the cumulative effects of road construction in the Bear Swamp IRA, Huron-Manistee National Forest, on downstream water users, including changes to turbidity, temperature, and flow regime. The analysis must include the cost of increased water treatment required by downstream municipalities and the economic impact on downstream fisheries and recreation.
"Riparian shade restoration (2000s climate) could decrease mean August stream temperatures by 0.62°C across the study network. Removing the current riparian shade resulted in a nearly 50% loss of habitat meeting the numeric temperature water quality criteria (12°C 7DADM) for char spawning and rearing, while restoring vegetation only increased the proportion of fish habitat meeting the criteria by ~10%. The linear relationship established in our models between reach shade and stream temperature indicates an increase of ~40% reach shade should cool a stream reach by ~1°C."
— Restoration Ecology (PMC/Wiley), 2022
The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling.
The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests.
The Roadless Rule is one of America's most popular conservation measures, and that support has not faded.
I'd rather see the Department focused on strengthening forest protections, not rolling them back. This proposal moves in the wrong direction.
Sincerely,