Re: Proposed rescission of the 2001 Roadless Area Conservation Rule
I live in Brightwood, right at the edge of the Mt. Hood National Forest, and I'm writing because I don't want to see the Roadless Rule go away.
I'll start with fire, since that's the reason being given for repeal. I'm not a fire scientist, but the research I've read doesn't back it up. People start about 84% of wildfires in this country (Balch et al. 2017, PNAS), and roads are how people get into the woods. A big look at thirty years of national forest fire records found roadless areas had about 2 ignitions per 1,000 hectares, and land within 50 meters of a road had around 7 or 8 (Aplet et al. 2026, Fire Ecology). The authors said building roads into roadless areas is likely to mean more fires. The Forest Service said the same thing in its own 2001 environmental impact statement, and I don't understand what's changed since then.
I also care about hunting and fishing here, and what worries me is the habitat. Elk in Oregon consistently choose ground away from open roads (Rowland et al. 2000), so every new road takes away country they'd otherwise use. Fish are the same story. The main scientific review I found says roads harm streams and aquatic life, and that the damage is rarely fully undone, which is why it says to hold onto the roadless areas we still have (Trombulak and Frissell 2000). Good hunting and fishing depend on good habitat. This isn't a fight between hunters and environmentalists either: groups like Trout Unlimited and Backcountry Hunters and Anglers oppose repeal too.
And then there's the old growth, which I think gets talked about as if it's just big trees. It's a whole habitat. The Forest Service's own researchers found that old-growth stands are critical nesting habitat for northern spotted owls (Lesmeister et al. 2019), and Trout Unlimited's president has pointed out that roadless areas are about 2% of the American landscape but shelter roughly 25% of our threatened and endangered species. Old forests also hold water in a way young or thinned forests don't. The shade, the layered canopy, and the dense understory keep the forest floor cooler, damper, and out of the wind (Frey et al. 2016, Science Advances). Forest Service researchers comparing hundreds of Northwest fires found open, younger forests had hotter, drier, windier conditions, and that those conditions fade fast once you step into an older forest (Lesmeister et al. 2021). Old-growth stands burned cooler and were less likely to burn at high severity than younger forest (Lesmeister et al. 2019). Roads and logging cut holes in that canopy, and the moisture goes with it. That is the opposite of fire prevention.
The Forest Service's own documents say repeal would open about 4.8 million acres of roadless forest to more active management, which in plain terms means logging. Mt. Hood alone has 118,000 acres of roadless land. Old growth takes centuries. We don't get it back.
More than 1.6 million people spoke up for this rule when it was adopted. Please keep it in place.
Thank you for reading this.
A.C. Eggen, Rhododendron, Oregon