The USFS should stop the rule making process to rescind time 2001 Roadless Rule (66FR3244). Preserving forests means protecting them not only from fire, but from the political and corporate interests that continuously seek to monetize public lands.
The USFS's own research (Long-term forest health implications of roadlessness, 2020, Sean P. Healey
Environmental Research Letters. 15: 104023.) has shown that human-caused wildland fire occurs at higher rates near roads than in roadless areas. While more rapid response to fire, facilitated by roads, may decrease the size the fire, this is offset be the increased fire frequency.
Studies have shown time and time again, if you want to protect homes in the wildland urban interface you need to fire proof the structure not cut down all the trees.
In addition, the rescinding of the roadless rule implies that wildfire risk will be reduced by thinning. This may be true for the short term but, without follow-up maintenance or prescribed burns, thinned forests often experience dense spurts of sapling and brush regrowth, which can recreate high fuel loads in less than 10 years.
Analysis from the same study cited above showed that roads are strongly associated with the spread of invasive plant species in national forests. Non-native plants are twice as common within 500 feet of a road as farther away. The study concludes that based on 20 years of monitoring data rescinding the roadless rule road prohibitions would not improve forest health or reduce wildfire risk. Invasive plant species degrade the land for wildlife and livestock.
Adding roads and increasing road density will also fragment the habitat, which has been shown to have a negative effect on forest plants and animals, and increase human/wildlife conflict. Roadless areas are important to the survival and well being of threatened and endangered species.
Most roadless areas are located remotely at the top of pristine watersheds. Road building, development and resource extraction will have a negative impact on the watershed's water quality and quantity, which impacts all downstream users.
One of USFS goals in the rescinding the Roadless Rule is to increase local control. This goal conflicts with current policy and executive orders (Executive Order 14192, Unleashing Prosperity Through Deregulation, Executive Order 14225, Immediate Expansion of American Timber Production, and Executive Order 14154, Unleashing American Energy). The current policy combined with these executive orders will increase non-local development and resource extraction. Plus, the USFS's increased weakening of NEPA combined categorical exclusions will further erode the already limited local public input.
In Montana, where I live, polls indicate that 80% of the state favors keeping roadless areas as they are. Part of the reason we favor it is for recreation, which is a big contributor to the state's economy. But it is more than that, it is also the solitude and stress relief people get from being out in nature.
The USFS asks for viable alternatives to rescinding the Roadless Rule. I say, do nothing. Keep roadless areas as they are. If you are looking for economic justification, how about all the below cost timber sales on USFS lands we could avoid? That money saved for doing nothing should be enough justification. If not, you can include the clean up costs the government ends up stuck with to clean up after mining companies that go bust. Finally, the loss of recreation dollars that are spent visiting the untrampled roadless areas.