Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
My family hikes and camps in these areas to slow down and get back to the basics that nourish us - connection with each other and nature. We feel fortunate to have places like the High Uintas Wilderness and the roadless area of Pettit in the Sawtooth National Forest, and we must protect these wild spaces from development for future generations, including our son as he grows.
Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and the families who depend on those lands have every reason to question what the agency proposes to do here. The Pettit roadless area in the Sawtooth National Forest has given our family many wonderful memories through the years. Rescinding the 2001 Roadless Area Conservation Rule puts places like Pettit and the High Uintas at risk of the very road construction and surface disturbance the rule was designed to prevent. The agency has not shown it understands what it is trading away.
The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Expanding the road system into the landscapes where we hike and camp does not reduce fire risk; the agency's own prior findings say it increases it. I ask that the agency explain why the proposal departs from those findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas.
The economic justification is no stronger. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that negligible extraction benefit, the agency's own Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value that spans from deeply negative to modestly positive, while the existing road system already carries a $6.9 billion maintenance backlog. Across the Intermountain region, which includes Utah and the High Uintas watershed, 1,466 municipal water intakes sit in watersheds containing affected roadless areas, a cost the analysis does not appear to internalize at all. How does the agency justify expanding a system it cannot afford to maintain, in pursuit of revenues its own numbers show are negligible?
The regulatory flexibility analysis does not hold either. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The Sawtooth National Forest supports guided outfitting and recreation that depends on the character of roadless land. Spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the permit holders actually operating in the affected areas, is not a serious analysis of impact. I ask that the agency withdraw the certification and assess the consequences for the small businesses actually holding permits in the potentially affected roadless areas.
Finally, "The proposal solicits 'any reliance in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." My family has made choices about where to go, where to invest time and memory, based on the protections the 2001 rule provides. This comment is exactly the kind of reliance interest the agency invited and is now obligated to weigh. The agency must identify and account for the reliance interests described in the comments it receives, including this one, before it takes any further step toward rescission.