“greater public access can increase human-caused ignition potential”
“The 2001 Rule already allows fuel-reduction work under its exceptions”
“answer is to fix the approval process, not to remove protection”
“people start most wildfires in the United States”
What it names
Works cited
U 2001
The comment
I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and ask USDA to adopt the No Action alternative.
The case for rescission rests on benefits the proposed rule itself describes as uncertain. The preamble says management opportunities "would be modest and localized" and that "it is difficult to predict the potential impact rule rescission may have on timber harvest." Against those limited gains, the Department estimates about $6.1 million a year in lost value to recreationists, along with trade-offs for recreation and tourism businesses. Removing a national standard that protects 58.5 million acres needs a stronger justification than that.
The wildfire rationale also cuts both ways. The proposed rule concedes that greater public access "can increase human-caused ignition potential." According to the National Interagency Fire Center, people start most wildfires in the United States, and roads bring people into country that currently has few ignition sources. The 2001 Rule already allows fuel-reduction work under its exceptions. If those exceptions have been too hard to use, the answer is to fix the approval process, not to remove protection from every inventoried roadless area.
New roads also threaten water. The Forest Service reports a $6.9 billion deferred maintenance backlog for roads and bridges, and the agency's own research synthesis, Forest Roads: A Synthesis of Scientific Information (2001), identifies roads as a major source of stream sediment and a common pathway for invasive plants. Adding road mileage the agency cannot maintain will mean more erosion and more sediment in headwater streams. The proposed rule lists public drinking water among the values land management plans must address, but it offers no evidence that forest-by-forest planning will protect those sources as reliably as a national rule. Once a large unroaded area is divided by roads, its value as connected habitat and a migration corridor cannot be restored. A decision that permanent deserves a high burden of proof.
Process matters as well. By the Department's account, most Tribal governments consulted oppose rescission, citing sacred sites, water quality, and subsistence resources, and only 29 of 64 requested consultations had taken place when the proposal was published. The Department has determined that this action has substantial direct effects on Tribes, so it should not be finalized until that consultation is complete. The preamble also acknowledges that later plan amendments "could increase the area where timber harvest and road construction would be allowed." Forest plans can be changed one forest at a time; the 2001 Rule provides protection that does not depend on each revision.
I am a Colorado resident and a fly fisher. Colorado's state roadless rule is not affected by this proposal, but I care about trout streams and backcountry on national forests across the West, and the water quality in those streams depends on the unroaded watersheds this rule protects.
Please withdraw the proposed rescission and keep the 2001 Roadless Rule in place.