I am writing as a private citizen to oppose the rescission of the 2001 Roadless Rule, and to urge the Department to withdraw the proposal.
I have spent many days and nights on National Forest (NF) land, from the from Florida to Washington State. Some of my happies and most peaceful memories are from my adventures. It is a true privilege and responsibility we hold to live in a country that has so much protected wilderness. A decade ago I drove from Raleigh, NC to Acadia and back with some friends. While camping in Allegheny National Forest we were able to see beavers and beaver ponds for the first time. But what also struck me was the infrastructure: spurs, skid roads, gates, washed-out ditch lines, and derelict culverts.
The Forest Service already manages roughly 370,000 miles of road, and by the agency's own reporting, it carries a deferred maintenance backlog on that system measured in billions of dollars. Undersized and failing culverts are a documented problem across the system. The proposed rescission would open the remaining 44.7 million acres of unroaded NF System land to new construction at a moment when the agency cannot maintain what it built in the twentieth century. The Draft EIS does not, in my reading, adequately grapple with this. A new road is not a one-time cost. It is a permanent maintenance liability and a permanent sediment source, and the agency is already insolvent against the liabilities it has.
I have hiked and camped for years in Pisgah, Nantahala, Cherokee, and George Washington & Jefferson NF. These mountain ranges are headwaters that supply drinking water to many water districts. The Forest Service has long stated that national forests supply drinking water to roughly 60 million Americans across the country, and undeveloped watersheds are the cheapest filtration any of those systems will ever have. Forest roads are consistently identified as the dominant chronic sediment source in managed forest watersheds; Luce and Black's work on road sediment production and the broader synthesis by Trombulak and Frissell (2000, Conservation Biology) on the ecological effects of roads on terrestrial and aquatic communities are the standard references. Sediment is also what kills Southern Appalachian brook trout. The remaining wild populations are largely confined to cold, steep, and high-gradient headwater streams. These fish do not survive with the introduction of fine sediment in the spawning gravels, increased water temperatures and passage effects of road crossings.
In 2020 I drove through New Mexico, Colorado, Wyoming, Montana, and Utah, camping mostly on national forest land. Camping In the Shoshone and Bridger-Teton NF was a dream come true for an avid hunter and outdoors man. The Big Game tourism is big business in Wyoming and other wilderness areas. Elk habitat effectiveness declines with road density has been established since Lyon's work in the early 1980s, and the security-area concept of Hillis et al. (1991) is built directly on it. Hunters and the hunting industry lose when elk habitat is impacted.
From the Southern Appalachia, through San Juan NF, to the Northern Cascades, I have seen time and time again the visible impact along every road I drove. Roads are the number one factor when it comes to the introduction of invasive species. Gelbard and Belnap (2003, Conservation Biology), working on the Colorado Plateau, documented roads functioning as conduits for exotic plant invasion, with improved road surfaces associated with markedly higher exotic cover in adjacent vegetation. Cheatgrass does not arrive on its own. It arrives on tires and on graded shoulders, and it changes the fire regime once it does.
The Department's stated justification is wildfire risk reduction. I want to address it directly, because I think it is the weakest part of the proposal. Balch et al. (2017, PNAS) found that humans ignite roughly 84 percent of U.S. wildfires and have tripled the length of the fire season. Ignitions cluster along roads, because that is where people are. Building roads into currently unroaded country does not lower ignition risk in that country. It raises it. The Draft EIS should quantify projected new human ignitions attributable to new access. Second, the 2001 rule already permits cutting, sale, or removal of timber where it maintains or improves roadless characteristics, including for hazardous fuels reduction, and permits treatment in areas dominated by species that were uncharacteristic before European settlement. If wildfire is the concern, fund treatment in the wildland-urban interface, where the homes are. Do not use fire as a justification to construct new roads throughout the 45 million acres of roadless designated forests.
I am not opposed to well maintained roads through National Forests, I am opposed to new roads. ask the Department to withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule. Use your power to protect our wild spaces.