For nine years, I have taken my son hiking in Cleveland National Forest and Inyo National Forest, observing plants and wildlife, staying fit, and finding relaxation. I want my child, and other children, to have public wilderness available to all, preserved not only for people but for the trees, plants, and animals that live there and far preceded us as species. Trees and plants, after all, allow us air-breathing creatures to live. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens what I value in those forests, and the agency's own document raises questions the notice does not answer.
The agency states, in the Rationale for the Proposed Rule, that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." That framing is not reconciled with the document's own findings. The same document cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency should reconcile the forest health rationale with those internal findings before finalizing this rule.
The agency also estimates, in the section on Economic Benefits from Recreation in Roadless Area Forests, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That figure is set against roadless recreation benefits of upwards of $1.5 billion, and the same section acknowledges that the magnitude of losses is unknown. Roads and changes to recreation settings accumulate and persist; the 1 percent annual cap does not capture that reality. I hike and camp in these forests, and so do my son and other children. The agency should produce a cumulative recreation loss estimate over a longer horizon and compare it with projected timber revenue, rather than relying on a single-year figure that the document itself qualifies as uncertain.
Finally, the agency's own data, cited in the section on Implications for Forest Vegetation, Health, and Carbon, show that in the operable areas most likely to be logged, "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest." Old and mature stands together make up the large majority of the timberland the proposed rule would open to harvest. The document does not identify any old-growth-specific protection beyond general land management plan compliance. These are the stands I want my child and other children to still find decades from now. The Forest Service must separately analyze and disclose what safeguards, specific to old-growth, would apply before harvest could proceed in this land base.