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We appreciate the opportunity to comment. The Tennessee Wildlife Federation (TWF, the Federation) is an 80-year-old Tennessee-based wildlife conservation non-profit founded by outdoor writers and sportsmen. Our mission is to lead the conservation, sound management, and wise use of Tennessee’s wildlife and great outdoors. The Federation is opposed to rescinding the 2001 roadless rule and is supportive of Alternative 1, no action.
The 2001 Roadless Rule, which defines modern-day inventoried roadless areas (IRAs) and sets the framework for Forest Service management of these areas, was first introduced in response to a need for a national rule that offers a baseline of forest protection in addition to management at the unit level. The rationale for this rule introduction was concern for the cumulative impacts of roads and timber harvesting, management and fiscal constraints created by the National Forest Service (NFS) road network, and increased litigation costs that would be reduced by a nationwide policy. The Roadless Rule identifies 58.2 million acres, 30% of NFS lands, as IRAs, and outlines certain exceptions where forest road construction, reconstruction, and logging are permissible.
In Tennessee, there are nearly 85,000 acres of IRA lands, which amounts to about 12% of our national forest area, mostly within Cherokee National Forest. These lands represent some of Tennessee’s wildest spaces, and the Federation has concerns about negative impacts to the health of the Tellico headwaters and remote trout streams if the protections outlined by the Roadless Rule were rescinded. The current rule allows for timber cutting and removal when necessary for normal active forest management activities as outlined by unit-specific forest management plans, which strikes a balance between ensuring that Tennessee’s IRAs are not overmanaged or overprotected. While the Federation appreciates the offering of a third alternative that allows for continued roadless rule protections for some forest lands classified as IRAs, this option is not viable for Tennessee. The intention of Alternative 3 is to remove prohibitions in Wildland-Urban Interface zones within 0.5 miles of an existing road, and for Tennessee, this alternative leaves only 642 acres under current Roadless Rule protection.
The current Roadless Rule allows for a balanced forest management system in IRAs, and provides ample exemptions for activities such as wildlife habitat management, flood control, and wildfire prevention. Rescinding the rule would not significantly improve the Forest Service’s ability to perform these activities, but it would increase the risk of damaging habitat, increase sedimentation of waters, and decrease the overall quality of Tennessee’s wildest places.
It is the Federation’s belief that there is enough flexibility in current rule that allows for sound forest and habitat management while balancing the necessity of keeping Tennessee's most remote places wild. Many of our IRA lands provide essential habitat, and the current rule has contributed to the overall health of many coldwater trout streams in Eastern TN. We respectfully urge the Department of Agriculture to follow Alternative 1 and keep the 2001 Roadless Rule in place to continue to maintain the balance between ensuring that Tennessee’s most wild spaces are well-managed while not being over-preserved.