I am submitting these comments regarding the effect that rescission of the 2001 Roadless Rule could have on the Ashley National Forest, Flaming Gorge National Recreation Area, Manila, Utah, and Daggett County.
I request that USDA retain the protections of the 2001 Roadless Rule, or at minimum maintain equivalent or greater protections for inventoried roadless areas in and around Daggett County and Flaming Gorge National Recreation Area.
I spend significant time in and around Manila and Flaming Gorge and have personally observed that the undeveloped character of the surrounding National Forest is one of the area's defining qualities. Visitors come here for Flaming Gorge, fishing, hunting, wildlife, camping, hiking, scenery, and access to relatively undeveloped public lands. For a small rural community like Manila, these scenic and recreational resources are economic infrastructure. Their long-term value should be weighed against any projected short-term benefit from additional timber, mineral, development, or road access.
The lands surrounding Manila and Flaming Gorge derive substantial value because large portions remain undeveloped, scenic, intact, and connected. Forest Service planning documents recognize approximately 119,511 acres of inventoried roadless areas within Flaming Gorge National Recreation Area and recognize the area's scenery and recreation as important drivers of tourism and the local economy.
Roadless areas of particular concern include Sheep Creek West, Sheep Creek East, Hideout Draw, Bare Top, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge.
USDA should evaluate the cumulative effects of losing roadless protections across these adjoining areas rather than considering future roads only one project at a time. Roads can fragment wildlife habitat, increase erosion and sedimentation, spread invasive species, change recreation patterns, increase opportunities for human-caused wildfire ignition, and permanently alter scenic and undeveloped landscapes.
At minimum, I request that USDA retain existing protections for roadless areas surrounding Manila, Flaming Gorge Reservoir, Sheep Creek, Bare Top, Hideout Draw, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge unless a location-specific analysis demonstrates that removing those protections would provide benefits exceeding the long-term costs to scenery, recreation, wildlife habitat, watershed integrity, wildfire risk, road maintenance, and Daggett County's recreation-based economy.
I request that USDA retain the protections of the 2001 Roadless Rule, or at minimum retain equivalent roadless protections for inventoried roadless areas in and surrounding Daggett County and the Flaming Gorge National Recreation Area.
The roadless areas of particular concern in Daggett County include Sheep Creek West, Sheep Creek East, Hideout Draw, Bare Top, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge. These areas collectively form a significant portion of the undeveloped landscape surrounding Manila and Flaming Gorge.
I ask USDA to evaluate the cumulative effect of losing national roadless protections across these adjoining areas rather than evaluating future roads one project at a time. Once roads are constructed, the effects are not limited to the physical roadbed. Roads can fragment wildlife habitat, increase erosion and sedimentation, increase invasive-species pathways, change recreation patterns, increase human-caused ignition opportunities, and permanently alter scenic and undeveloped characteristics.
This issue is especially important around Flaming Gorge Reservoir, Sheep Creek, Carter Creek, Goslin Creek, and their tributaries. The Forest Service's Flaming Gorge planning documents recognize the importance of watersheds and identify erosion, soil displacement, reduced infiltration, and damage to vegetation and wildlife habitat as concerns associated with intensive use. Protecting intact roadless watersheds should therefore remain an important preventative management tool.
At minimum, I request that USDA retain existing roadless protections for the inventoried areas surrounding Manila, Flaming Gorge Reservoir, Sheep Creek, Bare Top, Hideout Draw, Mt. Lena, Little Hole, Roadshed, North Slope, Goslin, and Grizzly Ridge until the Forest Service has completed a location-specific analysis demonstrating that removal of those protections would provide benefits exceeding the long-term costs to scenery, recreation, wildlife habitat, watershed integrity, wildfire risk, road-maintenance obligations, and the recreation-based economy of Daggett County.
For these reasons, I request that USDA select the alternative that retains the 2001 Roadless Rule, or establish equivalent or heightened protections for the Ashley National Forest and Flaming Gorge National Recreation Area in Daggett County, Utah.