Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
For more than five decades, I have enjoyed hiking, birding, hunting, fishing, canoeing, kayaking, and more in roadless areas across this country, from the White Mountain National Forest in New Hampshire to the Bob Marshall Wilderness in Montana and in many other states.
These areas have given me and my friends and family some of the most enjoyable outdoor experiences of our lifetimes. Rescinding the Roadless Rule would put the quality of such experiences for Americans in jeopardy. I file this comment to oppose rescinding the Roadless Rule and to make clear why the U.S. Department of Agriculture's own analysis makes that rescission indefensible.
Hiking in a roadless expanse is exhilarating and an unmatched experience for me. There is nothing like the silence, the solitude, the beauty, and the unbroken immensity of these landscapes to lift the soul. These feelings should not be taken lightly; they are what lasts.
The issues of water quality, protection against wildfires, over logging and habitat degradation are what last also when more roads are built in these areas.
The White Mountain's 16 inventoried roadless areas total 240,669 acres, and they are the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region that includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions. The Bicknell's thrush, the Canada lynx, the northern long-eared bat, the brook trout and the American marten all inhabit these forests. The Weeks Act of 1911, which authorized federal purchase of private land for national forests, was passed specifically because of what happened when New England's mountains were clearcut. We have already learned this lesson once.
I have noticed in my lifetime the degradation of fishing on the Blackfoot River in Montana due to the impacts of logging, wildfire and other detrimental activities in that watershed, not to mention climate change. The agency's own document acknowledges that skid roads, trails, log landings, and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That figure appears in the document and then goes nowhere. No projection of sediment delivery to downstream water supplies follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before it proceeds any further.
I have spent decades birding these forests, and the science the agency itself cites should give it pause. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is striking, and it appears in the document applied to nothing. No projection across the 40.1 million acres of potentially affected environment follows it but should.
Removing prohibitions on road building will also harm big game. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. Yet no population-level effect on big game is projected anywhere in the document. Hunters who have relied on roadless country for decades deserve more than a cited finding floating without consequence. The agency must project the effects on big game populations and hunter opportunity before this rescission advances.
These forest areas are owned by the public and should be managed with regard to their wishes and values. The agency itself recognizes as much: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is exactly such an interest. Decades of planning, travel, and expectation have been built around the protections the 2001 rule established. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it can lawfully change course.
Rescinding the Roadless Rule will result in damage to habitat, to water, and to the recreational experience of Americans who value these landscapes as something loftier and more life-enriching than a monetary asset or line item. My opposition is stated clearly, and I expect clear responses to each of the specific failures this comment identifies.
Sincerely,
William Brassard Jr.
Newtown, CT 06470