Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The Roadless Rule has protected millions of acres of backcountry that I depend on. I live near Sequoia National Forest and have backpacked and hiked extensively in Inyo National Forest as well as national forests in Washington, Oregon, Montana, Wyoming, and New Mexico. What draws me to these places is old growth forest and relatively untouched ecosystems. I do not enjoy hiking or camping in clear-cut forests or in areas easily accessible to motorized vehicles, and the Roadless Rule is precisely what keeps those areas from becoming the latter.
The agency's own record undermines its wildfire rationale for this rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency is offering wildfire management as a justification for opening roadless areas, it must explain how that argument survives its own findings. I ask that the agency explain why this proposal departs from those prior findings and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas.
The economic case for rescission is similarly thin. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that backdrop, the Forest Service is already $6.9 billion behind on maintaining the roads it has, operating on a road budget of roughly $73 million a year. It seems like a great waste of taxpayer money to build new roads into country that has none. I am strongly opposed to my taxes being used to build roads that have no benefit to anyone but timber companies. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying that maintenance backlog? The agency must answer that question with specificity before this rule moves forward.
The regulatory flexibility analysis contains a related problem. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading projected losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm.
Finally, the proposal itself 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 one such interest. I have organized my recreational life around public lands protected by the Roadless Rule, choosing where to hike and backpack based on the understanding that those places would not be opened to roads and extractive industry. An agency that invites statements of reliance and then accounts for none of them in its analysis has not discharged its obligations when changing course. The agency must identify and weigh the reliance interests described in the comments it receives, including this one.
I am extremely disappointed that despite broad public support for keeping the Roadless Rule, the USDA has continued efforts to repeal it. This is clearly not what the American people want or feel is in their best interest. The agency should explain on the record why it is placing the preferences of extractive industries above those of the public it is charged with serving.
Sincerely,
Jessica Henning
Visalia, CA