Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Hunting in the woods with friends, breathing clean air in the campgrounds of Oregon and Washington, watching the recovery continue on the slopes of Mount St. Helens. These are the things I am asking you to protect when I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001.
Being out in the woods is good for the soul. The beauty of wild places and the animals in them is unmatched. I also spend time in state and national campgrounds in Oregon and Washington for the clean air, the quiet, and the enjoyment of nature away from the noise of city life. It is affordable vacation for many people. I want my children and grandchildren to have wild places with old-growth trees to revere and experience. I do not think they should inherit fewer of these places than I did.
The Siuslaw National Forest holds the Oregon coast range, the dunes, fresh water, and salmon. Salmon depend on cold water, and the agency's own record states that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and that warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, with the affected area including Essential Fish Habitat and critical habitats managed by NMFS. The Siuslaw's roadless areas amount to 52,000 acres of coast range forest that the agency would open to new road construction. I ask the agency to address what specific protections replace those lost for cold-water fish habitat in the Siuslaw if this rule is rescinded.
The Deschutes National Forest is a high desert place of calderas and ancient formations, fantastic and unlike anywhere else. Bend and the surrounding area get their water from this forest, and this should not be threatened. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The Deschutes holds 136,000 acres of inventoried roadless area, and the lower Deschutes holds one of only two national strongholds for federally threatened bull trout. I ask the agency to explain how rescinding federal roadless protections over these watersheds is consistent with its obligations to communities and to listed species whose strongholds sit inside them.
The Olympic National Forest is magical. Having no roads through the middle of the peninsula is a true treasure. The 86,000 acres of roadless area there, with their old growth and pure water, must be maintained. The agency argues that new roads serve wildfire management, yet its own 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." I ask that the agency reconcile this proposal with that finding and explain what ignition data now overrides it.
The agency also argues that opening these areas generates economic benefit. Its own record states: "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." The agency projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. The agency already carries a $6.9 billion road maintenance backlog on a road budget of about $73 million a year. No new roads.
The Gifford Pinchot National Forest, with Mount St. Helens and its continuing recovery, holds 213,000 acres of roadless area I have visited since childhood. The agency now argues that state-specific management can replace the national rule, yet its own record shows: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit already rejected the last attempt to substitute local approaches for a national rule, finding that piecemeal local decisions can erode nationally significant roadless values.
Leave the little remaining old growth alone. Leave the natural water sources alone. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That process failure alone demands a full answer before this rescission moves any further.
Sincerely,
Kristina Rheaume
Portland, Oregon