I am submitting the comment regarding the proposed rescission of the 2001 Roadless Area Conservation Rule.
The Coronado National Forest is my current closest national forest, and is the one that currently makes this a personal issue. I spend my time on public lands as a landscape photographer, particularly drawn to pine forests, mountain peak, changing light, and landscapes of the American West. Every once in a while, I am lucky enough to capture wildlife as well.
While I’m out in the Coronado National Forest, I hope to see specials such as black bear, mountain lion, coatimundi, bobcat, and the countless bird species that make southeastern Arizona such a remarkable place. The possibility of encountering those animals and knowing that they can live with a degree of isolation is part of what makes these lands valuable to me.
I also want to acknowledge something that I think is important to this discussion; I understand the argument for access.
Public lands belong to the public, and I believe people should have meaningful opportunities to experience them. Roads can provide access for recreation, people with mobility limitations, emergency responders, firefighters, hunter, anglers, and land managers. I do not believe that every roadless area should be treated as untouchable under every circumstance. But I also do not believe that the answer to improving access is simply to build more roads into currently roadless areas.
Road construction changes the character of a place. It can increase human activity, fragment habitat, create maintenance obligations, and introduce impacts that remain long after the original reason for constructing the road has disappeared. I believe the Forest Service should carefully weigh those permanent consequences against the specific public benefit a proposed road would provide.
I am also concerned about the wildfire rationale for rescinding the Roadless Rule. I understand the argument that roads can provide faster access for firefighters and that benefit should be considered. However, access has another side: more roads also mean more human activity in forests, and human activity is a significant source of wildfire ignitions.
Recent research examining wildfire records across the National Forest System from 1992 to 2024 found that wildfire ignition density was substantially higher near roads than in more remote areas. The study found that lands within 50 meters of roads had the highest ignition density, while inventoried roadless areas had much lower ignition density. I believe the complex relationship between roads and wildfires needs to be looked at carefully when determining when and where to build a road.
I am similarly concerned about opening current roadless public lands to increased resource extraction and particularly mining.
I recognize that mining provides important resources for our county and that responsible resource development has a place in public-land management, but the environmental consequences of some mining operations can last for generations.
Once example that has stayed with me is the Berkeley Pit in Butte, Montana. I lived in Butte for 13 years, and have seen firsthand how dramatically mining can alter the landscape. The pit and surrounding historic district are now part of a large superfund site. EPA documents describe widespread contamination of the area from historic mining and milling. The citizens are constantly having to fight for continued treatment, monitoring and cleanup decades after the mining activity that created many of those problems has ended.
I do not believe this to be an argument against mining, but rather an argument for responsible resource development and accountability for restoring the land afterwards.
Most importantly, I believe we need to remember what public lands are.
They are not simply resources belonging to the current generation to use as we see fit. They are public lands held in trust for generations of Americans who have not been born yet.
I may or may not have children of my own, but that does not change how I think about this. The people who will use these forests fifty, one hundred, or two hundred years form now deserve to inherit more than whatever we decide is economically useful today.
We are temporary stewards.
Our responsibility should be to leave these lands in at least as good a condition as we inherited them, and whenever possible, better.
I respectfully ask the Forest Service to retain meaningful protections for inventoried roadless areas and to manage these lands with the long-term interests of the American public, and future generations in mind.