Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The Mark Twain National Forest borders our farm, and I have spent years hiking through it, paddling the Huzzah, the Current, and the Meramec, and listening for the hundreds of migrating birds that roost in those woods each spring and fall. The forest sits right on the Mississippi Flyway, and what moves through it matters. I oppose the rescission of the 2001 Roadless Area Conservation Rule.
The Anderson Mountain roadless area, 2,741 acres inside the Mark Twain National Forest, is the kind of place this rule was written to protect. I have watched loggers, hunters, and recreational users work that country both well and badly. What improves it is education: workshops, demonstrations, skill classes. What does not improve it is building additional roads into country that has none. We already have ample access for all users through a multitude of existing roads and trails, and the agency carries a maintenance backlog that expanding a road system cannot cure. The record states 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." I ask that the agency reconcile this proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.
I know firsthand what it takes to keep roads from fouling a river. We farm along the Huzzah and have worked hard, and spent a lot of money, to decrease erosion from our fields and banks and improve water quality before it enters the river. Increasing the burden on the Forest Service does not benefit anyone. The birds tell a parallel story. 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 migratory birds I love hearing and sometimes spotting each spring and fall depend on contiguous, unroaded forest structure along the flyway. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet no projection applying that range to the 40.1 million acres of potentially affected environment appears anywhere in the document. I ask that the agency make that projection explicit and place it in the record.
As we watch the decline of wild birds and insects across our beautiful state of Missouri, from quail and songbirds to Monarchs and fireflies, it is plain that we must act now to protect our own land and the public's land if we want our grandchildren to experience even half of what we have. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed, and that elk avoid roads and select unroaded habitat, yet the document projects no population-level effect on big game anywhere in its analysis. The agency should project the effects of rescission on big game populations and the hunters who pursue them, in this forest and across the affected acreage.
Finally, 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. The regenerative forestry practices the Forest Service and the Missouri Department of Conservation have expanded in the Mark Twain are improving habitat and increasing biodiversity, and those gains rest partly on the landscape integrity this rule maintains. My family has made real investments, financial and physical, in the water quality of the Huzzah on the assumption that the adjoining public land would remain protected. That is a reliance interest. The agency invited it and must weigh it. I ask that every reliance interest described in the comments received, including this one, be identified, assessed, and answered in the final record before any decision is made.
Sincerely,
Beverly Tucker Knight
St Louis, MO