“opportunity for improvement in some areas such as fire preparedness”
“clear cut logged and the trails fragmented by new or reactivated roads”
What it names
Roadless areas
Wilderness Study Area
The comment
Thank you for the opportunity to comment on the proposed Roadless Rule Rescission. I enter my comments as an individual who enjoys many recreational hobbies that make use of the Forest system.
In general I support the stance of the International Mountain Bicyling Association, however the fundamental issue with Roadless Rule is that any top-down national rule does not adequately address State and local variables. Compromise will always be necessary but the blanket rules guarantee that this use conflict is needlessly broad. What is ideal for Colorado isn't necessarily for West Virginia, Alaska or New Hampshire. Nor is indeed what plans work in a very busy National Forest near Denver going to work for a remote Forest near Craig.
The USFS recognizes this, which is why Colorado and Idaho needed specialized Roadless plans already. Why not apply this system-wide so that each state or region the ability to develop similar Roadless plans that are tailored to their needs?
I would suggest that the Roadless Rule being rescinded would be tolerable and perhaps an opportunity for improvement in some areas such as fire preparedness with a few important caveats.
That USFS needs a set of guidelines that give local Forests and offices a clear framework from which to start. From my position as a mountain biker who enjoys exploration and dispersed camping having a Roadless Area turn into a Wilderness, Wilderness Study Area or Area of Critical Environmental Concern would be as equally undesireable as having it clear cut logged and the trails fragmented by new or reactivated roads. I can easily envision loss of Roadless Area designation as an advantage leveraged by both sides of the political land use spectrum to wildly opposing ends.
I'd also like the USFS to require state and local managers who wish to change an existing Roadless Area execute an inventory audit and follow a procedure that all stakeholders have ample opportunity to review and comment.
In summary I appreciate that Roadless Areas exist as a middle ground between Wilderness and general use recreation and extractive areas. So if the Roadless Rule is to be rescinded I urge the USFS to first have in place guardrails to prevent system-wide chaos.