Hiking at least weekly through the Pecos Wilderness, the Santa Fe National Forest, and the Carson and Cibola forests, I know what these landscapes are. In a 3 hour drive you can hit five different kinds of rock in the National Forests of New Mexico, an incredible resource and not something you get in other places. I have been an outdoor guide for over 15 years. Public land, wild land, and limited access to this land is essential not only for my work, but for the health of humanity. What makes me happy out there is seeing wild things, plants, animals, fungi, getting to be wild, and not crowded or polluted. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly that, and I oppose it without reservation.
The agency claims that recreation losses from this rescission would be modest. But its own document states, in the Economic Benefits from Recreation in Roadless Area Forests section, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That figure is placed against roadless recreation benefits of upwards of $1.5 billion, and the same section acknowledges that the magnitude of losses is unknown. Roads and shifts in recreation settings accumulate over decades, and a single-year 1 percent cap does not capture that reality. The agency should estimate cumulative recreation losses over 20 years as roads are built and settings change, and compare them with projected timber revenue, and it should answer that question plainly.
The document also claims, in the Rationale for the Proposed Rule section, that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." But the document also cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. Those two positions cannot simply sit side by side without explanation. I am asking the agency to reconcile the forest health rationale with its own findings on fuel treatment constraints and insect risk in roadless areas.
The proposed action would open timberland where the agency's own data, cited in the Implications for Forest Vegetation, Health, and Carbon section, show that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest." Old and mature stands together make up the large majority of the land most likely to be logged. The Gila, Lincoln, Carson, Cibola and Santa Fe National Forests of New Mexico hold some of this country. These stands are irreplaceable. The document identifies no old-growth-specific safeguards beyond general land management plan compliance before harvest could proceed. The agency must separately disclose and analyze protections specific to old-growth before any harvest is authorized in this land base.
Our forests, as they are, are the most valuable resource in America. They are absolutely irreplicable. The decision before this agency is not a minor administrative adjustment. It is a choice that will shape these lands for every generation that follows. I expect the agency to answer each of these points before it proceeds.