This comment expresses strong opposition to the proposed rule, 91 FR 53827, since it is not aligned with the US Forest Services' mission and responsibility to citizens of the United States of America, as explained below, and I express my strong disagreement with the proposed rule and the process used to develop it. Adoption of the proposed rule would be neglect of the Forest Services' duty to manage National Forest for many uses in for the benefit of the citizens of the United States of America. Scientific evidence shows ROADLESS AREAS preserve clean water, clean air, species of importance, the health of areas with roads, and the value of forest products.
The proposed rule is contrary to 16 USC 1604(a) and (b) regarding development of landscape-level management plans. The economic impacts described in the proposed rule are vague and incomplete. The proposed rule will increase bureaucracy, cost and regulatory burden on citizens and private enterprise by requiring hundreds of different local land management plans and is not in the interest of the people of The United States of America.
Roadless areas prevent clear cutting instead of selective logging which increases fire risk. Roads are not required for selective logging and road construction money, and the cost of construction and maintenance is not calculated directly in the "Timber" section of the proposed rule. Elimination of the current rules governing roadless areas, under a single national blanket, will promote a return to pre-2001 abuses of National Forest in which large areas were clear-cut allowing densely forested areas to grow back with increased fire risk.Furthermore, contrary to the proposed rule's statement that "rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments," it would provide for greater likelihood of human-caused wildfire ignition and growth of the wildland-urban interface.
The Forest Service needs funding to restore the health of areas that have been used for commercial logging using selective logging and other best practices to assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, timber, watershed, wildlife and fish, and wilderness. The proposed rule jeopardizes all of the above products and services by reducing prices of forest products, polluting water sources, eliminating critical habit for wildlife and fish, eliminating wilderness quality land, and reducing opportunities for non-motorized recreation.
In 2001, the current ROADLESS AREAS RULE (66 FR 3244) was adopted after extensive study and agreement by stakeholders to balance the use of National Forests for human and environmental health and commerce. The proposed rule will negatively impact the health of citizens of the United States, public infrastructure, and the value of commerce. Firstly, the proposed rule would eliminate protection for ROADLESS AREAS in National Forests and therefore endanger human health and well-being by polluting water sources, spreading invasive species, and emitting greenhouse gases and other pollutants that promote climate change and its negative impacts on the health, wealth and happiness of citizens of the US, including wildfire. Secondly, the proposed rule is not a result of scientifically based study nor of rigorous cost-benefit analysis that accounts for the costs of road construction and maintenance, impacts of water pollution, and reduction in price of forest products due to increase in supply subsidized by the government in competition with the free market price. In addition to the reasons given above, since, the proposed rule is not based on sound environmental or economic analysis implementation of this rule is not in the interest of the people of the United States of America and constitutes dereliction of responsibility of the US Forest Service and its administrators.