“infrastructure maintenance backlog of 8.6 billion dollars”
“generate 5-11 million dollars for the U.S. treasury”
“fraction of a percent of the U.S. total revenue”
“cutting the forest service's operating budget and firing 15% of its employees”
What it names
Works cited
Johnston et al. 2023
The comment
To whom it may concern in the USDA and USFS,
I am writing today to declare my opposition to the proposed recision of the Roadless Rule. The 2001 Roadless Rule should be upheld. America’s national forests and expanses of pristine wilderness are part of what makes America great.
In the purpose and need for action section:
You cannot claim that you are turning these tracts of roadless land over to management by local forest service officials, all while cutting the forest service’s operating budget and firing 15% of its employees, so that they don’t even have the resources to manage that same forest. You also cannot claim that this would be informed locally by tribes when the majority of tribal governments and the NCAI condemned this proposed recision in the first place.
It doesn’t cost the U.S. anything to keep these pristine national forest lands roadless. It does cost the U.S. money to build roads into remote places, especially to maintain them. According to the US Forest Service’s website, it currently has an infrastructure maintenance backlog of 8.6 billion dollars. We clearly cannot afford to add to that number, especially with the budget cuts that are being made to the USFS.
To me it seems this proposed recision seems like it is primarily about increasing logging and forest management to prevent wildfires. But it doesn’t make much economic sense. According to the USFS website, U.S. forest products industry generates 288 billion dollars annually and according to Vertical IQ, logging and timber alone generates roughly 15.7 billion dollars in revenue. According to your own statement on this document in the “Summary of potential impacts” section, you state it would generate 5-11 million dollars for the U.S. treasury, and 4.6-10.6 million dollars for the timber industry. Even if we achieved the upper bounds of the projected timber revenue as a result of this repeal, it would be a fraction of a percent of the U.S. total revenue, .07% (7/10,000ths) to be exact. That is a tiny number compared to the yearly revenue of the entire U.S. timber industry.
That tiny fractional revenue is simply not worth jeopardizing these areas which help supply drinking water to 25 million Americans (Olden et Al, 2026 in PLOS Water), protect endangered iconic species that rely on undisturbed contiguous forests (such as grizzly bears, salmon, trout, and even bald eagles), and contain old growth forests which are ecologically vital biodiversity hotspots, that provide water filtration and flood and drought mitigation to surrounding areas. Logging in these areas would destroy habitat, and pollute our waterways with eroded silt and sand, as well as herbicides sprayed to aid timber recovery.
Furthermore, if we’re talking about fire prevention, fires are 4 times more likely to start near roads than they are in pristine roadless forest areas (Aplet et Al, 2026, in Fire Ecology). Building more roads will increase ignition risk. Furthermore, logging increases fire risk over a decades long period. The way the U.S. typically deals with forest recovery in the wake of a clear cut or a wildfire, is by planting monoculture timber trees (or a few different species but still a relatively small diversity) and then spraying herbicide on the soil to kill any competing shrubs to ensure quickest timber growth for future harvests. However, this leads to a less biodiverse, conifer-dominated forest which is much more flammable and susceptible to devastating pest infestations. Forests that naturally recover from wildfires or cutting have greater biodiversity, and feature species that retain water more efficiently than conifers, making those forests more resistant to fires. Logging and replanting in these areas will cause the future forests that grow back there to be more flammable in the coming decades as well.
This proposal to rescind the Roadless Rule would de-regulate these forests on a national level, but local agencies have not been given the financial support they need to steward them either. It effectively throws our beautiful forests, rivers and wild public lands to the wolves of industry. And all for a measly portion of profit. The recision would not help with managing fires, and in fact would likely make it worse. It is for these reasons that I am petitioning that the 2001 roadless rule must be upheld in its entirety. Thank you for your consideration and time to review my comment.