Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The diversity of plants and wildlife in the Jefferson National Forest is astounding. The sounds of nature, without all the human activity, are a gift I hope my children and grandchildren will be able to cherish forever. That hope is precisely why I oppose the rescission of the 2001 Roadless Area Conservation Rule, and why I expect the agency to answer the specific concerns below on its record.
Public land should be managed with gratitude and reverence for the forests that sustain us. That means listening and observing before acting, then developing plans for producing and harvesting food, medicine and timber that do not trade lasting ecosystem health for the demands of rampant consumption. The agency's own data on fire risk alone should give this proposal pause. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why this proposal departs from that finding, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas.
We must protect our rivers and streams. There is nothing more foolish than contaminating the life-sustaining waters of our forested lands. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I want my tax money to support and protect the natural ecosystem of which we are a part, not degrade it. That extends to the fiscal question as well. The record shows: "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 the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.
We can do better than the constant extraction and exploitation, and small businesses operating in these forests deserve an honest accounting of what rescission will cost them. The regulatory flexibility analysis reaches its no-impact conclusion by spreading costs across every small firm in the sector nationally rather than examining the outfitters, guides and tour operators who actually hold permits in the affected areas. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency should withdraw that certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm.
We are speaking for those who do not yet have a voice, for my children, for theirs unborn. Let there be wild places for them to experience. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting these last unroaded lands. It has held none to undo it. 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. This comment is precisely such an interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one.
This forest is our home. We do not see it merely as a store of resources to manage. We seek to integrate with the forest, to learn from it how to live more in balance with the natural world and how to thrive together, as one composite-organism. I urge the agency to withdraw this proposal.
Sincerely,
Andrew Fry
Montgomery County, VA