Comment Analysis · Docket FS-2025-0001

FS-2025-0001-588037

Opposes rescissionPosted October 6, 2026 On Regulations.gov

Not scored for substance: the comment does not clear the floor of substantive signal.

Topics

  • Environmental Protection Biodiversity
    • “Draw the line at what cannot be replaced: roadless areas, old growth, headwaters”
    • “Wild places are the one inheritance we can give to the future only by refusing to spend it”
    • “Make protection the default”
    • “The Wilderness Act of 1964 defined wilderness as 'an area where the earth and its community of life are untrammeled by man'”
  • Economic Impact Fiscal
    • “outdoor recreation added $696.7 billion to the economy in 2024”
    • “GAO found the timber program lost about $11.4 million a year from 2005 to 2014”
    • “Agencies spent roughly $2.9 billion on cleanup from fiscal 2008 through 2017”
    • “Make extraction pay its full cost: real royalties, reclamation bonding, an abandoned-mine fund”
  • Water Quality Quantity
    • “Draw the line at what cannot be replaced: roadless areas, old growth, headwaters”
    • “water treatment needed indefinitely”
    • “released about three million gallons of acidic waste into the Animas River”
    • “As well dam for water-tanks the people's cathedrals and churches”
  • Cultural Heritage Indigenous
    • “Native nations managed these lands long before Europeans arrived”
    • “many hold the places now at risk to be sacred”
    • “Abraham Lincoln signed a bill granting Yosemite Valley... to be held 'for public use, resort, and recreation'”

What it names

National Forests
Tongass National Forest
Roadless areas
White Pine

The comment

What We Cannot Rebuild In 1864, in the middle of the Civil War, Abraham Lincoln signed a bill granting Yosemite Valley and the Mariposa Grove to California, to be held "for public use, resort, and recreation" and kept "inalienable for all time." Eight years later, Grant signed the law creating Yellowstone, widely regarded as the world's first national park. A young nation protected land anyway, because some things, once spent, cannot be bought back. The question is not whether mining and logging have mattered to America. They built much of what we live in. The question is whether the next acre of intact forest, roadless valley, or headwater should go on the ledger as one more resource to convert into revenue. History's answer, again and again, is that we regret it. THE EMPTY FORESTS In the nineteenth century, the white pine forests of Michigan, Wisconsin, and Minnesota were treated as inexhaustible. By about 1900 the pine logging of the Lake States was essentially finished, leaving some forty million acres of "cutover" land. The Peshtigo fire of 1871, fed in part by logging-altered landscapes, killed an estimated 1,200 to 2,500 people. Bison fell from an estimated 30 to 60 million to fewer than a thousand by the 1890s. The passenger pigeon, once numbered in the billions, was gone by 1914. Markets price what is in front of them well, and what can never be replaced badly. THE CONSERVATIVES WHO CONSERVED Theodore Roosevelt, a hunter, rancher, and Republican, protected roughly 230 million acres, including 150 national forests. He was no purist: "Conservation means development as much as it does protection." But in 1910 he set a standard: the nation should turn its natural resources over to the next generation "increased, and not impaired, in value." An open-pit mine with a perpetual water-treatment bill does not pass that test. In 1913, Congress let San Francisco dam Hetch Hetchy Valley inside Yosemite. John Muir wrote: "As well dam for water-tanks the people's cathedrals and churches." He lost, and the valley lies under a reservoir. WHAT THE LEDGER LEAVES OUT A 2020 Government Accountability Office report found at least 140,000 abandoned hardrock mine features on federal land. Agencies spent roughly $2.9 billion on cleanup from fiscal 2008 through 2017 and estimate more than $10 billion for even a fraction of the rest. The public pays. Colorado's Summitville gold mine is the textbook case: cyanide heap-leach mining, bankruptcy in 1992, then a Superfund cleanup estimated at $150 million or more, with water treatment needed indefinitely. In 2015, an EPA contractor at the Gold King Mine, idle for nearly a century, released about three million gallons of acidic waste into the Animas River. That is how long the bill takes to come due. The General Mining Law of 1872 still governs hardrock mining on more than 270 million acres of public land, and companies pay no federal royalties on gold, silver, or copper, unlike oil, gas, and coal producers. In Alaska's Tongass National Forest, GAO found the timber program lost about $11.4 million a year from 2005 to 2014, before counting roads. We paid to cut trees that took centuries to grow. THE ECONOMY IN THE STANDING FOREST The Bureau of Economic Analysis reports outdoor recreation added $696.7 billion to the economy in 2024, 2.4 percent of GDP. Not all of that depends on public land, but it is no niche. Moab, Utah, once a mining town, now runs largely on tourism and recreation. Extractive towns boom and bust with the ore. None of this means ignoring families who depend on timber and mining wages. It means real transition support. The choice is between a managed transition and a cliff. WHAT A COUNTRY IS FOR A rival idea has always shadowed the one that treats land as inventory, running from Thoreau's "in Wildness is the preservation of the World" through Muir and Roosevelt to Aldo Leopold's land ethic. Native nations managed these lands long before Europeans arrived, and many hold the places now at risk to be sacred. The Wilderness Act of 1964 defined wilderness as "an area where the earth and its community of life are untrammeled by man, where man himself is a visitor who does not remain." It passed the Senate 73 to 12 and the House 373 to 1, by a country that could afford to cut and dig and chose not to. We are richer now. WHERE THIS LEAVES US We still need copper and lumber. The argument is about where and how. - Draw the line at what cannot be replaced: roadless areas, old growth, headwaters. - Make extraction pay its full cost: real royalties, reclamation bonding, an abandoned-mine fund. - Fund transition for extraction communities. - Make protection the default. No one thanks the people who cut the last of the white pine. We thank the ones who set aside Yosemite and passed the Wilderness Act. Wild places are the one inheritance we can give to the future only by refusing to spend it.

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