My family paddles the New, Little, and James Rivers, watches birds and butterflies along the banks, photographs the water and the light, and goes out under open sky to watch meteor showers and the full moon rise over unpaved country. The Jefferson National Forest feeds the New River Valley of Southwest Virginia, and the clean, uncontaminated water that flows from it is not an abstraction to us. We have taken our children, now grown, from Buffalo Mountain to Raptor Ridge to see views of our area that show the world as it might have been before us. What I am opposing is the Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule, which would strip national-level protections from inventoried roadless areas across National Forest System lands and hand those decisions back down to individual forests with no baseline guarantee against road construction or timber harvest.
The agency's own document states, at the Scope of the Analysis section, that "An irreversible or irretrievable commitment of resources will not be made by the rulemaking because none of the rulemaking alternatives propose specific actions." That claim cannot stand next to what the same document discloses in its biodiversity, vegetation, and roads chapters: that the proposed rescission is likely to adversely affect 327 ESA-listed species and 71 critical habitats, and that permanent road construction and old-growth removal are reasonably foreseeable consequences. Two statements in the same document cannot describe the same set of probable outcomes and one of them call those outcomes non-irreversible. The agency must revise the Scope of the Analysis section to honestly account for the irreversible and irretrievable commitments its own effects analysis predicts, and must explain, specifically and plainly, how those two positions coexist.
On the timber side, the document discloses at Implications for Forest Vegetation, Health, and Carbon that in the operable areas most likely to be logged under the proposed action, "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 overwhelming majority of the timberland this rescission would open. The draft EIS identifies no old-growth-specific safeguards beyond general land management plan compliance, which varies by forest and provides no uniform floor of protection. I photograph birds, the sky, and the water, and I know that the habitats holding those things together are disproportionately concentrated in exactly this kind of mature, unroaded forest. The agency must separately analyze what protections would apply specifically to old-growth stands before any harvest could proceed in this largely mature and old-growth land base.
The agency's stated rationale also needs to be reconciled with its own findings. At Rationale for the Proposed Rule, the document asserts 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." Yet elsewhere the same document cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The forest health rationale for rescission rests on a claim the agency's own evidence undercuts. The agency must reconcile these findings before using forest health as justification.
Clean water is essential to all of us, and the water of the Jefferson National Forest serves the New River Valley. Roads bring sedimentation; sedimentation degrades the rivers I paddle and the water my community drinks. My tax money should preserve these places, not pave them over for the benefit of those who, as I see it, have never spent time in the quiet beauty of undeveloped land. Responsible stewardship, as Teddy Roosevelt envisioned it, means protecting these places with pride. The reckless cost of this rescission is not only financial. It is permanent.