Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The Mad River runs from Waterville Valley past Welch and Dickey mountains to the Pemigewasset, and I have fished those waters and hiked those trails for over 20 years. I also fish Upper Hall Pond. Our home sits at the base of Welch and Dickey mountains, with a direct view of those peaks and of the Sandwich Range extending toward us. I volunteer to maintain two of the local trails and to assess the condition of heritage sites within the White Mountain National Forest. I also volunteer on a local search and rescue team. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed under Docket FS-2025-0001.
The four inventoried roadless areas I know best, Waterville (4,312 acres), the Sandwich Range (16,797 acres), Pemigewasset Ext (15,840 acres), and Pemigewasset (32,255 acres), all lie within the White Mountain National Forest in New Hampshire. The White Mountain's 16 inventoried roadless areas total 240,669 acres and form the headwaters for rivers draining to the Connecticut, the Merrimack, and the Saco, providing drinking water to communities across New Hampshire, Vermont, and Massachusetts. Before these lands were protected, New England's mountains were clearcut, which is the condition that led directly to the Weeks Act of 1911 authorizing federal purchase of private land for national forests. I have already seen firsthand the destruction of heritage sites by early road development that preceded the roadless rule. Those sites will be under direct threat if this proposal proceeds. The agency must explain on the record why the history that created these protections is not addressed in its justification for removing them.
The proposal invokes wildfire management as a rationale for rescission. The agency's own 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." The Sandwich Range and Pemigewasset wilderness are places I enter regularly on foot. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and that it reconcile the rescission with the ignition data in its own draft environmental impact statement.
On economic grounds, the agency's own record states: "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 have witnessed the thousands of people drawn to these wilderness areas bringing economic activity to local communities. That activity will wane if these forests are opened to road construction and logging operations. There is no demonstrated economic need for such operations; abundant sources of wood and pulp exist throughout the United States and beyond. The agency must reconcile the proposal with its own economic analysis projecting timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year, 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, and do so on this record.
The agency must identify which specific administrative burdens are not already addressed by the rule's existing exceptions and quantify those burdens with specificity.
The proposal's treatment of sedimentation is not adequate. The agency's own document states that "skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and 'can contribute up to 90 percent of the sediment generated by timber sale activity.'" Excessive sedimentation of the Mad River and the local streams and ponds I fish is a direct consequence I expect from any expansion of road construction into the Waterville, Sandwich Range, and Pemigewasset areas. Across the Eastern region, which includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. The figure stating that skid roads and landings can contribute up to 90 percent of sediment generated by timber activity appears in the agency's document and then no projection of actual sediment delivery to those intakes follows. The agency must provide that projection before this rulemaking proceeds further.
Sincerely,
[Your Name]
[Your City, State]