FS-2025-0001-595373

Brief summary of my letter, attached: I am submitting these formal comments to express my unequivocal opposition to the Department of Agriculture and Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001; 90 Fed. Reg. 42179). I write as an applied natural resource economist with nearly 40 years of academic research and field experience examining the complex relationships between public land policy, natural ecosystem functioning, and regional economic development. As a resident of Virginia's Shenandoah Valley—situated directly between the George Washington and Jefferson National Forests—and as the author of several empirical research reports on the economics of public lands conservation (e.g., Virginia's National Forests and the Virginia Economy, 2002; Windfalls for Wilderness: Land Protection and Land Value in the Green Mountains, 2000; et al.) I have studied firsthand how forest conservation drives sustainable prosperity across rural communities in the Appalachians and across the United States. From an applied economic and public policy perspective, the Forest Service’s proposal to dismantle nationwide protections across 44.7 million acres of Inventoried Roadless Areas (IRAs) is economically inefficient, fiscally irresponsible, and analytically unsupportable. The agency’s justification rests on two demonstrably false premises: first, that opening IRAs to road construction and commercial logging is necessary to expand domestic timber supply and stimulate rural economies; and second, that road building is required to reduce catastrophic wildfire risk. As demonstrated by the Forest Service’s own official Cost-Benefit Analysis (USDA Forest Service, 2025b) and 33-year empirical fire datasets (Aplet et al., 2025), repealing the Roadless Rule will: - Yield a negligible, less-than-trivial contribution to national and state timber supplies while incurring high, below-cost extraction expenditures; -Severely exacerbate an existing $7 billion to $10 billion road deferred maintenance backlog for an agency that currently receives less than 20% of necessary annual road upkeep funding; - Liquidate billions of dollars in high-value ecosystem services, including clean drinking water filtration, flood mitigation, carbon sequestration, and municipal watershed protection; - Degrade the natural amenity assets that drive modern rural population growth, high-wage employment, and private property value enhancement; and - Directly increase wildfire ignition risks by extending road access—the primary vector for human-caused ignitions—into currently intact, low-ignition forest interiors. Furthermore, the agency’s rulemaking notice violates the National Environmental Policy Act (NEPA) and Executive Order 12866 by failing to evaluate "cumulative impacts" and "reasonably foreseeable" site-specific harms, while presenting a Cost-Benefit Analysis that reveals a negative Net Present Value (NPV) of up to -$92 million (USDA Forest Service, 2025b). I therefore urge the Department to withdraw this flawed rulemaking immediately. Rescinding the 2001 Roadless Area Conservation Rule represents an unjustified economic and fiscal misstep. It liquidates high-value, self-sustaining natural capital—clean water, carbon storage, backcountry recreation, and amenity-driven regional growth—to deliver a fractional, below-cost timber volume while expanding a road network that the Forest Service cannot afford to maintain and that directly increases wildfire risk. I formally request that the Department of Agriculture and the Forest Service: + Immediately withdraw Docket No. FS-2025-0001 and maintain the 2001 Roadless Area Conservation Rule in its entirety; + If the agency proceeds, prepare a comprehensive Regulatory Impact Analysis (RIA) under Executive Orders 12866 and 13563 that fully quantifies non-market ecosystem service losses, passive use values, and long-term road maintenance liabilities; and + Remedy the fundamental legal and analytical deficiencies in the Draft Environmental Impact Statement (DEIS) by conducting a thorough, site-specific "hard look" at cumulative environmental impacts, wildlife habitat fragmentation, and watershed degradation across individual Inventoried Roadless Areas, rather than unlawfully deferring site-specific analysis to future project-level decisions. -Spencer Phillips, PhD, Staunton, Virginia