I'm writing to oppose rescinding the Roadless Rule, either in whole or in part. The proposed rule would remove the Roadless Rule’s protections against destructive commercial logging and road building from nearly 45 million acres of forests on public lands that belong to all Americans. Alternative 3 does not offer a meaningful alternative to a full rescission, as it would remove roadless designations from more than 30 million acres of forest. Rescinding the 2001 Roadless Rule would irreparably harm our nation’s most important resources, which your agency under the current administration has started to disrespect and attempt to sell off, privatize, and ruthlessly extract from, all of which are egregious departures from the Forest Service's original intent when the agency was established.
Roadless areas experience some of the lowest rates of fire ignition across the national forest system. While many of the USDA’s statements regarding the rule’s rescission have asserted a need to cut roads into these intact forests to prevent wildfires, the latest scientific information effectively dispels that myth. The DEIS itself belies those assertions, finding that fire ignitions are four times more common near roads than in roadless areas; it states that “ignition density is approximately four times greater on other NFS lands compared to potentially affected IRAs and wilderness.” More roads will only heighten wildfire risk. And fuel treatments and forest health initiatives are already taking place across roadless areas.
The forests protected by the Roadless Rule play a vital role in sustaining wildlife, providing habitat for 57% of vulnerable terrestrial wildlife. Intact mature and old-growth forests, many of which are protected by roadless areas, serve as essential refuges for wildlife facing mounting pressures from climate change, wildfire, and human development. It is our responsibility to safeguard these species and the forests they call home. Additionally, forests protected by the Roadless Rule provide habitat for many endangered species, protect and promote biodiversity, and provide the conditions many wildlife species need to survive. The biological assessments accompanying the proposed rule identify 327 threatened and endangered species and 71 critical habitats as being likely to be adversely affected by rescinding the Roadless Rule. This is unacceptable.
The Roadless Rule protects over 80,000 miles of streams and rivers. Building roads through these currently protected forests would cause diversions of rainwater's natural path across the landscape, cause sediment buildup in streams and rivers, and increase the possibility of landslides and other stability issues caused by runoff. Pollution from road traffic and toxic byproducts accumulate on the road’s surface, further degrading the water quality entering rivers and streams and directly threatening sensitive aquatic life, including native fish species. Additionally, our Roadless forests protect the headwaters of many rivers and streams. At least 25 million Americans rely directly on roadless area-influenced watersheds for their drinking water. Commercial logging, which is a major motivation for rule rescission, directly degrades water quality by increasing sedimentation, turbidity, and nutrient runoff, effectively driving up water treatment costs for millions of customers in downstream municipalities. The only option is to take the No Action alternative and keep the Roadless Rule intact.
Further, the outdoor recreation economy brings in more money than commercial logging. One report estimated that the Roadless Area Conservation Rule brings $24 billion dollars of benefits each year across habitat, scenic, and recreation values. Hunting, fishing, and wildlife-watching alone contribute nearly $400 billion to the U.S. economy, while the broader outdoor recreation economy generates over $1.3 trillion annually. A potential 5-10% increase in Forest Service timber production from IRA logging would yield just $5.2-11.4 million of revenue to the federal government. This potential logging revenue would not add to the economic value of these forests. Rather, it would degrade the scenic beauty and other environmental values that drive our recreation economy.
I live near many protected roadless areas, including the Shasta-Trinity National Forest, the Lassen NF, and the Klamath mountains. Rescinding the Roadless Rule would negatively impact my love and enjoyment of these lands. I stand for the protection of our roadless areas and the beauty of the American landscape. I oppose rescinding the Roadless Rule and urge the Forest Service to take the No Action alternative.