I live in the small rural community of Williams, Oregon, in the Applegate Valley. Grayback Mountain, Big Sugarloaf Peak, the East Applegate Ridge Trail, the Siskiyou Crest: these are places where I hike, mountain bike, and enjoy photography, birdwatching, and relaxing in nature. We live surrounded by public lands managed by the Forest Service and BLM, including several Inventoried Roadless Areas: the Kangaroo Roadless Area, Condrey Mountain, McDonald Peak, Little Grayback and Collings-Kinney, all threatened by the proposed rescission of the Roadless Rule. There is already widespread industrial logging taking place in our watershed, and it disrupts my enjoyment of natural forests, clean water, and the recreational opportunities I depend on. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and ask the agency to respond to each of the points below before this rule is finalized.
The agency's stated rationale for rescission centers on forest health, but that rationale is not supported by the agency's own document. The notice 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," as stated in the Rationale for the Proposed Rule. Yet the document also cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. When I hike through intact old-growth forests on the East Applegate Ridge Trail or watch raptors and migratory songbirds over those stands, I am moving through forests the agency's own data suggest are not in crisis relative to managed lands. The agency must reconcile the forest health rationale with those specific findings, and it must do so with analysis, not assertion.
The agency also minimizes recreation losses in a way that obscures their true scale. The notice states that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally," as set out in the Economic Benefits from Recreation in Roadless Area Forests section. That single-year estimate is anchored to a 1 percent harvest cap and set against roadless recreation benefits of upwards of $1.5 billion, while the same section concedes that the magnitude of losses is actually unknown. Roads, once built, are permanent. Recreation settings, once degraded, do not recover on a human timescale. HIking, birdwatching, and landscape photography of old-growth forests and intact native ecosystems, the kind I pursue in these areas, depends entirely on settings that cannot be restored after industrial entry. The agency must estimate cumulative recreation losses over a 20-year horizon as roads compound and settings shift, and compare those figures against projected timber revenue, before this analysis can be considered adequate.
Perhaps the most serious gap concerns old-growth forests. The document discloses at the Implications for Forest Vegetation, Health, and Carbon section that in the operable areas most likely to be harvested 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 land the rule would open to logging, yet the document identifies no old-growth-specific protective standard beyond general land management plan compliance. Roadless areas provide clean water for my community of Williams, Oregon, and healthy forests are critical water sources for recreation, wildlife populations, and agricultural irrigation throughout our watershed. Old-growth forests anchor those hydrological functions in ways young plantations cannot replicate. The Forest Service must separately analyze and publicly disclose what old-growth-specific safeguards, if any, would apply before timber harvest could reach those irreplaceable stands.
I am tired of seeing taxpayer dollars subsidizing below-cost timber sales, and then further money spent to mitigate the destructive impacts that follow. Roadless areas should be managed for conservation values and the long-term ecological sustainability of the systems we depend on. The American public has expressed strong support for protecting roadless public lands. These areas and the old-growth forests within them should be protected from logging, mining, and industrial development. Protect our public lands for the people of the United States and for future generations.