Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The Green Mountain, the White Mountain, Piscah, George Washington, and Je!erson National
Forests (to list a few) are where I go for my spirit to feel wild, for peace of mind. That is the plain reason I oppose this rescission, and I want the agency to read these concerns carefully. Protecting wilderness (as through the Roadless Rule) is a moral imperative. In the words from
Edward Abbey's Desert Solitaire, "Wilderness is not a luxury but a necessity of the human spirit, and as vital to our lives as water and good bread. A civilization which destroys what little remains of the wild, the spare, the original, is cutting itself o! from its origins and betraying the principle of civilization itself." I'm deeply concerned for the vistas, mountain creeks, and forests I've lived and loved in my entire life.
Elliott Knob, inside the George Washington National Forest in Virginia, is a serene place. Enough accessible roads sit close by, yet it remains far enough into the wilderness to stay wild. That balance is what the 2001 Roadless Area Conservation Rule protects. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. Elliott Knob at 9,380 acres is one of them, alongside Crawford Mountain at 9,892 acres, Saint Marys Addition at 1,454 acres, Adams Peak at 7,135 acres, Rough Mountain Addition at 1,142 acres, and Jerkemtight at 16,687 acres, all in the George Washington. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing a!ected roadless areas. Roads bring sediment. Rescission puts those
intakes at greater risk, and I want the agency to say plainly how it intends to protect those drinking water sources if this rule falls.
The agency's own record undermines its wildfire rationale for rescission. The 2001 rule states: "Building a road into a forest at high risk from uncharacteristic wildfire e!ects 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." I ask that the agency explain why this proposal departs from that prior finding and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the a!ected roadless areas.
The economics do not hold up either. The agency's own record acknowledges: "the total timber volume a!ected 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." It does not make sense to ignore the billions of dollars inmaintenance backlogs on roads already accessible to the public. The agency's own Cost Benefit
Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to
+$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year? The agency must reconcile those numbers in this record before proceeding.
The agency argues that state-specific approaches can substitute for a national rule. But the agency's own prior record states: "the USDA discussed its dissatisfaction with the Roadless Rule
and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide approach.' 70 Fed.Reg. at 25,656." That experiment was tried before and failed judicial review. The agency must address its own prior finding that local decision-making can
incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies the Ninth Circuit identified when the national rule was last replaced with a
state-by-state scheme.
The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters
for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for
communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911, which
authorized federal purchase of private land for national forests, was passed because of what
happened when New England's mountains were clearcut. I have hiked those forests. I know what
is at stake. The agency should leave the 2001 rule in place.
Sincerely,