I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain the protections in 36 CFR part 294, subpart B.
I am a birder, photographer, and outdoor guide in northern Arizona. Natural quiet is an essential part of why I spend time outdoors. Being able to hear and identify birds by their calls is central to my experience, and I already encounter places where ATV and other motorized noise makes that difficult. It is becoming increasingly hard to find outdoor spaces where natural sounds are the dominant sounds.
My concern extends beyond my own enjoyment. Wildlife depends on sound to communicate, detect threats, and navigate its surroundings. The National Park Service has documented how human noise can interfere with wildlife communication and behavior. Natural soundscapes deserve meaningful protection as part of a healthy ecosystem.
Although this proposal does not itself authorize a particular road or ATV route, removing national roadless protections would create opportunities for future road construction and associated disturbance. Roads can fragment habitat, damage vegetation, compact soil, and contribute to erosion and sediment entering waterways. Those consequences need to be considered alongside any claimed benefits of increased access.
I support thoughtful access to public lands, including access for people with disabilities. But access should be carefully planned around ecological limits and the qualities that make a place worth visiting. More roads are not automatically a public benefit. Birders, hikers, photographers, and others also need places where they can experience wildlife and natural quiet.
The proposal’s own discussion of recreation acknowledges that expanded road access could reduce opportunities for quiet, remote recreation and create conflicts among users. Please give those losses meaningful weight in the environmental and economic analyses. Quiet recreation and intact landscapes have lasting value, even when that value is difficult to express in dollars.
I am also concerned about adding roads when the proposal identifies an existing $6.9 billion deferred maintenance backlog for roads and bridges. Before removing these protections, the agency should fully evaluate the long-term costs of road maintenance, enforcement, restoration, and damage to soil and water.
I recognize the importance of wildfire preparedness and protecting communities. Those needs should be addressed through carefully justified, targeted measures. I ask the Forest Service to explain why existing exceptions and less damaging alternatives cannot meet specific management needs while retaining national roadless protections.
Please retain the 2001 Roadless Rule and strengthen the analysis of cumulative impacts on natural soundscapes, birds and other wildlife, habitat connectivity, water quality, and quiet recreation. Future generations deserve opportunities to experience public lands where they can hear birds, wind, and water without persistent motorized noise.