“An intact watershed... cannot always be reconstructed”
The comment
Roadless Rule Comment — Working Draft
I live in the Sierra Nevada foothills of California. Here, wildfire is not an abstract idea. We watch the weather, and our hearts drop when we see smoke. We clear our land, check Watch Duty, and know what evacuation warnings mean.
Our forests must be actively and intelligently managed, and we need the Forest Service and firefighters to have the tools they need to keep communities safe.
I also oppose rescinding the Roadless Rule.
I understand the problem the Forest Service is trying to solve. Forests and wildfire have changed, and a twenty-five-year-old rule cannot anticipate every management need, but 44.7 million acres is an extraordinary amount of land to remove protection from in order to gain flexibility where it may sometimes be needed.
“Roadless” does not need to mean “unmanaged.” These are living places, containing headwaters, wildlife habitat, migration corridors, threatened species, soils, carbon stores, and places people hunt, fish, hike, and play. Many are also ancestral homelands Indigenous peoples knew, tended, burned, harvested, and cared for long before there was a Forest Service.
Some western forests desperately need active management, but that can mean prescribed and cultural fire, targeted thinning, selective harvest, habitat restoration, and temporary access where genuinely necessary. The Forest Service’s own research has found that lack of roads has not prevented fuel-management work in inventoried roadless areas.
A forest can be both protected and actively stewarded. The Forest Service's consultation found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission,” citing concerns including sovereignty, cultural survival, ancestral homelands, sacred places, water, subsistence resources, and repeated project-level review.
I am not asking the Forest Service to listen to Tribal Nations because I assume they will agree with me. They may not. A Nation may support burning, harvesting, thinning, or access I wouldn’t personally choose. Sovereignty means very little if we respect it only when we get the answer we want- that being said, I believe they deserve the respect and trust to make decisions about the land they know best.
Please keep national protection while allowing Tribal Nations a stronger role in deciding how these areas are stewarded. Expand co-stewardship and cultural fire programs, provide resources for meaningful participation, and recognize Indigenous knowledge as expertise where Nations choose to share it.
We do not need one answer for every acre. If an important fuel treatment genuinely requires temporary road access, build the temporary road, do the work, and then restore it. Burn where fire is needed. Thin where thinning is needed. And if a roadless watershed or habitat is healthy and there is no compelling reason to disturb it, leave it roadless.
Roads are useful tools, but Forest Service research also recognizes their potential costs to wildlife habitat, water, aquatic ecosystems, and the spread of invasive species. That doesn't mean “never build a road;” it means a road should solve a problem worth the cost of the road.
Timber, minerals, jobs, and economic development have real value. So do intact watersheds, wildlife habitat, cultural landscapes, and forests that have remained largely undeveloped. Some of these can be replaced. Others, once lost, may not be recoverable at all. Please, choose the more careful path.
Change the parts of the Rule that genuinely prevent necessary work. Create carefully limited exceptions. Allow temporary access where evidence shows it is needed. Expand prescribed and cultural fire. Work with Tribal governments as partners. Target resources where wildfire risk is greatest.
But keep protection as the starting point!
A regulation can be amended again. A forest treatment can be repeated. A temporary road can be restored. An intact watershed, an old habitat corridor, a cultural landscape, or a species population cannot always be reconstructed after we find out we made the wrong decision.
That is what I believe is at stake here: not whether we manage our forests, but how we manage them. Not whether a twenty-five-year-old rule can change, but whether the problems we’ve identified require us to discard the protection itself.
Please retain the Roadless Rule, improve it where experience shows improvement is necessary, and build the next generation of forest management around careful intervention, good science, Tribal sovereignty and stewardship, and the humility to recognize that sometimes the wisest management decision is to act- and sometimes it’s leaving a living landscape whole.