I submit this comment in opposition to rescinding the 2001 Roadless Area Conservation Rule, also known as the Roadless Rule. The idea of facilitating large-scale timber, mineral and oil extraction with associated road building projects on 58.5 million acres of inventoried roadless areas across the National Forest System by the single action of rescinding the Roadless Rule is unconscionable.
In the section of the Proposed Rule titled "Purpose and Need for Action", it is stated: "Today, the Department believes increased management flexibility in the administration of these lands is needed to better meet the multiple-use mission and provide benefits to the American people." Among the multiple uses supported by lands currently protected by the Roadless Rule are clean water, recreation, tourism, wildlife, commercial fisheries, subsistence harvesting and mental health. Protecting these uses provides greater benefits to the American people than the two uses most likely to benefit from rescinding the Roadless Rule, timber and mineral extraction. Those two extractive industries already have more than their share of the multiple-use equation. In the case of the timber industry, I encourage a return to their previously logged and managed areas for "sustainable" timber harvests.
One justification presented for rescinding the Roadless Rule is concern about wildfire risk and increasing access for fire suppression in roadless areas. Wildfire risk is almost nonexistent in Alaska's Tongass National Forest, the largest intact coastal temperate rainforest on Earth, and the fire risk is low in most coastal forests of the Pacific Northwest. Just as the argument against the Roadless Rule states that one size doesn't fit all, so, too, do proposed justifications for rescinding the Roadless Rule not apply to all the National Forests containing presently designated Roadless Area Conservation lands.
In the "Rationale for the Proposal" section, there are repeated references to "changed conditions" and also evolving "national policy" and "national priorities" on National Forest System lands. I am heartened to see some acknowledgement of the effects of global climate change on our environment. While the environmental "changed conditions" are huge and broad, the result of political changes manifested by the evolving "national policy" and "national priorities" may be more significant in the near term. The resulting push for accelerated resource extraction from the 58.5 million acres of Forest Service lands presently protected by the Roadless Rule will have profound environmental impact. Political priorities and mandates are ephemeral, while consequences of physical actions taken due to those priorities and mandates are longer lasting, and they may have significant negative environmental consequences which are difficult, expensive and perhaps impossible to repair.
In the "Summary" section, and in other sections throughout this Proposed Rule, it is stated that the intent of this proposed action is to "reduce regulatory burden". That is a ubiquitous refrain of the Trump administration, across the board. Given the amount of acreage presently managed under the Roadless Rule and the environmental complexity and variety represented by those lands, I submit that the "regulatory burden" is exactly what IS needed. While moving fast and breaking things may spur innovation in the tech industry, it is bad environmental policy. There is value in moving slowly and thoughtfully. Do not rescind the Roadless Rule. Rather, modify the process to thoroughly consider possible exceptions on a case-by-case basis, soliciting input, truly weighing pros and cons and then justifying decisions with facts and rational statements.
Thank you for considering my comment.