I am a resident living near the Siuslaw National Forest in the Pacific Northwest where I regularly enjoy hiking the trails in Siuslaw. I’ve enjoyed hiking and camping in other roadless national forest areas, including the Olympic, and the Willowa Whitman National Forests.
I am urging the USFS to retain the 2001 Roadless Area Conservation Rule and I select the No Action Alternative because the USFS did not provide any documented justification or evidence of any direct economic benefit for rescinding this rule. It sites no studies or reports to strengthen its position. Most documented studies point to an economic detriment that would result from rescinding this rule. This proposal to rescind a Rule that emerged from a thoroughly inclusive and collaborative bipartisan process is so poorly presented that its only result will be the immediate launch of multiple nationwide lawsuits.
One of the best aspects of the National Forest system is that its lands belong to all Americans; lands that all people pay for with their tax money, and that the use these protected areas are cost free. The roadless areas must stay that way for generations because the total roadless areas amount to only about 24% of the Forest Service lands.
The USFS has not provided a credible rationale for why the 2001 Roadless Rule should be rescinded. For example, the Forest Service makes the vague rationale that “as resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from the timely, place-based discretion needed to meet the Forest Service's multiple-use mission. The USFS states 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. This statement is false. The 2001 Roadless Area Conservation Rule does allow for emergency wildfires measures and other approved projects.
In addition, the USFS has not made a credible argument for why the Roadless Rules law is a problem for preventing wildfires and vegetative diseases.
Regarding wildfire threats, the USFS has not cited any evidence of where its efforts at fighting wildfires were hampered by the lack of roads in areas designated within the Roadless Conservation areas.
Conversely roads are proven to play a measurable role in wildfires.
NPS studies have already shown that 85% of wildfires are caused by human activities, and 78% of them occur within one half mile of a road.
The USFS has not cited any economic studies that show how extracting timber from these areas will create a significant ongoing economic benefit to surrounding communities. Over the decades of timber extraction, those jobs have proven to be temporary for surrounding communities. However, it is proven many times over that surrounding communities benefit from wildlife and recreational tourism where the scenic beauty is protected..
To be clear, adding more roads only adds millions more dollars in road maintenance costs when it’s reported that the Forest Service is already $7 to 9 billion behind in deferred maintenance on its 375,000 existing roads, culverts and bridges.
The agency is not estimating economic or environmental impacts correctly or consistently,
and the unintended consequences of rescinding this rule will further drain needed resources and have long term negative economic and environmental costs.
Again, the 2001 Roadless Rule already allows limited exceptions for road construction and timber harvesting in certain circumstances, such as responses to wildfires and other emergencies, just not industrial level timber extraction and road construction.
In summary I urge the USFS to retain the 2001 Roadless Area Conservation Rule and I select the No Action Alternative .