The proposed rule change says:
"In 2001, the Roadless Area Conservation Rule established a single, nationwide set of prohibitions intended to provide lasting protection for inventoried roadless areas within the National Forest System in the context of multiple-use management."
It goes on to say: "this deregulatory action advances the policy objectives of Executive Order 14192, Unleashing Prosperity Through Deregulation [...]. In Executive Order 14225, Immediate Expansion of American Timber Production, the President declared that “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” In Executive Order 14154, Unleashing American Energy, the President likewise declared that “it is in the national interest to unleash America's affordable and reliable energy and natural resources.” In Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, the President declared that “it is the policy of the United States to fully avail itself of Alaska's vast lands and resources” and “maximize the development and production of the natural resources located on both Federal and State lands within Alaska.”"
It goes on to say that even without protection of the Roadless Rule, NFMA requires that areas adopt land management plans that "addresses similar conservation objectives as the 2001 Roadless Rule was intended to address, such as ecological integrity, sources of public drinking water, diversity of plant and animal communities, sustainable recreation, scenic character, and protection of cultural and historic resources."
It adds: "In 2001, USDA and the Forest Service asserted that a national prohibition was the best means to reduce conflict and potential for incremental impacts to the ecological and social values of these areas."
It adds: "Where plans allow, rescission of the 2001 Roadless Rule could increase management flexibility for access (roads), vegetation management, targeted fuels treatments, and access for minerals or energy uses."
My comments:
In the summary of key considerations it says that near-term permanent road additions would be likely on 45.5% of affected lands and temporary roads are likely on 28.3% of affected lands, totaling 73.8% of the currently roadless areas. It says timber harvesting would likely increase on 16% of affected areas, estimating a maximum of approximately $11.4M in revenue for the US govt. It says that 24% of the affected areas are in the wildland-urban interface and would improve the ability to suppress forest fires in those areas. It estimates $6.1M losses in economic benefits for recreation (reducing the net maximum revenue for the US govt to $5.1M, which appears to also be independent of the costs of road construction, which seem likely to exceed $5.1M--therefore, this rule does not project net increase in revenue for the US govt as a result of this rule change). It claims that there would not "likely" be a net increase in mineral development, despite also stating above that this rule change would further the goals of Executive Order 14154, Unleashing American Energy. Those claims appear to be in conflict with each other.
I support the original goals of the roadless rule, which is to preserve pristine wilderness areas from encroaching "incremental" deterioration. The stated description and justification for the rule attempt to have it both ways -- it says that the rule change would pave the way for paving, timber harvesting, mining, and resource extraction, but also that we don't need to worry because maybe local officials might not decide to do those things. It cites legitimate-sounding needs for wildfire mitigation and prevention, but officials could have submitted a narrower rule change limited to the wildland-urban interface areas; or suggested broadening the allowed exceptions to enable effective wildfire prevention and response without also opening the areas to more harvesting and encroachment. Instead they have proposed a rule change that their summary estimates will in the near-term be likely to result in impacts to 73.8% of affected lands currently protected as pristine roadless areas. Its summary also does not project a net profit for the US govt from these rule changes, once their maximum projected revenues are compared against their projected costs and reasonable plausible road construction costs.
The Forest Service has a multi-use mandate, but this does not mean that every parcel of land is or should be expected to be multi-use, and it is necessary to protect these lands at the national level from incremental impact. These rare lands that remain pristine and wild should be protected and preserved as the unique and valuable receptacles of ecological habitat, natural wonder, and irreplaceable history. Once they are gone they cannot be brought back.