I am writing as a lifelong Pennsylvanian, a resident of Cumberland County, a former state park ranger, and a land protection professional, submitting this comment in my personal capacity. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and ask the Department to retain it.
My concern centers on the roughly 25,000 inventoried roadless acres in Pennsylvania's Allegheny National Forest, including Hearts Content National Scenic Area and the area surrounding Minister Creek. The Allegheny is Pennsylvania's only national forest, and though it sits across the state from me, its roadless acres are the commonwealth's share of this rule. These are old, wet hemlock and hardwood stands and headwater streams that support native brook trout and the Eastern hellbender, Pennsylvania's state amphibian. The other ninety-five percent of the Allegheny is already open to logging and drilling under a forest plan written by the local professionals who manage it. What this rescission reaches is the last five percent that plan was never allowed to touch: forest that spent a century recovering from being cut to the ground. At its plainest, the Roadless Rule is a rule against cutting roads back into forest that has spent a hundred years coming back.
I ask the Department to address the following in the final rule and EIS:
1. Wildfire. The stated rationale is wildfire risk, but the fire profile of eastern roadless areas is not that of the West. Hearts Content and Minister Creek are wet ground where fire risk is low and the risk to streams from road construction is not. How does the DEIS analyze fire risk for eastern inventoried roadless areas specifically, and how does it reconcile a national rescission with federal fire records showing that only a small fraction of wildfires start in roadless areas, while most ignite along roads?
2. Local control. The 2001 rule already contains the mechanism the Department says it wants: any state may petition for its own roadless rule, Idaho and Colorado did, and this proposal retains both. If returning decisions to local officials is the goal, why is national rescission necessary rather than the existing state petition process? What have the officials responsible for the Allegheny actually requested?
3. Water. What analysis has the Department conducted of road construction impacts on headwater stream sedimentation and the aquatic species that depend on cold, clean water in eastern forests, particularly now that the rescission of the Endangered Species Act harm definition has removed the regulatory backstop for habitat?
4. The record. The 2001 rule followed six hundred public meetings and 1.6 million comments. This rescission has had roughly two months of comment across two windows and no public meetings, and the agency's own scoping summary shows that the overwhelming majority of more than 600,000 comments opposed rescission. How will the final rule respond to that record?
At minimum, the Department should adopt an alternative that retains roadless protections in eastern national forests, where the wildfire rationale does not apply. Pennsylvania has one national forest. Its roadless acres are a promise a quarter century old, and I ask the Department to keep it.
Jared Abell
Carlisle, Pennsylvania