The Blue Mountains, Gifford Pinchot, Deschutes, Wenatchee, Rogue, and Siskiyou National Forests are where I hike and camp. These are inventoried roadless areas, and the proposed rescission of the 2001 Roadless Area Conservation Rule would directly change what those places are. I oppose this rescission.
The agency states, in the Rationale for the Proposed Rule, 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, which has contributed to challenges in addressing forest health concerns." That claim is the centerpiece of the forest health rationale. But the agency's own document undercuts it. The document cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land. The same document acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. Those two findings sit alongside the forest health assertion without any attempt to reconcile them. The agency needs to explain, specifically, how removing the rule addresses a forest health problem that its own cited research suggests the rule was not meaningfully causing.
On recreation, the agency frames its loss estimate as modest because it is capped at a fraction of operable land in any single year. But roads, once built, do not undo themselves, and recreation settings, once degraded, do not reset. The agency's own Recreation section acknowledges that the magnitude of losses is unknown, and it places the estimate against roadless recreation benefits it values at upwards of $1.5 billion. A single-year fraction does not capture what accumulates across decades as roads and altered settings compound. The agency should model cumulative recreation losses over a meaningful time horizon and compare them against projected timber revenue before treating the annual figure as an adequate accounting.
The forests I named are not abstractions. They are where I go. The agency must address both of these points directly in its response to public comment.