FS-2025-0001-606705

I am submitting this comment regarding the proposed rescission of the Roadless Area Conservation Rule and the Draft Environmental Impact Statement (DEIS). I am concerned that the economic case for rescission has not been demonstrated. If the purpose is to increase economic opportunity and improve management of public lands, the relevant question is whether rescission will produce a meaningful net economic benefit to the American public. The agency’s own analysis raises significant questions. 1. Projected timber revenue is a hypothetical maximum, not an expected return. The Forest Service identifies approximately 4.8 million acres where additional active management could potentially occur based on operability and existing land-management plans. It estimates that harvesting across all these areas annually could increase National Forest System sawtimber harvest by 5–10% and generate $5.2–$11.4 million annually in federal revenue. However, the agency acknowledges that harvesting all these areas annually is unlikely because of budgets, market conditions, and operability constraints. The final analysis should provide a reasonably foreseeable estimate of actual additional harvest and revenue rather than emphasizing a hypothetical upper-bound scenario. 2. New roads create long-term public liabilities. The Forest Service acknowledges an existing $6.9 billion deferred maintenance backlog for roads and bridges, while identifying road construction and maintenance costs as constraints on the benefits of rescission. Before treating new road access as an economic benefit, the agency should calculate its full lifecycle cost, including construction, maintenance, reconstruction, mitigation, and closure. The relevant calculation is: additional public revenue minus the full cost of infrastructure required to generate it. The DEIS does not demonstrate that this produces a positive return to taxpayers. 3. Recreation losses must be included in the net economic calculation. The agency estimates approximately $6.1 million annually in lost recreation economic benefits associated with affected areas. Those losses should be incorporated directly into the net-benefit calculation. If the agency presents $5.2–$11.4 million in potential annual federal timber revenue while identifying $6.1 million in annual recreation losses, the public should see the complete accounting of both. 4. The agency should explain potential impacts exceeding $100 million. The Federal Register states that additional impacts associated with the proposal could exceed $100 million and requests information concerning the range of economic impacts. The final analysis should identify what constitutes these impacts, whether they are costs, benefits, or transfers, which sectors experience them, and what assumptions produce the range. 5. Future opportunities should not be treated as realized economic benefits. The proposed rule does not authorize any specific timber sale or road project. Individual activities would depend on subsequent land-management and project-level decisions. The analysis should distinguish between economic activity reasonably expected to occur and activity that merely becomes legally possible. This matters because permanent infrastructure can create long-lived public costs even when the economic activity it facilitates remains uncertain. 6. Wildfire benefits should be quantified. The proposal identifies wildfire risk reduction as a potential benefit of increased access. The final analysis should quantify how much additional road construction is expected to facilitate fuels treatment or wildfire response, the resulting reduction in suppression or damage costs, and potential costs associated with increased access and ignition risk. A road that could provide access is not necessarily an economically realized wildfire benefit. Conclusion Public lands are public assets. Their management should be evaluated according to the net value they provide, not simply according to how many additional commercial activities become legally permissible. The Forest Service’s own analysis describes the potential opportunities as modest and localized, identifies a $6.9 billion road-maintenance backlog, estimates $6.1 million in annual recreation losses, characterizes the maximum timber scenario as unlikely, and acknowledges that additional economic impacts could exceed $100 million. Before rescinding the Roadless Rule, I ask the Forest Service to provide a transparent accounting of expected timber revenue, full lifecycle road costs, recreation losses, wildfire costs and benefits, impacts exceeding $100 million, and the economic value of retaining roadless areas. The proposed change should demonstrate a positive net economic return for taxpayers. The current DEIS does not yet establish that conclusion.