U.S. Department of Agriculture,
I am writing to oppose the proposal to rescind the 2001 Roadless Area Conservation Rule (docket number FS-2025-0001). Maintaining the roadless rule as a federal rule is essential for ensuring all states benefit from a shared baseline to protect to their natural resources. I am concerned that the expansion of timber production as proposed in Executive Order 14225 and extracting natural resources in Alaska as proposed in Executive Order 14153 will not be adequately balanced with ecosystem restoration and maintenance.
Opening more of our forests for timber production or to extract gas, oil, and other minerals, destroys the balance of a fragile ecosystem. These environments are inherently valuable, but they also help support us by providing wildlife habitat, clear air and water, sequestering carbon, and unparalleled recreation areas. I am concerned rescinding the Roadless Rule will encourage more frequent depletion of natural resources and increased negative impacts on our environment.
While the proposal cites changing insect and disease pressures as potential reasons for rescinding the rule, I believe more targeted screening approaches to avoid initial introductions would be more effective. Devastating invasive pests and pathogens, such as the emerald ash borer and Phytophthora ramorum, the causal agent of Sudden Oak Death, are primarily introduced through the foreign importation of plants primarily via the nursery and timber trades (Sun et al. 2024, Grünwald et al. 2012). The USDA should evaluate whether it would be more cost-effective to manage these pests and pathogens by screening for them at ports of entry and supporting local USDA and Forest Service professionals in routine surveying efforts. In the case of Sudden Oak Death, research has shown disease management solutions are most effective and cheaper when deployed earlier in an outbreak (Cunniffe et al. 2016).
I have greatly benefited from the roadless rule through my hiking, kayaking, and camping experiences across the US but particularly in North Carolina’s Pisgah and Nantahala National Forests. As a biologist who has studied the movement of pathogens in forested areas, I think conservation efforts focused on early mitigation efforts are more effective at preventing outbreaks. Rescinding the federal rule puts the health of natural ecosystems in jeopardy for an unconvincing purpose.
Thank you for considering these comments.
References
Cunniffe, N. J., Cobb, R. C., Meentemeyer, R. K., Rizzo, D. M., & Gilligan, C. A. (2016). Modeling when, where, and how to manage a forest epidemic, motivated by sudden oak death in California. Proceedings of the National Academy of Sciences, 113(20), 5640-5645.
Grünwald, N. J., Garbelotto, M., Goss, E. M., Heungens, K., & Prospero, S. (2012). Emergence of the sudden oak death pathogen Phytophthora ramorum. Trends in microbiology, 20(3), 131-138.
Sun, J., Koski, T. M., Wickham, J. D., Baranchikov, Y. N., & Bushley, K. E. (2024). Emerald ash borer management and research: decades of damage and still expanding. Annual Review of Entomology, 69(1), 239-258.