“DEIS names outfitters, guides and tour operators as affected”
“books lost recreation benefit at a minimum of $6.1 million a year”
“assess the impact on the small entities actually operating in or adjacent to the potentially affected roadless areas”
“Future generations deserve to experience nature fully”
What it names
Works cited
Furniss et al. 1991
The comment
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Public land belongs to all of us, and the 63,351 acres held within Georgia's 23 inventoried roadless areas belong to future generations as much as to anyone alive today. I oppose rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer the specific points below on the record.
Atlanta already has water issues, and the state of Georgia cannot absorb further damage to its water systems. Across the Southern region, which includes Georgia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis establishes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today, and opening them to road construction is the most direct way to change that. I ask the agency to explain, specifically and for Georgia's watersheds, how it accounts for the sediment risk roads introduce and what protections remain if the 2001 rule is removed.
Building new roads into country that has none, when the agency cannot maintain the roads it already has, makes no fiscal sense. "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." The DEIS itself concedes that road mileage, deferred maintenance and management costs are likely to increase under this proposal. A logged stand grows back. A road does not. I ask the agency to name the funding source for any new road construction and maintenance this rescission makes possible, and to state the projected change in the deferred maintenance backlog.
The small-business certification does not hold up. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The regulatory flexibility analysis reaches its no-impact conclusion by spreading an annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas, and it concedes some of those firms may lose those receipts entirely. The agency should withdraw the certification and assess the impact on the small entities actually operating in or adjacent to the potentially affected roadless areas, not the national average firm.
The agency has also invited reliance interests and then declined to weigh them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." Future generations deserve to experience nature fully and do not deserve the environmental fallout of sediment and damaged ecosystems this rescission will cause. That inheritance is a reliance interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one.
Finally, the agency cannot declare plan amendments beyond the scope of this proposal and then invite public comment on them in the same breath. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That posture asks the public to do the analysis the agency refused to do. The foreseeable scenario of expanded timber harvest and road construction should be analyzed as part of this action, not deferred to a future proceeding where today's commenters have no guaranteed voice.
Public land should be managed to protect it from further development and maintained responsibly for nature and our ecosystem. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. I ask the agency to answer each of the points above before this proceeding closes.
Sincerely,
Dana H
Atlanta, GA