I am opposed to the proposed rule rescinding the roadless rule.
Roadless areas in our national forests are incredibly valuable for how they provide habitat for wildlife, protect water quality and drinking water sources, and provide humans with opportunities for hiking, paddling, hunting, skiing, and more. And while the person reviewing these comments may also see the value in these things (thank you for your work on the tedious and thankless task of reviewing and summarizing comments, by the way!), I have no illusions that whoever is making the final decision on this rule will be swayed by such arguments. So instead, I’d like to state that rescinding the roadless rule would also have negative impacts on maintenance of existing roads and public safety.
First, the Forest Service does not have the engineering or roads staff necessary to properly maintain it’s current road system, let alone build new roads. My home is surrounded by the 2.3 million acre Wallowa-Whitman National Forest, and they have 3 roads managers to cover all of this ground, no road crews, and multiple vacancies in engineering. If the roadless rule is rescinded, and new roads are constructed without any increases in funding, this means the Forest Service would be diverting funds from road maintenance, existing roads would deteriorate and be more prone to failure and washouts, which would negatively impact public safety, recreational access, current active management projects, recreational access, and firefighting escape routes.
Second, most roadless areas are roadless because they are bad places to put roads. They’re steep, or rocky, or prone to landslides. Or they’re in remote areas where the distance to mills means there’s no way to make a timber sale break even. Or they’re not near towns, so there is no need to build roads to access inholdings or provide emergency access routes.
Finally, building roads in roadless areas would increase fire risk. The proposed rule change states that it is necessary to allow thinning projects and firefighter access in inventoried roadless areas. A rule change is not needed to achieve this – the Forest Service can conduct fuels thinning projects to reduce fire risk in roadless areas under the existing rule, and we have handcrews, rappel crews, and smokejumpers who are skilled at fighting fire off the road system. But more importantly, building roads into previously roadless areas would lead to more human caused starts. Campfires, dragging chains, and sparks from machinery are common causes of fire starts, and more road miles would lead to more starts, and end up increasing wildfire risk.