Re: RIN 0596-AD66, Docket No. FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule
I strongly oppose the proposed rescission and ask the Department to adopt the No Action alternative.
I live in Santa Cruz County, California, and have worked in mortgage lending on the Central Coast for 35+ years. I know what wildfire does to communities and home values, and I take the Department's concerns seriously. I have also supported the National Forest Foundation, the Forest Service's chartered partner; my contributions funded nearly 30,000 trees on national forest land. That taught me how slowly a damaged forest recovers, and that protecting intact forest is cheaper than restoring it. Rescission is not needed to address wildfire, and what it gives up cannot be restored.
1. The loss is permanent; the benefit, by the Department's own account, is small.
The preamble says management opportunities "would be modest and localized." The projected timber gain (5 to 10 percent more sawtimber; $5.2 to $11.4 million per year) assumes harvest across all 4.8 million operable acres, which the Department calls "unlikely." Against that, it estimates recreation losses of $6.1 million per year and total effects that "could exceed $100 million." Roads are rarely undone, and the agency already carries a $6.9 billion road and bridge maintenance backlog. Once roaded, intact watersheds, habitat, and quiet backcountry do not return. Trading permanent loss for modest, uncertain gain is poor policy.
2. The 2001 Rule already permits the wildfire work the Department cites.
The preamble says the prohibitions "removed important management tools." But the Rule expressly allows removal of "generally small diameter timber" to "reduce the risk of uncharacteristic wildfire effects" (36 CFR 294.13(b)(1)(ii)) and road construction "needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event" (§ 294.12(b)(1)). The real complaint is that these exceptions were used in a "limited and inconsistent" way due to reviews and approvals. That is an administrative problem with an administrative fix, not grounds to strip protection from 58.5 million acres. By the Department's figures, the wildland-urban interface covers only 24 percent (9.8 million acres) of the affected lands; three-quarters lies away from the communities the rationale is meant to protect.
3. New roads would add to wildfire risk.
Roads bring people, and people start fires. A national study of 1992–2012 records found humans ignited 84 percent of U.S. wildfires and nearly tripled the fire season (Balch et al., PNAS, 2017). The preamble concedes access "can increase human-caused ignition potential." Roads can also open private inholdings to development, as the Alaska petition requests; each new home at the forest edge adds ignition sources, fragments habitat, and adds to what firefighters must defend.
4. Rescission removes the national floor and leaves future development unanalyzed.
The proposal authorizes no projects, yet admits later plan amendments "could increase the area where timber harvest and road construction would be allowed," with impacts "beyond those summarized above," and treats them as out of scope. It also adds flexibility for oil, gas, and coal leasing. The analysis measures near-term effects under today's plans while removing the only national limit on tomorrow's. The cumulative effect across 100-plus national forests is not evaluated.
5. Public input would fragment.
These lands belong to all Americans. The 2001 Rule followed a national process with about 430 public meetings (66 FR 3244). Under rescission, each area would be decided forest by forest; a Californian would have to follow dozens of proceedings to have the voice available today in one. Tribes agree, citing "the unsustainable burden of project-level review." The process is also rushed: 21 days of comment on the notice of intent, 30 (since extended to 45) on a decision affecting 58.5 million acres, and only 29 of 64 requested Tribal consultations held.
Recommended alternative
Retain the 2001 Rule. If fuel-reduction work is slowed, fix that narrowly: (a) streamline approval of the existing exceptions within the wildland-urban interface, e.g., by delegating to regional foresters with fixed deadlines; (b) keep using the state petition process (5 U.S.C. 553(e); 7 CFR 1.28), as Idaho and Colorado did. This serves the Department's objectives without stripping protection from the three-quarters of affected land outside the interface.
I recognize the needs of timber-dependent communities and the danger of wildfire, but the Department's own numbers show modest, uncertain gains against permanent loss. I respectfully urge withdrawal of this proposal.
In closing, this land is largely as nature created it. Whatever one's beliefs about its origin, humans must leave some lands wild and untouched.
Respectfully submitted,
Forrest Cambell