Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The national forests belong to all of us, and to every generation that follows. I am asking the agency to keep the 2001 Roadless Area Conservation Rule in place and to address the specific failures in the record supporting its rescission.
I want my children, and all children, to experience freedom in our great national forests and parks. The United States is beautiful because of these places. Tearing them down serves no public purpose I can identify, and the record before the agency does not persuade me otherwise.
The agency has been down this road before, and lost. The record here shows that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That language comes from a prior attempt to substitute state-specific management for a single national rule, an attempt the Ninth Circuit rejected. The current proposal rests on the same premise: that local and state-level decision-making can substitute for national protection. The agency must explain, on this record, how the present proposal avoids the precise deficiencies that court identified the last time the agency tried this approach, and it must address its own prior finding that local decision-making can incrementally reduce roadless values of national significance.
The proposal also asks the public to comment on consequences the agency has simultaneously placed beyond the reach of its own analysis. 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 is not a coherent analytical process. The agency cannot in good conscience invite public views on a foreseeable outcome while refusing to analyze it. I ask that the agency bring the foreseeable plan-amendment scenario, including the expansion of areas open to timber harvest and road construction, fully within the scope of this action before any final rule is issued.
The carbon question is raised and then abandoned. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. Having stated that figure, the analysis does not follow it to its logical conclusion. There is no quantification of what happens to that stored carbon, or to ongoing sequestration, under the alternatives that permit harvest and roading. I care about what these forests hold and what they continue to do. The agency must quantify the projected change in carbon storage and sequestration under each alternative, because the number it cited is meaningless without that comparison.
Finally, the agency has reversed a factual finding it made in 2001 without explaining what changed. The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule. An agency is not free to simply announce the opposite of what it previously found. It must identify what evidence or conditions justify the reversal and must engage with what it concluded before. That explanation is absent from the current record, and the agency must supply it.
Please manage and care for this land. Nourish it so that it may live on for a hundred more generations of human and animal species alike. These forests are not ours to spend down. They are ours to pass on.
Sincerely,
Jenna Andrade
Cranston, Rhode Island