I oppose fully or partially rescinding the present Roadless Area Conservation Rule at this time.
I am a retired scientist living walking distance from Lake Tahoe, an Outstanding National Resource Water (ONR), and adjacent to one of its tributaries. My homesite is in a Wilderness Urban Interface (WUI) area where wildfire is a major and now growing catastrophic risk. In recent times (the last twenty years) we have experienced two catastrophic human caused forest fires in the Lake Tahoe Basin Management Unit, each destroying hundreds of residences.
My primary concern with full or partial rescission of the Roadless Rule at this time is that various potential enormous damaging effects, particularly from ongoing climate change and increased human usage, have not yet been assessed and quantified to adequate confidence levels. Three types of such possible negative effects are increased wildfire damage, recreation degradation, and water quality loss.
Wildfires historically occur much more frequently near roads, and hence would likely increase with Roadless Rule rescission, if local areas were to allow such roads. With climate changes, such as increasing temperatures and higher wind speeds, the range and damage level of severe wildfires has increased dramatically and will likely continue to do so. Communities far from the source of such wildfires will be in range. And there will likely be more such communities due to the national housing shortage. Allowing commercial and recreational vehicle usage in formerly roadless areas, in conjunction with climate change, will inevitably produce ever-increasing wildfire damage, including property losses and fatalities and ecological carbon sequestration losses. More knowledge is needed to define the increased extents and costs of wildfire damage that would result and that is acceptable to the public before rescinding any part of the Roadless Rules.
Recreation by people not in vehicles and in search of a natural undisturbed environment in former roadless areas will be degraded by full or partial rescission of the Roadless Rule. Degradations will include introducing on-trail or road vehicle danger, wide-spread vehicle and human noise, loss of access to undisturbed natural habitat, and general new increased roadless area damage and detritus from new commercial and recreational usages. Roadless areas are a national historical irreplaceable recreational treasure of the people. I believe the benefits cited for rescinding the Roadless Rules are not worth enormously degrading their recreational values to the public.
Water quality loss is likely due to new difficult to regulate incursions of people and machinery near many formerly isolated sources of potable water. Introducing traffic will cause sediment, dust, and other pollutants toe enter the water supply. Increased wildfire damage to the soil, forests, and meadows due to the higher frequency more more severe wildfires that result from climate change will also degrade the indigenous potable water.
In conclusion I hope that the Roadless Rule will not be fully or partially rescinded at this time due to the as yet unquantified potential damage levels to WUI residents lives and property, to loss of recreational value, to loss of water quality, and to the general reduction in sustainability of a healthy environment that would result.