USDA’s own assessment shows eliminating the Roadless Rule will increase fires, landslides, and costs

Why We Need To Fight The Roadless Rule Rollback

Update: Read PFPI’s comments on the DEIS

Download a pdf of this post here.

The Roadless Rule generally prohibits harvesting and roadbuilding (with key exceptions) in certain land parcels (“inventoried roadless areas”, IRAs) of National Forest System (NFS) land in 36 eastern and western states and Puerto Rico. The USDA, headed by Secretary Brooke Rollins, has proposed to eliminate those prohibitions, as outlined in the DEIS. An online map shows the IRAs and how they would be affected by the rollback proposal.

That the proposal has been incredibly unpopular from day one is shown by the submissions during the 2025 comment period for the notice of intent, which ran 99 to 1 opposing the rescission of the rule (p. 19 of the DEIS).

There are three “alternatives” proposed by the USFS for this rule. Alternative 1, our favored alternative, leaves everything “as is” – the roadless areas stay protected. Alternative 2 is the nuclear approach, getting rid of roadless areas altogether. And Alternative 3, while sold as a “reasonable alternative” is just as bad, eliminating all the roadless protections in the Tongass NF in Alaska, most of the roadless protections in the eastern US, and a substantial proportion of roadless protections in the western US.

We need the public to submit comments demanding that the USFS abandon this reckless rule modification altogether, sticking to Alternative 1 (“do nothing”) and avoiding the irreparable damages that Alt. 2 or 3 will do to our public lands. Below, you’ll find detailed information about the DEIS, the economic analysis published by the USFS, and what it means for our public lands if Alt. 2 or 3 come into effect.

If you don’t need all that detail, you can see a short summary of Roadless Rule rollback impacts at page 23 of the DEIS, then click here to go straight to the Federal Register to submit your comments to the USFS and let them know what a foolish idea it is to rescind the Roadless Rule. Your letter should clearly state that you support Alternative 1, no action, and that you oppose both Alternative 2 and Alternative 3. That is because even though Alternative 3 would retain some roadless areas, it would have disastrous effects – including removing all prohibitions on roadbuilding and timber harvesting for nearly all roadless areas in eastern states, and a large proportion of those in western states.

To see where the roadless areas are (there are a surprising number in eastern states), and what the different alternatives would do, you can view the Forest Service online map. Rather poor pdf reproductions of those maps are also available. We also show what areas would be lost under Alt. 3 at our online map of fire ignitions and mature and old growth forests in the roadless areas.

Overall, Alternative 3 would be a recipe for tying up the environmental community in eternal, expensive litigation – the avoidance of which was one reason for enacting the 2001 rule in the first place. Perhaps that’s the goal.

It’s worth noting that a number of activities are permissible in roadless areas under the 2021 rule (p. 21)

• Maintaining existing roads;

• Constructing or maintaining motorized and non-motorized trails;

• Mechanical thinning of small-diameter trees;

• Engaging in hunting, fishing, hiking, camping, and other recreational uses;

• Using a motorized vehicle, such as an off-highway vehicle, on a trail open to motorized

use; 

• Riding a bike on a trail open to mechanized use;

• Implementing prescribed burning; and

• Grazing livestock.

In other words, many uses are allowed under the 2021 rule. Rolling back the rule almost exclusively benefits resource exploitation, to the detriment of every factor considered in the DEIS. As summarized at p. 22,“In general, impacts from road construction and timber harvest activities could include: increased fire frequency (human-caused), reduction in primitive or semi-primitive recreational settings; sedimentation and impacts to water quality; landscape fragmentation; adverse impacts to threatened, endangered, or sensitive wildlife and plants; loss of scenic character; impacts to tribally important resources; or economic losses related to recreation or non-commodity values of roadless areas.”

Why it’s vital to oppose partial rescission (Alt. 3) as well as Alt. 2

As Alternative 2 would remove all prohibitions on all IRAs, its rationale and impacts are straightforward. The rationale for what parts of what IRAs would lose protections under Alt. 3 is somewhat more complex.

As summarized at DEIS p. 15, Alt. 3:

Removes all Roadless Rule prohibitions from IRAs in the Tongass National Forest

• Removes roadless rule prohibitions and designation on 31.7 million acres, including:

• 4.5 million acres of non-NFS lands and congressionally designated areas
• 17.9 million acres that are within ½ mile on either side of existing roads and/or within wildland-urban interface, outside of the Tongass National Forest, and
• 9.3 million acres of inventoried roadless area within the Tongass National Forest.

• Continues current management on 13 million acres pursuant to the 2001 Roadless Rule;

• Prohibits road construction, reconstruction, and timber harvest
• Provides limited exceptions for public health and safety, reserved or outstanding rights, existing or renewed mineral leases, and realignment to prevent resource damage or address safety hazards, and stewardship purposes (see 36 CFR 294.12 and 294.13 (2001)) (same as no action).

• Provides provisions to modify IRA boundaries based on locally led modification proposals (details at p. 18. This is important as it will permit the continued chewing away of IRA boundaries).

Alt. 3 also removes protections from areas that happen to have roads in them due to “mapping errors” and road construction that “occurred between 2001 and 2010 while the rule was enjoined, or pursuant to the 2001 Roadless Rule’s exceptions.” (p. 16). In other words, where there was formerly defiance of the Roadless Rule, that would be rewarded.

Their criteria for drawing the maps are laid out on p.17 of the DEIS.

Under Alt. 3, for all Forest Service Regions (viewable online), the percentage of IRAs with Roadless Rule prohibitions removed ranges from 60 to 97 percent (p. 17). Nearly every IRA in eastern states would be eliminated, the same as under Alt. 2 (full rescission), along with large proportions of IRAs in western states. The acreage impacted by the alternatives is summarized in a table at p. 21 and reproduced here.  Our map also shows which areas would lose protections.

How the different Alternatives will affect roadless area acreage

Why does the Trump administration want to rescind the Roadless Rule?

Why rescind the Roadless Rule, which according to the DEIS has worked so well for so many years to pour oil on the troubled, litigious waters of western land management? 

USDA’s claims that the rollback is about fire mitigation

USDA’s press release about the proposal is full of quotes about forest health, fire mitigation, and the need for management “flexibility.”

The DEIS expands on that verbiage. Under “Purpose and Need for Action” (p. 10), it says “The Department is proposing this rule rescission to reduce regulatory burden and return land management decision-making for inventoried roadless areas to local Forest Service officials…. Today, the Department believes increased management flexibility in the administration of these lands is needed to better meet the multiple-use mission and provide benefits to the American people… there is a need to increase local management flexibility and, where necessary, allow for active management to respond to changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface.”

However, this is all fundamentally misleading, as the body of the DEIS shows.  Evidence presented in the DEIS shows that roadless areas generally have fewer fire ignitions, less fire, and generally less insect infestation than other, roaded lands in the National Forest System.

Humans cause fires… and humans use roads… so more roads mean more fires

Many if not most fires on Forest Service lands are human-caused. That was well-understood in 2001 when the Roadless Rule was created, and it’s been demonstrated multiple times, most recently by Aplet et al, 2026, who showed that fires increase with proximity to roads. We mapped USFS data on fire ignitions versus IRA boundaries and the pattern is clear, even with the raw data. The USFS itself recently conducted a study using the ignition data, and presents the information in a table at p. 87. As expected, ignition density is dramatically lower in roadless areas and wilderness areas (which are a separate and sometimes overlapping designation with roadless areas) than other National Forest System (NFS) lands, though fires tend to be bigger in these areas, because they are often allowed to burn. The DEIS estimates that 57 percent of fires on other NFS lands are human-caused (p. 89). While the increased risk of ignition is acknowledged in the proposed rule’s cost-benefit analysis, it is not assigned a monetary value in the analysis, which does, however, assign a benefit of $9.9 million to $22 million annually to the “annual timber benefit to society.”

Fire ignition density and fire extent on roadless areas, wilderness, and other NFS lands

Logging and roadbuilding spread invasive plants that carry fire

One of the greatest spreaders of fire is invasive plants, particularly in the Intermountain west where dried cheatgrass and other annual grasses have contributed to a deepening cycle of fire. Invasives already exist in IRAs, but the DEIS acknowledges (p. 107) that under Alternatives 2 and 3, where road construction and timber harvest occur (along with “other development”), these activities “have the potential to introduce and spread invasive plant species due to ground disturbance… In the long term, increased disturbance could increase the spread risk of existing invasive plant populations.” In fact these plants love nothing better than stirred up soils and can quickly take over disturbed areas.

Insects and disease could increase, too

Notably, “forest health” outcomes follow a similar pattern. The DEIS reports that in western forests, the percent of forests at risk of mortality from insects and diseases “is similar or lower” in IRAs when compared to NFS forests outside of designated areas (p. 67). It almost seems like… undisturbed forests are healthier and more resilient!  (The USFS 2024 National Insect & Disease Risk Map is available online).

Limiting fire ignitions by prohibiting public access

Given the well understood connection between humans, roads, and fire, it’s not controversial to expect that punching roads into roadless areas will increase the incidence of fire. The DEIS mentions this conclusion multiple times. It even warns, “Alternative 3 has the same concern about new roads increasing ignitions, and these ignitions would be closer to communities, where they could potentially cause more damage” (p. 104).

What can be done? The DEIS says that despite more fires, new roads would increase the “potential for improved response times and increased initial attack success.” However, their other proposed solution is to limit access to our public lands: “Under alternatives 2 and 3, if there is an increase in public road access, the number and frequency of wildfires could rise. However, public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas.”(p. 105).

Once roads are built, road closures are often ignored by some public. ATVs and other recreational motorized vehicles can easily drive around gates or over berms. The FS currently employs about 650 law enforcement personal nationwide, or one officer for every 462 square miles of public lands. If roads are built into roadless areas, people will use them, the FS cannot enforce closures, and the risk of fire on “closed roads” that create additional challenges for emergency responders to access is a real threat. Recreation use of the backcountry is projected to increase quite dramatically by 2040 (p. 211), but areas desirable for recreation will shrink if the Roadless Rule is rescinded.

Fires do threaten communities – but the DEIS doesn’t actually address that risk

Fire does present a serious threat to certain communities in the western US. The DEIS concludes (p. 102) “Over 7 million acres (nearly 26 percent) of all inventoried roadless areas outside of Alaska intersect with high-priority firesheds (there are no high-priority firesheds in Alaska). Our assessment of the high-priority fireshed area within IRAs was further refined based on timber operability, which approximates the land available to combined timber and fuels projects. Approximately 3.6 million acres (52 percent) of the high-priority firesheds in the potentially affected IRAs are in the likely operable or operable-but-complex condition, meaning that mechanical fuels reduction activity could be feasible. About 16 percent fall within the likely operable category, likely providing the greatest opportunities for integration between hazardous fuels reduction and economical timber harvest (see Table 28), as consistent with land management plans. Local project-specific design would determine which part of these areas would be strategic for treatment.”

Leaving aside the question of whether intensive fuels management is an effective or efficient approach for mitigating fire risk, the DEIS does not consider an alternative that would focus mitigation in high-risk firesheds – despite all the public talk about concern over fire.  Instead, Alternatives 2 and 3 use one-size-fits all approaches to sweep away protections – including (under Alt. 3) for nearly all roadless areas in eastern states where the risk of fire is negligible. (Even Puerto Rico’s El Yunque National Forest, the only tropical forest in the USFS system, would lose protections under Alternative 3 – see the USFS online map or the Alt. 3 tab at our map).

The DEIS declines to quantify wildfire risk reduction or costs under the alternatives (p. 225), simply saying “any” reduction in risk “provides meaningful benefits to the public, industry, and the agency.”  Nonetheless, the DEIS acknowledges that authority already exists under the 2001 Roadless Rule to deal with fire and other situations as they arise on roadless areas via forest thinning and even road-building as necessary, as summarized at p. 14 of the DEIS, and notes that “Agency management records show that a lack of roads has not prevented fire prevention or protection measures, especially wildland fire use and prescribed fire” (p. 105). It further observes that the 2001 Roadless Rule allows hazardous fuels reduction in IRAs, including use of prescribed fire, and that a USFS database “indicates that hazardous fuels reduction has been completed on about 5 percent of the potentially affected IRA area over the most recent decade (fiscal years 2014-2024)” (p. 94). The intensity of activities seems to be comparable to elsewhere: “Previous research using similar agency data concluded that the 2001 Roadless Rule did not meaningfully constrain hazardous fuel treatment activities when considering the number and area of treatments as a share of total forested land” (p. 96).

However the problem, they say, is that there is a “general sentiment” in planning studies that roadless designation impedes mechanical treatment (p. 96). Thus, due to this failure of perception, evidently the answer is to sweep away all prohibitions on roadbuilding and logging so at least everyone will be on the same page.

Roads suitable for firefighting are expensive, and the USFS doesn’t have the budget

The USFS hasn’t seriously discussed or modeled what different programs of fire risk management would cost, perhaps all of the outcomes requiring roadbuilding are prohibitively expensive. Appropriate equipment can help fight wildland fire, but good roads are needed to “facilitate use of additional firefighting resources such as wildland fire engines, water tenders, bulldozers, material and equipment transport vehicles, and forestry equipment (such as fellers, skidders, masticators, and chippers).” Such resources are “best supported by roads with smooth surfaces, low grades, and wide corners, which generally correspond to permanent Forest Service roads with maintenance levels 3-5” (p. 97). 

Roads like that are expensive: “NFS road construction cost in the lower 48 states varies between $80,000 to $100,000 per mile for native surface (dirt) roads. Adding gravel surfacing is an additional $300,000 to $500,000 per lane mile, and approximately $1,000,000 to $2,000,000 per lane mile for asphalt paved roads. In Forest Service Region 10, Alaska, road costs are much higher, typically four to five times that of the lower 48 states. These costs do not include significant drainage structures such as bridges, retaining walls, or other substantial slope stabilization measures” (p. 40).

The DEIS assumes (p. 45) “that revenue generated by timber sales or other resource extraction activities would be used for some road-related system management but not be sufficient to cover the costs of constructing and maintaining all new roads related to a project.” That’s a large understatement, particularly given that appropriated funding for NFS roads declined from about $220 million to $70 million in 2020 and has stayed low since (p. 43) and deferred maintenance costs are currently around $7 billion (figure below is from p. 44).

Additionally, there could be resource tradeoffs that pit different areas against each other. The DEIS states (p. 23) that “NFS road mileage, deferred maintenance and management cost increases are likely under alternatives 2 and 3… There could be a need to shift resources or funding to account for additional permanent mileage added to the NFS system.”

On top of these problems the Trump Administration is planning additional attacks on roaded public lands.  Concurrent with the plan to rescind the Roadless Rule, they are proposing to radically change the rules which govern where motorized vehicles can travel on National Forest System lands. USFS has issued a Notice of Intent (NOI) announcing plans to revise travel management regulations. The proposal would flip two decades of USFS’s Travel Management Rule planning on its head by moving from a “closed unless open” basis, meaning that motorized use is only permitted on designated routes and in designated areas, to an “open unless closed” model, which would permit motorized use everywhere unless a route or area was specifically closed. It would also remove existing “national minimization criteria” that currently direct managers to consider minimizing damage to soils, watersheds, vegetation and other forest resources; harassment of wildlife and significant disruption of wildlife habitat; and conflicts among recreational uses.  

Fuels management is expensive, too

“Treating” forests to reduce fire risk is also expensive, costing the USFS more than $400 million annually. The DEIS (p. 215) puts costs for individual projects from $100 to $500 per acre and up to $2,000 per acre in certain areas. Prescribed fire is a primary treatment method, but natural ignitions can reduce overall risk (such as in backcountry areas like IRAs). However, “Mechanical thinning and mastication are increasingly used in wildland-urban interface zones and ecologically sensitive areas” with mechanical pretreatment costs averaging “between $300 and $2,000 per acre.” Opening up the IRAs would create the expectation that more fire control projects would occur, but how would USFS find the resources?

The Roadless Rule rollback is not actually about fire mitigation

In any case, it’s clearly timber and mineral/energy exploitation, rather than fire mitigation, that will wag the dog if the Roadless Rule is rescinded. The DEIS admits that building good roads necessary for equipment access will in any case not be a priority: “Alternative 2 would allow both temporary and permanent road construction where not otherwise restricted by land management plans. However, the prevalence of temporary, spur road construction within the operable areas around existing roads is likely, assuming that timber projects are the primary motivation and funding source for new roads (see National Forest System Roads section). New permanent road construction, strategically planned to support fuels and fire objectives, is less likely to be widespread within potentially affected IRAs, given the costs of road construction costs, maintenance funding limitations, constraints on placement of roads, and current land management plan restrictions” (p. 102). The project’s cost-benefit analysis does not include any substantive or quantified estimates of fire mitigation. Putting it all together, it’s hard to take the emphasis on fire mitigation in USDA’s press release seriously. The incessant emphasis on fire risk appears to mostly be a stalking horse for resource exploitation and logging, not fuel treatments.

How much timber would logging roadless areas yield?

Roadless areas were often designated as such because they are relatively difficult to access. So would timber extraction and roadbuilding actually occur if the rule were reversed? Evidently the timber industry thinks so, as they appear to support the rollback. The DEIS states again and again that logging and roadbuilding will likely occur, for example at p. 22: “Under alternatives 2 and 3, for areas removed from IRA designation, where national prohibitions no longer apply, it is reasonably foreseeable that road construction or timber harvest activities could increase in the future.”

Given current land management plans, “For alternative 2, about 4.8 million acres (16 percent of forested areas in the potentially affected IRAs) are in areas where current land management plans allow timber harvest and are more likely to be operable. Slightly less for alternative 3 (4.3 million acres)” (p. 22). However, while land management plans would continue to govern management under all alternatives, “plans may be amended in any manner whatsoever and are revised periodically. Local responsible officials (forest supervisors and regional foresters) would continue to have discretion to amend or revise a land management plan as deemed necessary.”(p. 19, bolding in original). This puts a huge amount of power into the hands of Forest Service officials that are essentially political appointees and who may be most interested in serving logging and mining interests (as appears to be the case for the head of the Forest Service).

Evaluating the potential yield from roadless area logging in the context of new timber production mandates demonstrates that the Trump administration and its cronies are willing to exploit these largely unspoiled areas for what is essentially a trivial increase compared to USFS logging overall.  

According to the DEIS (p. 206), the US overall produces around 55.2 billion board feet of lumber each year. The Forest Service sells on average just under 3 billion board feet per year, or around 5% of the total produced domestically (each year, the USFS enters into contracts, and typically “sells” slightly more timber than is actually cut). The US also imports quite a bit of lumber, including about 12 billion board feet per year from Canada.

Trump’s Executive Order 14225, Immediate Expansion of American Timber Production, calls for increasing timber production on National Forest Service lands as a matter necessary to “national security,” which makes it sound like this is yet another way to poke Canada. Congressional action also mandates increasing timber production on Forest Service lands, via Trump’s “Big Beautiful Bill.”  The mandate (p. 34) is to annually, “beginning in FY2026 and through FY2034, sell a quantity of timber on National Forest System land that is at least 250 million board feet greater than the quantity that was sold in the previous fiscal year, subject to land management plan limits. The Forest Service must annually enter into 40 20-year or longer contracts for the sale of national forest materials for FY2025-FY2034.”

A scaled-down version of this target appears in the 2026 “National Active Forest Management Strategy” via “increasing the annual timber volume offered by 25 percent over the fiscal year (FY) 2020 through FY 2024 average, with a goal of selling 4 billion board feet by FY 2028.”

How much could logging IRAs actually contribute to this goal? Estimates of potential timber removal take “operability” into account (p. 74), i.e., the ability to actually use logging equipment. The DEIS expresses the amounts of potentially harvestable timber in units of one hundred cubic feet (“ccf”), a different unit than the board feet statistics above. For Alt. 2, full rescission, it states (p. 77) “Applying current land management plan direction, national annual increases in sawtimber harvest in likely operable areas could be approximately 106,000 to 254,000 ccf per year and 147,000 to 303,000 ccf per year within likely operable but complex areas, a total of 253,000 to 557,000 ccf.”

The amount anticipated as possibly cut under Alt. 3, partial rescission, is actually greater: “Applying land management plan direction to national annual increases in sawtimber harvest in likely operable areas could be approximately 112,000 to 264,000 ccf per year and 106,000 to 237,000 ccf per year within likely operable but complex areas, a total of 219,000 to 501,000 ccf per year.” (p. 81).  

In terms of acreage, and given operability and current land management plans, logging could occur on “about 4.8 million acres (16 percent of forested areas in the potentially affected IRAs), and 4.3 million acres for alternative 3 (4.3 million acres)” (p. 22). In other words, there’s no real advantage of Alternative 2 in terms of the amount of logging  over Alternative 3 – the advantage comes from the ability to build roads everywhere, to reach other resources.

Using data on timber cut and sold by the Forest Service for 2020 – 2025 puts the potential new logging in context. Given the chronic underfunding of the USFS and the inability to spin up logging operations in time to meet the USFS’ goal of a 25% increase by 2028, we use the top estimate for the “operable” category (264,000 ccf per year) in our analysis. We converted the required yearly increment of adding another 250 million board feet to units of “thousand board feet” (MBF). In the table below, green shaded data are historical data; blue shaded values are the percent of the required increase (second column) that could be provided by IRAs if logging were immediately spun up to provide 264,000 ccf per year; orange shading is the percent of total wood sold from National Forests that could be provided by logging IRAs at that rate. As the target increased, the limited amount of timber obtainable from IRA’s would represent a decreasing proportion.

Historical and projected values for NFS timber sales and potential role of sales from IRAs

The conclusions of the DEIS are similar to our orange highlighted numbers: “Depending on the alternative, these areas could potentially contribute a 4 to 10 percent increase in total sawtimber harvest towards the nationwide increase across NFS lands” (p. 22).

Regarding revenue, “Alternative 2 is estimated to potentially provide opportunity for an increase in annual timber harvest compared to the no-action alternative, which is estimated to result in a total increase of potentially $5.2-11.4 million per year in revenue for the agency… If all of this harvest occurred, it could represent a potential 5-10 percent annual increase in total sawtimber harvest on National Forest System lands.” (p. 220).

However, “This harvest could replace or substitute existing harvest in non-IRA areas, which wouldn’t generate additional jobs. It is also possible that harvest in IRA operable areas is additional harvest which would generate new jobs. These economic impacts are not expected to be substantial overall given the harvest increase is potentially 5-10 percent across all forests nationwide within IRA operable areas, though impacts to local communities could be larger. Estimating the economic impacts is not possible given the unknown degree of substitution” (p. 220).

Meanwhile, while we’re talking about increasing logging, a Forest Service webpage, “By the numbers,” says there’s a backlog of 3.5 million acres of national forest lands awaiting reforestation, and the Forest Service is only managing to reforest about 189,000 acres per year.

The real costs: Increased landslides, polluted water supplies

The DEIS does a reasonably good job of highlighting the many impacts associated with building roads and logging in areas that are relatively undisturbed.  The impacts are predictably bad for ecosystems, habitats, and animal and plant species, as well as human values like quiet enjoyment and scenic views (Table 3 at p. 23 provides an overview of the main factors considered in the DEIS). Two related potential impacts seem particularly important to mention however in the context of impacts to communities: the degradation in water supplies that can accompany roadbuilding and logging, and the increased potential for landslides.

The discussion of water quality impacts of the alternatives starts at p. 122. It states that the “no action” alternative retaining the Roadless Rule “has little risk of potential adverse effects and provides the greatest protection of water quality” for municipal users, and is largely unaltered from natural conditions in terms of water yield or runoff timing. Predictably, regarding Alternatives 2 and 3, the DEIS states “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation. Additional road construction and timber harvest is reasonably foreseeable in potentially affected inventoried roadless areas and has the potential to impact water quality through increased sediment delivery.”

It notes that “the Eastern and Southern Regions are the most susceptible to additional impacts due to long histories of land use, agriculture, and industrial pollution surface waters. The Eastern and Southern Regions also tend to have the largest percentage of potentially affected inventoried roadless areas considered likely operable with greater than 40 percent across both Regions.”

It also notes (p. 124) that “Under alternative 3 there are more than 5,000 municipal water intakes within watersheds containing potentially affected roadless areas, outside of Alaska”, though it draws no further conclusions about the significance of this fact. Nor does the proposal’s cost-benefit analysis substantively discuss or quantify potential impacts to water quality. “Conservation of air and water quality” is treated as a “non-market”, “social” value, grouped with “enduring beliefs people hold about forests and the good, importance, or worth of specific aspects of them.” Obviously this is ludicrous, as any community facing the cost of a new water-treatment plant could confirm.

Regarding landslides, the DEIS states that for both Alternatives 2 and 3, “Forest harvesting and road construction may significantly increase the frequency and severity of debris flows by altering the landscape’s hydrology and soil stability. Harvesting and roads disturb the natural cycle of soil reinforcement and drainage, making slopes more susceptible to failure, especially in mountainous regions with heavy rainfall” (p. 111).  A great deal more alarming description is provided at p. 112. Despite these warnings, the risks and potential costs of landslides is not even mentioned in the proposed rule’s cost-benefit analysis, much less evaluated.

Qui bono?

Who would benefit from increased logging and roadbuilding? Not the majority of US citizens and residents, who pay taxes to support public lands. Even the DEIS is unusually blunt in this regard, observing that “Alternative 2 enhances the quality of life for people that value timber harvest and potential mineral and energy development and the economic contributions that these provide to the community…Alternative 2 would have the greatest negative effects to the quality of life for people that hold intrinsic value for the existence of roadless areas, the ecosystem services and recreation benefit they provide.”

Forest Service links to the timber industry are well-served by the current USFS head, Tom Schultz.

Minerals, oil, gas, and coal exploitation

Besides the timber industry, mining and drilling interests could benefit from rollback of the Roadless rule. It’s important to recognize that Brooke Rollins, the USDA Secretary, is rolling back other protections as well in order to facilitate other Trump executive orders on exploitation of domestic energy and resources.

The DEIS is somewhat vague about how much these interests might benefit from rescinding the Roadless Rule, since a certain amount of such exploitation is already allowed under the 2001 statute. However, it states that whereas under the existing Rule, “new or expanded authorizations for oil and gas or coal exploration and development would include surface use restrictions, including limiting road construction.” Under alternatives 2 and 3, “requests for new land use authorizations or leasable minerals could increase in areas no longer subject to the Roadless Rule. New authorizations and expanded authorizations may include road construction and reconstruction” (p. 23).  These risks should not be underestimated.

“Unleashing Prosperity Through Deregulation”!

That’s the title of another Trump Executive Order. However, as the DEIS makes extremely clear, eliminating Roadless Rule prohibitions on millions of acres to benefit a handful of executives is going to unleash a cascade of costs that will haunt communities and the Forest Service for decades to come.