As you know, Secretary of Agriculture Rollins announced on June 23 of this year the rescission of the 2001 Roadless Area Conservation Rule.
The Roadless Area Conservation Rule (36 CFR 294, Subpart B) encompasses nearly 59 million acres of National Forest & National Grasslands. This is around 30% of all USFS lands. The stated purposes of the Roadless Area Conservation Rule is as follows:
"To preserve biodiversity, protect watersheds, reduce erosion, sequester carbon, and safeguard habitats for over 1,600 sensitive plant and animal species, while also offering expansive areas for backcountry recreation."
The recent attempt by Senator Lee to introduce legislation that would have mandated the sale of up to 3 million acres of public lands rightfully received much attention and outcry. The very visible pressure from a broad spectrum of public lands users and advocates helped pull this off the table.
I have not necessarily observed the same level of urgency surrounding the Roadless Area Conservation Rule rescission. The announced rescission of the Roadless Area Conservation Rule has, in my estimation, much more serious and far-reaching consequences than the shelved public land selloff. Rescission of the rule does not require Congressional action. Executive agencies such as the U.S. Department of Agriculture generally have authority to modify or rescind rules as long as they follow the procedures of the Administrative Procedure Act (APA). Impacts could be far greater in terms of sensitive habitat, recreation, and sheer acreage.
Of course, these are also lands that comprise a great diversity of mixed-use recreational activities for those seeking relatively undisturbed and pristine settings, including permitted trail racing events. Additionally, these are wilderness study area-available lands that do not have the protections provided by designation under the Wilderness Act.
I created an interactive map in ArcGIS Pro showing a quasi-random sampling of trail running races that could be impacted by repeal of the Roadless Area Conservation Rule. This is overlaid on the USFS Roadless Area Inventory GIS dataset. The map is publicly shared. Here is the link:
Roadless Rule: Potential Trail Race Impacts
Almost 40% of the mountain races I looked at in regions with a high volume of Roadless Area Conservation Areas had portions of their courses within or immediately adjacent to these currently protected areas, including some very iconic events. While the preponderance of lands inventoried under Roadless Area Conservation Rule lie in the west, you can see that there are potential impacts to events across the country, especially along the Appalachian ranges
Primary arguments frequently presented by proponents of the repeal are it would help with wildfire mitigation & wildlife while helping with rural economies. Let’s take a brief look at counterpoints:
Concerning wildfire mitigation and habitat, we all know that the overwhelming majority of wildfires are human-caused. This anthropogenic effect is increased, not decreased, by significantly changing the scope of human activity within these lands. Furthermore, existing provisions already allow for fire resilience and habitat improvement, including forest thinning and prescribed burning. I think we know in our hearts and spirits the underlying intent of eliminating the Roadless Area Conservation Rule.
As it relates to rural economies, it is a myopic view that resource extraction is the only means of economic viability in rural & mountain areas. Recreation is not only viable, also just plain more sustainable in the long term.
According to the Bureau of Economic Analysis of the U.S. Department of Commerce (https://www.bea.gov/data/special-topics/outdoor-recreation), in 2023 the outdoor recreation sector generated approximately $1.2 trillion in economic output. This represents approximately 2.3% of this country's GDP. This also supported approximately 5 million jobs, which was 3.1% of U.S. employment.
Lastly, adding roads is fraught in its own right. Anyone who has spent more than 10 minutes on USFS lands with existing road networks knows how severely the maintenance/repair of existing facilities is already backlogged.
Here are instructions for viewing the map
The link again is here:
Roadless Rule: Potential Trail Race Impacts
Go to the ‘Layers’ button when you open the map. Click the icon circled in red.
Go to the 'Sample Races' layer. Click the arrow circled in red on the left to view the 30 example race courses in alphabetical order.
Click on the three dots on the left of the race name circled in red. Click the top item ‘Zoom to layer’ to view each race up close.
If you have issues viewing the map viewer or want to see other races added to this map, please let me know. Questions, comments, corrections, and/or suggestions are welcome too. You are absolutely welcome and encouraged to share the map.
The initial public comment period runs from August 29-September 19:
https://www.fs.usda.gov/managing-land/planning/roadless?utm
There is currently proposed bipartisan legislation to codify the Roadless Rule through Congress:
Most importantly, we need to be prepared during upcoming public comment periods to make our voices heard frequently, collectively, and loudly!!!!
Sincerely,
~Sean Harrasser (he/him)
Race Director, Wonderland Running