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Dear Chief: My name is Kevin, I'm a composer, and I stand for preserving our pristine backcountry. I oppose rescinding the roadless rule. I have many memories from peaceful walks, time with friends, and creative inspiration provided by Arroyo Seco. A favorite story of mine is hiking the Arroyo Seco Primitive Trail and camping for a few nights with some friends I was able to share backpacking with friends and family at Arroyo Seco, for many being the first time they tried it. Bulldozed road beds would disrupt or end that experience. Regarding the Arroyo Seco in the Angeles National Forest, California: Most listed species are declining, not recovering. A review of all ESA-listed species found that 52 percent had declining status trends, compared with 8 percent improving. The authors concluded that threats are persistent and pervasive, funding has been insufficient, and at least ten times more species probably qualify for listing than have been listed (Evans et al. 2016). — Evans et al., 2016 (https://doi.org/10.1002/bes2.1308) We need to stop infringing upon the natural world for our own means, even with the guise of wildfire protection, which the data shows isn't accurate. We need to support the environment first, as it's our remarkable home that provides endlessly. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “Early quantitative analysis showing roadless areas substantially complement biodiversity conservation, with many roadless areas overlapping areas important for imperiled species. — DeVelice & Martin, 2001 (https://doi.org/10.1890/1051-0761(2001)011[1008:ATETWR]2.0.CO;2)” Quantified Caribou Sensitivity in the Biological Assessment (1% Roads → 42% Decline) Never Carried Into the DEIS Effects Analysis The Draft Biological Assessment for USFWS species states at page 66: "The research predicts that for every 1% increase in roads in the matrix habitat, there will be a 42% decline in southern mountain caribou abundance (Lochhead et al. 2022)." This is the agency's own screening document quantifying an extraordinary sensitivity of a listed species to precisely the activity the rescission would newly allow — yet the DEIS's effects analysis nowhere presents, applies, or even acknowledges this ratio in evaluating alternatives. NEPA requires that an EIS contain "a reasonably thorough discussion of the significant aspects of the probable environmental consequences," and general statements do not substitute for the quantified analysis the agency itself possesses. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1213 (9th Cir. 1998); Klamath-Siskiyou Wildlands Ctr. v. Bureau of Land Mgmt., 387 F.3d 989 (9th Cir. 2004). I request that the DEIS incorporate the Biological Assessment's quantified road-density findings for southern mountain caribou into its species effects analysis and disclose the projected consequences of foreseeable road construction in affected matrix habitat. The Department's consideration of this comment and its underlying position — that the Rule should be retained — is appreciated. Best regards, CommentID: RLC-20260909-RGD2QJ