“Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I look for barred owls in my local…”

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I look for barred owls in my local neighborhoods and keep my eye on the sky when traveling around the state, both north and south, through the Mt. Baker-Snoqualmie National Forest region. My city and neighboring cities' water supplies depend on roadless areas as water sources, and knowing that my water quality is at risk of having sediment increases and overall quality losses is frightening. I should not have to worry about the quality of my water in my home city. Public land should be managed for ensuring that the environment we live in remains healthy. If the area around us is choked with roads and timber industry, we will suffocated along with our forests. The land itself has a right to proper management. My children, grandchildren, great-grandchildren and so on all deserve to inherit spaces that connect us to our origins as a species and as a society. Getting out in nature is beneficial for our well-being and health, and that is priceless compared to the short-term gain of having some more roads. It does not make sense to build roads into forested areas that do not already have them when we cannot manage to maintain the roads we already have. Prices for maintaining roads will only increase as we develop new ones, compounding the deficit in budget. Roads built haphazardly due to budget restrictions are worse than no roads. A forest can maintain itself, but roads will not. The country I am writing about includes the Mt. Baker-Snoqualmie National Forest. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Fragmentation is quantified and not applied I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 2: Elk survival, in the agency's own citation I watch wildlife, and the animals I go looking for need country roads have not reached. The agency's own citation makes that point better than I can. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity. Issue 3: Carbon is stated and dropped The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. 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. The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Aedan McCall Seattle, WA