FS-2025-0001-273644

Dear Mr. Schultz, As someone who spends a great deal of time hiking, backpacking, and exploring our national forests, the places I value most are often the ones farthest from roads. There is something increasingly rare about being able to walk for miles through uninterrupted forest, hearing only wind, water, and wildlife rather than vehicle traffic. These roadless areas provide a kind of solitude, naturalness, and sense of discovery that cannot be recreated once roads are built. I am deeply concerned that rescinding the Roadless Rule would put these experiences at risk. Once roads are constructed, the character of these landscapes changes permanently, and opportunities to experience truly remote, undeveloped public lands become increasingly scarce. For many of us, protecting roadless areas is not an abstract policy preference. It is about preserving the places where we hike, camp, reflect, and connect with nature in its most intact form. One occasion in particular illustrates what that relationship means in practice. During my hikes of New Hampshire's 4,000-foot mountains, the most memorable moments were the long stretches of solitude. Being able to disconnect from the constant presence of roads, noise, and development, and instead experience a landscape shaped primarily by natural processes, was genuinely invigorating and restorative. That experience is becoming rare, and once roads are built into these areas, they cannot be recovered. Protecting roadless forests means preserving the opportunity for future generations to experience that same sense of solitude, wildness, and connection to nature that has meant so much to me. The standing connection and the specific experience above together illustrate what the Rule has made possible over twenty-five years of operation. Regarding the Pemigewasset Ext in the White Mountain National Forest, New Hampshire: Moderate or 11-30% pop. decline severity and Restricted - small scope characterize the impact of 5.3.3 - Unintentional effects: subsistence/small scale (species being assessed is not the target) [harvest] on Monarch (Danaus plexippus, G4) in the Pemigewasset Ext Inventoried Roadless Area, White Mountain National Forest — losses that the current Roadless Rule helps constrain. For Monarch in Pemigewasset Ext, the connection between road construction and 5.3.3 - Unintentional effects: subsistence/small scale (species being assessed is not the target) [harvest] is direct: roads deliver the disturbance vectors — sediment, access, fragmentation — that NatureServe identifies as driving Moderate or 11-30% pop. decline severity impacts on this population. Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Monarch (Danaus plexippus) in the Pemigewasset Ext Inventoried Roadless Area, including the documented threat of 5.3.3 - Unintentional effects: subsistence/small scale (species being assessed is not the target) [harvest]. "Frequent human disturbance caused by mining development and road construction in the Kalamaili Mountain Ungulate Nature Reserve (KNR) — inhabited by >80% of Chinese khulan (Equus hemionus) — has interfered with or completely blocked their movement and access to parts of the reserve. The habitat of khulan in KNR went from a good natural habitat in 2005 to deterioration due to mining development in 2011. In 2019, road construction likely hindered its recovery to pre-mining levels. Our study revealed the significant impacts that mining development and road construction have had on the distribution of core habitats, ecological corridors, and movement of khulan." — Biological Conservation (ScienceDirect), 2022 “Road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” The proposed rescission should be withdrawn, and the Rule should continue as currently promulgated. In earnest, Todd Meigs