FS-2025-0001-474069

Dear Brooke L. Rollins, As an outdoor enthusiast, I am filing these comments to note that the 2001 Roadless Area Conservation Rule is among the most extensively supported rules in the administrative history of the Forest Service, and the Department's obligation to engage that record — rather than override it — is a matter of basic APA fidelity. I grew up exploring this area with a backpack. The first time I pitched my own tent was right here. I don’t want this area to be used by vehicles. Regarding the Oat Mtn. in the Sequoia National Forest, California: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Most remaining forest is already near an edge. Globally, 70 percent of remaining forest is within 1 kilometer of an edge, where the buffering, cooling, and habitat-providing functions of intact interior forest are compromised. Fragmentation reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs key ecosystem functions (Haddad et al. 2015). — Haddad et al., 2015 (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Oat Mtn., Sequoia National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Keep the Roadless Rule! The DEIS's Own Invasive-Plant Section at Pages 114-116 Measures Existing Infestation, Declares the Action Alternatives Indistinguishable on an Unsupported Assumption, and Never Carries the Assessment's 81-of-134 Listed-Plant Figure The DEIS analyzes non-native invasive plant species at pp. 114-116 and identifies roads as a vector at p. 150: "Road construction, routine roadside mowing, and the use of roads have been shown to facilitate the spread of non-native invasive plant species." This comment is directed at three specific defects inside that analysis, not at its absence. 1. The extent figure does not measure the risk the section is about, and the DEIS concedes as much on the same page. At p. 114 the DEIS reports that mapped invasive plants "cover approximately 309,000 acres (270,787 for alternative 3), less than 1 percent of the potentially affected environment area," derived from existing mapped occurrences in the Threatened, Endangered, and Sensitive Plant-Invasive Species database (n.44). Two sentences later it states: "It is likely that there are populations that have been undetected and have not been mapped." A magnitude framing built on an inventory the agency describes as incomplete cannot carry the weight the "less than 1 percent" phrasing gives it. Separately and more fundamentally, the figure measures current infestation, not introduction risk in areas that are currently uninfested. The North Carolina Wildlife Resources Commission put the distinction to the agency directly: "IRAs often have less non-native invasive plants due to the lack of roads and other pathways generally associated with their spread and distribution" (DEIS Vol. III, p. 210). On that record the low current percentage identifies the resource at risk; it does not bound the effect. The FEIS should correct the disclosure to state what the figure measures, what it does not, and what the acknowledged mapping gap does to it. 2. The finding that the action alternatives do not meaningfully differ is unsupported and is contradicted by the section's own numbers. At p. 116 the DEIS concludes that "the alternatives are not expected to differ significantly in regard to their contributions to the introduction and spread of invasive species." The stated basis is that "The areas of likely operability for these activities are not expected to be significantly different under alternatives 2 and 3." No support is offered for that assumption. The same section states that "Alternative 3 has fewer acres in the potentially affected area than alternative 2" (p. 115) and reports different mapped acreages for the two - 309,000 against 270,787. A conclusion that the alternatives are indistinguishable for this resource, resting on an operability premise the analysis never demonstrates, removes invasive species from the comparison the environmental impact statement exists to make. The FEIS should either supply the operability comparison the assumption requires or withdraw the finding. 3. The listed-plant exposure the agency has already quantified appears nowhere in the DEIS. The Draft Biological Assessment for USFWS species states at p. 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At p. 344 it quantifies the stake: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive species sincerely, Heidi Sager