Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The Angeles National Forest was my playground growing up. Hiking through it taught me to love and respect the natural world, and that immersion gave me something I still use today: I can identify the majority of the flora and fauna in my region, native, introduced, and invasive alike. I use that knowledge to teach friends and loved ones more about the environment around us. By knowing their names, we become more connected to the flora and fauna around us and the world as a whole. That connection is what I am fighting to protect when I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001.
In the roadless areas near me, finding rarer or less common bird species becomes more likely, and those sightings support local and national initiatives to track wildlife populations. The agency's own evidence explains why. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. That is not a contested claim from outside critics. It is the agency's own cited science, and then the agency proposes to open these areas anyway. I want my children and their children to hear more birdsong than I did, not less. I ask that the agency explain, directly and specifically, how it reconciles the bird-abundance findings it cites with the direction this rule takes.
The agency cites fragmentation science and then does nothing with it. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is stated and then abandoned. No projection follows for the 40.1 million acres of potentially affected environment. A range that wide matters enormously at that scale, and the public deserves to know which end of it is more likely under each alternative. I ask that the agency apply the cited fragmentation range to the 40.1 million acres before any final decision is made.
I also photograph what most people walk right past: the tiniest flowers along the Arroyo Seco and through the Angeles National Forest. Showcasing the little guys matters. Biodiversity is not only the charismatic species. The same DEIS that acknowledges fragmentation harms also tells us: "The agency's 428-page draft biological assessment closes: 'Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.' The DEIS tallies the determinations: 'may affect, likely to adversely affect' for 327 ESA-listed species and 71 designated critical habitats." The agency anticipates the harm. It names 327 species. It identifies no mitigation for any of them. The public is owed a species-by-species account of how those likely adverse effects will be avoided, and ESA consultation must be completed and published before any final rule is issued.
On the economics of roading: our money and taxpayer dollars are better spent supporting the local communities of flora and fauna, ensuring they have the right conditions to grow, thrive, and expand. The agency is already billions behind on maintaining existing roads. Opening roadless country to new construction compounds a maintenance burden the agency cannot currently meet. That spending choice deserves a direct answer on this record.
Finally, the climate argument the agency raises and then drops. "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 store carbon, yet analyzes no scenario involving the harvest and roading this rescission would enable. What happens to that carbon if these areas are opened? The agency must quantify the change in storage and sequestration under each alternative before it acts.
Public land should be managed for communal use and appreciation, to ensure that future generations have the same, if not better, opportunities I had to learn to love and connect with nature. The rule being rescinded made that possible. The evidence the agency itself assembled argues against rescinding it. I urge the agency to withdraw this proposal.
Sincerely,
Elena Mindry-King
Altadena, CA