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Dear Secretary Rollins and Chief Schultz,
As a kayaker and outdoor enthusiast, I am entering these comments to note that the proposed rescission of the 2001 Roadless Area Conservation Rule represents a fundamental reorientation of national forest management priorities — away from the long-horizon, public-value-centered framework the Rule embodies, and toward a project-by-project discretion that history suggests will not adequately protect roadless character.
South Fork Mills River and the surrounding areas are places that I have visited with my family for generations. I hike and swim in this area frequently with my daughter and grandson.
If this rule is rescinded I lose places that I go to for solace and to reconnect to nature and my family. Additionally, I am concerned about waterways that would be adversely affected as well as loss of precious habitat for bats, hellbenders, and many other species.
Regarding the South Mills River in the Pisgah National Forest, North Carolina:
Bat Habitat Connectivity Across Elevational Gradients — This area's elevation range—from 2,600 feet at Turkeypen Gap to 4,600 feet at Laurel Mountain—creates a continuous forest corridor essential for four federally endangered bat species: the Gray Bat, Northern Long-eared Bat, and Tricolored Bat (proposed endangered), which forage and roost across multiple elevations throughout the year. The unfragmented canopy and intact forest structure provide the interior habitat these species require; roads fragment this corridor into isolated patches, forcing bats to cross open areas where they are vulnerable to predation and collision. The roadless condition preserves the connectivity that allows these species to move between seasonal habitats without exposure.
Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 9.3 - Agricultural & forestry effluents on Monarch.
The DEIS must provide site-specific analysis of 9.3 - Agricultural & forestry effluents impacts to Monarch (Danaus plexippus) in the South Mills River IRA — not a programmatic discussion of roadless areas generally but a particularized assessment of this species in this place.
"Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term." — Conservation Biology (Wiley), 2013