Dear Chief Tom Schultz:
I am Abbreail, a novice birder, who has witnessed the compromised well being of birds and other invaluable species as a result of roads. I write as a wildlife observer to oppose the proposed rescission, and to ask the Department to weigh the rule's track record against what its sponsors are claiming about its costs. More experienced birders and ornithologist have inventoried roadless areas for twenty years and have shown that the rule is doing what it was supposed to do.
When roads come birds die. Animals die. The chickadees, hawks, etc. now have to compete with yet another threat to their lives in various forms. This will undoubtably lead to a decline in various populations and cost these areas in so many ways.
Regarding the Elk Creek in the Mendocino National Forest, California:
4.2 - Utility & service lines drives Slight or 1-10% pop. decline severity impacts across Pervasive (71-100%) scope for California Condor (Gymnogyps californianus, G1, E, XN) in the Elk Creek IRA, Mendocino National Forest.
The intact, unroaded condition of Elk Creek is the functional mechanism that currently limits 4.2 - Utility & service lines to its assessed severity and scope. Road construction removes this constraint and permits escalation.
The DEIS analysis of Elk Creek must incorporate NatureServe's standardized threat assessment data for California Condor (Gymnogyps californianus, G1), including the IUCN-CMP classification (4.2), Slight or 1-10% pop. decline severity rating, and Pervasive (71-100%) scope determination.
"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
Let the roadless areas remain what they are.
All the best,
CommentID: RLC-20261005-1X2I67