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I oppose USDA’s proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule under Alternatives 2 or 3 and strongly support Alternative 1, the No Action Alternative.
Rescission threatens millions of acres of intact National Forest habitat, watersheds and wildlife corridors. California contains approximately 4.39 million Inventoried Roadless acres, Wyoming approximately 3.24 million, and Montana approximately 6.40 million.
My attached comments identify several specific analytical gaps that I ask USDA and the Forest Service to address.
California: Gray wolves are naturally recolonizing their ancestral range in northern California. CDFW reports eleven confirmed packs and recognizes that roads and human activity can negatively affect wolves. Has the Forest Service analyzed, at the individual National Forest and Inventoried Roadless Area level, how Alternatives 2 and 3 would affect wolf habitat, dispersal and mortality risk in the Modoc, Lassen, Plumas, Shasta-Trinity, Klamath, Six Rivers and Mendocino National Forest landscapes? How does the DEIS account for dispersing wolves outside currently mapped pack territories?
Greater Yellowstone: Wyoming contains approximately 3.24 million roadless acres, including approximately 1.417 million acres in Bridger-Teton National Forest. Bridger-Teton and Caribou-Targhee directly adjoin Grand Teton National Park and contain habitat and corridors used by Greater Yellowstone wildlife.
Has USDA quantified how many currently roadless acres of secure or potentially secure grizzly habitat in Bridger-Teton and Caribou-Targhee could become available for roads under Alternatives 2 and 3, and the resulting effects on secure habitat and motorized-route density?
Most importantly, has USDA specifically analyzed female grizzly dispersal and establishment of reproductive home ranges? Future grizzly recovery depends not merely upon wide-ranging males appearing outside established recovery areas, but upon females successfully dispersing, surviving, establishing home ranges and reproducing. Roadless habitat in Bridger-Teton and Caribou-Targhee adjoining Grand Teton, elsewhere within the Greater Yellowstone Ecosystem, and beyond today’s designated recovery boundaries may be essential to future generations of grizzlies using ancestral corridors and recolonizing ancestral habitat.
The Final EIS should analyze where grizzlies may need to disperse in the future—not simply where bears occur today—and determine whether new roads and motorized access would impair those corridors or increase human-caused mortality.
Additional roads also mean habitat fragmentation, erosion and sedimentation, invasive-species pathways, human-caused wildfire ignition opportunities and additional taxpayer liabilities when the Forest Service already faces billions of dollars in deferred road and bridge maintenance.
For these reasons, I oppose Alternatives 2 and 3 and support Alternative 1. Please retain the 2001 Roadless Area Conservation Rule in full.
My complete substantive comments, specific questions, supporting information and sources are contained in the attached PDF and should be incorporated into the administrative record.