FS-2025-0001-557341

Dear Secretary: From the vantage of a wildlife observer and native plant advocate who has walked the boundary between roaded and roadless units of the same forest, I can attest that the difference is detectable, and on that basis I oppose the proposed rescission. Quiet, untouched places in nature like the Devil's Den are the sole remaining places humans can go to calm nervous systems undoing the cortisol damage created by man made work environments, affordability stressors and unchecked marketing our current society bestows on its' inhabitants. Paved roads immediately reduce permeable surface area and increase the speed at which water travels, impacting native flora and fauna and access to clean, fresh water. Invest in public railways or public transportation instead. Regarding the Devil's Den 09083 in the Green Mountain and Finger Lakes National Forests, Vermont: Roads, disturbance, and altered ecosystems create invasion pathways that let non-native plants, pathogens, and animals displace native biota. Non-native species concentrate near roads. A 2025 study tracking plant communities at varying distances from roads found non-native species in 94 percent of roadside plots, 27 percent of adjacent plots, and only 15 percent of plots furthest from the road. Roads also altered the underlying soil conditions in ways that favored non-native plants over native species (Clavel et al. 2025). — Clavel et al., 2025 (https://doi.org/10.1111/oik.11075) Rescinding the Roadless Rule would open the Devil's Den 09083, Green Mountain and Finger Lakes National Forests 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. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” Please see attached issues with invasive species not addressed by the literature of the rule repeal. Rescission of the Roadless Area Conservation Rule is opposed; its retention is respectfully requested. Best, C.N.