Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
I love the plants and fungi that grow on or near the forest floor, the animals and birds--small and large--that feed on them and scatter their seeds and spores, the raptors and wild cats and bears that can sometimes be glimpsed, and the cycle of life that flourishes in intact, undamaged forests and other landscapes.
Our public lands are havens for these beautiful life forms that have evolved together over millions of years. The forests they hold are clean-water sources that millions of people rely on. These forests, when populated with living trees, also remove carbon dioxide from the atmosphere, replacing it with oxygen that we need to live. Forest ecosystems are able to do these things without interruption when they are protected from roads that fragment them and damage the soil that their roots hold. Our duty, as responsible citizens and as a nation appreciative of the natural wonders we have inherited, is to protect these irreplaceable places so that both we and our future generations can enjoy them and the benefits they provide--clean air, clean water, recreation areas and more. It is detrimental to our country as a whole when our public lands are denuded of their forests; when roads break up the ecosystems their forests shelter and nurture; when environmental instability, polluted water and destructive landslides result from roadbed damage to and drying out of the soil and local climate.
Using our public lands and forests as merely one-time sources of minerals and timber destroys their ability to help keep our water and air free of clogging sedimentary residue, polluting air-borne particles and smoke. American citizens depend on clean water from pristine sources and waterways; cutting roadways through our public-land forests and cutting down the trees that remain severely damage the water nearly ten percent of Americans rely on.
The Forest Service is chartered with protecting and wisely using our publicly-owned forests. Many thousands of comments have been submitted
regarding your proposed rule change to allow roads to be cut through previously protected forests; 99% of the commenters oppose this rule change. The voice of the American people is the voice the Forest Service is required by law and charter to heed--not just the wishes and demands of extractive and other industries and corporations. It is a betrayal of all of us, of our children and grandchildren, and of generations beyond to ignore the public's clear disapproval of the proposed rule change. You have given neither sufficient time nor any public meetings to allow the public to weigh in on this critical issue. You and the administration do not own these lands that are in danger from the rule change--the American people do. To ignore their preference for protecting our public forests--to end the Roadless Rule without public assent--is to steal these lands from the American people. Please do not change or dismantle the protections of the Roadless Rule for our public forests and lands.
I am commenting again on the proposed dismantling of the protections for our public forests embodied in the Roadless Rule because I am a dedicated US citizen with a great sense of the value and irreplaceable environmental bounty that our forests shelter and support. It is important for all of our voices to be heard. I am imploring you to give the American people more time to weigh in on this proposed rule change, and to honor their right to public discussion of this and all other rule changes. The rules have in the past been put in place after serious environmental and scientific study and consideration of alternative management policies. You have a solemn duty to uphold the people's right to be a respected part of the decision-making process.
I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule.
I raise the following issues for the record and ask that the agency respond to each of them:
Issue 1: Fragmentation is quantified and not applied
I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent.
The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment.
I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.
Sincerely,
Ann McStay
Pittsburgh, PA 15243