“disclose, species by species, how the likely adverse effects... will be avoided”
The comment
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Hiking and looking for birds in these landscapes has shaped what I understand our public lands to be. I hike and camp for my happiness and to enjoy the beauty of our country. I travel frequently to locations this proposal will impact, exploring for the local birds and wildlife. I have visited many of these locations and cannot imagine our country without these incredible habitats.
The agency's own environmental review documents harm to birds and then sets that documentation aside. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. These are not contested findings introduced by opponents; they come from the agency's own review. Yet the proposal moves forward without projecting what those documented effects mean for the bird communities I travel to find. I ask the agency to explain, in its final environmental review, how it reconciles those cited findings with a decision that expands road construction across these habitats.
The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is wide, and the science behind it is the agency's own cited source. What the document never does is carry that number forward. The 40.1 million acres of inventoried roadless areas potentially affected by rescission sit in the analysis without any projection of what a 13 to 75 percent reduction in biodiversity would mean across that area. The agency should apply the fragmentation range it cited to the 40.1 million acres of potentially affected environment and publish that analysis before a final rule issues.
The same pattern appears with big game. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed, and that elk avoid roads and select unroaded habitat. Those findings are in the record. A population-level projection from them is not. The birds and wildlife I go looking for do not exist separately from the broader ecological communities these areas support. I ask that the agency project the effects on big game populations and hunter opportunity under each alternative it is considering.
Carbon storage receives the same treatment. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The DEIS then concludes these lands will continue to sequester and store carbon, without analyzing what timber harvest and road construction would do to that figure under any of the alternatives. That conclusion is not supported by the analysis provided. The agency must quantify the change in carbon storage and sequestration under each alternative.
The most serious gap in the record concerns protected species. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. The agency wrote those words. It anticipates the harm. The proposal identifies mitigation for none of it. The birds and wildlife I visit these areas to find are part of that 327. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule.
I oppose rescission of the 2001 Roadless Area Conservation Rule. The habitats these areas provide are not replaceable. The agency's own documents establish the harm; what is missing is any serious accounting for it.