FS-2025-0001-602213

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fifty years of living near the Eldorado National Forest, and a career spent working for the Forest Service itself, put me in a particular position to say this plainly: rescinding the 2001 Roadless Area Conservation Rule would be a mistake the land cannot recover from. We know what we've got and we love it and will fight tooth and nail to protect it. I have fished creeks on the Eldorado, Tahoe, Stanislaus and Inyo National Forests for trout my whole adult life. I have seen the logging slash left behind after timber operations, clogging streams with debris, slowing their courses, and triggering runoff from denuded slopes. Seldom have logging outfits been required to really clean up the mess they have made, from the quickly cut-in roads to the limbs, stumps and general debris left behind. The agency's own record confirms what I have watched with my own eyes: roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and that sedimentation can cause egg and juvenile mortality and reduced suitable habitat for trout. I want the agency to explain, on the record, how it reconciles its own sedimentation data with a proposal that invites exactly that activity into watersheds that are presently functioning. The negative impact to our water supply could be devastating, and the great care the agency has historically taken through its NEPA processes to protect streams, creeks, rivers and lakes is precisely what this rescission would dismantle. The Caples Creek and Silver Fork areas are where I do much of my birding, watching for songbirds, woodpeckers, owls and raptors from spring through summer and into fall. The birds there have water, cover and food because the habitat is intact. The DEIS cites the finding 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. Constructing roads and allowing timber harvests or mining operations would destroy critical habitat, and I and many others would no longer be able to enjoy birding on our National Forests if these protections are removed. The agency must explain what analysis it has conducted of cumulative bird habitat loss across the affected roadless areas in California, which total 4,389,760 acres across 381 inventoried areas, and what mitigation it proposes. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is stated and then left hanging, with no projection applied to the 40.1 million acres of potentially affected environment. I ask that the agency apply that cited fragmentation range to the full affected acreage and publish the result before any final decision. I spent years working in fire support, in contract management of fire and aviation resources during suppression and post-fire rehabilitation, and I have been part of advisory input to fire management on land management decisions during and after fires. I have seen the agency open old jeep trails and abandoned logging roads when fire access required it, using the equipment already available for that purpose. There are so many roads already on the maps that are not maintained, building new ones makes no sense. We do not need new roads. Finally, 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 anticipates the harm and proposes no mitigation for it. It must disclose, species by species, how those likely adverse effects will be avoided or mitigated, and ESA consultation must be completed and published before any final rule is issued. The agency's motto is the greatest good for the greatest number. That means these lands are managed for everyone, including those of us who fish for trout in the Eldorado's creeks, watch woodpeckers along Caples Creek, and photograph the wildness of places that are invaluable precisely because they remain undeveloped. The Caples Creek roadless area, all 17,854 acres of it, and the countless other roadless areas like it, are our heritage. We intend to pass them along intact. Sincerely, Kathryn Griffin Sacramento, California Kathryn Griffin See attached file(s)