RE: Docket FS-2025-0001, RIN 0596-AD66, Roadless Area Conservation proposed rule
Introduction
My family has held a recreation residence permit on a national forest since the 1930s. Wildlife has been one of the great gifts of our time there: elk and deer, birds, trout in the creek, and the occasional sign that something larger passed through at night. Those animals are there because large, unbroken country still surrounds us. I am commenting on how rescinding 36 CFR part 294, subpart B would affect fish and wildlife habitat.
What I am addressing
My comment concerns the environmental analysis of habitat fragmentation and effects on threatened, endangered, and sensitive species.
Analysis
Roads break up habitat. Wildlife research has documented for decades that roads increase disturbance and mortality, spread invasive weeds, raise poaching and harassment, and create barriers for animals moving between seasonal ranges. Elk, bears, and many other species avoid roaded areas. Fish suffer when road sediment fills the gravel they need for spawning.
The value of a roadless area for wildlife is not only the acres inside it but the connections between them. Roadless areas often serve as refuges during drought and fire and as sources from which animals recolonize nearby land. As conditions change, wildlife will need large, connected landscapes even more.
The 2001 rule covered 58.5 million acres of inventoried roadless areas (66 Fed. Reg. 3244, Jan. 12, 2001), and the current proposal would remove protection from more than 44 million acres. A change of that size affects habitat for many listed and sensitive species. The public needs a full, area-by-area accounting of those effects. A general statement that future projects will be reviewed individually is not enough, because cumulative fragmentation happens one project at a time and is rarely assessed as a whole.
Recommendations
1. Retain 36 CFR part 294, subpart B and select the no-action alternative.
2. Complete and publish formal consultation under the Endangered Species Act on the rescission as a whole, not only on later site-specific projects.
3. Include in the final analysis a cumulative habitat fragmentation assessment, including effects on wildlife movement corridors and native fish strongholds.
4. Identify the roadless areas that function as refuges for listed species and explain how they would be protected if the rule is removed.
Conclusion
Once a road divides habitat, that habitat does not recover on any timeline that matters to the animals living there. Please keep the 2001 Roadless Rule.