To the U.S. Forest Service:
These areas have been where I have found peace in a world that never feels still.
The most beautiful peaceful grounding times in my life have taken place in these areas. I come from generations who have enjoyed, worked, vacationed, and more in these areas and believe wholeheartedly that rescinding the Rule will do irreparable damage.
I'm not a climate scientist. I just read what the climate scientists publish. The 2001 Rule does measurable carbon work. Keep it.
Regarding the Minister Valley in the Allegheny National Forest, Pennsylvania:
Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate.
Rescinding the Roadless Rule would open the Minister Valley, Allegheny National Forest 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.
“Focal species, which define the habitat identity, proved to be very helpful in discriminating between habitat types and zones, as they actually exhibited higher abundances or frequencies within a habitat type, relative to other habitats. The detailed analysis of focal species abundance and turnover can be used as a short-term alert of plant community disruption, before the effects of disturbance become fully evident. Plant communities or vegetation types represent a key approach for biodiversity conservation above the species level and have been increasingly used as crucial units for inventory, planning and monitoring as they are good indicators of overall biodiversity. — AoB Plants / PMC, 2016 (https://doi.org/10.1093/aobpla/plw040)”
“Skid trails extended road edge effects on plant biodiversity up to 60 m into forest stands, serving as conduits for non-forest species and removing interior forest species. The addition of lime and clay substrates from road construction modified pH, nutrient content, soil moisture and bulk density, promoting roadside establishment of exotic and nitrophilous species. Limestone gravel damaged acidophilic species on roads and into stands, and the road effect was more damaging to forest species and less-competitive species on skid trails. — ScienceDirect / Biological Conservation, 2013 (https://doi.org/10.1016/j.biocon.2012.10.008)”
“Long-term drying associated with drainage and road construction resulted in a two to fourfold increase in total biomass in three of four fen sites, but this came at the expense of ground-layer mosses and understory species. Drainage induced a shift toward a drier peatland regime, favoring increased canopy and vascular plant density while decreasing moss cover and productivity. Within ground-layer communities, drainage favored dry-adapted hummock moss and lichen species over wet-adapted but desiccation-prone species typical of low-lying lawns and hollows. — Springer Nature / Wetlands Ecology and Management, 2015 (https://doi.org/10.1007/s11273-015-9423-5)”
“Road construction permanently occupied 73% of the total construction areas. Soil structure is fully destroyed and land productivity is lost in permanently occupied areas. The soil organic matter of pre-construction road was 3.57 times higher than post-construction, and soil bulk density in post-construction was greater than pre-construction by 10.3%. Topsoil formation proceeds very slowly — 1 cm of topsoil is formed under natural conditions every 300–400 years, yet it can be eroded in only one year on construction sites. — International Journal of Environmental Research and Public Health / PMC, 2022 (https://doi.org/10.3390/ijerph192316046)”
Draft EIS Discloses No Irreversible or Irretrievable Commitment of Resources for Any Alternative
Please please continue to uphold the Rule, continue to protect these lands, continue to allow future generations to experience a version of the world that is preserved naturally.
Thank you.