2001 Roadless Rule Revision

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001

I am writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule.

I recently was lucky enough to spend some time in Tongass National Forest. We spent 2 hours in total and I feel like I could have spent days. The towering old growth trees were magical. Not a road in site. I felt at peace here.

I grew up in Superior Wisconsin and my family would take trips to BWCA and Superior National Forest in the summer. The only transportation was boats, usually just canoes. Again, no roads. It is magical. Losing this would mean losing a place where kids learn about the power of nature.

My family used to spend some summers in Big Sky, near the Custer Gallatin NF. We would venture off and hike the trails with our bear spray. Words don't do it justice how amazing this land is without any roads. It is just you, nature, and the animals.

My comment concerns the following inventoried roadless areas specifically:

- Tongass National Forest (9,339,575 acres), Tongass National Forest, Alaska
- Superior National Forest (62,000 acres), Superior National Forest, Minnesota
- Custer Gallatin NF (848,000 acres), Custer Gallatin NF, Montana

Together these areas hold 10,249,575 acres of inventoried roadless land.

I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow.

I raise the following issues for the record and ask that the agency respond to each of them:

Issue 1: Wildfire and fuels management

The proposal justifies rescission in part on wildfire and fuels management grounds. The agency’s own record states:

"Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." (Roadless Area Conservation FEIS Vol. 1 (Nov. 2000), fire-occurrence discussion, printed p. 3-115)

"The net result is that there is a substantially increased level of fire occurrence outside inventoried roadless areas." (Roadless Area Conservation FEIS Vol. 1 (Nov. 2000), text introducing Table 3-19 (human-caused fire occurrence 1986-1996), printed pp. 3-104 to 3-105)

I ask that the agency explain in the DEIS why it now departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it disclose and analyze the increased risk of human-caused ignition that its own 2000 FEIS associated with road construction.

Issue 2: Timber economics and jobs

The proposal justifies rescission in part on timber economics and employment grounds. The record before the agency states:

"the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." (66 FR 3244, national social and economic effects discussion (citing FEIS Vol. 1, 3-326 to 3-350))

"there presently exists a backlog of about $8.4 billion in deferred maintenance and reconstruction on the more than 386,000 miles of roads in the Forest Transportation System." (66 FR 3244, "Fiscal Considerations", printed pp. 3245-3246)

I ask that the agency reconcile the proposal with its own prior economic findings, including the scale of the timber production actually affected and the deferred maintenance backlog on the existing road system, and that it disclose the fiscal consequences of expanding that system.

I ask that the agency address the Tenth Circuit’s holding that the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness, and that it explain in the DEIS the basis for any contrary position.

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 for the areas named above. 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,
Will Rogers
Elmhurst, IL 60126

RIN 0596-AD66 | Docket FS-2025-0001

Born in Sheridan, Wyoming to a ranching family, raised in Colorado, property owner in Skagit County, Washington. Hunter, veteran, member of Backcountry Hunters & Anglers, Ducks Unlimited, and Washington Waterfowl Association. I oppose the rescission.

I am not against roads or active management. My objection is that the preamble's own findings do not support the action.

1. THE PREAMBLE CONCEDES WHAT DEFEATS THE PURPOSE. At 91 FR 53829 the Department states opportunities would be "modest and localized" and that gains are "limited by road costs, maintenance funding gaps, and the $6.9 billion deferred maintenance backlog." I agree. If the constraint is budgetary, removing the regulation cannot produce the benefit. Request: show with funding and workforce analysis how rescission yields one additional treated acre.

2. THE AUTHORITY ALREADY EXISTS. 36 CFR 294.12(b) permits roads to protect public health and safety including imminent fire threat; 294.13 permits fuels cutting. That exceptions proved "limited and inconsistent due to associated reviews and approvals" describes a guidance problem, fixable by guidance. Request: analyze an alternative clarifying those sections while retaining Subpart B.

3. THE FIRE RATIONALE DOES NOT MATCH THE GEOGRAPHY. The Department reports WUI overlaps 9.8 million acres, 24 percent of affected roadless areas. Three-quarters is not community protection. Request: analyze in detail a WUI-bounded alternative removing the prohibitions only near at-risk communities and critical infrastructure.

4. IGNITION RISK IS CONCEDED BUT NOT QUANTIFIED. The Department acknowledges access "can increase human-caused ignition potential." Published analysis finds ignition density lowest in wilderness and roadless areas, highest near roads. An action justified as fire risk reduction that may increase ignitions requires a net-risk estimate. Request: quantify change in ignition density, acres burned, and suppression cost.

5. THE ECONOMICS DO NOT FAVOR THE ACTION. The Department estimates $5.2-11.4 million per year to the Treasury and Forest Service and $4.6-10.6 million to industry under a full-harvest scenario it concedes is unlikely, against roughly $6.1 million in annual recreation losses. The upper bound of an improbable case roughly equals the loss it creates, before maintenance liability. Request: count lifecycle cost of new permanent roads, capital plus perpetual maintenance, as a quantified cost.

6. RELIANCE INTERESTS. The Department invites comment on these but analyzes none. I bought property in Skagit County against a management baseline settled for 25 years. So did outfitters who built businesses on backcountry opportunity, and WDFW in setting seasons premised on existing security habitat. An agency reversing longstanding policy must assess serious reliance interests and explain why it discounts them. A solicitation is not an assessment.

7. ANALYZE A STATE-SPECIFIC ALTERNATIVE NOW. The Department preserves the Idaho and Colorado rules and invites petitions under 5 U.S.C. 553(e). I was raised in Colorado and know that country. It is a workable model, but it was built on top of an existing protection, not in the vacuum left by removing one. Idaho and Colorado negotiated from a protected baseline. Washington would petition only after protections are gone, bearing the burden of restoration rather than change. Request: analyze a state-specific alternative in detail, or explain why the tailored approach preserved in two states is unsuitable everywhere else.

8. RESOURCE EFFECTS NEED REAL SCALE. Washington's roadless areas, about 2.015 million acres or 22 percent of state national forest land, include headwaters in the upper Skagit and on the Olympic Peninsula overlying critical habitat for listed salmonids. Roads are the dominant sediment source and driver of mass wasting in this terrain. Request: quantify sediment delivery and culvert failure risk at the fifth-field watershed scale and confirm ESA Section 7 consultation status. Open road density is also among the best predictors of elk distribution and bull survival; with permanent road additions anticipated across 18.2 million acres, the effect on hunting opportunity is direct and foreseeable. Request: analyze against published road-density thresholds with state agency consultation on record.

The 2001 Rule is fiscally conservative policy. It needs no appropriation and creates no recurring liability. The Department has told the public the benefits are modest, localized, limited by a $6.9 billion backlog, roughly offset by recreation losses, and possibly accompanied by more ignitions. That record does not support removing protection from 44.7 million acres.

I request the No Action alternative, or a supplemental draft EIS analyzing the alternatives above with the missing reliance-interest and lifecycle-cost analyses.

Burlington, Washington

USDA Forest Service Re: Special Areas; Roadless Area Conservation, RIN 0596-AD66, Docket FS-2025-0001

To the Forest Service:

I am writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in South Lake Tahoe, California, surrounded by the national forest land this proposal would open to road construction and logging. I am asking the Department to withdraw the proposal in full and retain 36 CFR 294 Subpart B.

The comment period is too short for what is being decided.

The 2001 Roadless Rule took more than fifteen months to finalize, drew over 600 public meetings, and received more than 1.6 million comments, the largest public response to any rule in the nation's history at the time. When the Department announced its intent to rescind it, more than 625,000 people responded and over 99 percent opposed repeal.

The Department now proposes to undo all of it, along with a draft environmental impact statement, on 30 days' notice. That is not a good-faith invitation to participate. I ask that the comment period be extended to at least 90 days.

The wildfire rationale is contradicted by the Forest Service's own research.

Secretary Rollins has framed this rescission as a wildfire measure. The agency's own science does not support that framing.

Forest Service scientists mapped 26 years of ignitions along roughly 850 miles of road in the Angeles, San Bernardino, Los Padres and Cleveland national forests. Nearly two-thirds of human-caused fires there started along roadsides. A peer-reviewed study published this year in Fire Ecology, covering 1992 through 2024, found ignition density lowest in designated wilderness at 1.75 fires per 1,000 hectares and nearly as low in inventoried roadless areas at 1.97, while land within 50 meters of a road showed 7.4.

Roads do not extinguish fires. They carry the people, vehicles and equipment that start them. Building more roads into the last unroaded country in the national forest system will produce more ignitions, not fewer, and it will produce them in the most remote and most expensive places to fight fire.

The rule already permits the roads the Department says it needs.

This is the part of the proposal I find hardest to accept in good faith. The 2001 rule already allows road construction and reconstruction to address threats to public health and safety, including wildfire, and already allows cutting trees for fuels reduction. California has treated more than 240,000 acres of roadless land for wildfire risk under the existing rule, and the State has told the Department in writing that the rule has not hindered its forest management or prescribed fire work.

If the barrier the Department describes does not exist in the regulation, the stated purpose and need cannot support the action, and the draft EIS should be revised to reflect that.

What this means in the Tahoe basin.

In August 2021 the Caldor Fire crossed the Sierra crest and forced the evacuation of my entire city. I watched people I know pack their lives into their cars and leave, not knowing what they would come back to. Everyone here carries that.

One of the things that helped hold that fire was prior vegetation treatment in the Caples Creek roadless area, south of Lake Tahoe, in the Eldorado National Forest. Roadless land, treated under the existing rule, doing the very work the Department claims the rule prevents. The rule was not the obstacle. It has never been the obstacle.

More than four million acres of California national forest are at stake here. These are our headwaters, including the water in Lake Tahoe, whose clarity has taken decades of public investment to defend. Roads bring sediment, and sediment is the one thing that lake cannot absorb.

I would add the question retired Forest Service chiefs have already asked: why build new roads when the agency cannot maintain the ones it has, and when the accessible high-value timber was harvested long ago?

My request.

Withdraw the proposed rescission and retain 36 CFR 294 Subpart B in full. If the Department will not withdraw it, extend the comment period to no fewer than 90 days and revise the draft EIS to address the ignition-density research and the existing wildfire provisions of the current rule, neither of which the current analysis honestly confronts.

These are the last wild pieces of our national forests. Once a road goes in, the thing that made the place worth protecting is gone, and no future administration can put it back. I would ask you to weigh that against a rationale the agency's own scientists do not support.

Thank you for considering these comments.

I am a California resident who visits the Lake Tahoe Basin and surrounding national forests several times a year, along with public lands in Utah, Nevada, Wyoming, and Oregon. I oppose the proposed rescission of the 2001 Roadless Rule in its entirety.

The Roadless Rule protects nearly 45 million acres of undeveloped national forest nationwide, including roughly 80,000 acres — close to a quarter of all Forest Service land — in the Lake Tahoe Basin Management Unit and Tahoe National Forest alone. These areas include land near Luther Pass, portions of the Tahoe Rim Trail, and terrain skirting Desolation Wilderness and Freel Peak — places I have personally hiked and recreated in. They also provide habitat for sensitive and federally endangered species, including the Sierra Nevada red fox. Rescinding the national rule removes a durable, science-based standard in favor of case-by-case local decisions with no consistent floor of protection, at a moment when Tahoe-area roadless land is already facing pressure — the Pyramid Inventoried Roadless Area adjacent to Desolation Wilderness has already been targeted for new road construction under the Lake Tahoe West project, the first such proposal in a California IRA.

I am also concerned about the wildfire rationale offered for this rule. Research shows wildfires are significantly more likely to start near roads than in roadless terrain, since road access is strongly correlated with human-caused ignitions. At the same time, the Forest Service's own capacity to carry out fuels-reduction treatment has been reduced substantially in the past year through staffing and budget cuts. Opening roadless areas to road construction without the workforce or funding to follow through on treatment risks increasing ignition sources while doing little to reduce fuel loads.

I am further concerned about what happens after this rule is rescinded. With recently broadened categorical exclusions now in place, many individual road-building and logging projects that follow could proceed with little or no environmental review or public comment. I request that, at minimum, the agency commit to full NEPA review — not categorical exclusion — for any road construction or timber harvest project within currently inventoried roadless areas, including those in the Lake Tahoe Basin.

I ask the Forest Service to withdraw this proposed rule and retain the national roadless designation.

Thank you for considering this comment.

Comment on Proposed Rescission of the 2001 Roadless Area Conservation Rule
Docket: FS-2025-0001 | RIN: 0596-AD66 | 91 FR 53827 (Aug. 20, 2026)

I am a resident of Whatcom County, Washington. I fish the Nooksack and Skagit systems, and I do riparian restoration work on a salmon-bearing tributary in the Tenmile watershed with the Whatcom Conservation District. I oppose the proposed rescission and urge the Department to select the No Action alternative.

I am writing to identify one specific and serious gap in the Draft Environmental Impact Statement, and to request the methodology behind one economic figure.

The DEIS contains no watershed-scale aquatic effects analysis for ESA-listed salmonids.

The DEIS concludes that the proposed rule "is not expected to have a significant change to the commercial fishing or fish-processing industries" and offers no meaningful analysis of effects on listed salmonids in Puget Sound watersheds. That conclusion is not supported by the record, and it is inconsistent with the agency's own prior analysis.

Road construction, reconstruction, and associated harvest are among the best-documented sources of sediment delivery, altered hydrology, and elevated stream temperature in Pacific Northwest forested watersheds. The Forest Service compiled that record itself in the 2001 Roadless Rule Final EIS, where protection of high-quality headwater watersheds was a central justification for the rule. The Department cannot rescind a rule premised in part on aquatic protection without addressing the aquatic analysis it previously relied on.

In the inventoried roadless areas of the Mount Baker-Snoqualmie National Forest, three points require analysis that the DEIS does not provide:

Bull trout. The Coastal-Puget Sound distinct population segment is listed as threatened, with designated critical habitat overlapping IRAs in the Nooksack and Skagit drainages. Bull trout are among the most thermally sensitive salmonids in North America and depend on cold, low-sediment headwater habitat of exactly the type these IRAs contain. The DEIS does not analyze effects on critical habitat primary constituent elements.

Chinook and steelhead. Puget Sound Chinook and Puget Sound steelhead are both ESA-listed. The North Fork and South Fork Nooksack support the last remaining early-timed Chinook populations in the basin. These are a recovery priority and are already sediment and temperature limited. Additional road-derived sediment in the upper watershed acts on populations with no margin.

Northwest Forest Plan Aquatic Conservation Strategy. Many of these IRAs sit within Key Watersheds and Riparian Reserves. The DEIS does not analyze how rescission interacts with ACS objectives or with the watershed condition and road density standards that follow from them.

I request that the Department prepare a watershed-scale aquatic effects analysis for the Pacific Northwest region and complete ESA Section 7 consultation with NMFS and USFWS on this programmatic action before issuing a final rule. The statement that local decisions "would remain subject to the substantive requirements of the Endangered Species Act" does not discharge the obligation to analyze the effects of the decision being made now.

I would add one point the DEIS raises against itself. It acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. An unmaintained forest road is not a management tool. It is a chronic sediment source and a failure liability, and the agency's own budget history indicates new roads will join that backlog rather than clear it.

The DEIS estimates recreation losses at "an estimated $6.1 million annually." That is roughly fourteen cents per acre per year across 44 million acres, against a national outdoor recreation sector the Bureau of Economic Analysis places near $1.2 trillion in output. The Department has asked commenters for data and analytic methods. I ask the same of the Department: disclose the valuation model, the unit values applied, the source study, and the treatment of non-market and passive use values. As presented, the figure cannot be evaluated or challenged, which is itself a defect in the disclosure.

Requested action
- Select the No Action alternative and retain 36 CFR part 294, subpart B.
- At minimum, prepare a supplemental DEIS containing a watershed-scale aquatic effects analysis for ESA-listed salmonids in the Pacific Northwest, and complete Section 7 consultation.
- Disclose the methodology underlying the recreation valuation.
- Extend the comment period. Thirty days is not commensurate with a rulemaking affecting 44 million acres.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to select the No Action Alternative and retain the national Roadless Rule.

The proposal would remove a durable national conservation baseline from roughly 44.7 million acres of National Forest System lands and replace it with a patchwork of individual forest-plan decisions. That is not simply a procedural change. The Forest Service's own proposed rule acknowledges that permanent road construction could become allowable under existing forest plans on about 18.2 million acres, temporary roads would be more likely within approximately 11.3 million acres near existing roads, and roughly 4.8 million forested acres could become available for additional active management where plans and operability allow. Even if only a fraction is developed in the near term, the geographic exposure created by rescission is substantial.

Roadless areas are valuable precisely because they remain comparatively intact. New roads fragment wildlife habitat, alter drainage, increase erosion and sediment delivery to streams, facilitate invasive species, increase human disturbance, and can open previously remote areas to additional development. These effects accumulate across watersheds and landscapes. Site-specific NEPA review after the national protection has been removed is not an adequate substitute for preventing fragmentation in the first place.

The wildfire rationale does not justify wholesale rescission. The proposed rule itself acknowledges that greater public access can increase human-caused ignition potential. The existing Roadless Rule also contains exceptions. USDA should analyze whether those exceptions, treatments using existing access, prescribed fire, and narrowly tailored measures can address legitimate wildland-urban-interface risks without removing protections nationwide. A national safeguard should not be discarded because some locations may require site-specific management.

The economic case is also unpersuasive as presented. USDA states that timber-sale efficiency gains are expected to be incremental and constrained by road costs, market conditions, and a Forest Service deferred road and bridge maintenance backlog of approximately $6.9 billion. The agency also predicts no net change in domestic oil, gas, or coal production relative to baseline conditions, while identifying economic losses to recreationists in affected areas. Before creating opportunities for additional roads, the Forest Service should fully account for lifetime construction, maintenance, repair, decommissioning, watershed-restoration, and ecological costs.

I am also concerned that reliance on individual forest plans transfers the burden of defending roadless values from one national safeguard to repeated local proceedings. Communities, recreation users, Tribes, downstream water users, and wildlife managers have relied on the Roadless Rule for a quarter century. Forest plans can change, and the proposed rule acknowledges that future plan amendments could expand areas available for roads and timber harvest beyond the near-term acreage discussed in the analysis.

Tribal consultation is another reason not to proceed. The proposed rule reports that the majority sentiment among Tribal governments consulted is opposition, including concerns about sacred sites, traditional gathering areas, water quality, subsistence resources, sovereignty, and the burden of repeated project-level review. Meaningful government-to-government consultation should shape the decision before it is made, not simply be summarized alongside a final outcome.

If the Forest Service believes changes are needed, it should analyze narrower alternatives that retain a strong national roadless baseline while addressing specific, demonstrated public-safety needs. It should also fully evaluate cumulative effects on wildlife connectivity, threatened and endangered species, fisheries, drinking-water sources, old and mature forests, carbon storage, invasive species, soil stability, watershed function, quiet recreation, and Tribal cultural and subsistence resources.

The Roadless Rule has endured because some values are most effectively protected before roads, fragmentation, and development occur. Once an intact roadless landscape is divided by roads, restoring its ecological character is far more difficult and expensive than protecting it in the first place.

Please reject the proposed rescission, select the No Action Alternative, and retain the 2001 Roadless Area Conservation Rule.

I am an outdoor recreationist who frequently uses the Arapaho and Roosevelt National Forests. Every source I cite is federally funded and most is USDA Forest Service research. The agency must reconcile this proposal with the science it produces, and has not.

I recognize the rule removes only Subpart B and that Subparts C and D remain in effect. That is itself strong evidence against the Purpose and Need. Colorado and Idaho show that place based tailoring is already available inside the roadless framework, through the 5 U.S.C. 553(e) petition process the preamble itself points to. The DEIS never explains why that mechanism is inadequate, nor why the alternative to a national rule is no rule rather than more state rules. That alternative must be analyzed.

The Forest Service is publishing the California Southern Zone Human Caused Fire Ignition Analysis, mapping 26 years of ignitions across four national forests and 850 miles of roads. It finds roughly two thirds of human caused fires start along roadsides, and the agency is using it to prioritize treatment along existing roads. It cannot rely on that operationally while ignoring it when proposing new roads. Downing et al. (2022), with Rocky Mountain Research Station coauthors, found most cross boundary fires start on private land, and that on national forests road density was the strongest predictor of ignitions. My father spent 20 years with the Forest Service. Field staff have long understood that roads into backcountry terrain do not stop fires, they introduce what starts them.

The DEIS anticipates permanent roads across 18.2 million acres and temporary roads across 11.3 million acres and converts neither into expected ignitions, though it maintains the FPA-FOD and InFORM databases and its own roads and IRA layers. The Final EIS must model ignition density under both alternatives.

The 9.8 million acre WUI overlap figure is undifferentiated by distance from structures. Cohen (2000), written at the agency's Missoula Fire Sciences Laboratory, established that structural survival depends on conditions within 30 to 60 meters of the home, a finding USGS work (Syphard 2014) later confirmed empirically. Calkin et al. (2023), led by Forest Service researchers, concluded that wildland urban fire disasters are not a wildfire problem and that agencies managing wildland fuels have limited impact on community destruction. The Final EIS must report what fraction of the 9.8 million acres lies within 30 to 60 meters of habitable structures, and what fraction is untreatable solely because of Subpart B. Barnett et al. (2016) found only a 6.8 percent encounter rate between federal treatments and later wildfire.

PNW-GTR-509, the agency's own roads synthesis produced alongside the 2001 rule, documents sediment production, hydrologic alteration, invasive spread, and passive use value loss. RMRS-GTR-42-vol.6 documents the grass fire cycle, PNW-GTR-846 landscape scale fragmentation, and RMRS-GTR-114 post fire sedimentation costs to a Front Range municipal supply. The DEIS engages none of these and never says which of its own findings the agency now believes wrong.

The DEIS bounds its impacts with existing plan direction, concedes that later amendments could expand harvest and roads beyond those impacts, then declares amendments out of scope while requesting comment on them. Amendments enabled by rescission are reasonably foreseeable and must be analyzed, not deferred. The economics have the same defect: the preamble concedes a $6.9 billion road maintenance backlog without disclosing the added liability from 18.2 million newly available acres.

The preamble invites comment on these. I have organized my recreation around the roadless system for years because roadlessness delivers a low density, self reliant experience roaded lands cannot. The $6.1 million annual recreation loss figure obscures a class of experience no amendment restores once a road is built.

The DEIS fails to demonstrate a net wildfire benefit and fails to analyze the amendments and reliance interests its own preamble identifies. Every deficiency above is documented in research the government paid for and the Forest Service largely produced. The Forest Service must adopt the No Action Alternative and preserve these roadless areas intact.

Sources, all federally funded:
https://www.fs.usda.gov/about-agency/features/fire-never-starts
https://doi.org/10.1038/s41598-022-06002-3
https://doi.org/10.1073/pnas.2315797120
https://doi.org/10.1071/WF13158
https://doi.org/10.3390/f7100237
https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf
https://www.fs.usda.gov/rm/pubs/rmrs_gtr042_6.pdf
https://research.fs.usda.gov/treesearch/38282

I write in my personal capacity as a private citizen and Colorado public-lands user to oppose the rescission of the 2001 Roadless Area Conservation Rule. I urge the Department to retain the existing rule (the No Action alternative). The proposal would remove national protections for 58.5 million acres without a justification adequate to overcome its costs, the reliance interests it disturbs, and the agency's own data.

1. The Forest Service cannot maintain the roads it already has, and new roads would deepen an unfunded backlog. The proposal admits a $6.9 billion deferred maintenance backlog for roads and bridges. The agency's own infrastructure page reports an even larger agency-wide deferred maintenance backlog of over $8.6 billion in FY2023, and notes that most Forest Service infrastructure is more than 60 years old and past its intended lifespan (https://www.fs.usda.gov/science-technology/infrastructure/maintaining). Every new permanent road is a recurring maintenance obligation in perpetuity, not a one-time cost. The proposal estimates new permanent roads on up to 18.2 million acres where plans allow. Enlarging a network the agency already cannot fund directly contradicts its own National Asset Management Program, whose stated purpose is to reduce that backlog and decommission unneeded infrastructure. I ask the Department to quantify the long-term maintenance cost of foreseeable new roads as an explicit cost of this action.

2. The wildfire rationale is refuted by the agency's own ignition data. Roads are where most human-caused fires start. The National Park Service reports that nearly 85 percent of U.S. wildfires are human-caused (https://www.nps.gov/articles/wildfire-causes-and-evaluation.htm). The Forest Service's own March 2026 feature reports about 95 percent human-caused and finds that, in a 26-year Southern California analysis, nearly two-thirds of human-caused fires started along roadsides, stating that roadsides account for the majority of human-caused ignitions (https://www.fs.usda.gov/about-agency/features/fire-never-starts). The proposal itself concedes that greater public access can increase human-caused ignition potential. Building roads and opening access into landscapes that are currently roadless, and that therefore have almost no human ignition sources, would import the single largest cause of human-caused fire into the last places that lack it. A rule justified as wildfire mitigation cannot be reconciled with the agency's own finding. Moreover, only 9.8 million acres (24 percent) of affected roadless areas overlap the wildland-urban interface, so roughly three-quarters are not where community-protection arguments apply, and existing exceptions already permit fuels treatment where it protects communities.

3. The benefits are small and speculative; the reliance interests are real. The proposal estimates fully realized timber harvest, which it calls unlikely, at only $5.2 to $11.4 million per year on about 4.8 million operable acres, against roughly $6.1 million in annual recreation losses and total impacts that could exceed $100 million. For 25 years, hunters, anglers, outfitters, and recreation economies have relied on these areas remaining undeveloped. The Department specifically invited comment on reliance interests, and these deserve real weight against speculative extraction revenue.

4. NEPA and consultation. The proposal treats the foreseeable plan amendments that would expand roads and harvest as beyond scope while admitting they may follow. The final EIS should analyze that foreseeable footprint, not only the constrained near-term snapshot. The agency also reports that the majority of Tribes consulted oppose the rescission and that this action warrants government-to-government consultation under E.O. 13175. That consultation should be completed before any final decision.

For these reasons, I ask the Department to retain the 2001 Roadless Rule. Once roads and harvest fragment these landscapes, their water, wildlife, and quiet-recreation values cannot be restored. The modest and uncertain benefits do not justify that irreversible tradeoff.

I am writing to urge the Forest Service to withdraw its proposal to rescind the 2001 Roadless Area Conservation Rule.
I live in Asheville, North Carolina, and previously lived in Charlotte. I have also spent a great deal of time in the Robbinsville and Waynesville areas, where family has lived for years. I hike regularly, and some of my fondest memories are in the Pisgah, Nantahala, and Cherokee National Forests: visiting the Joyce Kilmer Memorial Forest and Linville Gorge, hiking Black Balsam Knob, and so many others. I recall the view from the top of Fryingpan Mountain lookout tower: in some directions there were roads, but in others a pristine, untouched, natural landscape at a scale I had never seen before. It was a profound experience, and it inspired me to plan vacations around exploring national forests, parks, and recreation areas in other states. Witnessing nature, untouched, at scale, is a precious gift, and we owe it to future generations to preserve that experience.
The stated justification for this rescission, wildfire prevention, is factually inaccurate, and the agency's own records show this. Roughly nine in ten wildfires are human-caused, and research shows ignitions are up to four times more likely near roads than in roadless areas, because roads bring people, vehicles, cigarettes, and sparks. A 2020 Forest Service study based on nearly two decades of monitoring data concluded that more roads do not produce better forest health through increased fire-management activity. Fuel reduction treatments already occur inside inventoried roadless areas at rates comparable to or greater than elsewhere in the National Forest System, and historical fire maps show roaded and roadless forests have burned at similar rates since 2001. In short, the Roadless Rule does not prevent responsible fuels work, and more roads are more likely to increase ignitions than reduce fire risk. Framing the removal of protections for 44 million acres as a wildfire measure is not supported by the evidence; it reads as a pretext for opening these lands to road building and commercial logging.
The economic arguments are also weak. The Forest Service already carries a road maintenance backlog on the order of $10 billion. Building new roads deepens that liability with taxpayer money, and below-cost timber sales on national forest land have historically lost the agency millions of dollars annually. Meanwhile, intact forests drive an enormous and growing economy: national forest recreation visits generated $10.1 billion in local spending and supported more than 150,000 jobs in 2019 alone, and outdoor recreation broadly is now a trillion-dollar-plus sector. Every trip I take in western North Carolina means money for local restaurants, hotels, campgrounds, and small businesses. Those gateway communities depend on the landscapes this proposal would fragment and erode. Trading that durable, broadly-shared economic base for a one-time timber cut is bad arithmetic even before counting lost water quality, wildlife habitat, and carbon storage.
The public has already spoken on this matter twice. The original rulemaking was the most extensive in federal history, drawing over 1.6 million comments with roughly 90 to 95 percent in favor of protection. This rescission has generated thousands of comments, and independent analyses suggest about 99 percent oppose the rollback. Opposition of that magnitude, across the political spectrum, should end the discussion. Proceeding anyway would signal that public comment is theater and the outcome was decided in advance.
It is hard to avoid asking who actually benefits from this. The most enthusiastic supporters of this proposal are timber industry organizations, not firefighters, not forest ecologists, and not the recreating public. When a policy is opposed by 99 percent of commenters, contradicted by the agency's own science, and applauded chiefly by the industry that stands to extract value from it, the only logical conclusion is that the government is working for private interests, rather than for the tax-paying public it is duty-bound to serve.
The Forest Service has real wildfire challenges, and the right tools for that work - targeted fuels treatment near communities, prescribed fire, wildland-urban interface planning - are all permitted under the current rules.
A blanket removal of national protections, delegated to local managers while the agency's staff, budget, and scientific capacity are being cut, is not a valid wildfire prevention strategy. It is a slow-motion land transfer, with no evidentiary basis, no coherent economics, and no public support.

For these reasons, I ask the agency to do the right thing and withdraw the proposed rescission in its entirety. Leave the 2001 Roadless Area Conservation Rule in place, and invest in maintaining and protecting the natural beauty of our country.

I strongly oppose the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule.

I am a resident of Arizona, an avid hiker and a lover of our public lands and wild spaces. The Roadless Rule protects our national forests from large-scale logging, which is the ultimate goal of this administration's move to rescind the rule. If this happens, roughly 25,000 miles of trails, 10,000 climbing routes, 1,000 miles of whitewater, and more than 10,000 miles of biking terrain will be put at risk. It will also permanently damage natural refuges for endangered and non-endangered animals alike and will permanently alter critical ecosystems that protect against the evergrowing impacts of climate change.

This move is clearly incredibly unpopular. The last time this was proposed in 2025, it drew over 625,000 comments in three weeks, with 95% opposing rescinding the Roadless Rule. Public polling finds that 76% of Americans oppose this action, with 71% of Republicans, 80% of Democrats, and 80% of unaffiliated voters opposed. Even 72% of voters who cast ballots for Donald Trump oppose this action.

The agency frames rescission as a wildfire-risk reduction measure, but the evidence points the other way. A 2025 analysis by the Wilderness Society found wildfire density is lowest in wilderness and protected forest areas and highest in areas near roads, since roads are a primary vector for human-caused ignitions. Removing roadless protections and building more roads into backcountry forest is more likely to increase ignition risk than reduce it. Logging would also remove fire-resistant old-growth trees from protected areas, which are critical to wildfire mitigation.

Actions done to wilderness areas cannot be undone. Once the land is gone, you can't get it back. For these reasons, I urge the USDA to withdraw this action and retain the 2001 Roadless Rule in its entirety.

Dear Mr. Schultz,

For an outdoor enthusiast who has experienced the difference between walking into country shielded by the 2001 Rule and entering adjacent lands subject to road-building and extraction, the proposed rescission presents not a policy adjustment but a fundamental reorientation of what national forests are managed to provide.

Roadless areas are different. They are valuable, just as they are. Once compromised they are endangered by human-caused fire, human-assisted invasive species and misuse, which includes inefficient extraction.

On the foundation just described, I turn to the specific grounds for my opposition to rescission.

Regarding the Quilcene in the Olympic National Forest, Washington:

Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior.

Rescinding the Roadless Rule would open the Quilcene, Olympic 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.

I strongly urge the selection of the No Action alternative -- leave the Roadless Rule in place.

Suppression has degraded fire-dependent ecosystems. A century of aggressive fire suppression — made possible by road access — has transformed fire-adapted forests like longleaf and ponderosa pine. Without periodic low-intensity fire, fuels accumulate and forest structure shifts toward conditions that support catastrophic, stand-replacing fires (USDA Forest Service 2001). — USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf)

The Secretary should allow the 2001 Rule to remain and decline to proceed with rescission.

With respect,

CommentID: RLC-20260820-3TETDT

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain the rule.

I live in western North Carolina, surrounded by the Southern Appalachian Mountains and National Forest lands. These places are not abstract lines on a map to me. I hike, fish, camp, and spend a significant amount of my free time outdoors. One of the things I value most about our National Forests is that there are still large areas where forests, streams, wildlife habitat, and mountain landscapes have not been fragmented by an expanding network of roads.

The Roadless Rule strikes a reasonable balance. It does not prohibit the public from using these lands. People can hike, hunt, fish, camp, and otherwise enjoy them. Instead, it primarily limits new road construction, road reconstruction, and timber harvesting in inventoried roadless areas, while already containing exceptions for legitimate management needs.

I understand the argument that Forest Service managers need flexibility to reduce wildfire risk and manage unhealthy forests. I support responsible prescribed burning, hazardous-fuel reduction, restoration, and other science-based management when those actions are necessary. But I do not believe those concerns justify eliminating nationwide roadless protections across tens of millions of acres.

If particular provisions of the existing rule interfere with necessary wildfire mitigation or ecological restoration, those provisions should be addressed specifically. Rescinding the entire rule is an unnecessarily broad solution.

I am particularly concerned about the long-term consequences of new road construction. A timber harvest may affect an area for decades, but a road can fundamentally change a landscape for generations. Roads fragment wildlife habitat, increase erosion and sediment entering streams, create opportunities for invasive species, and require continuing maintenance. Once previously undeveloped landscapes are fragmented by roads, restoring their original character can be extremely difficult.

I am also concerned that transferring these decisions entirely to individual forest-management plans could gradually erode protections over time. National forests belong to the American public, including generations that have not been born yet. Some places deserve a durable baseline of protection that does not depend entirely on changing local management priorities or political administrations.

These roadless areas also have economic value precisely because they remain relatively undeveloped. Outdoor recreation, hunting, fishing, tourism, clean water, intact watersheds, and healthy fisheries all depend on functioning forest ecosystems. Their value should not be measured solely by the timber or resources that could be extracted from them.

I therefore ask the Forest Service to select the alternative that retains the 2001 Roadless Area Conservation Rule rather than the proposed nationwide rescission.

If the Forest Service believes changes are necessary to improve wildfire mitigation or ecological restoration, I encourage the agency to pursue narrowly tailored amendments or additional exceptions while preserving the rule’s fundamental protections against unnecessary road construction and development.

We inherited these public lands from generations before us, and we have an obligation to leave some large, intact forests for the generations that come after us.

Please retain the Roadless Rule