2001 Roadless Rule Revision

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

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

Thirty years of hunting, introduced to it by my Dad and my Grandpa, a World War Two Navy veteran. My Grandpa has passed, and the forest is where I go now to feel his presence. That connection depends on the kind of country that stays wild, that stays roadless, that gives animals the space they need. The agency's proposal to rescind the 2001 Roadless Area Conservation Rule would damage that, and I oppose it.

The grouse question is the sharpest one for me. I have hiked and hunted all over Woodford 09086, a 2,456-acre roadless area in the Green Mountain National Forest, and I know from being there that if roads are expanded, we will lose the habitat that allows grouse to rebuild their numbers. The DEIS names ruffed grouse among the game that needs complex forest structure with mast-producing trees, and it confirms that some species show such strong site fidelity that they cannot simply adapt when habitat changes. That is exactly the problem. The DEIS also states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is documented, cited, and then left hanging, never projected across the 40.1 million acres of potentially affected environment the agency's own documents describe. I ask that the agency apply that fragmentation range to the full 40.1 million acres in its analysis and show what the realistic outcome looks like for upland bird habitat and hunter opportunity in places like Woodford.

On the broader wildlife picture, 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. The agency offers no population-level projection anywhere in the document from that finding. The same gap exists for upland birds. The agency must project the effects on game populations and hunter opportunity, by species, before it finalizes any rescission.

The agency argues that the 2001 rule exceeded its statutory authority. The Tenth Circuit resolved that question, holding the rule was within the authority Congress granted and did not create de facto wilderness. The court's own language on that point is: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must explain, with specific legal reasoning placed in the record, why it believes it may take a position contrary to that holding.

The agency also cites permitting and administrative burden as justifications for rescission. The rule itself includes exceptions for the preservation of reserved or outstanding rights, for Forest Service construction necessary for public health and safety, for existing mineral leases, and for community wildfire protection. If genuine burdens exist that those exceptions do not already address, the agency has not identified them or quantified them. That is not an adequate basis for eliminating protections that cover Vermont's 6 inventoried roadless areas totaling 25,096 acres. The agency must name each specific burden it claims is unaddressed by existing exceptions and provide numbers.

I hike and camp throughout the Green Mountain National Forest, including Lye Brook Addition 09085, 1,111 acres that represent to me what this state and this nation should protect for all Americans. Vermont sits within an Eastern region where 286 municipal water intakes are located in watersheds containing affected roadless areas. Roads bring sedimentation, and sedimentation reaches those intakes. The agency has not accounted for that cost in any concrete way. A beautiful place like the Green Mountains, once roaded and fragmented, does not come back in a generation. That should be answered for, plainly, before this rule is rescinded.

Sincerely,
Kyle Metarko
Winhall, VT

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 live in Washington State. I hike, trail run, backpack, and climb in inventoried roadless areas in four national forests: Olympic, Mt. Baker-Snoqualmie, Okanogan-Wenatchee, and Gifford Pinchot. I camp on Forest Service land, mostly dispersed rather than in developed campgrounds, so the unroaded character of these areas is not incidental to how I use them. It is the whole basis of it. My objections come from the Department's own numbers.

FOREST PLANS ARE NOT A SUBSTITUTE, AND THE PROPOSAL SHOWS IT

The central argument is that the NFMA planning framework already addresses the same conservation objectives (91 FR 53828). But the impact summary states that roughly 18.2 million acres, or 45.5 percent of the affected environment, are lands where current forest plans already allow permanent road construction and only the 2001 Rule prohibits it (91 FR 53829). That figure measures the gap between what the plans do and what the Rule does. On nearly half the acreage, the plans do not provide the protection the proposal credits them with. Please either demonstrate unit by unit that plans supply equivalent protection, or state in the FEIS that rescission causes an immediate net loss of protection across those 18.2 million acres.

THE UPSIDE IS SMALL AND THE LOSS IS PERMANENT

The proposal calls the opportunities "modest and localized." About 4.8 million acres meet both operability and plan allowance. If all of it were harvested annually, which the Department calls unlikely, the result is $5.2 to $11.4 million per year in federal revenue. Against that: an estimated $6.1 million per year in recreation losses, and a $6.9 billion deferred maintenance backlog on roads the agency already cannot fund. Roadless country, once roaded, does not come back. I cannot see how those figures justify giving up 44.7 million acres of something irreplaceable, and I ask that the FEIS weigh the two side by side rather than in separate sections of the analysis.

THE WILDFIRE RATIONALE DOES NOT HOLD

Subpart B already permits suppression, prescribed fire, and cutting to reduce uncharacteristic wildfire effects under 36 CFR 294.13(b)(1). If those exceptions are used inconsistently, the fix is to streamline them, an alternative the Department has not analyzed. Only 24 percent of IRAs overlap the wildland-urban interface, so a WUI-targeted alternative would capture nearly all the community protection benefit at a fraction of the cost. Please analyze one. The proposal also concedes that road access raises human ignition potential without quantifying it. The FEIS should estimate that net change.

FORESEEABLE PLAN AMENDMENTS CANNOT BE EXCLUDED

The proposal admits later amendments could expand where harvest and roads are allowed, then places them "beyond the scope" (91 FR 53830). The entire purpose of rescission is to move discretion to the plan level. Those effects are foreseeable and belong in the analysis, along with cumulative effects from the 2020 Alaska Roadless Rule.

RELIANCE

Twenty-five years of settled protection shaped how backcountry recreation in Washington works: where outfitters run trips, where volunteers maintain trail infrastructure, and where people like me invest years of training, permits, and planning in trips that only function in unroaded terrain. The areas I use are specific: South Quinault Ridge, Green Mountain, and Rugged Ridge in Olympic; the Nooksack, Skagit, Stillaguamish, and Snoqualmie headwaters in Mt. Baker-Snoqualmie; the North Cascades roadless areas near Washington Pass in Okanogan-Wenatchee; and the roadless lands adjoining Goat Rocks and Indian Heaven in Gifford Pinchot.

Dispersed camping is what I most want the Department to look at. It is not permitted, counted, or ticketed, so I doubt it appears anywhere in the $6.1 million recreation estimate, and it is the use most immediately eliminated when an area is roaded. If the cost-benefit analysis has no method for valuing dispersed backcountry use, the FEIS should say so plainly rather than presenting a recreation figure that reads as complete. Quiet recreation is not interchangeable with road-based recreation, and no plan-level process recreates it later.

The FEIS should also identify which IRAs in these forests feed municipal and tribal drinking water supplies, and quantify the sediment risk at the road densities rescission would permit.

PROCESS

Thirty-two days is not enough to review a three-volume draft EIS plus three supporting analyses covering 44.7 million acres. Please extend the comment period by at least 90 days, and complete Tribal consultation, which the Department describes as ongoing and majority-opposed, before issuing any final rule.

Please retain the 2001 Roadless Rule and select the No Action alternative. If the Department proceeds regardless, please adopt something narrower: a WUI-targeted exception, or a streamlined path for the exceptions already in 36 CFR 294.13(b).

Thank you for considering this.
Savanna Kreykes, Kirkland WA

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and support the No Action alternative. My full comment is attached; this summarizes my principal objections and requests.

I am a nurse pratitioner, with a graduate degree in public health and emergency management and a prior career in federal law enforcement. I farm in Moore County, North Carolina, downstream of national forest headwaters.

I do not oppose active forest management. I oppose removing a durable national protection on a record the Department's own analysis does not support.

1. THE DEPARTMENT'S OWN NUMBERS UNDERCUT ITS STATED PURPOSE.

The preamble concedes management opportunities would be "modest and localized." Rescission would expand operable timber management to roughly 4.8 million acres — 16 percent of forested acreage in affected inventoried roadless areas. The Department states that harvest across all of it is "unlikely due to budgets, unforeseen limits on operability, and market conditions," and that even then the return would be $5.2 to $11.4 million per year to the Treasury and Forest Service and $4.6 to $10.6 million to industry. Against that ceiling, the Department estimates recreationist losses of roughly $6.1 million annually and total additional impacts that "could exceed $100 million."

An agency may change a discretionary policy. It may not do so on a rationale its own record contradicts. I request that the final rule state whether quantified benefits exceed quantified costs, and if the Department declines to so find, explain why nationwide rescission is nonetheless warranted.

2. THE WILDFIRE RATIONALE DOES NOT REQUIRE RESCISSION.
36 CFR 294.13(b) already authorizes timber cutting to maintain or restore ecosystem composition and structure, including reducing the risk of uncharacteristic wildfire effects. Section 294.12(b) already authorizes roads for public health and safety. The Department's actual complaint, per the preamble, is that use of these exceptions was "limited and inconsistent due to associated reviews and approvals." That is an administrative burden argument, not an authority one.

If those requirements are unworkable, the remedy is to streamline them — a far narrower action delivering the claimed fuels benefit without withdrawing protection from 58.5 million acres. I request the final EIS analyze, as a distinct alternative, retention of Subpart B with simplified procedures for the existing 294.12(b) and 294.13(b) exceptions.

The preamble also concedes greater access "can increase human-caused ignition potential." The final EIS should quantify ignitions created against acres treated, not note the tradeoff in a single qualifying clause.

3. WATER AND PUBLIC HEALTH.
Forest roads are the principal source of sediment from managed forest land, and on steep slopes road cuts and fills initiate a disproportionate share of landslides and debris flows. Hurricane Helene demonstrated this in western North Carolina in September 2024; communities lost potable water for weeks. As a clinician I treat the consequences — respiratory failure, cardiovascular events, and deterioration of medically fragile patients during infrastructure loss.

I request the final EIS identify the public water systems whose source watersheds overlap inventoried roadless areas, the populations served, and the sediment and turbidity effects foreseeable from new road construction — particularly in the steep, high-precipitation terrain of the Southern Appalachians.

4. FOREST PLANS ARE NOT AN ADEQUATE SUBSTITUTE.
The notice states near-term permanent road additions could occur on about 18.2 million acres where plans allow them but the Roadless Rule prohibits them. That figure is itself the measure of the protective gap between the Rule and existing plan direction. The notice also concedes subsequent plan amendments "could increase the area where timber harvest and road construction would be allowed," then places them "beyond the scope" of this rulemaking. The Department cannot rely on the planning process as the safeguard justifying rescission while excluding that process's foreseeable results from its analysis. I request the final EIS analyze those amendments.

5. PROCESS.
The 2001 Rule was adopted after hundreds of hearings over roughly two years. This rescission proceeds on a 21-day scoping period drawing 220,000+ letters for over 625,000 individuals, a 30-day comment period, no hearings outside Alaska, ANILCA Section 810 hearings not yet noticed, and Tribal consultation still ongoing as this record closes.

I urge the Department to extend the comment period to at least 120 days, hold hearings in affected regions including the Southern Appalachians, and complete consultation and the Section 810 analysis before the record closes.

I respectfully request selection of the No Action alternative and retention of 36 CFR part 294, Subpart B.

Matthew C. Kuhn, MSN, MPA, AGACNP-BC

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

Twenty-six years of owning a cabin at Lake Quinault have given me a clear picture of what is at stake in the South Quinault Ridge roadless area and across the Olympic National Forest. The old growth stands of Douglas Fir, Spruce, and Cedar that surround the lake in this temperate rainforest are not abstract policy objects. They are what I return to. Building roads for access into this mountainous terrain will likely increase erosion and degrade water quality and the salmon habitat. I oppose rescission of the 2001 Roadless Area Conservation Rule and file these comments for Docket FS-2025-0001.

Public lands should be managed for conservation of old growth stands and water resources, public recreation, and resource use, with balance among these purposes. The Roadless Rule provides that balance. So much of the national forests are already open to development and logging, and what remains of our roadless forests should remain a high priority so future generations can experience them and have the opportunity for quality water sources. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and the South Quinault, and Moonlight Dome areas within the Olympic National Forest represent exactly the irreplaceable country this rule was written to protect.

The proposal justifies rescission partly on permitting and administrative burden, but the rule as written already contains flexibility. It generally banned road building subject to limited exceptions, including "the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." I ask the agency to identify which specific burdens fall outside these existing exceptions and quantify them, on the record, before using regulatory burden as a reason for nationwide rescission.

The agency is also selling this action as wildfire protection, but its own effects analysis contradicts that framing. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." That is more than seven times the ignition rate on roaded land. The agency must quantify the expected increase in human-caused ignitions resulting from new road access and weigh it explicitly against the claimed reduction in wildfire hazard before that rationale can bear any weight.

Its own accounting makes the contradiction worse. The agency's Cost Benefit Analysis Table 4 (p. 30) lists among the qualitative unquantified costs of this proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; agency road maintenance burden." In the benefits column, "reduced wildfire risk" sits among the benefits the agency says it cannot quantify. The promise of fire reduction is unquantifiable; the cost of increased ignition risk is acknowledged but also left unquantified, beside data showing roaded land burns at a far higher human-caused rate. The agency must quantify the net wildfire effect of this action in either direction before wildfire can serve as any justification for it.

There are so many existing back-country roads already in disrepair and needing brush clearing, drainage work, and surface repair to make them passable. Our tax dollars would be better spent repairing and maintaining the roads that already exist than building more into country that has none. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Roads and their facilities can produce the overwhelming majority of sediment from a timber sale, and removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities, and growth of coho salmon in what the agency's own materials describe as Essential Fish Habitat and critical habitats managed by NMFS. The South Quinault Ridge stands above a watershed where these consequences are not theoretical.

Finally, the agency's stated purpose is to reduce regulatory burden and return decision-making to local officials, not fire management. The overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS itself says the benefits of added fuel-management access "would likely be modest and localized." The agency constructed and then rejected a WUI-targeted alternative that would have addressed the fire rationale without eliminating protection for the remaining 76 percent of affected roadless acres. The agency must explain, in plain terms, why that narrower alternative was set aside in favor of nationwide rescission.

Sincerely,
Barbara Bailey
Tacoma, WA

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

Dirt roads in Oregon's rain country do not stay solid. They turn to mush, and that mush moves downhill into streams. This endangers the drinking water of hundreds of thousands of of Oregonians and residents of other states, as well as endangering young and adults endangered salmon to go to the ocean or return to spawn in the rivers and streams. I know this from my career as a water and storm water engineer at the Portland Water Bureau and other engineering work, and it is the reason I am filing this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule.

Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and 1,522 municipal water intakes in the Pacific Northwest region sit in watersheds that those areas feed. The connection between road building and sedimentation is not theoretical. I have personally watched dirt roads in Oregon contribute major sediment loads to tributaries that supply drinking water and support salmon. I have also personally seen timber, mining and other commercial operations fail to follow the water-protection commitments they agreed to. Rescinding this rule hands those same interests access to land that is currently protected without requiring a full environmental impact statement as the law provides. That alone is a sufficient reason to stop this proposal, but the agency's own record raises several additional problems that deserve a direct answer.

The proposal points to wildfire and fuels management as justification for rescission, but the agency's own analysis cuts against that argument. Its 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." Roads create ignition risk, not suppression capacity, and the agency's own DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain why this proposal departs from its own prior findings and reconcile the rescission with that ignition data.

The economic rationale is equally hard to square with what the agency's own record says. The record acknowledges that "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." Against that marginal contribution, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year while booking recreation losses of at least $6.1 million a year. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. How does an action whose own analysis cannot establish a net benefit justify expanding that system? The agency must reconcile those numbers before proceeding.

On statutory authority, the record contradicts the proposal's premise. A court reviewing the 2001 rule held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes a specific explanation, on the record, for any position that the rule exceeded its statutory authority in light of that holding.

Finally, on water and salmon, I want to be direct about what is at stake in Oregon specifically. Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon. I have personally measured the higher temperature water than road ditches contained and seen the eroded sediments in prime spawning habitat that cover high quality spawning areas and making the both hot and unsafe for spawning. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS. I worked long enough in water systems to know that impaired streams are far harder and more expensive to fix than to prevent. The agency must explain how it accounts for these documented harms to Essential Fish Habitat and drinking water watersheds in the Pacific Northwest when no full environmental impact statement has been completed for this rescission.

The Roadless Rule protects land that belongs to the citizens of the United States. This proposal should not move forward.

Sincerely, Elaine Kuehn, PE, Professional Engineer,
Portland, OR

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

The scenery, wildlife, and big old trees of the Mt Baker-Snoqualmie roadless areas have been a source of joy and peace for us for over fifty years. I oppose this rescission because those places are worth protecting, and because the agency's own record does not support taking them apart.

Our public lands are our heritage. Once logged, mined, or traveled by vehicles, they are gone forever. A primeval forest cannot be recreated. That is not sentiment; it is a permanent, irreversible loss of something that belongs to every American. The agency owes the public a serious accounting of what is being traded away and why.

Here in South Snohomish County, we rely on drinking water from watersheds in roadless areas. Drought and wildfires are already stressing our water sources. Roads would make it worse. The agency's own analysis found that roads and their associated facilities can produce up to ninety percent of the sediment from a timber sale. Fewer than twelve percent of the watersheds fed by roadless areas have impaired streams today. Opening these areas to road construction risks degrading the water supplies of communities that have no easy alternative. I want the agency to explain on the record how it weighs that risk against the benefits claimed for this rescission, and to show what specific measures would prevent sediment loading in municipal watersheds like ours.

On wildfire, 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." The proposal justifies rescission partly on fuels management grounds, yet this finding points in the opposite direction. The agency must explain why the proposal departs from its own prior conclusions about fire occurrence, and how it reconciles this rescission with the ignition data in its own draft environmental impact statement.

On the state-by-state approach, the agency's own record quotes the USDA discussing "its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The courts have already evaluated this argument. I want the agency to address how this proposal avoids the legal deficiencies identified when the agency last attempted to substitute state petitions for a national rule, and to explain why local decision-making will not incrementally erode roadless values that are nationally significant.

The Forest Service is already $6.9 billion behind on maintaining existing roads. Punching new roads into roadless areas will benefit logging and mining companies. Taxpayers must not be on the hook for this. The rule as written already allows exceptions for public health and safety and for reserved or outstanding rights. The agency's own text confirms: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If those exceptions are insufficient, the agency should identify which specific needs fall outside them and quantify the burden on the record. It has not done so.

Finally, the agency certified no significant impact on small businesses while its own Cost Benefit Analysis records a lost recreation benefit of at least $6.1 million a year and its own draft environmental impact statement names outfitters, guides, and tour operators as affected parties. That certification was reached by spreading losses across every small firm in the sector nationally rather than examining the permits and receipts of the businesses actually operating in the affected areas. The agency should withdraw that certification and conduct an honest assessment of the small entities whose livelihoods depend on the roadless areas this proposal would open to road construction.

Sincerely,
Nancy S Johnson, Edmonds, WA

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

Cold water is the whole thing. Roads are how you ruin it. I fish spring creeks in Pennsylvania and I see it happening: the subterranean water table shifts, the spring creek issuance changes, and the source is often what you put on the land and how you let water move through it. Road access is a version of that same problem on the exposed side, above ground. That is what I know in my gut, and rescinding the 2001 Roadless Area Conservation Rule does not pass the gut test.

I am writing about inventoried roadless areas I chose because they matter to me: Northern Massanutten, 9,444 acres in the George Washington National Forest in Virginia; Southern Massanutten, 11,985 acres; Gum Run, 12,620 acres; Oak Knob, 10,882 acres; Skidmore, 5,641 acres; Dry River in the same forest; Big Schloss, 8,375 acres in the George Washington in West Virginia; and in the Monongahela National Forest in West Virginia, North Mountain Hopeville, 6,525 acres, and Dolly Sods Roaring Plain, 13,392 acres. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. The Monongahela's 20 inventoried roadless areas total 174,885 acres and protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions.

The agency's own DEIS states that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number appears in the document. No projection of what that sediment load actually reaches the streams below follows it. The spring creeks I watch in Pennsylvania do not recover quickly from sediment pulses. The Monongahela protects headwaters that become drinking water for millions of people. The George Washington's roadless acres protect tributary systems that feed into those same broader watersheds. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas, and put that projection in the record.

The DEIS states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." That sentence is offered as reassurance. It is not one. Less than 12 percent impaired now tells me nothing about what happens after road mileage increases in places like the Dolly Sods Roaring Plain or the Gum Run drainage. The DEIS says forest plans address sources of public drinking water, but identifies no enforceable plan provision by name. I want the agency to identify, forest by forest, which specific plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Name them.

The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The Monongahela's roadless acres shelter the Cheat Mountain salamander, the West Virginia northern flying squirrel, the northern long-eared bat, snowshoe hare, and red spruce ecosystems described as relics of the last ice age. Dolly Sods carries spruce-bog habitat more reminiscent of northern Canada than West Virginia. These species and places are exactly what fragmentation science describes as vulnerable. But the cited range is never applied to the 40.1 million acres of potentially affected environment. A range of 13 to 75 percent applied to 40.1 million acres produces a projection the agency owes the public. I ask that the agency apply that cited fragmentation range to the full potentially affected acreage and show its work.

Finally, the DEIS states: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." That is the agency telling me that existing roads are already damaging water quality because there is not enough money to maintain them. The same document proposes opening roadless areas to additional road construction. I want the agency to reconcile those two positions in plain language. We can have financial prosperity and conservative conservation practices, and I believe a deal can be negotiated, but not by adding road mileage on top of a maintenance shortfall that the agency's own analysis identifies as a cause of water quality harm. Find a different path forward.

Sincerely,
Sean Eagan
Manchester, MD

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

This area is very near where I live. I hike here often. I have photographed peregrine falcons. spotted owls, warblers of many kinds, bears, turkeys, elk and more.

it would be soul crushing to see it altered and harmed by logging and vehicle use. Moreover, the Forest service cannot even maintain existing roads. Plowing in new ones is just going to make mess of destruction, noise, riparian loss, and erosion.

You can reach Poverty Creek in a passenger car on pavement. It often has water and the birding is wonderful. Leave the car to find miles of main canyon and side canyons to explore!

I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas:

- Apache Kid Contiguous (67,542 acres), Cibola NF, New Mexico
- Poverty Creek (8,770 acres), Gila NF, New Mexico

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: Fragmentation is quantified and not applied

I go out to watch wildlife and birds, and what I look for lives in unbroken habitat. The agency measured what fragmentation costs and then set the finding aside. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent.

The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment.

Issue 2: Elk survival, in the agency's own citation

I watch wildlife, and the animals I go looking for need country roads have not reached. The agency's own citation makes that point better than I can. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat.

No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity.

Issue 3: Carbon is stated and dropped

The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. 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 concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative.

Issue 4: The agency's own assessments predict harm to 327 protected species

I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. 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.

Not may: will increase the likelihood, and the agency anticipates the harm. The phrase "likely to adversely affect" appears more than 150 times across the USFWS assessment alone, and the proposal identifies mitigation for none of it. 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 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,
Mary Katherine Ray
Winstom, NM

Dear Secretary Rollins,

I am very excited that the USDA has at least initiated the opportunity for our local USFS to once again have some say and authority over their local resources. This is not only important for the health of these forests but also for the local communities.
I would like to see ALTERNATE 2 put in place with ALTERNATE 3 being my second option.

My background includes living and being raised in SW Montana, recreating in all parts of the state of MT, along with others, working in our National Forests and actively flying helicopters for fire suppression throughout the west. When I am not fighting fire, I am recreating in our National Forests on almost all of my off days.

I will highlight a few important points that helped me come to my decision to be in favor of rescinding the roadless rule. After reading through the summary and the environmental impact statement presented by the USDA along with peer reviewed articles and the 2009 West Pioneer Inventoried Roadless Area-Wilderness Character Evaluation along with Wilderness Suitability Resources for this area I find it obvious for the need to rescind the roadless rule.

Some important highlights for me include:
1. Even if the roadless rule was rescinded there is a large list of protections in place along with many regulatory and legal hurdles before any new project would be completed. Returning these roadless areas back into the actual National Forest will not make them unprotected by any means.
NEPA, Taylor Grazing Act, General Mining Law, Mineral Leasing Act, Endangered Species Act, National Historic Landmarks, Special Management Areas and a long list of many more will still be in place to protect our National Forests.

2. Allow the local officers in charge of that forest to manage it for the health of the land and the local communities that work and play on that land.
-If the roadless rule was rescinded many believe that roads will be built throughout these areas. As stated in the Environmental impact statement, there are roads already in place in a large portion of the roadless area with new temporary construction only occurring within 0.5 miles of a current road, this is only 28.3% of the affected lands. Permanent road construction will be less likely to occur on anything more than 0.5 miles but at least the option would be available. Over half of the roadless areas are deemed unreasonable for road construction. Along with the current backlog of maintenance for roads already in the system and a smaller budget, new road construction is highly unlikely.

3. Logging and fuel management is very important. There are many factors that affect fire activity. As we all know, humans start 85% of our fires, this does increase near roads. So yes, more fire starts will occur near roads if there were any reopened or built. However, fires that start near roads have found to be smaller and less intense due to fuel management and access. Areas such as WSAs, Wilderness and IRAs typically see larger uncontained fires with higher intensity due to no fuel management being utilized for decades and no fire breaks due to roads and management.
My job is to insert fire fighters and preform water drops. Less roads means less opportunity to have fire fighters on the ground. Safety is the largest issue and having no barriers such as roads to work from, fires become much larger. Firefighting is expensive, firefighting aviation is even more expensive. We cannot rely on more aircraft to stop fires. You must have fire fighters on the ground for any air resources to be effective. This can't be done without road access.

4. The East and West Pioneer WSAs (both IRA) unexpectedly took away many of Beaverhead counties recreational opportunities. Maverick Mountain Ski Area recently burned due to the Sand Fire. The West Pioneer WSA has sat since the 80's with no roads and no management occurring. Almost half of the entire acreage has now burned in the last 25 years, including Maverick which sits on the southern boundary. Many factors led to the loss of this treasure, however this Lightning started fire saw minimal direct suppression due to safety and access for fire fighters.

The East pioneer WSA in 2001 took away access to mountain lakes for the community even though there are jeep trails, ATV and single track already in place. These lakes have manmade damns and concrete headgates ranchers have been using for irrigation for decades.
There are 69 named Lakes in the Pioneers. Prior to 2001 a dirt biker/OHV could access 25 lakes out of 69. After 2001 access dropped to 19 out of 69. This is not fair and equal use recreation. Nobody is asking for new trails to untouched lakes and areas, people just want local FS officers to evaluate local forests to provide equal opportunity for the community economically, recreationally and for overall forest health.

Thanks for at least considering rescinding the roadless rule. No action is by far the worst action.
Shane Cottom
SW Montana

I support rescinding the 2001 Roadless Rule. I've watched how the broader litigation environment around federal forest management — much of it enabled by the same NEPA-based legal tools that surround roadless designations — gets used by activist groups to delay or kill fuel-reduction work and to roll back non-hiking access, even when local forest managers have already made a reasoned decision. I don't think a single nationwide rule, frozen in place since 2001, is the right way to manage 59 million acres of forest with wildly different fire risk, terrain, and community needs. I'd rather see that judgment made by local and regional forest managers who actually know the ground.

The numbers back this up. The Forest Service's own data shows more than 40% of inventoried roadless areas now carry high or very high wildfire hazard potential, and only about 5% of that acreage has received any hazardous-fuels treatment since 2014 — a huge and growing gap between fire risk and actual management on the ground.[1] Meanwhile, the government's own watchdog has documented for over two decades that appeals and litigation routinely delay hazardous-fuels reduction projects across the National Forest System, sometimes adding years to timelines even when the agency ultimately wins in court.[2] That's not a hypothetical — it's a repeatedly documented pattern, and it's exactly the dynamic I've seen play out: management decisions get made, then get tied up fighting a lawsuit instead of getting fuel on the ground.

The rule itself has never been legally settled ground, either. In 2008, a federal district court in Wyoming ruled the Roadless Rule was promulgated in violation of NEPA and the Wilderness Act and issued a nationwide injunction against it — one of at least 11 major court fights and a Supreme Court petition the rule has generated over 25 years.[3] A rule that has spent a quarter-century bouncing between injunctions, reinstatements, and appeals isn't a stable foundation for either fire management or access planning — it's a standing invitation for the next lawsuit.

I also want to see the Forest Service have real flexibility to expand recreation access, including motorized use, where local managers decide it makes sense — inventoried roadless areas already contain thousands of miles of motorized trail, and the rule's road-construction and reconstruction limits constrain the agency's ability to maintain, reroute, or expand that access over time.[4] And there's already a working precedent for a better path than blanket rescission or blanket preservation: Idaho and Colorado both petitioned for and received their own state-specific roadless rules years ago, tailored to their own land and communities instead of a one-size-fits-all national standard.[5] That's the model I'd want applied more broadly — local control over how roadless land gets managed, not a permanent freeze set by a rule written in 2001.

It is about time. The National Forests were established to be actively managed under a multiple use doctrine to protect watersheds. There are millions of acres of wilderness with no active management, millions more in National Parks with no active management focused solely on recreation, millions more of National Wildlife Refuges with little active management focused solely on wildlife. Eliminating the primary disturbance agent (I.e. doing fire prevention) in our interior west forests and not replacing it with management that emulates it to remove material and regenerate the forests is blind stupidity. The results are 100%predictable. Overgrown forests susceptible to bark beetles, high fuel loadings, and then uncontrollable wildfires burning out entire drainages. Fires that burn through riparian areas and burn so hot the soil layers that contain the forest nutrient base is destroyed setting that forests productivity back thousands of years. Destroying the very resources people say they want to protect. A thought out active management program can not only protect those resources, it can enhance fisheries, promote wildlife habitat, restore multi aged landscapes far less prone to wildfires and in the process provide for wood products to reduce our importing those products from Australia, New Zealand, Indonesia, Canada, etc. I was a US Forest Service Certified Silviculturist working much of my career in those western ecosystems and understand the the disturbance regeneration processes of those systems. Anyone that does understand them knows the folly, waste, and damage done to those forests by not actively managing, watching them die and then burn. Restore active management and restore the Certified Silviculturist Program so you have people that understand the systems and can prescribe appropriate treatments. Start the active management (fuel reduction) on the Sequoia National Forest that has become incredibly overgrown and is going to send a fireball up the hill into Sequoia National Park and kill the most magnificent trees on the planet, our giant redwoods.

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

I urge the Forest Service to retain the current Roadless Rule under Alternative 1 and reject the proposed nationwide rescission under Alternative 2 and any alternative that substantially weakens protections.

The DEIS stated purpose of the proposed rescission emphasizes greater local decision-making authority in forest planning processes. Yet, the original Roadless Rule was established in part due to the failure of the local forest planning process to maintain ecological, cultural, and public values of roadless areas to an adequate level. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protective measures.

As a [ _________ ], I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk and that putting these forests under local control would have little adverse impact on the ability to protect their values as undeveloped wildlands.

The DEIS recognizes that increased road construction can provide additional opportunities for wildfire response and fuels management, but it can also increase opportunities for unplanned human-caused ignitions. 96.2% of fires start within 800 meters of a road. It is clear that more roads mean more fires.

Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes.

The agency should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by an analysis of trade-offs026.08.25 of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks and hazards during suppression operations.

Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System. Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, and other ecological values. The Roadless Area Conservation Rule was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the Roadless Rule is rescinded or revised under Alternatives 2 and 3.

The Forest Service should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System.

The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, and other culturally significant areas.

I urge the Forest Service to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.

New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources.

Future consultation on individual projects is not an adequate substitute for considering these impacts before nationwide protections are removed.

For these reasons, I urge the Forest Service to retain the 2001 Roadless Rule under Alternative 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities.

I am definitely in favor of rescinding the roadless rule. I know from my experience that when the rule went into affect on 45 million acres of national forest land, our country experienced a larger amount of unhealthy insects and diseases in our forest lands, and it is the main reason for the increased acres burned in uncontrollable wildfires. Removing 45 million acres from active forest management was a huge mistake. The roadless rule went against the very design of our national forest, to manage and use our forest land for multiple uses. We already had a large amount of wilderness land designated by Congress. This rule was pushed through without a decision by Congress and effectively increased the amount of unproductive wilderness by 45 million acres. All of this roadless land was locked up and could not be managed by the professionals who knew what it takes to make our forests healthy and more resilient to wildfire.
As a professional forester for more than 38 years I saw examples where entire watersheds of single age (old) lodgepole pine forests within a roadless area were killed by bark beetle epidemics. Next, wildfire in all of that dead timber raged out of control in that watershed and spread to other watersheds, resulting in devastating flooding and erosion. If land managers were allowed to increase the age class diversity in those watersheds, when the bark beetle epidemic came, less area, maybe only ¼ of the watershed would have been killed. In other areas of ponderosa pine where fire had been excluded for decades, the stands became so thick and unhealthy, wildfire could no longer be controlled, and high intensity crown fires destroyed thousands of acres. If these stands could have been thinned, when a fire started, it would be more likely to be a beneficial underburn rather than an uncontrolled crown fire.
We must return commonsense active management to our national forests for the good of forest health and for the good of our country. Rescind this big mistake known as the roadless rule.