2001 Roadless Rule Revision

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

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

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

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

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

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

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.

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

Alaska salmon water is what brought me to care about this rule, and the devastation I have seen from clearcutting in the Northwest tells me exactly what rescinding it will cost. I have fished for salmon in Alaska. I look for woodpeckers, eagles, and moose in the forests. I paddle rivers and lakes that are crystal clear. When forests are removed, there is nothing left to photograph: the birds and wildlife are gone, and the landscape is blemished. That is the experience this proposal would accelerate, and I am filing this comment in opposition to the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001.

Alaska alone holds 150 inventoried roadless areas totaling 14,778,685 acres. Under both action alternatives described in the DEIS, the Tongass keeps zero acres of roadless protection. That means the waters where I fish for salmon, and the forests where I look for moose and birds, lose the baseline shield the 2001 rule provided. The Tribal Summary Impact Statement credits that protection with the recovery of deer and moose populations in Alaska specifically by preserving old-growth winter shelter. Rescission removes that footing. I ask that the agency explain, on the record, what substitute protections it has identified that would preserve old-growth winter shelter functions for moose at the scale the 2001 rule maintained.

On the question of statutory authority, the proposal argues that the 2001 rule exceeded the power Congress granted. A federal appellate court reviewed that question and held: "Exercising jurisdiction pursuant to 28 U.S.C. § 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." 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 the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and that it explain on the record the basis for any contrary position.

I have fished for salmon in Alaska, and the DEIS acknowledges what road-related sediment does to that fishery. The document 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." The affected area includes Essential Fish Habitat, and the science is clear that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities, and growth of coho salmon. What the DEIS does not do is carry the 90 percent figure forward into any projection of actual sediment delivery downstream. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas.

The rivers and lakes I paddle are crystal clear, and the drinking-water implications of this rescission deserve a complete answer. 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." Nine municipal watersheds are named in the DEIS for Alaska alone: Ketchikan, Petersburg, Sitka, Juneau, Wrangell, Kake, Klawock, Craig, and Hydaburg. The document claims that existing forest plans address sources of public drinking water, but it does not identify a single enforceable plan provision that replicates what 36 CFR 294.12 and 294.13 provide. I ask that the agency identify, forest by forest, which plan provisions are equivalent to those sections for municipal watersheds.

When forests are opened by roads, the birds I look for are the first to disappear. The DEIS cites the finding that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. That quantified harm sits in the document without being projected across the landscape the proposal would open. The same problem appears with habitat fragmentation: the DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet no projection applies that range to the 40.1 million acres of potentially affected environment. I ask that the agency apply the cited fragmentation range to those 40.1 million acres before any final decision is issued.

The agency must answer these questions fully and specifically. The 2001 rule should be retained.

Sincerely,

Steven Paulsrud
Muscatine, Iowa

Docket FS-2025-0001 / RIN 0596-AD66 / 91 Fed. Reg. 53827 (Aug. 20, 2026)
Special Areas; Roadless Area Conservation -- Proposed Rescission

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Department to select the No Action alternative.

I am a physician with 21 years of clinical experience, a father of two daughters, and a lifelong outdoorsman who has hunted, fished, hiked, camped, climbed, and biked across unroaded public land my entire life. I submit a detailed comment as an attachment and summarize its principal objections here.

1. The record does not show the 2001 Rule blocked needed management. The preamble asserts the Rule limited vegetation management but identifies no project denied or abandoned because of subpart B, no count of section 294.13(b) exception requests, and no data on the burden of that exception process. Under State Farm, an agency must examine the relevant data and articulate a rational connection between the facts found and the choice made. That connection is absent.

2. The Department's own figures contradict its justification. The preamble calls the effects "modest and localized" (53829) while designating the rule economically significant with impacts that "could exceed $100 million" (53830). It finds no substantial direct effects on States but substantial direct effects on Tribes for the same action (53831). It justifies rescission by wildfire risk while conceding expanded access "can increase human-caused ignition potential" (53829), and never nets the two. It reports that only 24 percent of inventoried roadless acreage lies in the wildland-urban interface -- meaning 76 percent is not, and the remedy is grossly overbroad relative to the stated need.

3. The economics do not support the action. Claimed timber revenue of $5.2 to $11.4 million per year is largely offset by an acknowledged $6.1 million per year in lost recreation benefit, and is dwarfed by the Department's own $6.9 billion deferred road maintenance backlog. Building new roads the agency cannot maintain converts a speculative one-time gain into a permanent unfunded liability and a chronic source of sediment in municipal watersheds.

4. The Regulatory Flexibility Act certification is unsupported. The Department certifies no significant impact on small entities two pages after estimating millions in annual losses falling on outfitters, guides, and recreation businesses that are small entities under 5 U.S.C. 601(6). It should withdraw the certification and prepare an Initial Regulatory Flexibility Analysis.

5. Reliance interests are solicited but never analyzed. Twenty-five years of reliance by water providers, state wildlife agencies, Tribes, and recreation-dependent businesses is identifiable and substantial. Regents requires the agency to assess and weigh it, not merely ask about it.

6. The process is incomplete. Of 64 requested Tribal consultations, only 29 had been held when this proposal published, and the Department itself found substantial direct effects on Tribes warranting consultation under E.O. 13175. ANILCA Section 810 subsistence hearings are scheduled after the comment period closes, so the public cannot comment on the subsistence findings.

As a physician I would add that the preamble treats two public health questions as afterthoughts: source-water protection for communities that draw municipal supply from National Forest watersheds, and wildfire smoke exposure, which is fire's dominant health burden and is nowhere analyzed.

Requests: withdraw the proposed rule and retain 36 CFR part 294, subpart B. In the alternative, extend the comment period to at least 120 days; complete all 64 Tribal consultations and the ANILCA Section 810 evaluation and reopen comment; withdraw the RFA certification; and publish the exception-request record, a forest-by-forest inventory of which plans would maintain roadless protections absent subpart B, and a reliance-interest analysis.

Full comment attached.

Stacy Johnson
Salt Lake City, Utah
August 30, 2026

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

Forty years of fishing in Alaska teaches you something about delicate ecosystems. Building more roads in or near the Tongass will damage what remains, and I am writing to make sure that concern is on the record before this agency acts.

The Tongass is the largest intact temperate rainforest left on Earth. It holds over 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by United States national forests. Executive Order 14153 directs the agency to exclude the Tongass from the 2001 Roadless Rule entirely, and the Federal Register rescission notice confirms this in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. Nine municipal watersheds, Ketchikan, Petersburg, Sitka, Juneau, Wrangell, Kake, Klawock, Craig, and Hydaburg, are named in the DEIS as affected. Five species of Pacific salmon use those streams. I have fished in Alaska for over 40 years. I am not speaking in abstractions.

With ownership comes responsibility, and right now this agency is not meeting its own. The DEIS acknowledges its own financial condition: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." The same document states that road mileage, deferred maintenance and management costs are likely to increase under the proposal. It should never bite off more than it can chew. I ask the agency to name the specific funding source for new road construction and maintenance and to state its projected change in the deferred maintenance backlog.

The economic case for this rescission is not made. The Cost Benefit Analysis states that "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." That range runs from a loss to a gain. The cost column excludes road construction costs the same document quantifies at $80,000 to $100,000 per mile, and roughly $500,000 per mile in Alaska. The upper bound assumes maximum potential harvest the analysis itself calls uncertain. This document was placed in an agency file folder, not on the docket. I ask that the agency place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and maintenance costs included, and show the arithmetic behind any claim that impacts could exceed $100 million.

The small-business certification is equally contradicted by the agency's own numbers. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting analysis reaches its no-impact conclusion by spreading losses across the national average firm rather than assessing the guides and outfitters actually holding permits in these areas. The agency must withdraw that certification and assess the entities actually operating in the affected roadless areas.

Finally, "the proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency cannot ask the public to comment on consequences it has declared out of scope. Wilderness areas must be managed thoughtfully with long-term vision, and that requires honest analysis now, not deferred review later. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action.

I wrote to the Trump administration in 2025 and heard nothing back. I don't think they are listening and do not care what we think or how we feel. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the 2001 rule. It has held none to undo it. In the words and spirit of Theodore Roosevelt: preserve our land.

Sincerely,

Sincerely,

Joe Hermann
Denver, Colorado

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.

I'm commenting on the Regulatory Flexibility Act certification, because I'm the kind of business it says doesn't exist. Sunlight Sports has sold gear in Cody since 1971, hard against the Absarokas. Five inventoried roadless areas on the Shoshone sit within a day of my front door - Trout Peak, Wapiti, the South Fork, Carter Mountain, Francs Peak - and that's where my customers are headed when they walk out of here with a pack on.

The Forest Service has certified that this rescission won't have a significant economic impact on a substantial number of small entities, because it creates no new recordkeeping, reporting, or compliance requirements. That's accurate, and it's the wrong measurement. A regulatory flexibility analysis looks for burden on a regulated party. Nobody at my address is regulated by the Roadless Rule. We are capitalized by it. The analysis has no line for that, so it found nothing.

Here is what it would have found. Most mornings in June somebody puts a map on our counter and asks what they need. That conversation is the business. At least a third of our annual revenue comes from people going into the backcountry, which in Cody means the Shoshone. Our staff wrote the local guidebook, and most of the hikes in it that aren't in Yellowstone begin in or cross inventoried roadless area. We guide clients in those same drainages under a Forest Service permit, which is a federal authorization to sell an experience whose value comes entirely from the ground the agency proposes to reclassify. Put a road up one of those drainages and the agency hasn't restricted my permit. It has marked down what the permit lets me sell.

Park County took $519 million in visitor spending last year. Wyoming's outdoor recreation economy runs $2.3 billion in value added and 16,500 jobs. It grew half a percent in 2024 against four percent nationally. This is a thin economy, and what holds it up is the difference between our side of the Absarokas and everybody else's.

The agency's own draft EIS makes this argument for me. It projects between $4.6 and $10.6 million a year in benefit to the timber industry, against as much as $9 million a year in lost visitor spending in nearby communities. At page 45 it concedes timber revenue would not cover the cost of building and maintaining the new roads. At page 43 it acknowledges those roads add to a $6.9 billion maintenance backlog the agency already can't work through. An analysis that puts the recreation loss in the same range as the timber gain, and says the roads won't pay for themselves, has described a significant economic effect on somebody. It just didn't go looking for who.

Wildfire is the stated reason for all of this, and in Wyoming it's backwards. Trout Unlimited's read of Forest Service data puts 32 percent of Wyoming's treated National Forest acreage inside inventoried roadless areas, done under exceptions the current rule already contains. Aplet, Hartger and Dietz published thirty-three years of ignition data in Fire Ecology this year: 7.99 ignitions per thousand hectares within fifty meters of a road, 1.97 inside roadless areas, nearly all of the gap human-caused. The agency's own draft carries the same finding at pages 89 and 101. Building roads to reach fire, in country where fire arrives on roads, gets you more fire.

I want to be straight about what I'm objecting to. Rescission doesn't order anybody to log anything. It doesn't turn a trail into a road. It doesn't touch the Endangered Species Act or NEPA, and nothing in the Absarokas gets cut this fall.

What it does is move where the protection lives. Today a road proposal in Wapiti or on Carter Mountain has to clear a national rule. After rescission it clears a forest plan, on its own revision cycle, in front of whoever is running that office that year. I buy inventory nine months ahead. I sign leases. I hire people in April for a season that pays the winter. All of it assumes something about what this country will be in five years, and the 2001 rule has been the most reliable input I have. It held through four administrations, two adverse rulings out of Judge Brimmer's court here in Wyoming, a Tenth Circuit reversal, and a Supreme Court that declined to take it up in 2012.

I'm asking the agency to withdraw the proposed rescission. Failing that, withdraw the small entity certification and prepare an initial regulatory flexibility analysis that examines gateway community businesses whose revenue depends on the recreational character of inventoried roadless areas, including outfitters and guides holding special use permits and the retailers who supply them. And give it the sixty to ninety days a rule this size normally gets. Thirty days doesn't build a record next to the six hundred public meetings and 1.6 million comments that made this rule.

There will be somebody at the counter with a map next June. I'd like the map to still be right.

Wes Allen Sunlight Sports, Cody, Wyoming

To whom it may concern:

I am writing to express my strong opposition to the U.S. Department of Agriculture and Forest Service's proposed rule to rescind the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B). For 25 years, the 2001 Roadless Rule has provided vital, stable protections for approximately 58.5 million acres of pristine National Forest System lands. Dismantling this foundational safeguard threatens critical ecosystems, burdens taxpayers with unmanageable infrastructure liabilities, and fails to withstand legal and scientific scrutiny.
1. Flawed Justifications Regarding Wildfire and Forest Health
The agency's primary rationale—that lifting roadless protections is necessary to mitigate catastrophic wildfire risk—contradicts established fire ecology and the operational reality of backcountry management.
Increased Human Ignitions: Scientific consensus demonstrates that human-caused fire ignitions correlate directly with road access. Constructing new roads into remote backcountry introduces vehicular traffic, industrial equipment, and recreational activity, exponentially raising the risk of fire starts where natural buffers currently exist.
Existing Exceptions Suffice: The 2001 Roadless Rule (36 CFR 294.13(b)) already contains targeted exceptions for small-diameter timber harvesting and vegetation management explicitly designed to reduce hazardous fuel loads. Using wildfire as a pretext to authorize broad commercial sawtimber removal and permanent road-building ignores the targeted mechanisms already available to land managers.
2. Fiscal Irresponsibility and the Maintenance Crisis
Rescinding protections to expand commercial timber and infrastructure access directly conflicts with the agency's current fiscal realities.
Unpayable Infrastructure Liabilities: The Forest Service is already struggling with a $6.9 billion deferred maintenance backlog for existing roads and bridges. Constructing new permanent roads into steep, unstable backcountry terrain creates permanent liabilities that the agency cannot fund, degrading environmental quality while compounding safety hazards across the existing road network.
Uneconomic Timber Harvest: Backcountry timber extraction in remote roadless areas yields marginal economic returns that frequently fail to cover the high costs of road construction, bridge installation, and long-distance hauling, resulting in de facto taxpayer subsidies for isolated commercial operations.
3. Legal and Procedural Deficiencies
The proposed rescission exposes the agency to severe legal vulnerabilities under the Administrative Procedure Act (APA) and the National Environmental Policy Act (NEPA).
Arbitrary and Capricious Reversal: Under State Farm, an agency reversing a long-standing policy must provide a reasoned explanation supported by empirical evidence demonstrating that conditions have fundamentally changed. The agency's reliance on executive orders and shifting political priorities does not overcome twenty-five years of established science showing that local forest planning processes are insufficient to prevent incremental fragmentation.
Procedural Inadequacy: Issuing a truncated, roughly 30-day public comment window during late summer for a major, decades-old rule affecting nearly 50 million acres of public lands and a complex Environmental Impact Statement inhibits meaningful public, scientific, and Tribal review, violating foundational notice-and-comment requirements.
Contiguous roadless areas represent our nation's finest remaining core habitats, critical clean municipal drinking water sources, and vital refuges for threatened and endangered species. Trading permanent landscape stability for marginal, uneconomic timber yields and unpayable infrastructure burdens is contrary to the public interest.
The U.S. Department of Agriculture must immediately withdraw the proposed rescission of 36 CFR Part 294, Subpart B, and instead maintain the 2001 Roadless Rule while focusing finite agency resources on maintaining existing infrastructure and conducting targeted fuels reduction where it is most needed.
Sincerely,
SAN

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

The scenery of nature matters to me. Capturing it, listening to it, protecting the places where it still exists, those are not abstract goals. They are why I am filing this comment against the proposed rescission of the 2001 Roadless Area Conservation Rule.

Healthy and plentiful wildlife, including predator species, is the key to biodiversity and resilient environments. I believe we should all work to protect their habitats from the disruptions and destructive activities that would cause them to flee. Roads are exactly that kind of disruption.

The agency's own record also says it plainly about unnatural fires: "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." If the agency accepts that finding, it cannot simultaneously argue that opening these areas to roads is a responsible approach to fire management. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile this rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas.

Clean water is derived from protected watersheds without impairment by extra amounts of sediment from roads and the activities that require them. That is not my formulation alone. The agency's own analysis identifies roads and their facilities as capable of producing up to 90 percent of the sediment from a timber sale. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas. Opening these lands to roads puts that protection at risk for a return the agency's own numbers cannot justify. The record shows 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." The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. The agency must explain on the record how it justifies expanding a road system already carrying a $6.9 billion maintenance backlog on numbers like these.

The proposal argues that state-by-state approaches can replace the national rule. The agency's own prior rulemaking record shows the agency itself described that path as rejecting the rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. But the agency's own prior finding was that local, incremental decision-making can erode nationally significant roadless values in ways a patchwork of state plans cannot prevent. The Ninth Circuit agreed when it reviewed the last attempt to substitute state-specific rules for the national one. The agency has not explained how this proposal avoids those same deficiencies, and it must do so before this rescission moves forward.

Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. A federal appeals court already addressed that question directly. The Tenth Circuit 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." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and that it did not create de facto wilderness. The agency must state clearly, in this record, the basis for any position that contradicts that holding.

I take photographs of nature on vacation. I listen to the sounds of places that still have healthy amounts of wildlife and native vegetation. I want those places to exist. This rescission does not serve that interest, and the agency's own data do not support it.

Sincerely,
Janette Dean
Caledonia, MN

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule and remove and reserve 36 CFR Part 294, Subpart B.

The 2001 Roadless Rule has protected 58.5 million acres of inventoried roadless areas for 25 years, safeguarding clean drinking water sources, intact wildlife habitat, and some of the last unfragmented forest landscapes in the National Forest System. Rescinding this rule and pushing all roadless management decisions down to individual forest-level land management plans would trade a stable, science-based national standard for a patchwork of local decisions vulnerable to shifting budgets, political pressure, and inconsistent implementation across more than 150 national forests.

I have several specific concerns:

- Loss of durable protection. Land management plans can be amended or revised at any time by local officials. Unlike the current rule, they offer no lasting floor of protection for roadless areas' ecological integrity, water quality, or recreational value.
- Tribal opposition and inadequate consultation. The agency's own tribal summary shows the majority of Tribes consulted oppose this rescission, citing threats to sovereignty, cultural sites, and subsistence resources, and describing consultation as insufficient given the scope of the change. That opposition should weigh heavily against moving forward.
- Underestimated cumulative impacts. The proposed rule's economic analysis treats near-term effects as "modest," but acknowledges that subsequent land management plan amendments could open far more acreage to roadbuilding and logging than the initial estimates capture. The public deserves a full accounting of that downstream risk before this door is opened.
- Weak justification for a wholesale rescission. Concerns about wildfire risk and forest health could be addressed through the exceptions and amendment processes already available under the existing rule, rather than eliminating national protections altogether.
- Recreation and local economies. Millions of visitors rely on roadless areas for quiet, undeveloped recreation. The agency's own analysis estimates real economic losses to recreation-dependent communities, while projected timber and mineral benefits are speculative and limited.

For these reasons, I urge USDA to withdraw this proposal and retain the 2001 Roadless Rule.

To whom it may concern.
I am a 68 year old retired timber industry worker and live in what used to be referred to as the timber capital of the world. Roseburg Oregon. With a long history of timber workers in my family.

Over the last 40 years I have witnessed the devastating effects of poor timber and land management, excessive fuel loads on the forests floor, mill closures, devastated county budgets, massive fires and getting worse. And perhaps the worst and absolutely most unforgivable is after a fire is not going in and cleaning up the forest after a fire. Absolutely unforgivable and a waste of resources. Shame on whom ever thinks this is a good idea.
One particular fire that happened in Douglas county on the Umpqua national forest was the 1988 apple creek fire. That burn scar is absolutely an eye sorer and has burned at least two other times in the last 38 years. Had that been treated and replanted there would be a beautiful green forest that at this age would be ready for thinning producing a valuable resource, jobs and county receipts. And this is not even the worst example on the Umpqua national forest.

A prominent enviro-maniac back in the eighties. A Mr. Andy Curr at a meeting at the Douglas county courthouse right after the apple creek fire when asked about logging and rehabilitating burns, famously said and I quote. Logging a burn is like raping a burn victim. My reply to that and by any body that knows anything about burn victims is the first thing you do after a burn is to remove all the dead and dying skin and start replacing it with new and healthy skin. And that is way it used to be done.

Fire is a useful tool in fact or at least legend even the Native American peoples used fire to control over growth, or should I say under growth to enhance game grazing but because of aggressive fire suppression over the last hundred years that is a limited tool. But grazing, logging and recovering resources can and should be aggressively deployed. It would create jobs, tax revenue for communities and maybe even stop the devastation caused by wildfires. These lands owned by the people are meant to be for multiple use. That means grazing, logging, mining and recreation. With the roadless rule all of that is limited and I support canceling the roadless rule and get our forest back to multiple use.
Sincerely, Kenneth Finney.