Substantive Analysis

2001 Roadless Rule Revision

Counting comments is only the start. Every substantive comment is read and scored for what it actually contributes — evidence, legal argument, engagement with the environmental analysis, alternatives, and specific requests. The document those comments engage is on the site too: the annotated DEIS walks the agency’s draft analysis issue by issue, with sample comments on each identified issue.

How substantive is the input?

Share of the 333,894 substantive comments that meaningfully do each of the following.

Makes a specific request

Identifies an analytical gap

Draws on first-hand local knowledge

Offers an alternative

Cites specific evidence

Names a specific place

51%

Cites law or regulation

Engages the environmental analysis

How hard are they to dismiss?

A substance score says how much a comment contains. It does not say whether the agency can set it aside. Federal rules let an agency answer a comment by saying the analysis already covers it, that it shows no cause and effect, or that it is not substantive at all — and the four things that make a comment substantive are not equally good at surviving those replies. A comment that names a statute is the hardest to dismiss; one that only asserts a problem is the easiest.

These are the 56,943 comments rated so far. It is a smaller number than the comment counts elsewhere on this page: where thousands of people sent the same campaign letter, that letter is rated once rather than once per signature.

A1 — cites the law itself — the agency cannot say the analysis already covers it, and cannot certify it as non-substantive

A2 — shows a cause and effect, or offers an alternative — a “no cause and effect” dismissal cannot reach it

A3 — substantive, but every standard dismissal is still available

A0 — does not clear the substantive bar — counted, not answered

92%

By substance score band — the cells off the diagonal are the point. A short comment citing a statute must still be answered; a long, detailed one with no legal or causal hook can be set aside.

What the strongest comments are about

Every substantive comment is scored; the top tenth within each stance (4,472 exhibits) is the “gold” set. This is how those exhibits’ topic mix differs from the substantive pool they are drawn from — bars to the right are topics the strongest comments raise more often than the pool, to the left less often (percentage points).

How comments are scored

A strong public comment does more than register an opinion. A model reads each substantive comment and scores it 0–3 on eight things — 3 means the comment does that thing clearly and well, 0 means not at all — the eight add up to a substance score out of 24. In the exhibits below, the passages that earned points are shaded in the category’s colour — the same colours shown in the score panel above each comment.

Local knowledge — Draws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.

Evidence — Backs claims with specific facts, data, or research.

Legal — Cites statutes, regulations, or legal obligations.

EA analysis — Engages the agency's environmental analysis directly.

Analytical gap — Identifies something the analysis fails to address.

Alternative — Proposes a different course of action.

Request — Makes a specific, actionable request of the agency.

Specific place — Names a specific location — from a region down to an exact creek, trail, road, or map reference.

The strongest opposing comments

The 10 opposing comments with the highest substance scores. Each opens with its scorecard, then the comment with its scored passages shaded — hover a mark to see what it earned.

Substance score19 / 24A1 · Must be answered — it names the law

Local knowledge2 / 3

Evidence1 / 3

Legal2 / 3

EA analysis3 / 3

Analytical gap3 / 3

Alternative2 / 3

Request3 / 3

Specific place3 / 3

I regularly visit the inventoried roadless areas of the Sam Houston National Forest in Texas (Big Creek, Winters Bayou, Big Woods, Little Lake Creek) and formerly visited the San Bernardino National Forest.

I oppose the rescission and comment on both the proposed rule and the Draft EIS. I request a specific response to each numbered item in the Final EIS.

1. The cost-benefit analysis does not support the action

The preamble estimates annual recreation losses of about $6.1 million against $5.2-11.4 million a year in Treasury and Forest Service revenue, a figure assuming harvest across every operable acre, which the Department calls unlikely. It states these against a $6.9 billion road maintenance backlog, and concedes impacts could exceed $100 million.

The FEIS should state plainly whether the projected timber revenue exceeds the lifecycle maintenance cost of the roads required to obtain it. If it does not, the economic rationale fails.

2. The wildfire rationale is contradicted by the Rule's text

36 C.F.R. § 294.13(b)(1)(ii) already permits cutting generally small diameter timber to maintain or restore ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects. Section 294.12(b) permits roads for public health and safety. Nothing restricts prescribed fire, managed wildfire, hand thinning, or mastication. Small diameter material is what fuels reduction targets; the Rule restricts commercial removal of large trees, which is not fuels reduction.

The preamble concedes that greater public access can increase human caused ignition potential. The Department cites the Rule's statement that such cutting "is expected to be infrequent," but that states an expectation, not an operative limit: it sets no cap and adds no approval condition.

I therefore request that the FEIS identify, by project name, forest, and year, each hazardous fuels project in the last ten years a responsible official could not implement solely because of the 2001 Rule. Without this list, the stated purpose lacks record support under Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983).

3. The treatment statistic does not establish causation

The low treatment rate in high hazard roadless acreage since 2014 is equally consistent with appropriation limits, workforce capacity, and WUI prioritization. The preamble itself says budget and physical constraints will limit road construction after rescission, conceding the constraint is fiscal. The FEIS must analyze these rather than assume the Rule is the cause.

4. Reliance interests are unaddressed

The Department invites comment on reliance interests. Reversing a twenty five year policy requires more detailed justification where serious reliance interests exist (FCC v. Fox Television, 556 U.S. 502 (2009); Encino Motorcars, 579 U.S. 211 (2016)). Land management plans were revised against this backdrop and allocated timber production elsewhere; recreation businesses, outfitters, and water providers invested on the same assumption. The proposal analyzes none of it.

5. "This rule authorizes nothing" does not excuse NEPA analysis

The Department justifies rescission by its expected effects while failing to analyze them. Its own figures, permanent roads newly permissible across 18.2 million acres and temporary across 11.3 million, are foreseeable consequences NEPA requires it to examine. The FEIS must quantify sediment and drinking water impacts, ESA effects and § 7 status, and cumulative effects with the reinstated Alaska Roadless Rule and E.O. 14225 timber targets.

6. The range of alternatives is inadequate

The DEIS carries forward only three alternatives: no action and two rescission variants. No intermediate conservation alternative was analyzed in detail, including those Tribes requested. The FEIS must analyze:

(a) retaining the Rule while broadening and streamlining the § 294.13(b)(1)(ii) fuels exception near the WUI, with mandatory temporary-road decommissioning

(b) a state and Tribal petition process

(c) delegating exception approval to forest supervisors, with deadlines

(d) geographically limited rescission supported by unit-level evidence

7. The process is inadequate

The Department allows 30 days for a proposed rule, three volume Draft EIS, and cost benefit analysis governing 58.5 million acres, with hearings only in Alaska under ANILCA § 810. Of 64 Tribal consultation requests, 29 have been held, and the Department acknowledges majority Tribal sentiment opposes the rescission.

I request a comment period of no fewer than 90 days, hearings in each affected state, and completed tribal consultation before any final action.

Requested action: withdraw the proposal and retain 36 C.F.R. Part 294, Subpart B. Alternatively, extend the comment period, hold hearings outside Alaska, complete consultation, and analyze the item 6 alternatives.

Respectfully submitted,
an anonymous member of the public

In short: The comment establishes that the proposed rule contains deficiencies in its cost-benefit analysis, wildfire rationale, treatment statistics, reliance interest analysis, NEPA compliance, range of alternatives, and public comment process, and requests specific procedural and substantive changes to the rulemaking.

Substance score19 / 24A1 · Must be answered — it names the law

Local knowledge1 / 3

Evidence3 / 3

Legal2 / 3

EA analysis3 / 3

Analytical gap3 / 3

Alternative2 / 3

Request2 / 3

Specific place3 / 3

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

In short: The comment establishes that the agency's justification for rescinding the Roadless Rule is contradicted by its own data showing higher human-caused ignition rates on roaded land, and requests that the agency quantify the net wildfire effects and specific regulatory burdens on the record before proceeding with nationwide rescission.

Substance score18 / 24A2 · Hard to dismiss — it shows cause and effect

Local knowledge3 / 3

Evidence3 / 3

Legal0 / 3

EA analysis3 / 3

Analytical gap3 / 3

Alternative1 / 3

Request2 / 3

Specific place3 / 3

I am a forest scientist who researches wildfire and heat/drought impacts on western US forests in OR, WA, CA, and CO. I am writing to strongly object to the proposed removal of the roadless rule, which purportedly is about reducing wildfire risk. This is FALSE - the rescinding of the roadless rule is really a timber and deregulation rule that mentions fire but is not about fire at all. Fire ignition data, including the USFS's 2001 finding that roads increase human-caused fire, rebut the rationale behind this proposed change. People start most fires in the American west. Increased public road access will raise the number and frequency of wildfires, without doubt. And USFS forest management plans already restrict harvest on 26.7 million acres regardless of the roadless rule. Additionally, the USFS cannot even maintain the forest roads it has already built, as it has a roughly $6.9 billion maintenance backlog on its roads!

In addition, the proposed change makes NO economic sense and is wasteful to American taxpayers like myself. The USFS' own cost-benefit analysis shows a net present value range of negative $92 million to positive $199 million over fifteen years. The timber benefit of $9.9 to $22.0 million has to be weighed against $6.1 million in recreation losses and $5.3 to $11.5 million in forgone passive use. And there is a glaring arithmetic error: Table 1 lists minimum annual forgone benefits as $5.3 million while footnote 6 says costs include both the $6.1 million recreation loss and the $5.3 to $11.5 million passive use loss. The minimum should be $11.4 million!

Critically, the biological assessment is a draft and incomplete. Even the draft finds this action is likely to negatively impact at least 300 listed species and some 45 designated critical habitats. The impacted species include grizzly bears, wolverines, gray wolves, Canada lynx, Mexican wolves, and fisher cats. Section 7 of the draft consultation is incomplete. A 30-day comment period based on on an incomplete biological assessment is not a lawful basis for a final rule.

In conclusion, I am urging you to select Alternative 3, or better yet, no change to the Rule. The USFS' own analysis shows that limiting rescission to within a half mile of existing roads and the wildland-urban interface captures roughly 80% of the timber benefit on a fraction of the footprint — this is exactly where the fire prevention rationale is strongest! Why is the propsoal not focused on this if it's about fire? Also, please consider alternatives that multiple tribes requested that the agency did not analyze.

Thank you.

In short: The comment establishes that the proposed rescission of the roadless rule is factually unsupported by fire data, contains a specific arithmetic error in Table 1 regarding forgone benefits, relies on an incomplete biological assessment and Section 7 consultation, and fails to analyze tribal-requested alternatives, thereby documenting a significant deficiency in the agency's analysis.

Substance score18 / 24A1 · Must be answered — it names the law

Local knowledge1 / 3

Evidence3 / 3

Legal2 / 3

EA analysis3 / 3

Analytical gap3 / 3

Alternative1 / 3

Request2 / 3

Specific place3 / 3

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.

In short: The comment establishes that the Draft EIS fails to provide a watershed-scale aquatic effects analysis for ESA-listed salmonids in the Nooksack and Skagit watersheds, specifically regarding bull trout, Chinook, and steelhead, and requests the disclosure of the methodology behind the $6.1 million annual recreation loss estimate.

Substance score20 / 24A1 · Must be answered — it names the law

Local knowledge1 / 3

Evidence3 / 3

Legal2 / 3

EA analysis3 / 3

Analytical gap3 / 3

Alternative2 / 3

Request3 / 3

Specific place3 / 3

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge USDA to withdraw it and adopt the No Action alternative. The preamble's own findings do not support the stated purpose and need, and the record fails to analyze costs the agency itself acknowledges.

I live in Arizona and Vermont, and have seen firsthand the ecological and economic benefits of the rule. In addition to using public lands for recreation, these lands protect our nation's heritage, and natural resources we will rely on into the future. As Arizona is currently in a water crisis due to decreased Colorado River flows, intact national forests that ensure clean water supply and aquifer recharge are essential--and any change to this rule can be read as disrespect for the citizens of that state. Near Tucson, where I live, the The Upper Rincon and Santa Rita IRAs on the Coronado National Forest protect sky island headwaters above the Tucson basin, and the Arizona National Scenic Trail crosses both. USDA should analyze the rescission's effects on these watersheds and on recreation along the trail.

The agency's findings undercut its rationale. USDA justifies rescission by citing wildfire, insects, and forest health (91 FR 53828), yet concedes management opportunities would be "modest and localized" (53829). Projected timber gains assume harvest across all 4.8 million operable acres, which USDA calls "unlikely" (53829). Speculative benefits cannot rationally justify removing protections from tens of millions of acres. Under Motor Vehicle Mfrs. Ass'n v. State Farm (1983), the agency must show a rational connection between the facts found and the choice made. It has not.

Drinking water impacts are unanalyzed. The preamble acknowledges roadless areas at high risk of intense fire that threatens "drinking water sources" (53829) and records Tribal concern for water quality (53832), but quantifies no effect of new roads, harvest, or leasable mineral development on sediment, turbidity, or treatment costs for downstream utilities. USDA should identify affected public water systems by watershed and quantify these effects before any final action.

USDA admits the rule will raise human-caused ignition risk. The preamble states greater public access "can increase human-caused ignition potential" (53829). The fire benefit it cites, fuel treatment in the wildland-urban interface, involves 9.8 million acres, about 24 percent of affected areas (53829), and the 2001 Rule already permits cutting small-diameter timber to reduce uncharacteristic wildfire effects (36 CFR 294.13(b)(1)). A narrower alternative exists: clarify that exception for WUI fuels work while keeping protections elsewhere. USDA must explain why it rejected that option.

Economic costs are understated and fall on small entities. USDA estimates $6.1 million per year in lost recreation benefits, plus closures, noise, user conflicts, and trade-offs for tourism (53829-30), and says impacts could exceed $100 million (53830). Outfitters, guides, and tourism operators are largely small businesses, yet USDA certifies no significant impact on small entities (53831). That certification conflicts with its own findings. New roads would also add to a $6.9 billion deferred maintenance backlog (53829) that the analysis does not cost out.

Wildlife and subsistence analysis is incomplete. The preamble lists threatened and endangered species and plant and animal diversity among the values at stake (53828), notes possible long-term effects on commercial fisheries (53830), and defers ANILCA Section 810 subsistence hearings to a later notice (53830). Finalizing before that analysis is complete would be premature.

Tribal consultation is incomplete. USDA concedes the rescission has substantial direct effects on Tribes, that most Tribes consulted oppose it, and that only 29 of 64 requested consultations have been held (53831-32). The final Tribal impact statement will appear only with the final rule. Proceeding first is inconsistent with E.O. 13175 and the federal trust responsibility.

Reliance interests must be weighed. USDA invites comment on reliance interests (53830). Under DHS v. Regents (2020), an agency changing course must consider them. Water utilities, recreation businesses, Tribes, and communities have relied on these protections for 25 years.

I request you withdraw the proposed rule and adopt No Action. The USDA justifications for changing this rule are contradicted within its own documents. This increases new fire risk, decreases water quality, and disproportionately affects the economies of smaller towns and rural America. This cannot be justified and cannot go through.

In short: The comment establishes that the agency's proposal to rescind the Roadless Area Conservation Rule is unsupported by its own findings, specifically citing deficiencies in the analysis of drinking water impacts, wildfire ignition risks, economic costs to small entities, and incomplete tribal consultation, while requesting the adoption of the No Action alternative.

Substance score20 / 24A1 · Must be answered — it names the law

Local knowledge3 / 3

Evidence3 / 3

Legal2 / 3

EA analysis3 / 3

Analytical gap3 / 3

Alternative0 / 3

Request3 / 3

Specific place3 / 3

I spent college up in the western NC mountains and their beauty match no other, destroying these lands for development and logging would be detrimental to tourism and the environment.

I am an archaeologist who loves to hike in nature and protect lands.

Land is already being destroyed and developed on in many other places in the state, including where I live now. To see my refuge be affected by greedy corporations who want land and money hurts my heart greatly. Protect these lands, the diversity they hold and the emotional significance to millions of people.

I recently went hiking in the Linville Gorge and visited the falls, it was amazingly beautiful and refreshing. After many trails were affected by Hurricane Helene and have only recently been reopened the revenue lost for those years will only grow if land is taken.

I first hiked in the Appalachian mountains and I wish to take my kids there for their first hikes. I need them to experience the beauty of one of the oldest mountain ranges in the world in its natural state not in capitalistic infrastructure the exudes greed.

Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality.

Mineral extraction, oil and gas development, and associated infrastructure permanently industrialize otherwise undeveloped landscapes.

Roadless areas store carbon, buffer temperature extremes, and provide intact refugia where species can shift in response to a warming climate.

DEIS Regional Carbon Accounting Omits a Forest Service Region and Drops the Source's Own Attribution of the National Forest System Sink

The Draft EIS's National Forest System carbon baseline misstates the source it cites, in two respects that appear within a single sentence and that the source itself resolves.

At Volume I, page 74 (Alternative 3 – Modified Roadless Rule/IRA Boundaries, Potentially Affected Environment, Forest Vegetation), the Draft EIS states: "In 2021, forested lands within the national forest system sequestered 43.5 million metric tons (MMT) CO2, which follows national trends of increasing forest biomass in recent decades, however forests in the drier and more fire prone Intermountain, Rocky Mountain, Northern, and Southwestern Forest Service regions had net carbon loss (31.5 MMT CO2) while the remaining regions had a net carbon increase, sequestering 63.5 MMT CO2 (Domke et al. 2023)."

First, the sentence's components do not produce its own total. A net loss of 31.5 MMT set against a net gain of 63.5 MMT yields a net sink of 32.0 MMT, not the 43.5 MMT the same sentence reports. The source shows where the discrepancy comes from. Domke et al. 2023, table 3 ("Carbon stock changes (net flux) from forest land remaining forest land within the National Forest System (NFS) by NFS region and year (MMT CO2 Eq.)"), gives 2021 net flux for all nine National Forest System regions. The four regions the Draft EIS names as net-loss regions are the four with positive values — Intermountain 11.5, Rocky Mountain 12.2, Southwestern 6.9, and Northern 0.9 — which sum to 31.5, the figure the Draft EIS reports correctly. The remaining five regions are Alaska (4.0), Eastern (11.5), Pacific Northwest (28.3), Pacific Southwest (5.7), and Southern (25.5), which sum to 75.0 MMT of net uptake, not 63.5. The Draft EIS's 63.5 is 75.0 less the Eastern Region's 11.5: the Eastern Region has been dropped from the uptake side while the total continues to include it. Restoring it reconciles the sentence, because 75.0 less 31.5 is 43.5, which is table 3's own net line for 2021.

Both are factual corrections within the meaning of 7 CFR 1b.7(f)(2)(v), and under 7 CFR 1b.7(f)(3) the agency should cite where in the Final EIS each correction is accounted for. The issue is substantive under 7 CFR 1b.11(a)(53) because it bears on compliance with applicable laws: an agency may not rest an environmental analysis on a characterization that the record it chose to rely on contradicts. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A). Domke et al. 2023 is a Forest Service publication cited in the Draft EIS's own literature cited section, so these corrections require nothing of the agency beyond agreement with its own source.

In short: The comment establishes that the Draft EIS's carbon accounting in Volume I, page 74 contains a mathematical error by omitting the Eastern Region's 11.5 MMT from the net uptake calculation, resulting in a discrepancy between the reported total (43.5 MMT) and the sum of its components (32.0 MMT), which contradicts the agency's own cited source, Domke et al. 2023, Table 3.

Substance score18 / 24A1 · Must be answered — it names the law

Local knowledge2 / 3

Evidence3 / 3

Legal2 / 3

EA analysis3 / 3

Analytical gap2 / 3

Alternative0 / 3

Request3 / 3

Specific place3 / 3

Dear Ms. Rollins:

As an outdoor enthusiast, I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to note that the Department's statutory obligations under the Multiple Use — Sustained Yield Act and the National Forest Management Act require a genuine accounting of the non-commodity values the Rule protects — an accounting that the proposed rescission's record has not provided.

I've been lucky to call the PNW home for the last 26 years and the Larch and Gifford Pinchot areas around the Gorge and Mt. Hood mean more to me than can adequately be expressed. I urge to resist the fascistic impulse to acquiesce towards corporations with nothing to offer beyond the carving up of our shared outdoor resources.

We live in an area that is still dealing with the impacts of the Celilo Falls destruction. I urge you again to reconsider allowing additional development in an effort to boost the bottom lines of short term corporate interests. Like the falls, once these resources are destroyed we cannot get them back.

Regarding the Larch in the Mt. Hood National Forest, Oregon:

The threat mechanism classified as 4.1 - Roads & railroads (IUCN-CMP 4.1) is actively degrading habitat for Cascade Torrent Salamander (Rhyacotriton cascadae, G3) in the Larch Inventoried Roadless Area, Mt. Hood National Forest, at Serious - slight severity across Restricted (11-30%) scope.

The persistence of Cascade Torrent Salamander in Larch under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 4.1 - Roads & railroads to one that accelerates it.

NEPA requires the agency to take a hard look at the effects of rescission on Cascade Torrent Salamander (Rhyacotriton cascadae) in the Larch IRA. The DEIS fails this standard without site-specific analysis of 4.1 - Roads & railroads at the severity and scope documented by NatureServe.

"The expansion of road networks degrades the slope stability and further increases the susceptibility to landslides. Deforestation, infrastructure construction, and mining triggered about 16% of fatal landslides from 2004 to 2016. High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians, which means that forests protecting both biodiversity and landslide risks to human society are important conservation targets."
— Proceedings of the National Academy of Sciences, 2022

The "No Direct Effect" Framing Is Contradicted by the Assessments' Own "Reasonably Certain" Findings and by the Record

The USFWS Biological Assessment frames the action at page 377: "The Forest Service has determined that rescinding the Roadless Rule will have no direct effect on ESA-listed resources because it does not authorize, fund, or carry out future forest management activities." The same document undoes that framing. Page 376: "it is reasonably certain that active forest management and road construction will increase in these areas." Page 24: "it is reasonably certain to occur that there would be an increase in new proposals for uses involving road construction or reconstruction." And the agency's own Tribal Summary Impact Statement records the decisive rejoinder (p. 2): "The Hopi Tribe noted that removing prohibitions, in itself, has an impact." An agency may not deconstruct a programmatic action into harmless paperwork while its own documents find the consequences reasonably certain; reasonably foreseeable effects of removing a prohibition are effects of the action. 42 U.S.C. § 4332(2)(C); Kern v. U.S. Bureau of Land Mgmt., 284 F.3d 1062 (9th Cir. 2002) (programmatic NEPA analysis may not defer all effects); Ocean Advocates v. U.S. Army Corps of Eng'rs, 402 F.3d 846 (9th Cir. 2005). I request the FEIS analyze the reasonably certain increase its own assessments find, rather than resting on the no-direct-effect formulation.

The Rule has protected these forests across multiple administrations. I'm asking this one to do the same.

Respectfully,

CommentID: RLC-20260909-YP9YL1

In short: The comment establishes that the proposed rescission of the 2001 Roadless Area Conservation Rule lacks a required NEPA 'hard look' analysis regarding the reasonably certain increase in road construction and its specific impacts on the Cascade Torrent Salamander in the Larch Inventoried Roadless Area of the Mt. Hood National Forest, contradicting the agency's 'no direct effect' framing with its own biological assessments and cited scientific data.

Substance score18 / 24A1 · Must be answered — it names the law

Local knowledge2 / 3

Evidence2 / 3

Legal2 / 3

EA analysis3 / 3

Analytical gap3 / 3

Alternative1 / 3

Request2 / 3

Specific place3 / 3

Subject: Technical Comment on Evidentiary Deficiencies: Roadless Rule Proposed Rescission (91 FR 35421; Docket FS-2025-0001)

I am a Buncombe County, NC resident who was significantly impacted by Hurricane Helene and who regularly hikes in and around the Pisgah Mountains and Bent Creek Experimental Forest. As such, I am deeply concerned about the inevitable damages to my community, region and beyond that would be caused by a rescission of the Roadless Rule. The below is a detailed update to my initial comment posted yesterday, August 20th, 2026.

I formally demand that the U.S. Forest Service select the "No Action" alternative and withdraw the proposal to rescind roadless protections. The August 20, 2026, DEIS fails to take the "hard look" required by NEPA (42 U.S.C. § 4321). Proceeding on this record would be arbitrary, capricious, and a violation of the Administrative Procedure Act (5 U.S.C. § 706(2)(A)).

The following deficiencies must be resolved before a Final EIS is published:

1. Outdated Post-Disaster Baseline: The DEIS violates 40 C.F.R. § 1502.15 by relying on pre-disaster data. Nearly two years after Tropical Storm Helene, the slopes of Craggy Mountain, Big Ivy, and Harper Creek are structurally altered by severe landslides and geologically unstable. Proposing timber roads on failing slopes ignores active local conditions and contradicts the agency's 2023 Revised Land Management Plan for the Pisgah and Nantahala National Forests.

The Forest Service must pause this process and coordinate with the North Carolina Geological Survey to map post-Helene landslide risks before acting further.

2. Omission of Municipal Infrastructure Costs: Under Loper Bright Enterprises v. Raimondo, courts no longer grant deference to unsupported agency assumptions; the burden of proof belongs to the Forest Service. The French Broad River Basin supplies drinking water to 100,000+ Asheville area residents. Roads and logging on storm-damaged slopes will surge sediment loading, shifting filtration costs onto local ratepayers. This omission also violates Goal 2 of the agency’s 2026–2030 Climate Adaptation Plan.

The agency must consult the Asheville Water Resources Department and disclose a quantified estimate of water treatment cost increases imposed on ratepayers.

3. Unaddressed Road Maintenance Backlogs: Under the State Farm precedent (463 U.S. 29), an agency decision that ignores a central part of the problem cannot stand. The Forest Service carries a multi-billion-dollar road maintenance backlog.

The USFS must place into the record the exact dollar backlog for the Grandfather Ranger District and the Appalachian Ranger District office in Mars Hill, explaining how building new roads is defensible when it cannot fund the upkeep of failing roads outside its own district office.

4. Wildfire Rationale Contradicts Regional Science: In humid, high-rainfall forests of Western North Carolina, roads are a wildfire delivery mechanism, not a firebreak. Decades of data show human-caused ignitions (vehicle sparks, equipment, unattended campfires) expand with road access into backcountry.

The Forest Service must disclose the predictive modeling and methodology used to conclude new roads will not increase wildfire risks to communities like Asheville.

5. Skipped Endangered Species Consultation: Road construction and canopy fragmentation will alter high-elevation microclimates critical to the federally endangered Spruce-Fir Moss Spider and Carolina Northern Flying Squirrel. The Endangered Species Act requires formal Section 7 consultation before an action proceeds.

The Forest Service must halt this rulemaking until Section 7 consultation with the USFWS is completed.

Data Quality Act Request: Pursuant to the Data Quality Act, I formally request that the Forest Service release the raw GIS datasets and predictive software used for the DEIS. If the agency lacks localized, post-Helene geological and hydrological data for the Pisgah-Nantahala, it must disclose that gap rather than proceed as though it does not exist.
The DEIS was built on a baseline that no longer exists. Until the Forest Service accounts for post-Helene ground conditions, water filtration impacts, its maintenance backlog, regional fire science, and its ESA obligations, the only defensible choice is the "No Action" alternative.

In short: The comment establishes that the DEIS for the Roadless Rule rescission is legally deficient because it relies on pre-Hurricane Helene data, omits municipal water treatment costs and road maintenance backlogs, contradicts regional wildfire science, and fails to conduct required Endangered Species Act Section 7 consultations for the Spruce-Fir Moss Spider and Carolina Northern Flying Squirrel.

Substance score17 / 24A2 · Hard to dismiss — it shows cause and effect

Local knowledge1 / 3

Evidence3 / 3

Legal0 / 3

EA analysis3 / 3

Analytical gap2 / 3

Alternative2 / 3

Request3 / 3

Specific place3 / 3

The roadless areas of the Grand Mesa Uncompahgre Gunnison National Forest are where I hike, camp, backpack, snowshoe and ski. They are the buffers to my favorite Wilderness Areas and invaluable habits and corridors for wildlife as well as sensitive plants. Though I live in Colorado and the rescission of the 2001 Roadless Area Conservation Rule (Rule) will not affect the state where I live, I recreate, wildlife watch and seek solitude in roadless areas across the country. These landscapes belong to all of us regardless of where we live. I vehemently oppose the rescission of the Rule and the agency's own documents make the case against this proposal better than I can.

The Recreation and Scenery section of the draft EIS shows, at Table 41, that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." I personally advocated for these designations during our forest plan revision and know the value of these settings. The same document's Social and Economic section records substantial visitor expenditures in affected areas, and the background data indicates that national forests containing inventoried roadless areas receive approximately 125 million of the 164 million total annual National Forest System visits. Despite that, the purpose and need statement never weighs the claimed regulatory burden reduction against the concrete risk of degrading the recreation settings that generate those visits and that local spending. The agency should explain, in the final EIS, how many of the primitive and semi-primitive acres documented at Table 41 are projected to shift to roaded-natural or more developed recreation opportunity spectrum classes under each action alternative over a 20-year horizon, and should quantify what that shift means economically for recreation-dependent communities like the ones near the Grand Mesa Uncompahgre Gunnison.

The agency's treatment of alternatives is equally difficult to accept. The draft states that an alternative maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was eliminated from detailed study as not being responsive to the purpose and need. That rationale is circular. The purpose and need was written to require deregulation, so it excludes by definition any alternative that preserves meaningful protections. The agency should explain in non-circular terms, in the final EIS, why an alternative built around temporary-road-based hazardous fuel treatment and selective harvest inside inventoried roadless areas cannot meet the stated fire and forest-health objectives, and should add such an alternative to the range of alternatives studied in detail.

I have attended presentation by wildland firefighters and have read scientific research about wildfire mitigation. Science and firefighters agree that this proposed rescission is not based in science related to wildfire mitigation. We know that the majority of wildfires start alongside or with close proximity to roads and firefighter organizations like FUSEE oppose rescission of the Rule. More roads mean more fires; Ecosystem integrity and prohibition of road construction and motorized use in designated roadless areas help prevent wildfires.

Clean water, wildlife habitat, and the primitive character of these places are not abstractions to me. The agency must address all these factors. Thank you for your consideration of my objection to rescission of the Rule.

In short: The comment establishes that the draft EIS fails to quantify the economic and recreational impacts of shifting primitive settings to developed classes, relies on a circular purpose and need statement to exclude a viable alternative involving temporary roads for fuel treatment, and ignores scientific evidence that road construction increases wildfire risk.

Substance score17 / 24A1 · Must be answered — it names the law

Local knowledge2 / 3

Evidence2 / 3

Legal2 / 3

EA analysis1 / 3

Analytical gap3 / 3

Alternative1 / 3

Request3 / 3

Specific place3 / 3

To the Department of Agriculture and the Forest Service:

As someone who has spent almost two decades enjoying this area and raising my children here, I value these forests and the protections provided by this rule.

I have found peace and connection by enjoying this area.

If this rule is rescinded, it become more at risk of wildfire, threatening my home, my community, and generations' abilities to enjoy recreating in the area.

Regarding the Dome Peak in the Routt NF, Colorado:

Dome Peak contains the headwaters of Hinman Creek, Coulton Creek, Lester Creek, Cabin Creek, and Farwell Creek—a network of cold, high-elevation streams that feed into the Elk River system and ultimately the Colorado River basin. These headwaters are critical spawning and rearing habitat for four federally endangered fish: bonytail (*Gila elegans*), Colorado pikeminnow (*Ptychocheilus lucius*), razorback sucker (*Xyrauchen texanus*), and humpback chub (*Gila cypha*, federally threatened). The cold water temperatures and clean spawning substrates maintained by intact riparian vegetation and undisturbed stream channels in this roadless area are irreplaceable for these species' survival across their entire range.

Greater Sage-Grouse in the Dome Peak IRA depends on the unroaded landscape to moderate exposure to 7.1 - Fire & fire suppression. Road construction in this area eliminates the spatial buffer between the threat source and occupied habitat.

NEPA requires the agency to take a hard look at the effects of rescission on Greater Sage-Grouse (Centrocercus urophasianus) in the Dome Peak IRA. The DEIS fails this standard without site-specific analysis of 7.1 - Fire & fire suppression at the severity and scope documented by NatureServe.

"Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term."
— Conservation Biology (Wiley), 2013

Unreconciled Contradiction Between Road-Access Fire Rationale and IRA Ignition-Density Data

The Draft EIS never reconciles its own comparative fire data with its road-access rationale for rescission. On the one hand, the document states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and its Wildfire Occurrence discussion reports IRA ignition density at "12 fires per million acres per year," compared to "42 fires per million acres per year" on other NFS lands—roughly 3.5 times higher. Yet elsewhere the DEIS suggests increased road access under Alternatives 2 and 3 will aid fire management, without addressing whether more roads will instead push ignition density in currently roadless areas toward the higher rate already observed on roaded lands. This is precisely the kind of internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002); and Seven County Infrastructure Coalition v. Eagle County (2025), consistent with APA 5 U.S.C. § 706(2)(A). I request a dedicated section reconciling these figures before finalization.

Let the Roadless Rule stand.

Best,

CommentID: RLC-20260906-LOHWR7

In short: The comment documents that the Draft EIS fails to provide site-specific analysis of fire and fire suppression impacts on Greater Sage-Grouse in the Dome Peak IRA and contains an unreconciled internal contradiction regarding wildfire ignition densities in roadless versus roaded areas, thereby violating NEPA and APA standards.

The strongest supporting comments

The 3 supporting comments with the highest substance scores, shaded the same way. Support comments score lower overall — exhibits are the top of each side (the 90th percentile within that sentiment), so these are the strongest of a lower distribution.

Substance score13 / 24A3 · Substantive, but easier to set aside

Local knowledge2 / 3

Evidence3 / 3

Legal0 / 3

EA analysis3 / 3

Analytical gap1 / 3

Alternative1 / 3

Request0 / 3

Specific place3 / 3

Dear Director:
I am submitting these comments as an individual who has worked in mineral exploration in Southeast Alaska since 2009, and has lived in Ketchikan, Prince of Wales Island and Juneau. I now work as an independent consultant to companies exploring in the region, and these comments are my own.

My first work in Southeast was at the Niblack project on Prince of Wales Island, where I was Project Manager from 2009 to 2020. Niblack has tidewater access and roads on patented mining claims, which supported underground development and exploration drilling. The Tongass had been temporarily exempted from the Roadless Rule in 2003, and in 2009 the Forest Service approved exploration drilling at Niblack in a Decision Memo. When a federal court reinstated the 2001 rule on the Tongass in 2011, its judgment allowed the drilling approved in 2009 to continue. However, our drill sites had since been revised based on underground exploration results, so the Forest Service halted our helicopter-supported surface program on National Forest land mid-season. At significant cost to budget and schedule, we moved crews to another project and returned in the fall to drill only from patented claims. A separate 2012 authorization allowed surface drilling to resume, and that was the last field program I managed before the project went into care and maintenance.

That is the practical effect of the rule on Tongass projects. Since 2009 I have watched the Tongass move in and out of the 2001 rule with court rulings and changes in administration. The status of the Tongass under the rule has been reversed four times, in 2003, 2011, 2020 and 2023. Approval of exceptions has also changed four times: the Secretary reserved it from 2009 to 2012, it was delegated to regional foresters in 2012 and 2018, and in 2021 pending decisions were elevated to the Department again (DEIS pp. 3 and 6). Each change resets the planning assumptions for projects on the forest. This unpredictability makes it difficult to raise investment for exploration in Southeast and even more difficult to execute programs when the money is raised.

Companies and investors generally understand that exploration in Southeast works with helicopters and barges. Most of the programs I've managed in my career, in and outside of Alaska, have been helicopter-supported, because it isn't practical to build a road to a prospect without a proven resource. However, drill pads and landing zones require cutting trees, which in my experience can fall under the same scrutiny as road building in the Tongass.

Access for developing and operating a mine comes later, when a project succeeds and needs a road to advance. The companies I work with in Southeast have projects on state, BLM and private land, where access is decided project by project. Southeast is a mineral district, and its mineral belts don't follow political or ownership boundaries. Inside a Tongass roadless area, a mining road also needs a discretionary exception, on top of the environmental review and plan approval it already requires. Whether a successful project can build a road depends on which side of that boundary it sits.

I was the Director of the Center for Mine Training at the University of Alaska Southeast in Juneau, which prepares people from the region for well-paying mining careers. In 2025 the average annual mining wage in Southeast was $134,545, more than twice the regional average of $66,796 (Southeast Conference, Southeast Alaska by the Numbers 2026). Jobs like these let people build a life without leaving Southeast. The operating mines, Greens Creek, Kensington and Dawson, provide most of them today. New ones depend on new discoveries advancing, and on the Tongass that relies on access.

I support Alternative 2, rescission of the 2001 rule. Not once while working in the Tongass for over 15 years did I encounter someone wanting to build a network of roads throughout the forest. The residents of Southeast Alaska are among some of the most environmentally aware people I have met and care deeply about protecting what they enjoy about living here. Every road would still require site-specific environmental review, consultation with Tribes, the subsistence protections of ANILCA and approval under the Forest Service's minerals regulations. I would rather those decisions be made project by project, by people who know the ground, than set nationally and reversed every few years.
Thank you for considering these comments.

In short: The comment establishes that the repeated reversals of the Roadless Rule status in the Tongass National Forest create regulatory unpredictability that hinders mineral exploration investment and execution, and supports the rescission of the 2001 rule in favor of project-by-project decision-making.

Substance score12 / 24A3 · Substantive, but easier to set aside

Local knowledge3 / 3

Evidence1 / 3

Legal0 / 3

EA analysis1 / 3

Analytical gap2 / 3

Alternative0 / 3

Request2 / 3

Specific place3 / 3

I am submitting this comment as a livestock grazing permittee on the Sycamore allotment, Prescott National Forest, in the Verde River watershed. I depend directly on National Forest System roads to manage my permit — moving and gathering cattle, maintaining stock tanks and other water developments, checking and repairing fence, and meeting the terms of my grazing permit. I ask that as this rule making moves forward, and as any resulting forest-plan or project-level decisions are made, the agency keep two things squarely in view.

1. Protect ranching access and infrastructure explicitly.
Returning roadless-area decisions to individual forest plans and project-level review, as this proposal does, should not put existing ranching access at risk. The roads and routes permittees currently rely on to administer their allotments — including in inventoried roadless areas — are working infrastructure, not incidental use. I ask that the Forest Service commit, in guidance implementing any rescission, that (a) existing routes needed to administer active grazing permits remain open and maintainable without new procedural barriers, (b) permittees are treated as cooperating stakeholders — not just members of the general public — in any forest-plan-level roads analysis that follows this rule change, and (c) maintenance or reconstruction of a road needed to reach a stock tank, water development, or allotment boundary is not treated the same as new road construction for other purposes.

2. Don't open more roads than the agency can maintain.
The proposed rule itself acknowledges a $6.9 billion deferred maintenance backlog for Forest Service roads and bridges. That backlog is not an abstraction where I ranch — roads I already depend on are washed out, rutted, or impassable because there has never been funding to maintain them properly. Rescinding the roadless rule without a funded maintenance plan risks making this worse, not better: every mile of new road opened for recreational access (OHV routes, dispersed camping spurs, etc.) is a mile added to a system the agency has already shown it cannot keep up. Recreational traffic accelerates wear on shared routes — the same roads ranchers use to move cattle and equipment — and when there's no maintenance budget behind that added use, degradation compounds and eventually falls back on permittees to work around washed-out or unmaintained roads just to do routine allotment work.

I am not opposed to local, project-level decision-making replacing a blanket national rule — in principle, that flexibility could serve ranching interests better than a one-size-fits-all prohibition. But flexibility without funding is not flexibility, it's deferred cost shifted onto the roads people already use. I ask that any decision to open new roads in former roadless areas — particularly for recreation — be paired with a real maintenance funding commitment, and that expanding the road network not be prioritized ahead of maintaining the routes that grazing operations, and other working uses of the forest, already depend on.

In short: The comment establishes that the commenter is a livestock grazing permittee on the Sycamore allotment in the Verde River watershed who relies on National Forest System roads for permit administration, and documents the specific risk that rescinding the roadless rule without a funded maintenance plan will exacerbate the $6.9 billion deferred maintenance backlog, thereby degrading the working infrastructure required for grazing operations.

Substance score11 / 24A1 · Must be answered — it names the law

Local knowledge1 / 3

Evidence0 / 3

Legal2 / 3

EA analysis1 / 3

Analytical gap2 / 3

Alternative2 / 3

Request2 / 3

Specific place1 / 3

**To:** Director, Ecosystem Management Coordination, USDA Forest Service

**Docket ID:** FS-2025-0001 (Document ID: FS-2025-0001-223869)

**Regulation Identifier Number (RIN):** 0596-AD66

**Subject:** Public Comment on Proposed Rule and Draft EIS: Special Areas; Roadless Area Conservation (36 CFR Part 294)

---

### 1. Submitter Interest & Operational Philosophy

I am submitting this comment as a resident living within the Tahoe National Forest. Living directly in a high-risk wildfire landscape gives me a firsthand look at the practical challenge of land management: catastrophic, stand-replacing wildfires represent the single greatest threat to human communities, clean water, and regional biodiversity.

When a severe crown fire incinerates an entire watershed, the resulting canopy loss, soil sterilization, and subsequent monsoonal debris flows destroy coldwater fisheries and fragile native plant communities far more permanently than localized mechanical intervention ever could. Therefore, protecting the landscape and protecting the fisheries requires making **hazardous fuel reduction operationally and economically feasible**.

I urge the Forest Service to avoid the two failing extremes—neither an unconstrained, permanent road network that degrades the land, nor an inflexible "no-roads" mandate that paralyzes active forestry. The Final Environmental Impact Statement (FEIS) should select an action alternative that provides **targeted, low-impact operational access** designed to protect the forest from catastrophic fire while preserving underlying watershed integrity.

---

### 2. Concrete Management Recommendations for the Final Rule

#### A. Enable Operational Feasibility via Temporary, Low-Impact Access

* **The Constraint:** Modern heavy machinery (masticators, feller-bunchers, processing heads, and chip vans) cannot treat overstocked stands without basic physical access. Relying entirely on costly helicopter yarding or hand crews makes large-scale landscape treatments economically unviable.
* **The Solution:** The final rule should explicitly authorize the construction of **temporary access spurs and landings** within Inventoried Roadless Areas (IRAs) specifically for mechanical fuel reduction and forest health restoration.
* **The Guardrail:** To prevent permanent habitat fragmentation, mandate that these temporary routes be legally bound to post-project decommissioning (re-contouring natural drainage, decompaction, and cross-draining) within two years of harvest completion.

#### B. Focus Heavy Mechanical Work on Strategic Defense Zones

* Prioritize road-assisted mechanical thinning along logical fire containment features—such as major ridgetops, natural fuel breaks, infrastructure corridors, and the Wildland-Urban Interface (WUI).
* Treating these strategic anchor points provides wildfire suppression crews safe, defensible space to halt incoming megafires before they enter sensitive, high-elevation core basins.

#### C. Protect Watersheds Through Best Management Practices, Not Paralysis

* Fuel treatments and watershed preservation are complementary goals. The rule should incorporate standard, high-level **Forest Service Water Quality Best Management Practices (BMPs)** rather than broad categorical bans:
* Utilize existing dry season/frozen ground operating windows to prevent soil compaction and rutting.
* Require robust rolling dips and temporary culvert standards on all operational spurs to prevent sediment bleed into nearby streams.
* Restrict ground-based heavy machinery on extreme slopes (greater than 35%) where high soil-shear risks exist, focusing mechanical road access on stable ridges and rolling terrain.

#### D. Prevent Unmanaged Post-Project Use

* The primary driver of human-caused wildfire starts and weed dispersal along forest access routes is unmanaged public vehicle traffic.
* All operational corridors constructed for fuel management must remain strictly closed and gated to unauthorized private motorized vehicles during active operations, followed by immediate physical obliteration once slash processing and haul operations conclude.

---

### 3. Conclusion

We do not have to choose between protecting our aquatic ecosystems and protecting our forests from catastrophic fire. Inaction carries the ultimate ecological cost: incinerated headwaters, debris-choked rivers, and destroyed communities.

Providing forest managers with the flexibility to build temporary, well-engineered, and strictly decommissioned access spurs strikes the exact balance needed—it makes fuel reduction operationally achievable while maintaining the long-term health of our landscape, soils, and coldwater fisheries.

In short: The comment establishes that the current regulatory framework fails to provide operationally feasible access for mechanical fuel reduction in Inventoried Roadless Areas, and requests the final rule authorize temporary, low-impact access spurs with mandatory decommissioning to mitigate wildfire risk while protecting water quality.

Opposing comments — the lower end

The three lowest-scoring opposing exhibits, for a sense of the range.

Substance score7 / 24A3 · Substantive, but easier to set aside

Local knowledge0 / 3

Evidence2 / 3

Legal0 / 3

EA analysis1 / 3

Analytical gap1 / 3

Alternative0 / 3

Request0 / 3

Specific place3 / 3

Special Areas; Roadless Area Conservation Public Comment,WHAT THE HELL ARE YOU PEOPLE THINKING? LEAVE OUR FORESTS, INDIGENOUS LANDS ALONE! The billionaires shouldn't be able to own every damned thing!Last year, more than 625,000 people from across the United States wrote to the USDA, urging the agency to keep the bipartisan 2001 Roadless Area Conservation Rule, which protects our forests from wildfires and corporate exploitation.Please do not rescind the Roadless Area Conservation Rule, Secretary Rollins. Allowing road construction and logging in these forests will destroy areas crucial to Native Tribes’ spirituality, culture, identity, and survival. These forests provide clean drinking water for more than 60 million U.S. residents and are crucial ecosystems for the wildlife that Tribal Nations depend on. The U.S. federal government has legal obligations to Tribes, including engaging in early and meaningful government-to-government consultation before making decisions about ancestral Tribal homelands. If you take this step to rescind the Roadless Rule, you will violate Tribal sovereignty and therefore the U.S. Constitution. In your own draft environmental impact statement, the federal government incorrectly claims that rescinding the Roadless Rule is a solution to the wildfire crisis. But fires don’t start without cause, and the U.S. Forest Service itself has stated that 9 out of 10 wildfires are caused by people. In fact, fires are four times more likely to start near a road due to cigarettes thrown from car windows, abandoned camp fires, and hot under-carriages of cars igniting tall dry grass.Over the years, many Tribes have spoken out against repealing or making exceptions to the Roadless Rule. Many have done so in the past year, so I’m writing to lift up their voices and urge you to fulfill your obligations to them. The Central Council of the Tlingit and Haida Indian Tribes of Alaska wrote: “The Tongass is more than an ecosystem -- it is our home. It is the foundation of our identity, our culture, and our way of life.” They explained that this step took place “without any prior consultation with our Tribe or other Southeast Alaska tribes” and called on the USDA to “suspend this decision until meaningful consultation is held with tribal nations, as required under federal law and trust obligations.”Gloria Burns, the President of the Ketchikan Indian Community in Alaska said: “We the people of Kichxáan are the Tongass. You cannot separate us from the land… This is an attack on Tribes and our people who depend on the land to eat. The federal government must act and provide us the safeguards we need or leave our home roadless… Without our lungs (the Tongass) we cannot breathe life into our future generations.”The President of the Organized Village of Kake in Alaska explained: “The remaining old growth timber is so important for providing shelter, the berries, and our medicines. It provides shade for our streams to keep them cool so our salmon can return year after year. We are the people of the forest and salmon people. Salmon has sustained us for thousands of years.” His Tribe also hunts deer and moose, which are rebounding after past clear-cut logging.And the President of the Organized Village of Kasaan in Alaska wrote: “The Roadless Rule has worked well for our Tribe and our community by helping to protect customary and traditional uses of our lands and waters, and the fish, wildlife, trees and plants. This helps us honor our ancestors and provide for current and future generations. It would be a grave mistake to roll back these protections. The Roadless Rule must continue to be upheld across the Tongass National Forest.”Please keep the 2001 Roadless Rule. If you want to make any changes, please meaningfully engage in decision-making with sovereign Tribal Nations, in order to honor your constitutional, trust, and treaty obligations to Tribes.Joe Chassereckless-self-dove@duck.com22313 v st.Ocean Park, Washington 98640

In short: The comment places on the record specific tribal opposition to the rescission of the 2001 Roadless Area Conservation Rule, citing constitutional and trust obligations for government-to-government consultation, and challenges the agency's draft EIS claim that rescinding the rule addresses the wildfire crisis by citing Forest Service data on human-caused fires and road proximity risks.

Substance score7 / 24A3 · Substantive, but easier to set aside

Local knowledge0 / 3

Evidence2 / 3

Legal0 / 3

EA analysis1 / 3

Analytical gap1 / 3

Alternative0 / 3

Request0 / 3

Specific place3 / 3

Special Areas; Roadless Area Conservation Public Comment,Last year, more than 625,000 people from across the United States wrote to the USDA, urging the agency to keep the bipartisan 2001 Roadless Area Conservation Rule, which protects our forests from wildfires and corporate exploitation. Once again White Men are ignoring treaties; sovereignty of Native Americans and; the grounds they have been granted. Stop thinking you can do anything you want for you will pay in the end.Please do not rescind the Roadless Area Conservation Rule, Secretary Rollins. Allowing road construction and logging in these forests will destroy areas crucial to Native Tribes’ spirituality, culture, identity, and survival. These forests provide clean drinking water for more than 60 million U.S. residents and are crucial ecosystems for the wildlife that Tribal Nations depend on. The U.S. federal government has legal obligations to Tribes, including engaging in early and meaningful government-to-government consultation before making decisions about ancestral Tribal homelands. If you take this step to rescind the Roadless Rule, you will violate Tribal sovereignty and therefore the U.S. Constitution. In your own draft environmental impact statement, the federal government incorrectly claims that rescinding the Roadless Rule is a solution to the wildfire crisis. But fires don’t start without cause, and the U.S. Forest Service itself has stated that 9 out of 10 wildfires are caused by people. In fact, fires are four times more likely to start near a road due to cigarettes thrown from car windows, abandoned camp fires, and hot under-carriages of cars igniting tall dry grass.Over the years, many Tribes have spoken out against repealing or making exceptions to the Roadless Rule. Many have done so in the past year, so I’m writing to lift up their voices and urge you to fulfill your obligations to them. The Central Council of the Tlingit and Haida Indian Tribes of Alaska wrote: “The Tongass is more than an ecosystem -- it is our home. It is the foundation of our identity, our culture, and our way of life.” They explained that this step took place “without any prior consultation with our Tribe or other Southeast Alaska tribes” and called on the USDA to “suspend this decision until meaningful consultation is held with tribal nations, as required under federal law and trust obligations.”Gloria Burns, the President of the Ketchikan Indian Community in Alaska said: “We the people of Kichxáan are the Tongass. You cannot separate us from the land… This is an attack on Tribes and our people who depend on the land to eat. The federal government must act and provide us the safeguards we need or leave our home roadless… Without our lungs (the Tongass) we cannot breathe life into our future generations.”The President of the Organized Village of Kake in Alaska explained: “The remaining old growth timber is so important for providing shelter, the berries, and our medicines. It provides shade for our streams to keep them cool so our salmon can return year after year. We are the people of the forest and salmon people. Salmon has sustained us for thousands of years.” His Tribe also hunts deer and moose, which are rebounding after past clear-cut logging.And the President of the Organized Village of Kasaan in Alaska wrote: “The Roadless Rule has worked well for our Tribe and our community by helping to protect customary and traditional uses of our lands and waters, and the fish, wildlife, trees and plants. This helps us honor our ancestors and provide for current and future generations. It would be a grave mistake to roll back these protections. The Roadless Rule must continue to be upheld across the Tongass National Forest.”Please keep the 2001 Roadless Rule. If you want to make any changes, please meaningfully engage in decision-making with sovereign Tribal Nations, in order to honor your constitutional, trust, and treaty obligations to Tribes.Patricia Rowellrowellpat3@gmail.com1520 Grassymeade LaneAlexandria,, Virginia 22308

In short: The comment places on the record specific data regarding human-caused wildfires and road proximity risks to refute the agency's draft EIS claim that rescinding the Roadless Rule mitigates wildfire crises, while documenting the violation of constitutional and treaty obligations to consult with specific Alaska Tribes.

Substance score7 / 24A1 · Must be answered — it names the law

Local knowledge0 / 3

Evidence0 / 3

Legal2 / 3

EA analysis1 / 3

Analytical gap0 / 3

Alternative1 / 3

Request0 / 3

Specific place3 / 3

To: USDA Forest Service Planning Team
Re: Notice of Intent to Rescind the 2001 Roadless Area Conservation Rule (90 FR 42179)
Dear USDA Forest Service Planning Team,
As an active trail advocate, mountain biker, and member of the Southern Off-Road Bicycle Association (SORBA), I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select the “No Action” alternative, maintaining the vital protections provided by the 2001 Roadless Rule.
Inventoried Roadless Areas (IRAs) protect intact watersheds, preserve natural landscapes, prevent harmful forest fragmentation, and safeguard irreplaceable backcountry mountain biking experiences.
I go to the mountains all the time. My friends live there. I bikepack and backpack in the wilderness. I learn about nature there. I need that space. Others do too. We have a lot of roads. Can’t we utilize what we have more effectively? Crimony.
Rescinding the 2001 Rule threatens to open these prized lands to road construction and resource extraction, risking the integrity of beloved non-motorized trail networks, increasing the spread of invasive species, and damaging the outdoor recreation economy that local communities rely upon.
The Forest Service should prioritize protecting these unique backcountry spaces. Please uphold existing protections and adopt the “No Action” alternative in the Environmental Impact Statement.
-Ed

(See attached file.)

In short: The comment documents opposition to the rescission of the 2001 Roadless Area Conservation Rule, asserting that the action would threaten non-motorized trail networks, increase invasive species spread, and damage the local outdoor recreation economy.

Supporting comments — the lower end

The three lowest-scoring supporting exhibits, for a sense of the range.

Substance score6 / 24A0 · Counted, not answered

Local knowledge1 / 3

Evidence0 / 3

Legal0 / 3

EA analysis1 / 3

Analytical gap0 / 3

Alternative1 / 3

Request0 / 3

Specific place3 / 3

Please rescind the roadless rule. Our forest service agents need better access to these areas. Timber needs to be harvested in these areas. It is a renewable resource, and timber does have a lifespan. It’s more jobs for the local logging/milling industries. Areas that have been logged are better for multiple wildlife habitats. It would be a huge help for wildfire safety, especially if some of the Helene damaged areas could be cleaned up and utilized for timber/ firewood for the community. And our national forests need more drivable roads and or public access points. I’m a 5-6th generation yancey county native who doesn’t own enough private land to hunt on my land. I pay taxes and buy hunting license every year and my access and ability to hunt our PUBLIC land is hindered by so many private land owners that limit access to public lands we used to hunt. I don’t understand why/ where my tax dollars go. The whole pisgah national forest that lies on the west side of highway 80 south can only be accessed from a few dead end roads. There is not enough parking to access the majority of this land. Locust creek road had thousands of tax payer dollars spent on roads/bridges/culverts/gravel years ago and one private land owner shut down the whole road and essentially wasted all the time and money spent to get this area accessible. Anti hunters and hikers can’t understand that I should have the same right to use this public land to hunt the same as they should be able to hike. Open the roads. Harvest the timber. Unlock the gates. North Carolina is beautiful mountainous property, it can still be “wild” and have a road or some trees cut. Many species thrive in timber cuts. I’ve said for years if we could use some of the numerous roads that have been shutdown just in my lifetime, It would be beneficial to the taxpayers and the people who work for the forest service. Permit system would be amazing. Charge a yearly fee to get a sticker for your vehicle, sticker grants access. No sticker, fines and penalties. Have it fixed so access could be purchased when hunting license are bought. Charge a steep price. Everyone I know would pay a substantial amount to be able to drive to dogs that are hurt instead of having to walk miles upon miles of ROADS that are already built. I’m all for not creating new roads which cause erosion, but there are many roads in great shape that are already there that could be utilized. Imagine some of the older men in our area who once were able to walk these mountains, who have bought hunting licenses for 50-60-70 years, and can no longer walk these roads, getting to drive them and once again see some of the beautiful places that we have around here. Please, please, please, open every road that you can. Many people around here, my self included, have moved, or are considering moving away from the place we love and have loved for multiple generations because the last little bit of hunting land we have just keeps getting harder and harder to access. I don’t wanna leave these mountains. I love them. But other states are far more hunter friendly and it’s truly heartbreaking that a state with a bear hound as our state dog, and the rich history our pride and joy, Mt. Mitchell shares with the bear hunting legend tom Wilson, treats bear hunters like outcasts and second hand citizens. Our way of life is fading fast. How can we ensure a future generation of bear hunters will want to have anything to do with it when everyone is against us. Please let us use the land we pay for and the land that we love.
Sincerely, Chad Chrisawn.

In short: The comment places on the record that the Pisgah National Forest west of Highway 80 South is inaccessible due to limited entry points and private land closures, specifically citing the closure of Locust Creek Road, and asserts that the commenter's standing as a Yancey County native and taxpayer is compromised by these access restrictions.

Substance score6 / 24A0 · Counted, not answered

Local knowledge1 / 3

Evidence0 / 3

Legal0 / 3

EA analysis1 / 3

Analytical gap0 / 3

Alternative1 / 3

Request0 / 3

Specific place3 / 3

I am writing to express my strong support for the U.S. Department of Agriculture’s proposal to fully rescind the 2001 Roadless Area Conservation Rule. My name is Eugene Hacker, and I am a resident of Lake Isabella, California. Over the last two decades, I have watched catastrophic wildfires destroy vast portions of our beautiful Southern Sierra forests. It is devastating to see my favorite backcountry recreation areas burn because of heavy fuel overgrowth and a lack of active management. The areas that have managed to escape recent fires are now incredibly dense, overgrown, and highly vulnerable to the next lightning strike or accidental ignition. A rigid, top-down federal mandate like the 2001 Roadless Rule limits our local land managers when they need flexibility the most. Our local U.S. Forest Service supervisors and district rangers understand the unique terrain, fuel hazards, and community risks of the Sequoia National Forest far better than officials in Washington, D.C. They need every tool available—including mechanical thinning, brush mastication, and the temporary access roads required to move heavy equipment—to aggressively reduce fuel loads, establish strategic fire breaks, and protect our communities and remaining green forests. Rescinding this rule does not mean environmental oversight ends; it simply shifts authority back to the local Forest Land Management Plan where decisions can be tailored to the immediate wildfire crisis on the ground. Please finalize this rule to give our local forestry officials the authority they need to properly manage our public lands and mitigate these catastrophic wildfires. Thank you for your time and consideration of my comments.

In short: The comment establishes the specific geographic location of Lake Isabella, California, and the Sequoia National Forest as the sites where the commenter claims to have observed catastrophic wildfires and fuel overgrowth, thereby documenting the local context for the request to rescind the 2001 Roadless Area Conservation Rule.

Substance score6 / 24A0 · Counted, not answered

Local knowledge1 / 3

Evidence0 / 3

Legal0 / 3

EA analysis1 / 3

Analytical gap0 / 3

Alternative1 / 3

Request0 / 3

Specific place3 / 3

Endorsing rescission of the outdated roadless restrictions rooted in the 1971 RARE process and the rigid national policies that followed.

As a longtime Lewiston resident with roots in north-central Idaho, time split on the Clearwater River side near Kooskia, and a lifetime of hands-on work in the outdoors—motorcycle touring the backcountry, running an ATV for practical access, fishing, property management, and simple self-reliant living—I fully support rescinding the restrictive roadless framework that traces back to the Forest Service’s 1971 Roadless Area Review and Evaluation and the one-size-fits-all national rules layered on later.

These policies locked up millions of acres of National Forest land under a near-blanket prohibition on new roads and active management. In practice that means limited access for responsible recreation, harder and more expensive firefighting and fuels reduction, restricted timber and other multiple-use activities that once supported rural communities, and managers who can’t respond to local conditions without jumping through national-level hurdles. Idaho already showed a better way with its own 2008 Roadless Rule—collaborative, themed management that allows more flexibility where it makes sense while still protecting the highest-value wild country. The national version never did that.

Around here—Nez Perce-Clearwater country, the edges of Hells Canyon country, the routes people actually use for adventure touring, hunting, fishing access, and emergency response—roads and managed access are tools, not enemies. When overgrown stands, insect kill, and fuel loads build up because you can’t get equipment in to thin or create breaks, the result is bigger, hotter fires that destroy the very values the roadless designations claimed to protect. Local foresters and communities know the ground better than a 25-year-old Washington rule written for every landscape from the Tongass to the Appalachians.

Rescinding the national roadless prohibitions returns decision-making to the people and professionals who live with the consequences. It does not automatically mean roads everywhere or clear-cuts on every ridge. It means forest plans, public process, and local judgment can decide where limited road access improves recreation opportunities, reduces catastrophic fire risk, supports watershed health through active management, or allows sustainable use without locking the land into permanent non-management. That is consistent with the Multiple-Use Sustained-Yield Act and with the practical reality of living next to these forests.
Idahoans value wild country. We also value the ability to use it, manage it, and protect communities and resources from preventable disasters. The 1971 inventory process and the rigid rules that grew out of it have outlived their usefulness as a national straightjacket.

Rescind it, keep the flexibility Idaho already negotiated for itself, and let local knowledge guide the rest. That is the practical, filter-free approach that actually serves the land and the people who live with it.

In short: The comment establishes the specific geographic scope of the roadless rule's impact by identifying Lewiston, north-central Idaho, the Clearwater River near Kooskia, Nez Perce-Clearwater country, and Hells Canyon country as the local areas where the commenter resides and where the policy's restrictions on access and management are felt.

Sharing & methodology

These results are meant to be shared.

Please cite us. This analysis is the intellectual property of Roadless.org and Nicholas Holshouser. You are welcome to reproduce it — every reproduction must include this citation:

Roadless.org and Nicholas Holshouser, “2001 Roadless Rule Revision — Substantive Analysis,” https://roadless.org.

How it works. A large language model (an open-weight Qwen 2.5 model) reads each substantive comment and scores it 0–3 on eight dimensions — evidence, legal grounding, engagement with the environmental analysis, analytical gaps, alternatives, specific requests, position, and local knowledge — and extracts quote-accurate verbatim spans for the highest-scoring exhibits. A comment counts as “substantive” when it clears a floor filter — it must show at least one substantive signal (a named entity, a specific citation, a stated analytical deficiency, or first-person testimony), which screens out one-line and purely conclusory submissions before any model scoring.