2001 Roadless Rule Revision

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.

The proposal justifies itself partly on wildfire and fuels management grounds. The agency's own record contradicts that justification directly. It states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must explain, in its response, why the proposal departs from this finding, and how it reconciles the rescission with the ignition data in DEIS Table 21, which the record indicates shows far higher fire density on roaded land than inside the affected roadless areas.

The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The courts that reviewed that specific question disagreed. The Tenth Circuit 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." The agency should address that holding directly, including the court's conclusions regarding authority under the Organic Act and the Multiple-Use Sustained-Yield Act, and state on what basis it holds a contrary view.

On the question of whether the agency can afford what it is proposing: the country is now $40 trillion in debt. Spending more to build new roads when we cannot afford to maintain the ones we already have makes no sense. The agency's own DEIS confirms this is not a hypothetical concern: "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 DEIS further states that road mileage, deferred maintenance, and management costs are likely to increase under the proposal. The agency should name the funding source for any new road construction and maintenance the rescission enables, and state the projected change in the deferred maintenance backlog.

Finally, the economic case for rescission has not been made. The agency's own Cost Benefit Analysis states: "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." A range spanning from a $92 million loss to a $199 million gain is not a finding of net benefit. The cost column as presented excludes road construction costs the same document quantifies at $80,000 to $100,000 per mile, along with maintenance and fuel treatment costs also quantified in that document, and the upper bound assumes maximum potential harvest the analysis itself calls uncertain. That analysis was not placed on the docket where the public could find and evaluate it. The agency should place the Cost Benefit Analysis on the docket, restate the net present value with road and fuels costs included in the cost column, and show the arithmetic supporting any claim that impacts could exceed $100 million.

Sincerely,
Blake Puhak
Richmond, VA

2. The Department's equivalence premise is testable, and the record does not test it. The proposal asserts that land management planning "ensures each land management plan addresses similar conservation objectives as the 2001 Roadless Rule was intended to address" (91 FR 53828). Subpart B covers only areas inventoried as of 2001; roadless acreage identified in later planning inventories is governed by planning alone. Vermont contains substantially more Forest Service-identified roadless acreage than the approximately 26,000 acres subpart B covers. That yields two categories of comparable land in one forest, under one plan, differing only in whether subpart B applies — a direct test of the equivalence premise, which the draft EIS does not appear to present.

3. The impact analysis excludes the mechanism through which impacts would occur. The Department bounds its estimates by existing plan direction, concedes that subsequent plan amendments could expand impacts, places plan changes outside the scope of the rule, and then requests estimates that account for them (91 FR 53830). Because the rule's stated purpose is to restore discretion to forest-level planning, plan amendments are the reasonably foreseeable means by which it operates. Bounding effects by unamended plans understates reasonably foreseeable effects.

4. Reliance interests are unaddressed, the small-entity certification is internally inconsistent, and the distributional analysis is missing. The Department invites comment on reliance interests but does not appear to quantify twenty-five years of reliance by recreation businesses, water systems drawing from roadless headwaters, and adjacent property owners. It certifies no significant impact on a substantial number of small entities while estimating roughly $6.1 million in annual recreationist losses and impacts that could exceed $100 million (91 FR 53830-53831); outfitters and guides are predominantly small entities. Responding to the Department's request regarding distributional effects: the monetized benefits are dispersed nationally while the costs are concentrated in specific communities adjacent to affected areas and among downstream watershed users, so national aggregates do not disclose the actual incidence.

Recommendations:
(1) Select the No Action alternative and retain subpart B.
(2) Analyze purpose and need separately for eastern inventoried roadless areas, and limit any final rule geographically if that analysis does not support rescission in the East.
(3) Test the equivalence premise by comparing management outcomes in pre-2001 and post-2001 inventoried roadless acreage in the eastern forests.
(4) Analyze a plan-amendment scenario in the final EIS.
(5) Withdraw the Regulatory Flexibility Act certification, complete an initial regulatory flexibility analysis, and present a regional distributional analysis.
(6) If additional flexibility is warranted, amend 36 CFR 294.13(b)(1) by adopting the standard already in force at 36 CFR 294.24(b)(1)(iii) — "To reduce the risk of uncharacteristic wildland fire effects to an at-risk community or municipal water supply system" — rather than rescinding the subpart.

Rescission is not necessary to achieve the Department's stated purpose. Amendment using language the Department already applies in the Idaho rule it is retaining would achieve it. Thank you for considering these comments.

1. The wildfire rationale ignores the Forest Service's own research. The "Rationale for the Proposal" cites wildfire risk as a reason for rescission. But the Forest Service's own Research and Development program has found that fuel-treatment activity has actually occurred at a higher per-acre rate in roadless areas than in roaded areas, and that roaded and roadless forests have burned at similar rates since 2001, a "neutrality" its researchers attribute to higher human-caused ignition near roads offsetting suppression-access gains. Recent peer-reviewed work using 30 years of national-forest fire records found ignition density roughly three times higher within 250 meters of a road than beyond 2,000 meters, and concluded new roads into roadless terrain are likely to increase total ignitions. The proposed rule does not address this research anywhere in its "Wildfire risk" discussion. I request the Department directly address its own R&D findings before finalizing this rule.

2. The Department's own cost-benefit figures don't support the rule. The "Summary of Potential Impacts" states rescission would open only 4.8 million acres (16%) of forested IRAs to new active management, generating just $5.2–11.4 million/year in public revenue, against a disclosed $6.9 billion road maintenance backlog, $6.1 million/year in lost recreation value, and a total annual cost the Department itself says "could exceed $100 million." I request a single reconciled accounting showing how the claimed benefits outweigh these disclosed costs, particularly given this rule's designation as "economically significant" under E.O. 12866.

3. Case-by-case NEPA review may not reduce burden. The rule states future projects would still require site-specific NEPA compliance at the individual forest level. Replacing one national standard with review at 175+ forest units is not self-evidently less burdensome, and the rule does not compare the administrative cost of each approach.

4. Litigation history should factor into the durability analysis. The rule's own "Background" section describes the 2001 Rule as having been enjoined and reinstated multiple times, including a Ninth Circuit affirmance in *California ex rel. Lockyer*. Combined with the majority Tribal opposition and consultation concerns documented in this same docket, a rushed rescission is likely to face comparable challenge, undermining the near-term benefits claimed.

5. Thirty days is inadequate for an economically significant rule. This comment period is shorter than the 21-day NOI period that 54 members of Congress already called insufficient, despite covering a full proposed rule, draft EIS, and cost-benefit analysis spanning ~45 million acres. I request an extension to at least 60 days.

Conclusion: The Department's own disclosures — not outside assumptions — show disclosed costs exceeding disclosed benefits, an unaddressed body of agency fire research cutting against the wildfire rationale, and unresolved litigation risk. I urge the Department to retain the "No Action" alternative and withdraw this proposed rescission of 36 CFR Part 294, Subpart B, or at minimum to extend the comment period and reconcile these figures before proceeding to a final rule.

Sincerely,
Tyler Batdorf

REQUEST: identify, by unit, year, and acreage, every fuels, insect and disease, or hazard-tree project the Forest Service declined to propose or could not approve solely because of 294.12 or 294.13, and explain why 294.13(b)(1)(ii) was insufficient. The notice has no such list. Without one, the need is unsupported.

2. THE MEANS ARE NOT MATCHED TO THE STATED END

The notice reports 9.8 million acres of wildland-urban interface overlap and 18.2 million acres where plans would permit permanent roads. It removes the prohibition across all of it, not the acreage where the stated risk is documented. A rescission scoped to documented risk would serve the stated purpose. This one reaches further.

The record also points elsewhere for cause. Acres treated for wildfire risk fell from roughly 4.1 million in FY2024 to roughly 2.6 million in FY2025 -- 35 percent, with the rule unchanged in both years -- amid the loss of roughly 5,000 staff. Rescission adds no crews and no appropriations. If the constraint is workforce, a rule change cannot relieve it.

3. THE EXECUTIVE ORDERS ARE NARROWER THAN THE USE MADE OF THEM

E.O. 14153 section 3(c), 90 Fed. Reg. 8351, directs the Secretary to address the 2023 Alaska Roadless Rule and reinstate the 2020 Alaska rule. It is Alaska-specific on its face and cannot support a nationwide rescission reaching some 45 million acres -- 58.5 million less the retained Idaho and Colorado rules (9.3M and 4.2M).

More fundamentally, each cited order states that it creates no right or benefit enforceable at law and is to be implemented consistent with applicable law. That clause cuts both ways: it defeats a challenge to the orders, and equally defeats any suggestion that the Department was compelled. Authority over National Forest System lands is delegated by statute. An order may direct how the Secretary exercises discretion; it cannot enlarge it or substitute for the findings NFMA and MUSYA require. See also 16 U.S.C. 531(a): multiple use does not mean the combination of uses giving "the greatest dollar return or the greatest unit output."

4. THE DEPARTMENT ALREADY BUILT THE ALTERNATIVE

Subparts C and D answer the notice's own premise. Idaho's management themes and Colorado's upper-tier structure deliver graduated, place-based flexibility -- community protection zone treatment, temporary road authority -- inside a retained roadless rule. Both have stood since 2008 and 2012, and are being kept. Explain why that model cannot be extended, and why targeted amendments to 294.12 and 294.13, drawn from 294.42-.43, were not analyzed.

5. REQUESTS FOR THE RECORD

a. State whether ESA section 7 consultation on this rescission has been initiated, with whom, and when. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), set aside the identical 2005 repeal for failing to consult before effecting it. This notice mentions the Act once, in a savings clause.

b. Publish the models behind the harvest, revenue, and recreation figures, or omit them from any final rule; data relied on must be exposed to comment. State the "potentially affected environment" acreage and reconcile it to 58.5M, or another figure as apporpirate.

c. Place the ANILCA section 810 evaluation, notice, hearing, and findings inside the EIS, as 16 U.S.C. 3120(b) requires.

d. Add monitoring, reporting on acres roaded, and a scheduled reassessment -- rescission is reversible on paper; installed roads are virtually irreversible.

Thank you for your service to the People of the United States.

The wildfire rationale given for this proposal conflicts directly with the agency's own findings. The agency's 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." I often hike in the White River National Forest, which holds 90 inventoried roadless areas totaling 639,604 acres. The idea that opening those areas to roads reduces fire risk is contradicted by the agency's own ignition data. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain, point by point, why this proposal departs from its own prior findings on fire occurrence and how it reconciles the rescission with those numbers in its own record.

The economic case is equally weak. The agency's record acknowledges: "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 forests of Nantahala and Pisgah, where I have also spent considerable time, hold 52,304 acres and 99,369 acres of inventoried roadless areas respectively, protecting the last wild headwaters of rivers flowing to both the Atlantic and the Gulf, alongside black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The agency must reconcile that range with the proposal's stated purpose, and must explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when the agency's own analysis cannot establish a net benefit.

On legal authority: the proposal suggests the 2001 rule exceeded statutory authority. The courts that reviewed this directly held otherwise. The agency's record includes: "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." The Tenth Circuit found 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 must state on the record what legal basis, if any, supports a contrary reading of that authority after that holding.

Finally, the small-business certification in this rulemaking cannot stand as written. It reaches a no-significant-impact conclusion by averaging a projected $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and the record concedes some firms may lose those receipts. Dividing forests with roads would be a perilous decision for those businesses as well as for the forests themselves. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas.

Protection and strengthening of roadless areas is crucial to the health and longevity of our country and our planet. These comments are filed in that conviction.

Sincerely,
Steve Wood
Boulder, Colorado

The wildfire rationale does not hold up either. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The rescission is being justified in part on fuels management and wildfire grounds. That justification runs directly against what the agency itself documented. I ask that the agency reconcile this proposal with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from its own prior findings.

The economics are just as troubled. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from negative $92 million to positive $199 million. A Cost Benefit Analysis that cannot establish a net benefit does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. The agency needs to answer that directly.

The state-by-state approach argument has also already been tested. The agency's own record contains its earlier dissatisfaction with the national rule, describing its rejection of the rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. But the agency's own prior finding acknowledged that local decision-making can incrementally reduce nationally significant roadless values. The Ninth Circuit identified deficiencies the last time the agency tried to replace the national rule with a state-by-state framework. I want the agency to explain on the record how this proposal avoids those same deficiencies.

Finally, the statutory authority argument. Courts have already reviewed that question. 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." The Tenth Circuit 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 explain the legal basis for any position to the contrary, because that explanation is not currently in this record.

I fish Beaver Dam and Devil's Lake. I watch birds. I love Wisconsin Dells, the lakes and rivers there. These are not abstract values to me. The rescission of the 2001 Roadless Area Conservation Rule puts them at risk, and the agency's own documents do not justify that risk. I oppose this proposal.

Sincerely,
Melissa Meyler-Warlow
Milwaukee, WI, USA

"The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads."
— Fire Ecology (Springer Nature), 2026

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.

Retain the Roadless Rule.

Yours sincerely,

CommentID: RLC-20260908-100IK4

The Department states that the additional economic effects of rescission "could exceed $100 million" annually, while its own projected benefits are substantially smaller and less certain. The proposal estimates $5.2 to $11.4 million per year in incremental Treasury and Forest Service revenue, and $4.6 to $10.6 million per year in revenue to the timber industry, contingent on assumptions the Department itself calls unlikely to hold given "budgets, unforeseen limits on operability, and market conditions." Set against this, the Department projects a $6.1 million annual loss to recreation-dependent businesses alone, without a comparable dollar estimate for effects on commercial fishing, drinking water systems, or long-term ecosystem services. A rule expected to impose costs an order of magnitude larger than its most optimistic quantified benefits does not meet the standard of reasoned rulemaking required under Executive Order 12866, which the Department itself invokes as governing this action. I request that the final rule not proceed until the Department reconciles this asymmetry or provides a benefit estimate that can plausibly offset the projected costs.

B. The wildfire rationale is internally inconsistent

The proposal cites wildfire risk reduction as a central justification for rescission, yet the Department's own summary of impacts acknowledges that "greater public access can increase human-caused ignition potential in some locations." Independent research on fire ignition sources has consistently found that human-caused ignitions correlate with road density and access, which is consistent with the Department's own admission here. Additionally, the 2001 Rule already contains exceptions permitting fuel-reduction and forest-health activities without new road construction; the proposal does not explain why those existing exceptions are insufficient, nor does it quantify how much of the wildfire benefit claimed for rescission could be achieved without full repeal. I request that the Department provide an analysis isolating the wildfire-risk benefit attributable specifically to new road construction and timber harvest, as distinct from the benefit already available under the current rule's exception process.

C. The land management planning process is not a demonstrated substitute for a national standard

The proposal asserts that local land management plans can achieve "similar conservation objectives" to the 2001 Rule, but the rule text itself confirms this outcome is discretionary rather than assured: individual plans "could still include restrictions," and rescission "does not... compel" any particular plan outcome. This means the durability of roadless-area protection would vary by forest unit and could shift with each plan revision, creating exactly the kind of inconsistency and litigation risk that motivated the original 2001 national rule. Given that the 2001 Rule was itself the product of extensive litigation — including a Ninth Circuit affirmation in *California ex rel. Lockyer v. USDA*, 575 F.3d 999 (9th Cir. 2009) — replacing a litigated national standard with 100+ discretionary, revisable local plans is likely to generate a comparable or greater volume of legal challenges, undermining the Department's stated goal of reducing administrative burden.

D. Tribal consultation findings documented in the proposal itself raise unresolved E.O. 13175 concerns

The Department's own Tribal Input Received section states that the "majority sentiment among Tribal governments consulted is opposition to the proposed rescission," citing concerns that the Department has proceeded "without adequate government-to-government consultation" in fulfillment of its trust responsibilities. The Department separately determined that this rulemaking "would have substantial direct effects on Indian Tribes" sufficient to trigger E.O. 13175 consultation obligations. Given that only 29 of 64 requested consultations had been completed as of publication, I request that the Department complete the consultation process and incorporate its results into the rule before finalizing any decision, consistent with the Department's own determination that consultation is required here.

I urge the Department to withdraw the proposed rescission, or at minimum to address the analytical gaps identified above before proceeding to a final rule.

Respectfully submitted.

3. Reconcile the road maintenance figures. The proposal cites a $6.9 billion deferred maintenance backlog for roads and bridges. Commenters have documented $10.8 billion across 370,000 miles, a majority attributable to deteriorated roads causing sedimentation and fish passage barriers. Adding road mileage to a system the agency cannot maintain is not management. State the correct figure and explain how new construction is funded against it.

4. Reconcile the New Hampshire acreage. The record variously describes 235,000 and more than 265,000 acres of inventoried roadless area in the White Mountain National Forest. Publish the controlling number and its basis.

5. The agency has already demonstrated what it does with this discretion. Roadless acreage identified in the 2005 White Mountain Forest Plan fell outside the 2001 rule, and the Forest Service asserted it owed those lands no comparable protection, then proposed logging in them — including South Carr Mountain, Mill Brook, and Kanc 7. This is documented agency conduct, not speculation. Address it directly.

6. The local-decisionmaking premise fails without local staff. The entire rationale rests on forest supervisors exercising informed place-based judgment. Forest Service staffing has been reduced. Provide the staffing levels assumed by this proposal and the analysis supporting them.

7. The petition pathway converts a national trust into a patchwork. The proposal invites petitions under 5 U.S.C. 553(e), with Idaho and Colorado as precedent. National Forest System lands are held for all citizens, not for whichever party petitions hardest. Explain how the agency will prevent fragmentation of a national standard into state-by-state exemption.

8. Reliance interests and Tribal consultation. The proposal solicits comment on reliance interests; twenty-five years of recreation economies, conservation easements, and land use decisions built on this rule are such interests, and the agency must weigh them, not merely note them. USDA also determined that E.O. 13175 consultation was warranted here and then documented majority Tribal opposition. Finalizing over that record demands explanation.

In New Hampshire the trade is a $3.9 billion outdoor recreation economy against a $1.4 billion forest products industry, and the agency's own estimate of $6.1 million in annual lost recreation benefit nationally. Retain the rule.

Adam Davidson
Derry, New Hampshire

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.

The Mt. Baker North IRA (16,873 acres) in Mt Baker-Snoqualmie National Forest possesses unique ecological characteristics — including distinct species assemblages, watershed configurations, and ecosystem composition — that a programmatic analysis covering 2,332 roadless areas cannot adequately evaluate.

A programmatic EIS cannot evaluate the specific impacts of road construction on the particular watersheds, wildlife corridors, and ecological systems within the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest. NEPA does not permit substituting generic, landscape-scale analysis for site-specific impact evaluation.

The DEIS must include individualized analysis of the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest, addressing site-specific impacts to watersheds, wildlife habitat, and ecological integrity. A programmatic EIS covering 2,332 areas does not meet NEPA's requirement under 40 CFR 1502 for analysis commensurate with the significance of the action.

"Inventoried roadless areas considered in this rule constitute roughly one-third of all National Forest System lands, or approximately 58.5 million acres. Of the 58.5 million acres of inventoried roadless areas considered in the FEIS, approximately 34.3 million acres have prescriptions that allow road construction and reconstruction. The remaining 24.2 million acres are currently allocated to management prescriptions that prohibit road construction; however, protections in these existing plans may change after future forest plan amendments or revisions. Over the past 20 years, roads have been constructed in an estimated 2.8 million of those 34.3 million acres of inventoried roadless areas."
— USDA Forest Service

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.

The Department is urged to resolve this proceeding in favor of retention, not rescission.

Yours truly,
Garrett Rowles
CommentID: RLC-20260901-ZYCHBW

The "may affect" standard does not require proof of population-level impact or demonstrated mortality. A reasonable possibility that road building, timber harvest, or increased access in the Pemigewasset Ext IRA disturbs, displaces, or degrades habitat for Northern Myotis (Myotis septentrionalis, E) is sufficient to trigger the Section 7 formal consultation obligation.

The formal consultation obligation for Northern Myotis (Myotis septentrionalis, E) in the Pemigewasset Ext IRA, White Mountain National Forest, is species-specific. The agency cannot satisfy it through a generic programmatic consultation or a blanket finding covering all listed species across all roadless areas. Each species in each area requires its own consultation finding and its own determination of effect.

"Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road."
— Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing van Dijk et al. 2025, 2025

Federal Recovery Plans and Status Assessments Rely on Roadless Protection; the Assessment Quantifies the Exposure and the DEIS Ignores It

The agency's own species documents treat roadless protection as a load-bearing assumption. The grizzly bear SSA, quoted at page 122: "lasting" land designations such as Wilderness and IRAs "ensure that large proportions of recovery zones and additional areas outside the recovery zones remain secure for grizzly bears into the future without the development of new roads, extractive industries, or other human structures." The 2017 lynx SSA, quoted at page 99, anticipated "continued management of national parks, designated wilderness and roadless areas… to maintain natural ecological processes." Page 91: the Service identifies National Forest lands as "the most suitable lands for reintroduction and recovery of the Mexican wolf, predominantly due to lower levels of human development and disturbance." The assessment then quantifies the exposure it would create: 69 of 137 wolverine detections in IRAs fall in operable areas, placing wolverine "in the highest vulnerability category to the proposed action" (p. 93); "Approximately 41% of [Mt. Graham red] squirrel critical habitat occurs in IRAs and of that critical habitat, 76% of it is classified as operable" (p. 80); 12% of lynx critical habitat is in the action area with 46% of the IRA portion operable (p. 100); and for Heliotrope milk-vetch, "100 percent of its critical habitat overlaps with the action area" (p. 348). None of these reliance findings or exposure figures appear in the DEIS's effects analysis. I request the FEIS disclose, for each species whose recovery plan or SSA relies on roadless protection, the quantified critical-habitat exposure its own assessment computed, and analyze the effect of removing an assumption federal recovery planning treats as lasting.

I'm asking you to keep the 2001 Roadless Rule in place.

Earnestly,

CommentID: RLC-20260905-RJWYGV

Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Trombulak et al., 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)

Rescinding the Roadless Rule would open the Mt. Baker West, Mt Baker-Snoqualmie National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary.

Recission of the roadless rule would be devastating for me personally and for my community who love and respect the outdoors.

Unquantified Roadless-Specific Forest Health Data Supporting Causal Rationale

The DEIS asserts that the 2001 Roadless Rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns" (Rationale for the Proposed Rule, pp. 18-19), yet this three-step causal chain is offered with no acreage figures, no roadless-specific fire, insect, or disease incidence statistics, and no comparison of forest health outcomes between roaded and roadless lands. An agency asserting materially changed conditions must articulate a rational connection between facts found and the choice made, not a bare assertion, 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 Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), and unsupported factual premises violate APA 5 U.S.C. § 706(2)(A). I request quantified, roadless-specific data on acres affected, fire risk indices, and treatment backlogs, with a direct roaded-versus-roadless comparison, before this rationale is relied upon to justify rescission.

Failure to Provide Sensitivity Analysis for Acreage-Derived Percentages

The Draft EIS's own acknowledged 0.4-million-acre discrepancy between the 44.7-million-acre IRA figure and the 44.3-million-acre National Forest System land figure is never carried forward into any of the derivative percentages presented in the Affected Environment section, including the 56 percent Tongass figure, the 66.5 percent timber-harvest restriction figure, the 54.5 percent road-construction restriction figure, and the 2.8 percent NWPS overlap figure (pp. 20-36). Having conceded uncertainty in the base acreage, the agency cannot present percentages calculated from it as precise without disclosing how that uncertainty propagates. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), an agency that identifies a data-quality problem must grapple with its implications for downstream conclusions rather than disclose it in passing. Presenting these figures without error bars is also arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request that the agency provide sensitivity ranges or error bars for every acreage-derived percentage in this section before finalizing the rescission.

I oppose this rescission, clearly and without qualification. I'm asking the Department to withdraw the proposal.

With respect,
E Burnham

CommentID: RLC-20260908-0HAQRV

My first objection concerns water. Forest roads are the dominant chronic sediment source in managed forest watersheds — a finding confirmed by the agency's own synthesis (Gucinski et al., PNW-GTR-509, 2001; Trombulak and Frissell, *Conservation Biology* 14:18–30, 2000) — and road density is one of only five landscape metrics that predict brook trout persistence across the species' eastern range (Hudy et al., *North American Journal of Fisheries Management* 28:1069–1085, 2008). This matters acutely here: nearly 294,000 acres of Virginia's roadless areas support native brook trout, and about 60 percent of the state's brook trout streams lie within the George Washington and Jefferson National Forests, along with the headwaters of the Shenandoah, Potomac, and James. Roading and the harvest it enables add sediment and strip canopy shade from headwater streams, raising summer temperatures in a coldwater species already being pushed upslope. The DEIS should quantify that loading rather than defer it to project-level analysis.

Second, roads are an irreversible pathway for invasive plants. Non-natives establish where soil is disturbed and disperse along road corridors (Parendes and Jones, *Conservation Biology* 14:64–75, 2000; Gelbard and Belnap, *Conservation Biology* 17:420–432, 2003). Unlike a timber sale, this impact does not end when the operation ends and cannot be mitigated afterward — there is no practical way to eradicate established invasives from Appalachian forest interiors. The intact roadless cores of the GW&J are among the last places in the mid-Atlantic where native understory communities remain largely uninvaded.

Third, the wildfire rationale offered for this action is contradicted by the best available science. A nationwide analysis of every recorded ignition on national forest land from 1992 through 2024 found ignition density lowest in designated wilderness (1.75 fires per 1,000 ha) and nearly as low in inventoried roadless areas (1.97), while lands within 50 meters of a road had by far the highest density (7.99) (Aplet et al., *Fire Ecology* 22:8, 2026). The result held in every Forest Service region. Since roughly nine in ten wildfires are human-caused, this is the expected outcome: roads deliver ignition sources. The Department cannot rest its purpose and need on wildfire risk reduction without engaging this record.

Fourth, rescission would degrade the recreation these lands support. What I value about running and camping in roadless country is exactly what roads destroy: shade, quiet, clean water, and solitude. A long day on the Wild Oak Trail loop works because the canopy holds and the ridges are quiet; a logged and roaded version of that circuit is a poorer experience, and no trail relocation fixes it. Rescission also invites expanded off-highway vehicle use, with the noise, rutting, erosion on steep slopes, and litter that follow. The GW&J totals roughly 1.8 million acres — there is ample already-roaded, previously harvested ground where timber management and fuels work can occur, and the Forest Service has in fact treated some two million acres of inventoried roadless areas under the existing rule's flexibility.

Finally, I object to the process. The 2001 rule followed a two-year process, more than 1.5 million comments, and over 430 public hearings; this rescission is being advanced with a 30-day comment period and no hearings at all, on a DEIS covering roughly 45 million acres — well short of the 60 to 90 days typical at this scale. In the prior comment period, 99 percent of more than 625,000 comments opposed rescission. I ask that the Department select the no-action alternative and retain the 2001 Roadless Area Conservation Rule in full. At minimum, extend the comment period and hold public hearings in the affected regions, including Virginia.

Respectfully submitted,
Paul Jacobs
Washington, DC

The wildfire rationale offered in support of rescission is similarly unreconciled with the agency's own data. The proposal frames road-building as a tool for fuels management, yet the 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." If the agency's own prior findings show that roading increases human ignition risk by that magnitude, the record must explain why rescission advances fire safety rather than undermining it. I ask that the agency reconcile the rescission with the ignition data in its own DEIS and explain, specifically, why this proposal departs from those prior findings on fire occurrence in roadless areas.

The biodiversity loss the agency itself quantifies is left hanging without application to the lands actually at stake. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the document and then goes nowhere. No projection is made across the 40.1 million acres of potentially affected environment. A number that large, attached to a range that wide, demands more than a citation. The agency must apply the cited fragmentation range to the 40.1 million acres at issue and explain what the resulting losses mean for the wildlife communities those acres support.

Finally, the rulemaking is internally inconsistent on reliance. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is exactly the kind of interest the agency invited. Hunters and wildlife-dependent communities have organized their expectations, their public land use, and their support for conservation policy around protections that have been in place for more than two decades. An agency reversing course is obligated to assess what its prior policy created, not merely to ask for comments and discard them from the balance sheet. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before finalizing any rescission.

Sincerely,
Eric Houtchen
Owensboro, KY

Without the protections of the 2001 Roadless Area Conservation Rule, Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) in the Secesh Inventoried Roadless Area, Payette National Forest, loses its primary buffer against 7.3 - Other ecosystem modifications, assessed at Extreme or 71-100% pop. decline severity across Restricted (11-30%) scope.

The persistence of Suckley's Cuckoo Bumble Bee in Secesh under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 7.3 - Other ecosystem modifications to one that accelerates it.

NEPA requires the agency to take a hard look at the effects of rescission on Suckley's Cuckoo Bumble Bee (Bombus suckleyi) in the Secesh IRA. The DEIS fails this standard without site-specific analysis of 7.3 - Other ecosystem modifications at the severity and scope documented by NatureServe.

"Grazing by domestic herbivores is the most widespread land use on the planet, and also a major global change driver in grasslands. We show that aridity partly explains the responses of biodiversity and multifunctionality to long-term livestock grazing. Grazing greatly reduced biodiversity and multifunctionality in steppes with higher aridity, while had no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relative lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity."
— Nature Communications, 2023

Rescission is unwarranted; the Department should allow the 2001 Rule to stand.

With determination,

CommentID: RLC-20260823-SU0EAT

"Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups."
— Landscape Ecology (Springer Nature), 2025

A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this proposal gives it.

Respectfully submitted,

CommentID: RLC-20260902-IP0AIZ

If the DEIS does not evaluate how rescission affects Northwestern Pond Turtle (Actinemys marmorata, G2) in Briscoe with respect to 7.2 - Dams & water management/use, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA.

"Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups."
— Landscape Ecology (Springer Nature), 2025

“Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)”

Failure to Connect Species/Habitat Baseline to Rescission-Specific Impacts Analysis

The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized.

Rescission would not be a reasoned policy choice on the record presented; the Department should not finalize it.

Respectfully,

CommentID: RLC-20260908-OTV7WU

For Eastern Hellbender in Sam Knob (addition), the connection between road construction and 7.2 - Dams & water management/use is direct: roads deliver the disturbance vectors — sediment, access, fragmentation — that NatureServe identifies as driving Moderate or 11-30% pop. decline severity impacts on this population.

The DEIS analysis of Sam Knob (addition) must incorporate NatureServe's standardized threat assessment data for Eastern Hellbender (Cryptobranchus alleganiensis alleganiensis, T2), including the IUCN-CMP classification (7.2), Moderate or 11-30% pop. decline severity rating, and Restricted (11-30%) scope determination.

"Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups."
— Landscape Ecology (Springer Nature), 2025

An administrative record spanning more than two decades argues against rescission; the Department should act accordingly.

Yours in conservation,

CommentID: RLC-20260820-N33JYC

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

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

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

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

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

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

Sincerely,
Sean Eagan
Manchester, MD

The fire argument cuts against the proposal, not for it. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Roading the Quinault region would increase the possibility of fire. That is not my speculation. That is what the agency's own draft environmental impact statement shows. I ask that the agency explain why the proposal departs from those findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The proposal cannot establish that the economics add up. The agency's own record states 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 production figure, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. A road system already carrying a $6.9 billion maintenance backlog would be expanded for a return the agency cannot demonstrate is positive. Roading the South Quinault area would destroy my business as a tour guide in a currently unroaded area and would negatively affect the hiking trails my customers rely on. The agency must reconcile those numbers on the record and explain how an action whose own analysis cannot establish a net benefit justifies this rescission.

The proposal also must reckon with what the existing rule already allows. The 2001 rule did not ban all road construction. It included exceptions for public health and safety, for reserved or outstanding rights, and for existing uses. The proposal justifies rescission on permitting and administrative burden grounds, but it does not identify which specific burdens are not already addressed by those exceptions. Our community gets its drinking water from the Quinault region. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The public health and safety exception was written for exactly those stakes. The agency should identify on the record which burdens it claims are unmet by existing exceptions, and it should quantify them.

Finally, the agency's own record documents 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 proposal offers no population-level projection for big game. The South Quinault area is part of a functioning ecosystem. A rule change with documented effects on wildlife behavior demands that the agency project what those effects mean at the population level before any final action is taken.

I make my livelihood in this region. The mushrooms I forage and the tours I lead depend on this place staying whole. What the agency treats as an administrative question is, for me and for my community, a practical one: whether the water is clean, whether the forest stands, whether the business survives. I expect a substantive response in this docket.

Sincerely,
Matt Houghton
Quinault, WA

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

On wildfire, the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on fuels management grounds, yet this finding points in the opposite direction. The agency must explain why the proposal departs from its own prior conclusions about fire occurrence, and how it reconciles this rescission with the ignition data in its own draft environmental impact statement.

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

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

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

Sincerely,
Nancy S Johnson, Edmonds, WA

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

Our public land should be managed for now and for our children's children. Abolishing roadless areas and allowing ATVs and dirt bikes everywhere completely ruins what makes them worth visiting. I already see plenty of drunk idiots on Razors nearer to the accessible roads, starting illegal campfires and littering everywhere. I do not want that driven up into roadless backcountry. If you remove the roadless rule, the dregs of society will come for the Lost Rivers backcountry around Borah Peak. The Borah Peak roadless area covers more than 130k acres in the Salmon-Challis National Forest. That NF contains the largest roadless complex outside of designated wilderness in the lower 48, and it supports Chinook salmon, steelhead, bull trout, wolverine, mountain goat, bighorn sheep, and gray wolf. The Angel Peak North roadless area covers 12,577 acres in the Humboldt-Toiyabe National Forest, the largest national forest in the lower 48, where each roadless range rises from the Great Basin like a sky island with its own ecology, its own water, its own wildlife. The Humboldt-Toiyabe holds 354 inventoried roadless areas totaling 3,383,849 acres, and verified species there include Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and elk. Stop trying to ruin what little we have.

The proposal justifies rescission partly on wildfire and fuels management grounds. That argument contradicts the agency's own findings. According to the Forest Service, "more than 90 percent of wildland fires are the result of human activity, and ignitions are almost twice as likely to occur in roaded areas as they are in roadless areas (USDA Forest Service 1998, 2000)." Opening these landscapes to roads and motorized access does not reduce fire risk. It imports the ignition sources the agency's own data identify. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The agency also claims administrative burden justifies rescission, but its own record states: "It makes little fiscal or environmental sense to build additional roads in inventoried roadless areas that have irretrievable values at risk when the agency is struggling to maintain its existing extensive road system (FEIS Vol. 1, 1-5 and 3-22)." The rule as written already contains exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which burdens those exceptions fail to address. I ask that it do so specifically, and that it quantify those claimed burdens on the record rather than assert them.

The proposal's regulatory flexibility analysis certifies no significant impact on small entities. The agency's own CBA analyzes lost recreation benefit at a minimum of $6.1 million per year and names outfitters, guides, and tour operators among the affected parties, yet the certification is reached by spreading the $9 million annual expenditure loss across every small firm in the sector nationally (no case-by-case analysis whatsoever). The analysis even concedes some firms may lose these receipts. That is not a no-impact finding. The agency should withdraw the certification and assess the small entities actually operating in the potentially affected roadless areas, not the national average firm.

Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have planned repeated fall trips into the Angel Peak North roadless area in the Humboldt-Toiyabe based on the protections the 2001 rule provides. That is a reliance interest. The agency invited these comments and must weigh what it receives. I ask that it identify and assess the reliance interests described in the record before reaching any final decision.

Thanks,
Maxwell Erickson
North Las Vegas, NV

The 2001 Roadless Rule does not address livestock-grazing impacts, and grazing has continued uninterrupted in Inventoried Roadless Areas. A mapping analysis estimates that between 10 million and 15 million acres of these lands are actively grazed by domestic livestock each year. Livestock can damage streams and springs, remove riparian vegetation, compact soils, spread invasive plants, and displace native wildlife. New road construction would enable harmful livestock grazing to expand. And those grazing their livestock aren't even paying for their impacts or paying a fair price for their leases.

The Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values. The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights.

The Forest Service should also prohibit new mineral leasing within these lands. More than 9,000 miles of mapped motorized trails cross roadless areas. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk! Road raise the risks to rural communities!

Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies. I ask that the Forest Service withdraw the proposed rescission and adopt a stricter national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use.

We must preserve these tracts for future generations. Making them more prone to wildfire and other use-related abuses that scar the land and take away dwindling habitats harms everyone. Please withdraw the proposed rescission, and make a stricter national rule. Monied interests should not offset the greater good, or trump our commitments to future generations while making our wild lands more susceptible to human-caused wildfire.

Water is a critical resource of growing importance to all Americans, and it is essential that we preserve the quality of water in nature. The Wolfpen roadless area protects the headwaters that feed the Red River, which means road-induced sedimentation in that area is not an abstract national statistic but a direct threat to a named Wild and Scenic River corridor. The agency's own prior analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The proposal does not explain how Kentucky's sole roadless area, positioned at the headwaters of its only protected river, is supposed to absorb that sediment load. I ask that the agency address this specific hydrology on the record.

On the question of fire, the agency's own record is difficult to square with the proposal's direction. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The rescission is justified in part on wildfire and fuels management grounds, but the agency's own ignition data cuts the other direction: "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." The agency must quantify the expected increase in human-caused ignitions from new road access and weigh that figure against any claimed reduction in wildfire hazard before proceeding.

The regulatory flexibility analysis presents a separate problem. 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. That certification is reached by spreading the loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The analysis itself concedes that some firms may lose these receipts. The certification should be withdrawn and the impact assessed against the small entities actually operating in the potentially affected roadless areas, not an averaged national firm.

Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is itself such an interest. The agency has an obligation, when changing course, to identify and weigh the reliance interests its prior policy created. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken.

Sincerely,
Ralph Grove
Louisville, KY

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

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

2. THE ECONOMICS DO NOT CLEAR THE TAXPAYER BAR.
Preamble figures: $5.2M-$11.4M per year to the Treasury and Forest Service, $4.6M-$10.6M per year to the timber industry, against an acknowledged $6.9 billion deferred maintenance backlog on roads and bridges and roughly $6.1M per year in lost recreation benefit. Best case, the timber upside is a rounding error against the backlog and is largely cancelled by the recreation loss. At the low end of the agency's own range it is net negative. Request: model full lifecycle cost per new road mile (construction, maintenance, culverts, decommissioning) and disclose the net fiscal position. Adding assets we cannot maintain is how the backlog reached $6.9 billion.

3. ROADS CARRY IGNITIONS. THAT IS THE AGENCY'S OWN SCIENCE.
Roughly nine in ten wildfires are human-caused. Forest Service researchers mapped 26 years of ignitions along about 850 miles of road in the Angeles, San Bernardino, Los Padres and Cleveland National Forests. The preamble itself concedes that greater access "can increase human-caused ignition potential." Request: quantify it. Model expected additional ignitions per new road mile against expected acres treated and show the net change in community risk. Right now the fire rationale is asserted, not calculated.

4. THIS REDUCES LOCAL CONTROL. IT DOES NOT INCREASE IT.
Idaho and Colorado already built their own roadless rules by petition under 5 U.S.C. 553(e), and this proposal leaves both intact. That is proof the current framework is not one-size-fits-all. States that wanted tailoring got it. Full rescission does not hand decisions to local officials. It removes the floor and pushes every acre into plan revisions and project-level NEPA: more federal process, more litigation, more delay. That runs against the stated deregulatory purpose of E.O. 14192.

5. RELIANCE INTERESTS, SINCE THE PREAMBLE ASKS FOR THEM.
Twenty-five years of private investment sits on this rule. Outfitters, guides, ranchers whose operations depend on intact headwaters, and the lodging, fuel, food and retail businesses in gateway towns whose product is the country next door. I am on the customer side of that economy, and my money goes to those towns because of what surrounds them. In 2024 outdoor recreation was $1.3 trillion in output, 2.4% of GDP and 5.2 million jobs, and hunting and shooting was the fastest-growing category in it at 16.5%. A projected $6.1M annual recreation loss does not credibly describe that exposure. It is a placeholder.

6. TAILORING.
The community-protection rationale rests on WUI overlap: 9.8 million acres, 24%. Rescinding 100% of the rule to reach 24% of the acres is not narrow tailoring. A WUI-scoped alternative delivers the fire benefit without the rest, and I would support it.

7. PROCESS.
The 2001 rule came out of 600 public meetings and 1.6 million comments. This round is 30 days with no public meetings, on a proposal the preamble concedes could exceed $100 million in annual effects. That gap will be the first thing a court looks at.

One last thing. I camp on Forest Service ground, dispersed sites off forest roads across the Eastern Sierra, the Great Basin and the Northern Rockies. I photograph the night sky out there because dark sky has a hard boundary: it exists where roads and lights do not, and there is less of it every year. That country is an asset on the national balance sheet, and it took 25 years to stop borrowing against it. Roosevelt understood you do not liquidate the principal to make a quarter.

Keep the rule. Fund the treatments. Use petitions where states want something different.

A supporting statement with citations and a fiscal table is attached.

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

I have lived in this community for 24 years. In that time we have faced two huge wildfires, one being the largest in Oregon at the time. During the Chetco Bar Fire, the smoke turned the sky an ominous color and I was having trouble breathing during the worst of it. That experience makes the agency's wildfire rationale for this rescission something I take seriously, which is exactly why I cannot accept it uncritically. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why this proposal departs from those findings and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The wildlife I encounter on these walks is not incidental. The birds, the bears, the bobcats depend on the character of this landscape. The DEIS cites the findings 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. The agency's own record on bears is equally direct: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. These findings appear in the agency's own draft environmental impact statement, and they bear directly on the black bears I have seen in the forests around South Kalmiopsis and Mt. Emily. The agency must address on the record how opening these 5,764 acres, 1,308 acres, 104,477 acres, and 91,560 acres to road construction is consistent with its own findings on wildlife impacts.

The economic justification for rescission fares no better under the agency's own numbers. The record before the agency states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit. I ask how an action whose own Cost Benefit Analysis cannot confirm a net gain justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

The agency's own accounting is perhaps the clearest indictment of this proposal. Cost Benefit Analysis Table 4 lists among the qualitative unquantified costs of the proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; agency road maintenance burden." The wildfire benefit the agency claims in favor of rescission sits in the benefits column explicitly because the agency says it cannot quantify it. The DEIS itself records human-caused ignition density at 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency is selling this rescission as wildfire protection while booking increased ignition risk as an unquantified cost and placing the promised fire reduction among benefits it admits it cannot measure. The agency must quantify the net wildfire effect of this action in either direction before wildfire can serve as any part of the justification for it.

Sincerely,
Kathleen Dickson
Brookings Oregon

2. The rule has not restricted my recreation — it is why the recreation is worth having. I've trained to ride the Shenandoah Mountain 100 out of Stokesville, and I ride that country throughout the year besides. Much of it is the Little River Roadless Area and the North River district around Reddish Knob, where mountain biking is already permitted on most trails. I say that plainly because the proposal is framed partly as restoring access: the 2001 rule has never kept me off a trail. What it has done is keep those trails from being logged and roaded. Removing it does not expand access; it degrades what access is for. Roughly a quarter of the Appalachian Trail also lies in Virginia, with parts of the corridor crossing IRAs. I request that the final EIS address impacts to the Appalachian National Scenic Trail corridor and to established non-motorized recreation in these areas.

3. This cuts against Chesapeake Bay obligations private parties already fund. Virginia holds roughly 394,000 acres of inventoried roadless area, more than any other eastern state, and these are headwaters draining to the James and the Potomac. The DEIS acknowledges increased erosion and sedimentation risk. On my projects I spend substantial money on stormwater management, erosion and sediment control, and nutrient credits — costs imposed because Virginia committed to reducing sediment loading to the Bay. I don't object to those obligations. I object to a federal action that adds unquantified sediment at the top of the same watersheds while the regulated private sector pays to remove it downstream. That is not a fair allocation, and not an efficient one: headwater sediment prevented is far cheaper than sediment removed. I request that the final EIS analyze whether this sedimentation is consistent with the Chesapeake Bay TMDL and Virginia's Watershed Implementation Plan, and if not, disclose who bears the offsetting cost.

4. The stated rationale is western; the record does not support applying it here. The justification rests on wildfire hazard, insect and disease mortality, and mechanical access — conditions describing the Interior West, not the central Appalachians. Roughly 97% of Virginia's timber harvest is on private land, and the GW forest plan already identifies about 42% of the forest as suitable for timber. The DEIS does not appear to identify Virginia stands where treatment is warranted and actually foreclosed by Subpart B. I request that the final EIS disclose, by forest, the acreage where the roadless prohibition is the binding constraint on a needed treatment, as distinct from acreage constrained by funding, terrain, or capacity. The agency also concedes timber revenue would not cover the cost of new roads, against a maintenance backlog near $6.9 billion. In my business, building an asset you cannot maintain creates a liability, not access — and an unmaintained road becomes a chronic sediment source.

5. On Alternative 3, I cannot evaluate what has not been disclosed. It removes designation from IRAs near existing roads and within the wildland-urban interface. Appalachian roadless areas are smaller, more fragmented, and closer to roads and settlement than western ones, so thresholds retaining meaningful acreage in Idaho may retain almost nothing in Virginia. I request that the final EIS publish acreage retained and removed under Alternative 3 by state and national forest, with the thresholds used. Absent that, the public cannot meaningfully comment on it, and I do not support it.

The 2001 rule is a floor, and its durability is most of what it provides. I urge selection of Alternative 1.

Rob Lanphear, Richmond, Virginia

The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds.

Issue 3: Fragmentation is quantified and not applied

I fish warmwater, and good fishing rests on habitat that stays connected. The agency quantified what fragmentation costs and never carried the number through: The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent.

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

Issue 4: Elk survival, in the agency’s own citation

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

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

Issue 5: Carbon is stated and dropped

The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons.

The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Belinda B Storie
Murfreesboro, TN 37129

The Mt. Baker North IRA (16,873 acres) in Mt Baker-Snoqualmie National Forest possesses unique ecological characteristics — including distinct species assemblages, watershed configurations, and ecosystem composition — that a programmatic analysis covering 2,332 roadless areas cannot adequately evaluate.

A programmatic EIS cannot evaluate the specific impacts of road construction on the particular watersheds, wildlife corridors, and ecological systems within the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest. NEPA does not permit substituting generic, landscape-scale analysis for site-specific impact evaluation.

The DEIS must include individualized analysis of the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest, addressing site-specific impacts to watersheds, wildlife habitat, and ecological integrity. A programmatic EIS covering 2,332 areas does not meet NEPA's requirement under 40 CFR 1502 for analysis commensurate with the significance of the action.

"Inventoried roadless areas considered in this rule constitute roughly one-third of all National Forest System lands, or approximately 58.5 million acres. Of the 58.5 million acres of inventoried roadless areas considered in the FEIS, approximately 34.3 million acres have prescriptions that allow road construction and reconstruction. The remaining 24.2 million acres are currently allocated to management prescriptions that prohibit road construction; however, protections in these existing plans may change after future forest plan amendments or revisions. Over the past 20 years, roads have been constructed in an estimated 2.8 million of those 34.3 million acres of inventoried roadless areas."
— USDA Forest Service

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.

The Department is urged to resolve this proceeding in favor of retention, not rescission.

Yours truly,
Garrett Rowles
CommentID: RLC-20260901-ZYCHBW

The proposal uses wildfire and fuels management as a justification, but the agency's own record undercuts that reasoning. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency should explain why this proposal departs from that finding, and reconcile the rescission with its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The proposal also argues that state-specific approaches can substitute for a single national rule. The agency has tried that before, and it did not survive review. The record shows that the agency previously expressed dissatisfaction with the Roadless Rule's nationwide approach and favored state-by-state rulemaking. The Ninth Circuit rejected that substitution. The agency must now explain how this proposal avoids the same deficiencies, and address its own prior finding that local, incremental decision-making erodes nationally significant roadless values that cannot be recovered once roads go in.

The regulatory flexibility certification claims no significant impact on small entities, but the agency's own analysis names outfitters, guides, and tour operators as affected parties, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The certification reaches its no-impact conclusion by spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the potentially affected roadless areas. The agency concedes that some of those firms may lose those receipts. That is not a finding of no significant impact. The certification should be withdrawn and replaced with an assessment of the businesses actually operating in these areas.

Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have built part of my career around these forests and the birds in them. The rule's protections are part of what makes that work possible. Under controlling precedent, an agency reversing course must identify and weigh the reliance interests its prior policy created. This comment is one such interest. The agency must account for the reliance interests submitted in response to its own invitation, including this one, before it proceeds further.

Sincerely,
Stephanie Mancilla
Santa Cruz & Modesto CA

The hiking I do on Craggy Mountain and Bearwallow Mountain, and the paddling and swimming I do at Lake James below Linville Gorge and Dobson Knob, depend on watersheds that road construction would disturb. The agency's own document acknowledges that skid roads, trails, log landings, and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number appears in the document, and then nothing follows it. No projection of how much sediment actually reaches downstream waterways, no estimate of what arrives at municipal intakes. The agency must quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before it can call this record adequate.

The drinking water question is not adequately answered by asserting that forest plans address it. The agency's own language acknowledges that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." That statistic represents a protection already functioning under the current rule, and the proposal offers no forest-by-forest accounting of which plan provisions would substitute for the enforceable protections at 36 CFR 294.12 and 294.13. The agency should identify those provisions, forest by forest, so the public can evaluate whether they are genuinely equivalent.

On the economic case for rescission, the agency's own record states 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 those marginal production figures, the Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value range spanning -$92 million to +$199 million. A range that wide cannot establish a net benefit. It cannot justify expanding a road system already carrying a $6.9 billion maintenance backlog. The agency must explain on the record how an action whose own economic analysis produces that degree of uncertainty, against acknowledged costs to recreation and watershed integrity, meets the standard of reasoned decision-making.

I oppose this rescission. The places I hike, the water I paddle and swim in, and the air I breathe during fire season are all touched by what happens in these roadless areas. The agency's own numbers, on ignition rates, on sediment, on drinking water, and on economics, point against this action. The public record should reflect a genuine response to each of those points before any final decision is made.

Sincerely,
Anna Patterson
Asheville, North Carolina

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

2. THE ECONOMICS DO NOT CLEAR THE TAXPAYER BAR.
Preamble figures: $5.2M-$11.4M per year to the Treasury and Forest Service, $4.6M-$10.6M per year to the timber industry, against an acknowledged $6.9 billion deferred maintenance backlog on roads and bridges and roughly $6.1M per year in lost recreation benefit. Best case, the timber upside is a rounding error against the backlog and is largely cancelled by the recreation loss. At the low end of the agency's own range it is net negative. Request: model full lifecycle cost per new road mile (construction, maintenance, culverts, decommissioning) and disclose the net fiscal position. Adding assets we cannot maintain is how the backlog reached $6.9 billion.

3. ROADS CARRY IGNITIONS. THAT IS THE AGENCY'S OWN SCIENCE.
Roughly nine in ten wildfires are human-caused. Forest Service researchers mapped 26 years of ignitions along about 850 miles of road in the Angeles, San Bernardino, Los Padres and Cleveland National Forests. The preamble itself concedes that greater access "can increase human-caused ignition potential." Request: quantify it. Model expected additional ignitions per new road mile against expected acres treated and show the net change in community risk. Right now the fire rationale is asserted, not calculated.

4. THIS REDUCES LOCAL CONTROL. IT DOES NOT INCREASE IT.
Idaho and Colorado already built their own roadless rules by petition under 5 U.S.C. 553(e), and this proposal leaves both intact. That is proof the current framework is not one-size-fits-all. States that wanted tailoring got it. Full rescission does not hand decisions to local officials. It removes the floor and pushes every acre into plan revisions and project-level NEPA: more federal process, more litigation, more delay. That runs against the stated deregulatory purpose of E.O. 14192.

5. RELIANCE INTERESTS, SINCE THE PREAMBLE ASKS FOR THEM.
Twenty-five years of private investment sits on this rule. Outfitters, guides, ranchers whose operations depend on intact headwaters, and the lodging, fuel, food and retail businesses in gateway towns whose product is the country next door. I am on the customer side of that economy, and my money goes to those towns because of what surrounds them. In 2024 outdoor recreation was $1.3 trillion in output, 2.4% of GDP and 5.2 million jobs, and hunting and shooting was the fastest-growing category in it at 16.5%. A projected $6.1M annual recreation loss does not credibly describe that exposure. It is a placeholder.

6. TAILORING.
The community-protection rationale rests on WUI overlap: 9.8 million acres, 24%. Rescinding 100% of the rule to reach 24% of the acres is not narrow tailoring. A WUI-scoped alternative delivers the fire benefit without the rest, and I would support it.

7. PROCESS.
The 2001 rule came out of 600 public meetings and 1.6 million comments. This round is 30 days with no public meetings, on a proposal the preamble concedes could exceed $100 million in annual effects. That gap will be the first thing a court looks at.

One last thing. I camp on Forest Service ground, dispersed sites off forest roads across the Eastern Sierra, the Great Basin and the Northern Rockies. I photograph the night sky out there because dark sky has a hard boundary: it exists where roads and lights do not, and there is less of it every year. That country is an asset on the national balance sheet, and it took 25 years to stop borrowing against it. Roosevelt understood you do not liquidate the principal to make a quarter.

Keep the rule. Fund the treatments. Use petitions where states want something different.

A supporting statement with citations and a fiscal table is attached.

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

The fire argument cuts against the proposal, not for it. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Roading the Quinault region would increase the possibility of fire. That is not my speculation. That is what the agency's own draft environmental impact statement shows. I ask that the agency explain why the proposal departs from those findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The proposal cannot establish that the economics add up. The agency's own record states 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 production figure, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. A road system already carrying a $6.9 billion maintenance backlog would be expanded for a return the agency cannot demonstrate is positive. Roading the South Quinault area would destroy my business as a tour guide in a currently unroaded area and would negatively affect the hiking trails my customers rely on. The agency must reconcile those numbers on the record and explain how an action whose own analysis cannot establish a net benefit justifies this rescission.

The proposal also must reckon with what the existing rule already allows. The 2001 rule did not ban all road construction. It included exceptions for public health and safety, for reserved or outstanding rights, and for existing uses. The proposal justifies rescission on permitting and administrative burden grounds, but it does not identify which specific burdens are not already addressed by those exceptions. Our community gets its drinking water from the Quinault region. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The public health and safety exception was written for exactly those stakes. The agency should identify on the record which burdens it claims are unmet by existing exceptions, and it should quantify them.

Finally, the agency's own record documents 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 proposal offers no population-level projection for big game. The South Quinault area is part of a functioning ecosystem. A rule change with documented effects on wildlife behavior demands that the agency project what those effects mean at the population level before any final action is taken.

I make my livelihood in this region. The mushrooms I forage and the tours I lead depend on this place staying whole. What the agency treats as an administrative question is, for me and for my community, a practical one: whether the water is clean, whether the forest stands, whether the business survives. I expect a substantive response in this docket.

Sincerely,
Matt Houghton
Quinault, WA

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

I go to Farles Prairie in the early morning to photograph birds. I like seeing the marked longleaf pines where the red-cockaded woodpecker lives. Red-cockaded woodpeckers recovered here from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. The agency's own record states 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) I have also seen deer, hogs, bear, and otters in this forest. The DEIS cites Wyoming research finding roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the agency's own analysis says the danger is disrupted migration and lost unroaded security. The agency owes this record a specific response to what road construction in these areas would mean for species that have recovered precisely because the land stayed unroaded.

The roads I cross backpacking are mostly sugar sand. Building roads to access timber would require far more than a sugar sand road, and the trucks that followed would bring more noise, smell, and pollution. No one has gone out hiking and backpacking in the forest and said, gee, if only there were more roads it would be better. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission in part on wildfire and fuels management grounds. I ask that the agency reconcile the 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.

The economics of this proposal do not hold together. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency should explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

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. That certification was reached by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency should withdraw the certification and assess the small entities actually operating in the potentially affected roadless areas.

Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such an interest. I visit and backpack through the Ocala National Forest and want to continue to have a wilderness experience. Public lands should be managed for the public to use, to enjoy, to find a calm place to relax, not to benefit companies exploiting the forest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one.

Sincerely,
Elizabeth Lambert

Dade City, Florida

The agency's own numbers undercut the economic case for this action. The record states 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 supply sits a cost-benefit analysis the agency cannot resolve in favor of the proposal: projected 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, and a net present value range spanning -$92 million to +$199 million. The Forest Service is already $6.9 billion behind on maintaining the roads it has, running a road budget of roughly $73 million a year. It does not make sense to authorize more roads when the agency cannot maintain the roads it already has. I ask the agency to reconcile the proposal with its own economic analysis and to explain how an action whose cost-benefit analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog.

Sediment is the direct link between new roads and the Smith River's water quality, and the agency quantifies the risk and then stops. The document acknowledges that skid roads, trails, log landings and similar disturbances are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity, but no projection of sediment delivery to downstream municipal intakes follows that finding. The agency's own data show that more than 7,000 municipal intakes sit in watersheds fed by these roadless areas and that approximately 24 million people use water originating there. The agency must quantify projected sediment delivery to those intakes, watershed by watershed, before finalizing any action.

The drinking-water question has a companion gap. The record 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." The DEIS asserts that existing forest plans address sources of public drinking water without identifying a single enforceable provision equivalent to what 36 CFR 294.12 and 294.13 currently provide. The agency must identify, forest by forest, which plan provisions would carry that protective function if the rule is rescinded.

On fire, the agency's own prior findings work against the justification offered here. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless cites wildfire and fuels management as grounds for rescission. The agency must explain why this proposal departs from those findings and reconcile the 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.

The Smith River is what it is because roads were kept out. The rule must not be rescinded.

Sincerely,
Adam Spencer
Gasquet, CA

2. The rule has not restricted my recreation — it is why the recreation is worth having. I've trained to ride the Shenandoah Mountain 100 out of Stokesville, and I ride that country throughout the year besides. Much of it is the Little River Roadless Area and the North River district around Reddish Knob, where mountain biking is already permitted on most trails. I say that plainly because the proposal is framed partly as restoring access: the 2001 rule has never kept me off a trail. What it has done is keep those trails from being logged and roaded. Removing it does not expand access; it degrades what access is for. Roughly a quarter of the Appalachian Trail also lies in Virginia, with parts of the corridor crossing IRAs. I request that the final EIS address impacts to the Appalachian National Scenic Trail corridor and to established non-motorized recreation in these areas.

3. This cuts against Chesapeake Bay obligations private parties already fund. Virginia holds roughly 394,000 acres of inventoried roadless area, more than any other eastern state, and these are headwaters draining to the James and the Potomac. The DEIS acknowledges increased erosion and sedimentation risk. On my projects I spend substantial money on stormwater management, erosion and sediment control, and nutrient credits — costs imposed because Virginia committed to reducing sediment loading to the Bay. I don't object to those obligations. I object to a federal action that adds unquantified sediment at the top of the same watersheds while the regulated private sector pays to remove it downstream. That is not a fair allocation, and not an efficient one: headwater sediment prevented is far cheaper than sediment removed. I request that the final EIS analyze whether this sedimentation is consistent with the Chesapeake Bay TMDL and Virginia's Watershed Implementation Plan, and if not, disclose who bears the offsetting cost.

4. The stated rationale is western; the record does not support applying it here. The justification rests on wildfire hazard, insect and disease mortality, and mechanical access — conditions describing the Interior West, not the central Appalachians. Roughly 97% of Virginia's timber harvest is on private land, and the GW forest plan already identifies about 42% of the forest as suitable for timber. The DEIS does not appear to identify Virginia stands where treatment is warranted and actually foreclosed by Subpart B. I request that the final EIS disclose, by forest, the acreage where the roadless prohibition is the binding constraint on a needed treatment, as distinct from acreage constrained by funding, terrain, or capacity. The agency also concedes timber revenue would not cover the cost of new roads, against a maintenance backlog near $6.9 billion. In my business, building an asset you cannot maintain creates a liability, not access — and an unmaintained road becomes a chronic sediment source.

5. On Alternative 3, I cannot evaluate what has not been disclosed. It removes designation from IRAs near existing roads and within the wildland-urban interface. Appalachian roadless areas are smaller, more fragmented, and closer to roads and settlement than western ones, so thresholds retaining meaningful acreage in Idaho may retain almost nothing in Virginia. I request that the final EIS publish acreage retained and removed under Alternative 3 by state and national forest, with the thresholds used. Absent that, the public cannot meaningfully comment on it, and I do not support it.

The 2001 rule is a floor, and its durability is most of what it provides. I urge selection of Alternative 1.

Rob Lanphear, Richmond, Virginia

The proposal justifies itself partly on wildfire and fuels management grounds. The agency's own record contradicts that justification directly. It states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must explain, in its response, why the proposal departs from this finding, and how it reconciles the rescission with the ignition data in DEIS Table 21, which the record indicates shows far higher fire density on roaded land than inside the affected roadless areas.

The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The courts that reviewed that specific question disagreed. The Tenth Circuit 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." The agency should address that holding directly, including the court's conclusions regarding authority under the Organic Act and the Multiple-Use Sustained-Yield Act, and state on what basis it holds a contrary view.

On the question of whether the agency can afford what it is proposing: the country is now $40 trillion in debt. Spending more to build new roads when we cannot afford to maintain the ones we already have makes no sense. The agency's own DEIS confirms this is not a hypothetical concern: "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 DEIS further states that road mileage, deferred maintenance, and management costs are likely to increase under the proposal. The agency should name the funding source for any new road construction and maintenance the rescission enables, and state the projected change in the deferred maintenance backlog.

Finally, the economic case for rescission has not been made. The agency's own Cost Benefit Analysis states: "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." A range spanning from a $92 million loss to a $199 million gain is not a finding of net benefit. The cost column as presented excludes road construction costs the same document quantifies at $80,000 to $100,000 per mile, along with maintenance and fuel treatment costs also quantified in that document, and the upper bound assumes maximum potential harvest the analysis itself calls uncertain. That analysis was not placed on the docket where the public could find and evaluate it. The agency should place the Cost Benefit Analysis on the docket, restate the net present value with road and fuels costs included in the cost column, and show the arithmetic supporting any claim that impacts could exceed $100 million.

Sincerely,
Blake Puhak
Richmond, VA

The proposal uses wildfire and fuels management as a justification, but the agency's own record undercuts that reasoning. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency should explain why this proposal departs from that finding, and reconcile the rescission with its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The proposal also argues that state-specific approaches can substitute for a single national rule. The agency has tried that before, and it did not survive review. The record shows that the agency previously expressed dissatisfaction with the Roadless Rule's nationwide approach and favored state-by-state rulemaking. The Ninth Circuit rejected that substitution. The agency must now explain how this proposal avoids the same deficiencies, and address its own prior finding that local, incremental decision-making erodes nationally significant roadless values that cannot be recovered once roads go in.

The regulatory flexibility certification claims no significant impact on small entities, but the agency's own analysis names outfitters, guides, and tour operators as affected parties, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The certification reaches its no-impact conclusion by spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the potentially affected roadless areas. The agency concedes that some of those firms may lose those receipts. That is not a finding of no significant impact. The certification should be withdrawn and replaced with an assessment of the businesses actually operating in these areas.

Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have built part of my career around these forests and the birds in them. The rule's protections are part of what makes that work possible. Under controlling precedent, an agency reversing course must identify and weigh the reliance interests its prior policy created. This comment is one such interest. The agency must account for the reliance interests submitted in response to its own invitation, including this one, before it proceeds further.

Sincerely,
Stephanie Mancilla
Santa Cruz & Modesto CA

Wildfire and forest health are legitimate concerns, but full rescission is not the only answer. The current rule permits roads needed to protect public health and safety from an imminent threat of fire or another catastrophe. It also permits generally small-diameter timber removal for ecological restoration and reduction of uncharacteristic wildfire effects, plus incidental cutting for fire-line construction. See 36 CFR 294.12(b)(1) and 294.13(b)(1)-(2). If those approvals are inconsistent or too slow, USDA should repair that process instead of erasing the national standard.

The Forest Service’s own research deserves a direct response. Sean P. Healey’s peer-reviewed 2020 study found similar burn rates in roaded and roadless forests, documented fuel treatments in roadless areas, and found non-native plants twice as common within 500 feet of roads. Nearly twenty years of monitoring did not support eliminating road prohibitions as a forest-health measure. DOI: https://doi.org/10.1088/1748-9326/aba031. The final EIS should explain with current evidence why USDA reaches a different conclusion.

This is also a Tennessee issue. The Forest Service lists about 85,000 inventoried roadless acres out of 698,000 National Forest System acres in Tennessee. The base Cherokee National Forest plan was approved in 2004. Even with amendments, a plan more than twenty years old should not automatically be treated as an adequate substitute for the national rule.

I ask USDA and the Forest Service to:

1. Select Alternative 1 and retain the rule unless and until a narrower replacement with enforceable protections is completed.

2. If added flexibility is needed, create defined, evidence-based procedures for hazardous-fuel and forest-health work, especially near the wildland-urban interface, instead of a blanket rescission.

3. Require every new road to have a documented need, life-cycle cost estimate, maintenance funding, water-quality controls, and enforceable decommissioning. Temporary roads must actually be temporary.

4. Publish a forest-by-forest gap analysis showing current protections, what each plan allows, and what changes under each alternative. Include clear maps and a specific analysis for Tennessee and the Cherokee National Forest.

5. Analyze cumulative and distributional effects, including sediment and drinking water, invasive species, human-caused ignition, wildlife fragmentation, recreation, tourism, and indirect effects on small rural businesses. No direct compliance duty does not mean no economic impact.

6. Complete Tribal consultation and Alaska subsistence analysis before choosing a final alternative, and require meaningful advance notice and comment before any plan or project removes roadless protections.

I am not asking the Forest Service to ignore unhealthy conditions or prevent emergency work. I am asking it to act with precision, evidence, and public accountability. Roads and their costs can outlast the timber sale and the administration that approved them. Keep the national floor, improve exceptions where evidence supports it, and do not replace a durable rule with promises that future decisions will be careful.

3. Reconcile the road maintenance figures. The proposal cites a $6.9 billion deferred maintenance backlog for roads and bridges. Commenters have documented $10.8 billion across 370,000 miles, a majority attributable to deteriorated roads causing sedimentation and fish passage barriers. Adding road mileage to a system the agency cannot maintain is not management. State the correct figure and explain how new construction is funded against it.

4. Reconcile the New Hampshire acreage. The record variously describes 235,000 and more than 265,000 acres of inventoried roadless area in the White Mountain National Forest. Publish the controlling number and its basis.

5. The agency has already demonstrated what it does with this discretion. Roadless acreage identified in the 2005 White Mountain Forest Plan fell outside the 2001 rule, and the Forest Service asserted it owed those lands no comparable protection, then proposed logging in them — including South Carr Mountain, Mill Brook, and Kanc 7. This is documented agency conduct, not speculation. Address it directly.

6. The local-decisionmaking premise fails without local staff. The entire rationale rests on forest supervisors exercising informed place-based judgment. Forest Service staffing has been reduced. Provide the staffing levels assumed by this proposal and the analysis supporting them.

7. The petition pathway converts a national trust into a patchwork. The proposal invites petitions under 5 U.S.C. 553(e), with Idaho and Colorado as precedent. National Forest System lands are held for all citizens, not for whichever party petitions hardest. Explain how the agency will prevent fragmentation of a national standard into state-by-state exemption.

8. Reliance interests and Tribal consultation. The proposal solicits comment on reliance interests; twenty-five years of recreation economies, conservation easements, and land use decisions built on this rule are such interests, and the agency must weigh them, not merely note them. USDA also determined that E.O. 13175 consultation was warranted here and then documented majority Tribal opposition. Finalizing over that record demands explanation.

In New Hampshire the trade is a $3.9 billion outdoor recreation economy against a $1.4 billion forest products industry, and the agency's own estimate of $6.1 million in annual lost recreation benefit nationally. Retain the rule.

Adam Davidson
Derry, New Hampshire

I care how my tax money gets spent, and I expect an honest accounting before public assets are traded away. The agency's own analysis cannot provide one. The Cost Benefit Analysis: “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.” The cost column excludes the road construction ($80,000 to $100,000 per mile, roughly $500,000 per mile in Alaska), maintenance and fuel treatment costs the same document quantifies, and the upper bound assumes maximum potential harvest the analysis itself calls uncertain.

An economically significant rule whose own analysis spans from a $92 million loss to a $199 million gain has not shown a benefit; the analysis was published in an agency file folder rather than on the docket, and the rule’s claim that impacts “could exceed $100 million” (91 FR 53830) appears with no arithmetic anywhere, though every quantified annual line item is under $22 million. I ask that the agency place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind the statement that impacts could exceed $100 million.

Issue 3: The small-business certification contradicts the analysis beside it

I care where the costs of this decision land, because it is my money either way. The certification here does not survive the analysis printed beside it. 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm.

Issue 4: Twenty-four million people’s drinking water is asserted away

Clean water matters to me, and my own tap may trace back to this country. I do not accept assurances in place of analysis. 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.

The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Anna Tench
Athens, Georgia

1. The range of alternatives is inadequate.
NEPA requires analysis of a reasonable range of alternatives, and the record already shows that intermediate approaches exist and function. Colorado and Idaho operate under state-specific roadless rules developed cooperatively with the agency, and both are excluded from this action. That is direct evidence that state-specific rulemaking is a practicable means of addressing genuine regional management needs without nationwide rescission. The following should be analyzed in detail:
(a) retention of the 2001 rule with narrowly drawn amendments addressing fuels reduction in the wildland-urban interface;
(b) a state petition process extending the Colorado and Idaho model to states demonstrating specific need;
(c) no action.
Relatedly, the purpose and need are framed around wildfire risk, but the proposed action applies nationwide without regard to fire regime, ignition history, or proximity to communities at risk. Roadless areas in the Southeast, the Great Lakes, and the northern Rockies do not share a fire problem. The Draft EIS should disclose what proportion of inventoried roadless acreage lies in the wildland-urban interface, where treatment demonstrably reduces risk to structures

2. The record does not establish that the existing rule is the binding constraint.
The 2001 rule permits road construction and timber cutting under specified exceptions. Before rescinding it on the grounds that it blocks needed management, the agency should place in the record: how many projects were proposed within inventoried roadless areas over the last decade; how many were authorized under existing exceptions; how many were denied and on what grounds; and how many were delayed or abandoned for reasons unrelated to the rule, including appropriations, staffing, contractor capacity, and unrelated litigation. Without that showing, the claim that the rule is the operative barrier is unsupported, and the Draft EIS cannot demonstrate the action will achieve its stated purpose.

3. Incrased access is a known ignition vector, and the offset is not quantified.
Most wildfire ignitions in the United States are human-caused, and human-caused ignitions concentrate along roads and points of access. A rescission enabling new road construction across tens of millions of acres therefore carries a countervailing effect on the risk it is intended to reduce. The Draft EIS should quantify projected new road miles under the proposed action, the expected change in human-caused ignition frequency associated with that access, and the net effect on acres burned and structures lost. The fuels-treatment benefit analyzed in isolation is not a sufficient disclosure.

4. Lifecycle road cost is not adequately disclosed.
The agency carries a substantial deferred maintenance backlog against a road system it already cannot maintain to standard. New construction creates a permanent maintenance obligation and a permanent sediment-delivery liability. The Draft EIS should disclose projected capital and lifecycle maintenance costs for roads anticipated under this action, and state whether it assumes appropriations sufficient to maintain them. If it does not, the consequences of an expanded and under-maintained road system — chronic sedimentation, culvert failure, unauthorized use — are reasonably foreseeable effects requiring analysis.

5. Additional deficiencies.
Inventoried roadless areas supply headwaters for municipal and agricultural water systems far beyond forest boundaries; the Draft EIS should identify the downstream systems and populations served and analyze water quality and treatment cost effects. The 2025 notice of intent generated more than 600,000 comments, and the final EIS should respond substantively to the concerns raised rather than restate the purpose and need.

Finally, road construction in currently roadless terrain is functionally irreversible on any relevant policy timescale. Decommissioning is expensive, rarely funded, and does not restore hydrologic or habitat function within decades. That asymmetry weighs against nationwide action on an incomplete record.

I request the agency select the no-action alternative, or develop and analyze a state-specific rulemaking process modeled on the existing Colorado and Idaho rules.

Daniel Kirchhoff, Highland, IL 62249

The agency justifies this rescission partly on wildfire grounds, and that rationale collapses under the weight of the agency's own data. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The draft environmental impact statement makes this even more precise: "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." These are the agency's own words and the agency's own numbers. How does the proposal square a fire-safety rationale with findings this stark? I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that figure against whatever reduction in hazard it claims to achieve, showing the math in full.

The regulatory flexibility analysis is similarly hard to defend. The proposed rule certifies no significant impact on small entities, yet the same supporting documents undercut that conclusion: "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 certification reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters, guides and tour operators who actually hold permits in the affected areas. The analysis itself concedes some firms may lose these receipts. A national average is not an assessment of actual harm. The agency should withdraw the certification and conduct a genuine analysis focused on the small businesses that operate inside the potentially affected roadless areas, not a diluted figure that hides real damage behind a large denominator.

The agency has also invited comments about reliance on the current rule without committing to weigh them. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The wild places protected by the 2001 rule are places the public has counted on for more than two decades. Plans are made around their protection. The question of what the agency owes to those who relied on a long-standing rule is not a procedural formality. Under established administrative law, an agency changing course must engage with the reliance interests its prior policy created. The agency must identify and genuinely weigh the reliance interests described in the comments it receives, including this one, and it must do so before any final action is taken.

The Forest Service held more than 600 public meetings and received more than 1.6 million comments before issuing the 2001 rule. It has held none to undo it. These are the last unroaded portions of the national forests, and a road, unlike a logged stand, does not grow back. The generation that comes after mine should not inherit fewer wild places because this agency moved quietly and without adequate justification. I ask that the agency address each of the failures identified here in its final record.

Sincerely,
Hannah
Campbell, CA

When I drive or fly to trailheads, I buy gas, groceries, lodging, and guide services in gateway towns on every trip. Considering the draft EIS and cost-benefit analysis undercount recreation-economy losses against timber value, you should weigh in that I spend about $500-$3-4,000 on a trip to these untouched areas as one solo traveler. Take in the financial impact.

Also take in the environmental impact: it appears that when the 2001 rule was finalized, roadless areas included 354 municipal watersheds providing drinking water to populations and serving as headwaters. I know I have stayed at campsites or rental cabins where drinking water warnings were issued because of spills or water quality issues. Again, multiply this by entire populations or entire segments of outdoor recreationalists. There will be endless complaints and lawsuits, not to mention wildlife affected and sickened. I will not be quiet if these changes take effect and in addition to this pushback, what measures have been planned for mitigation and remediation efforts?

Also, the stated justification for this change is fire danger. Secretary Rollins called the rule a barrier to wildfire risk reduction and described restrictions keeping forested acres off-limits to treatments, however, if I am understanding correctly, the rule already permits this work via vegetation management/cutting trees, to reduce wildfire risk to communities or restore ecosystem function, and it also allows road construction where needed to protect public health and safety from an imminent threat of flood/fire,or other catastrophic events. If the exceptions already exist and have been used, the agency needs to explain what problem full rescission solves. (Source: The Pew Charitable Trusts). Tying this back in to my home state of Wisconsin: I am an active Sierra Club member, and Elizabeth Ward, our chapter director, has pointed to drought and excessive heat in Wisconsin as evidence that climate change (i.e., not road access) is driving fire risk. (Source: Sierra Club, WXPR)
And, a peer-reviewed study in Fire Ecology (Source: Aplet, Hartger, and Dietz, January 2026) found that from 1992 to 2024 across the contiguous U.S., ignition density was lowest in designated wilderness (1.75 fires per 1,000 hectares) and nearly as low in inventoried roadless areas (1.97), while land within 50 meters of a road had the highest density at 7.99. Human-caused fires occurred more than seven times as often within 250 meters of a road as beyond 2,000 meters. (Source: nbcmontana). I know that keeping these areas pristine for advocates like me, and experienced outdoors people will keep us helping the Forest Service - free of charge! - through advocacy and safe camping and recreation practices. For every careless human there are many more mindful ones who support assisting in management.

Finally, the biggest slap in the face here is the process wherein this all came about. In the 2001 rule resulted from the largest public input process in Forest Service history: 600 public hearings and 1.6 million comments. Undoing it with no hearings outside Alaska is a disproportionate process, and inadequate public participation is a reviewable NEPA/APA issue. (Source: onX Maps)

The Bush administration's 2005 attempt used two comment periods each longer than 100 days, and a federal judge ordered the original rule reinstated in 2006. So basically, it is a precedent that this shortcutting has failed before. (Source: Wyoming Public Media)

At the very least, I ask that the comment period be extended and that more hearings be held in the most affected regions. And at the very most, it wasn't broke, so don't fix it.

The wildfire rationale also requires closer scrutiny. The Roadless Rule already contains exceptions allowing certain vegetation management and activities needed to address wildfire. USDA should identify specific projects that could not reasonably proceed under those exceptions and explain why narrowly tailored additional exceptions would be inadequate. The proposal also acknowledges that increased public access can increase human-caused wildfire ignitions. Rescission therefore carries a wildfire tradeoff that should not be treated as though additional road access is unambiguously beneficial.

The road economics are another serious concern. USDA acknowledges a $6.9 billion deferred-maintenance backlog for existing Forest Service roads and bridges. New roads create construction, maintenance, erosion-control, and eventual decommissioning costs. Before removing the Roadless Rule, USDA should demonstrate that the benefits of additional road access exceed these long-term public costs. It should not expand potential road obligations while the existing system is already severely underfunded.

I am particularly concerned with USDA’s assertion that individual forest plans are an adequate substitute for the national rule. The proposal acknowledges that approximately 18.2 million acres are in areas where current land-management plans allow permanent road construction but the Roadless Rule presently prohibits it. USDA also states that rescission would not require those plans to be amended or revised. This creates a significant transition and reliance problem: existing plans may have been developed while the Roadless Rule supplied the national protective baseline. USDA should not remove that baseline without first demonstrating, forest by forest, what protections would remain and whether current plans actually considered the consequences of losing the Roadless Rule.

USDA should also fully account for values that are difficult to monetize: clean water, intact watersheds, fish and wildlife habitat, habitat connectivity, hunting and fishing, quiet recreation, scenic character, and the option value of retaining large undeveloped landscapes for future generations. Roads and fragmentation can be difficult or impossible to reverse. That asymmetry matters: management rules can be amended later, but an intact roadless landscape cannot simply be recreated after development.

A more proportionate alternative is available. Retain the Roadless Rule and, if USDA can demonstrate that particular provisions prevent necessary wildfire, forest-health, or community-protection work, propose narrowly tailored amendments for those documented circumstances. That would provide needed management flexibility without eliminating protections from tens of millions of acres where no such need has been demonstrated.

For these reasons, I urge USDA to reject nationwide rescission and select the No Action Alternative. At minimum, the final decision should not proceed unless USDA demonstrates why targeted amendments cannot accomplish its stated objectives, fully accounts for long-term road costs and environmental impacts, and evaluates the loss of protections under each affected forest plan.

The wildfire rationale offered for this rescission is undermined by the agency's own findings. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal asks us to open roadless areas in the name of fuels management, but the agency's own data show that roading those areas dramatically increases ignition risk. I ask that the agency explain on the record why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own DEIS.

The economics do not hold up either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that negligible extraction gain, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. That range cannot establish a net benefit. The road system the agency would expand already carries a $6.9 billion maintenance backlog. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, adding costs the proposal does not fully account for. The agency must reconcile the rescission with its own cost-benefit record before proceeding.

The small-business certification is not credible on the face of the supporting analysis. 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 every small firm in the sector nationally rather than examining the guides and outfitters who actually hold permits in the affected areas. That methodology conceals the real impact. The agency should withdraw the certification and assess the small entities actually operating in these areas.

Finally, the agency invited reliance interests and then ignored them. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My use of places like Scodies for hiking, wildlife observation, and photography is exactly the kind of reliance interest the agency asked about and then failed to weigh. Under the legal standards governing agency reversals, this matters. The agency must identify and weigh the reliance interests described in the comments it receives, including this one.

No generation should inherit fewer of these places than the one before it.

Sincerely,
Corinna Cherian
Los Angeles, CA

Delegating these decisions entirely to individual forest-level land management plans, without any national floor, invites inconsistent protection across units with widely varying capacity, funding, and local political pressure — the opposite of the "sustainable, integrated management" the Department cites the 1976 NFMA planning process as providing. A national rule exists precisely because roadless values are a national public interest, not merely a local one.

I also object to the process itself: the original 2001 Rule was the product of roughly two years of review, over 600 public meetings, and 1.6 million public comments. This rescission is being decided on a 30-day comment period with no public hearings, for a change of comparable scale and consequence.

I urge USDA to withdraw this proposal and retain the 2001 Roadless Rule's national protections intact.

The wildfire rationale is contested. The proposal frames road access as wildfire reduction, but I ask the agency to reconcile that with research indicating most wildfire ignitions occur near roads — meaning new roads into currently roadless areas may increase human-caused ignition risk, not reduce it. I ask that the final EIS address this directly rather than assume roads reduce fire risk.

Watershed and forest health. Roadless areas protect drinking-water sources and intact habitat. Roads bring sedimentation, erosion, and fragmentation. I ask the EIS to fully account for these downstream costs, including to municipal water supplies — a concern of particular weight here in Washington, where forested watersheds feed communities across the region.

Procedural and durability concerns. The 2001 Rule was adopted after an exceptionally extensive public process. I am also concerned about the adequacy of this comment period: a draft EIS covering roughly 45 million acres has been given only 30 days for public comment, tied to the same deadline as the proposed rule, when comparable NEPA proposals of this magnitude commonly receive 45 to 90 days. I ask the agency to extend the comment period accordingly. Beyond process, a rescission of this scope invites the same legal challenges the rule has weathered for 25 years, creating years of management uncertainty for the very forests the agency says it wants to manage actively. I urge the agency to retain the national framework rather than trade a settled rule for prolonged litigation.

Reliance interests. Communities, outfitters, congregations, guides, and recreation economies have built expectations around these protections for two decades. I ask the agency to analyze those reliance interests as part of its cost-benefit review.

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

Respectfully,
John S.
Pastor, Seattle, Washington

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

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

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

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

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

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

Issue 3: Carbon is stated and dropped

The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons.

The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative.

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

I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats.

Not may: will increase the likelihood, and the agency anticipates the harm. The phrase "likely to adversely affect" appears more than 150 times across the USFWS assessment alone, and the proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Mary Katherine Ray
Winstom, NM

portions of the Tahoe Rim Trail, and Freel Peak. Luther Pass is occupied habitat for the Sierra Nevada red fox, federally endangered, and the American marten. The DEIS does not adequately analyze effects on listed species there, nor the conflict between new road construction and Lake Tahoe’s Total Maximum Daily Load program, under which two decades and hundreds of millions in public investment have targeted fine sediment reduction to restore lake clarity. Roads and disturbed surfaces are a principal fine sediment source.
The stated justification is wildfire risk reduction, and the record does not support it. Aplet et al. (Fire Ecology, 2026), covering 1992 to 2024 across all eight contiguous Forest Service regions, found ignition density of 7.99 fires per 1,000 hectares within 50 meters of a road, versus 1.97 in inventoried roadless areas and 1.75 in designated wilderness. The Forest Service attributes roughly nine of ten wildfires to human causes. Roads into roadless terrain increase ignition sources in the places the agency says it wants to protect.
Deficiencies I ask the agency to address:
1.The DEIS does not adequately analyze cumulative watershed effects in Sierra headwaters, including fine sediment impacts on Lake Tahoe clarity and effects on the Truckee, San Joaquin, Kings, Kern, and Owens River source waters serving millions of Californians.
2.It does not analyze how new road access increases human-caused ignition risk in high-hazard fuel types.
3.It does not evaluate a narrower alternative retaining roadless protections while permitting targeted fuels treatment where documented wildland-urban interface risk exists.
4.It does not analyze fragmentation and connectivity loss along the Sierra crest. Roadless areas in the Tahoe, Eldorado, Inyo, Sierra, and Sequoia National Forests form the corridor linking designated wilderness and Park units. The agency has not evaluated effects on species dependent on landscape-scale movement, including Sierra Nevada red fox, Sierra Nevada bighorn sheep, Pacific fisher, and wolverine, nor how fragmentation would degrade the wilderness character of adjacent designated areas it is obligated to preserve.
I have an eight-year-old daughter. She has backpacked in Desolation Wilderness, Yosemite, and out of Mammoth Lakes, reaching those places through roadless areas in the Eldorado, Stanislaus, and Inyo National Forests. She may be the first generation in twenty-five years to inherit the absence of these protections.
That asymmetry is the heart of my objection. The projected benefits are annual, modest, and reversible: a few million dollars in timber revenue and some administrative flexibility. The costs are permanent. A road cut into an unroaded drainage persists for generations through hydrologic change, sediment delivery, invasive species vectors, and fragmentation, long after the timber that justified it is gone. My daughter’s generation will inherit the roads. It will not inherit the revenue. The DEIS does not seriously analyze these irreversible and irretrievable commitments of resources, as NEPA requires at 42 U.S.C. 4332(C)(v), nor engage the policy Congress set at 42 U.S.C. 4331(b)(1), directing each generation to act as trustee of the environment for those that follow.

I ask the agency to strongly withdraw the proposed rescission.

I have lived in this community for 24 years. In that time we have faced two huge wildfires, one being the largest in Oregon at the time. During the Chetco Bar Fire, the smoke turned the sky an ominous color and I was having trouble breathing during the worst of it. That experience makes the agency's wildfire rationale for this rescission something I take seriously, which is exactly why I cannot accept it uncritically. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why this proposal departs from those findings and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The wildlife I encounter on these walks is not incidental. The birds, the bears, the bobcats depend on the character of this landscape. The DEIS cites the findings 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. The agency's own record on bears is equally direct: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. These findings appear in the agency's own draft environmental impact statement, and they bear directly on the black bears I have seen in the forests around South Kalmiopsis and Mt. Emily. The agency must address on the record how opening these 5,764 acres, 1,308 acres, 104,477 acres, and 91,560 acres to road construction is consistent with its own findings on wildlife impacts.

The economic justification for rescission fares no better under the agency's own numbers. The record before the agency states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit. I ask how an action whose own Cost Benefit Analysis cannot confirm a net gain justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

The agency's own accounting is perhaps the clearest indictment of this proposal. Cost Benefit Analysis Table 4 lists among the qualitative unquantified costs of the proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; agency road maintenance burden." The wildfire benefit the agency claims in favor of rescission sits in the benefits column explicitly because the agency says it cannot quantify it. The DEIS itself records human-caused ignition density at 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency is selling this rescission as wildfire protection while booking increased ignition risk as an unquantified cost and placing the promised fire reduction among benefits it admits it cannot measure. The agency must quantify the net wildfire effect of this action in either direction before wildfire can serve as any part of the justification for it.

Sincerely,
Kathleen Dickson
Brookings Oregon

I go to Farles Prairie in the early morning to photograph birds. I like seeing the marked longleaf pines where the red-cockaded woodpecker lives. Red-cockaded woodpeckers recovered here from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. The agency's own record states 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) I have also seen deer, hogs, bear, and otters in this forest. The DEIS cites Wyoming research finding roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the agency's own analysis says the danger is disrupted migration and lost unroaded security. The agency owes this record a specific response to what road construction in these areas would mean for species that have recovered precisely because the land stayed unroaded.

The roads I cross backpacking are mostly sugar sand. Building roads to access timber would require far more than a sugar sand road, and the trucks that followed would bring more noise, smell, and pollution. No one has gone out hiking and backpacking in the forest and said, gee, if only there were more roads it would be better. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission in part on wildfire and fuels management grounds. I ask that the agency reconcile the 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.

The economics of this proposal do not hold together. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency should explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

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. That certification was reached by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency should withdraw the certification and assess the small entities actually operating in the potentially affected roadless areas.

Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is such an interest. I visit and backpack through the Ocala National Forest and want to continue to have a wilderness experience. Public lands should be managed for the public to use, to enjoy, to find a calm place to relax, not to benefit companies exploiting the forest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one.

Sincerely,
Elizabeth Lambert

Dade City, Florida

The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons.

The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative.

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

I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency’s 428-page draft biological assessment closes: “Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.” The DEIS tallies the determinations: “may affect, likely to adversely affect” for 327 ESA-listed species and 71 designated critical habitats.

Not may: will increase the likelihood, and the agency anticipates the harm. The phrase “likely to adversely affect” appears more than 150 times across the USFWS assessment alone, and the proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule.

Issue 5: Every conservation alternative was eliminated by how the purpose was written

I want this land managed responsibly, and responsible management starts with an honest comparison of the options. The agency wrote its purpose so that comparison could not happen. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it “would continue to restrict local decision-making discretion” and because analysing roadless values is “an administrative and legal burden for the agency.”

A purpose written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Mariel Dryl
Denville, NJ 07834

The same record addresses bears. The DEIS quotes the federal grizzly bear recovery plan directly on what open roads do in grizzly habitat: "the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads." Bears are among the animals I seek out as a photographer. I ask the agency to explain, on this record, how it proposes to square that documented mortality risk with a rule that expands road access into areas where that risk applies.

The wildfire rationale the agency offers does not hold up against its own data. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal uses wildfire management as a reason to rescind the rule, but the agency's own DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must reconcile the rescission with that ignition data and explain why this proposal departs from its own prior findings.

The economic case is just as weak. The agency's record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, a net present value spanning -$92 million to +$199 million, and an existing road maintenance backlog of $6.9 billion. The agency cannot establish a net benefit by its own numbers. It must explain how an action whose own analysis cannot confirm a positive return justifies expanding a road system already carrying that backlog.

The permitting burden argument also fails on the record. The rule already contains exceptions, including those for public health and safety and for reserved or outstanding rights. The agency has not identified which specific burdens fall outside those existing exceptions, and it has not quantified them. I ask the agency to do that, specifically, before proceeding.

Finally, the regulatory flexibility certification is not credible. The proposal certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected, and the Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and it concedes some firms may lose those receipts. The agency should withdraw that certification and assess the impact on the businesses actually operating in these areas.

The animals I photograph depend on the quiet and the continuity of unroaded forest. The rule protects both. The record does not support rescinding it.

Sincerely,
Jim Markle
Carson City, NV

The bears I watch for in the Daniel Boone are part of a broader pattern that the agency's own analysis documents. The DEIS, citing the federal grizzly bear recovery plan, finds that the increased contact and conflict that come with open roads in bear habitat can ultimately end in bear mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. The ruffed grouse I look for fare no better under expanded roading: the DEIS names ruffed grouse among the game that needs complex forest structure with mast-producing trees, and notes that some upland bird species show strong site fidelity that limits how far they can adapt when habitat changes. The Daniel Boone also shelters the Virginia big-eared bat, with deep sandstone overhangs in the Red River Gorge supporting over 5,000 individuals, roughly 40 percent of the global population of a federally endangered species. The agency must address on the record how rescission is expected to affect the species it has already catalogued as present and sensitive in the forest.

The agency's own economics do not support this action. The record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I ask that the agency reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

The rule the agency proposes to rescind already contains the flexibility it claims to need. The agency's own description confirms it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. § 294.12(b)(1),(3)." The agency should identify which specific administrative burdens are not already addressed by those exceptions and quantify them.

The agency also certified no significant impact on small entities while its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year and names outfitters, guides and tour operators as affected. That certification was reached by spreading loss across every small firm in the sector nationally rather than assessing the permits actually held in the affected areas. I ask that the agency withdraw the certification and conduct an assessment of the small entities actually operating in these roadless areas.

Finally, "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is such an interest. My use of the Daniel Boone, my expectation that the Wolfpen area and its headwater streams remain protected, and my reliance on the Forest Service's stated purpose of watershed protection all constitute interests the agency invited and has not weighed. The agency should identify and weigh those reliance interests before any final action.

Sincerely,
Robert C. Burkhart
Eminence KY

This is not responsible management of public land. This will destroy the land making it unusable for anyone. Proper management is ensuring the land will be around for generations to come and enjoy. You claim this will decrease wildfire risks but science says it will actually increase the risk 4x.

Habitat fragmentation is some of the worst land management practices one can do and that is what adding roads to the national parks does. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent.
The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment.

Wildlife does not want roads, mines, and timber plants. The agency's own citation makes that point better than I can. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat.

The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons.

The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative.

The agency’s own assessments predict harm to 327 protected species

I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency’s 428-page draft biological assessment closes: “Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.” The DEIS tallies the determinations: “may affect, likely to adversely affect” for 327 ESA-listed species and 71 designated critical habitats.

Not may: will increase the likelihood, and the agency anticipates the harm. The phrase “likely to adversely affect” appears more than 150 times across the USFWS assessment alone, and the proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Anna, WV

On wildlife, the agency's own record makes the case I would make. The DEIS wildlife analysis finds that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations." Wolverine avoid roads used by winter machines. The same analysis cites findings that habitat fragmentation reduces biodiversity by 13 to 75 percent and that road-noise experiments in a roadless area cut bird abundance by over a quarter. I go to the Bridger-Teton looking for lynx and wolverine, two species whose persistence depends on exactly the undisturbed conditions that the current rule protects. The agency has not explained how expanding the road network into those areas is consistent with its own documented findings about what roads do to the animals it is legally obligated to consider. I ask the agency to explain, in this docket, how the proposal accounts for these documented effects on the species its own DEIS identifies as road-sensitive.

On fire, the agency's justification for rescission rests in part on fuels management, but its own prior findings say the opposite of what that justification requires. The DEIS 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." That sentence belongs to the agency, not to its critics. DEIS Table 21 reportedly shows far higher fire density on roaded land than inside the affected roadless areas. The agency must reconcile the proposal with those numbers and explain why it is departing from its own prior findings on fire occurrence and fuel treatment in roadless areas.

The economic rationale does not hold together either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. A range that wide, spanning positive and negative territory, cannot establish that this action produces a net benefit. It cannot do so while the road system already carries a $6.9 billion maintenance backlog. How does adding roads the agency cannot afford to maintain serve the public interest the proposal claims to advance? The agency should answer that question in this record.

On permitting burden, the rule as written already allows what the proposal claims to unlock. The agency's own text acknowledges that the rule "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)." Exceptions exist for public health and safety, for existing mineral leases, and for community wildfire protection. The proposal has not identified which specific operational needs fall outside those exceptions or quantified the burden that the existing rule actually imposes, as opposed to the burden imagined for it. The agency should do that work before proceeding.

Finally, the regulatory flexibility certification that this proposal has no significant impact on small entities is not credible on the face of the agency's own analysis. The DEIS names outfitters, guides, and tour operators as affected parties. The Cost Benefit Analysis books a minimum of $6.1 million a year in lost recreation benefit. Spreading that loss across the national average firm in order to reach a no-impact conclusion is not the analysis the law requires. The entities actually holding permits in the potentially affected roadless areas are the ones whose livelihoods are at stake, and the agency should assess them directly rather than averaging them into invisibility. The certification should be withdrawn and redone with the firms that will actually feel the consequence.

Sincerely,
Jonathan Ratner
Cora WY

portions of the Tahoe Rim Trail, and Freel Peak. Luther Pass is occupied habitat for the Sierra Nevada red fox, federally endangered, and the American marten. The DEIS does not adequately analyze effects on listed species there, nor the conflict between new road construction and Lake Tahoe’s Total Maximum Daily Load program, under which two decades and hundreds of millions in public investment have targeted fine sediment reduction to restore lake clarity. Roads and disturbed surfaces are a principal fine sediment source.
The stated justification is wildfire risk reduction, and the record does not support it. Aplet et al. (Fire Ecology, 2026), covering 1992 to 2024 across all eight contiguous Forest Service regions, found ignition density of 7.99 fires per 1,000 hectares within 50 meters of a road, versus 1.97 in inventoried roadless areas and 1.75 in designated wilderness. The Forest Service attributes roughly nine of ten wildfires to human causes. Roads into roadless terrain increase ignition sources in the places the agency says it wants to protect.
Deficiencies I ask the agency to address:
1.The DEIS does not adequately analyze cumulative watershed effects in Sierra headwaters, including fine sediment impacts on Lake Tahoe clarity and effects on the Truckee, San Joaquin, Kings, Kern, and Owens River source waters serving millions of Californians.
2.It does not analyze how new road access increases human-caused ignition risk in high-hazard fuel types.
3.It does not evaluate a narrower alternative retaining roadless protections while permitting targeted fuels treatment where documented wildland-urban interface risk exists.
4.It does not analyze fragmentation and connectivity loss along the Sierra crest. Roadless areas in the Tahoe, Eldorado, Inyo, Sierra, and Sequoia National Forests form the corridor linking designated wilderness and Park units. The agency has not evaluated effects on species dependent on landscape-scale movement, including Sierra Nevada red fox, Sierra Nevada bighorn sheep, Pacific fisher, and wolverine, nor how fragmentation would degrade the wilderness character of adjacent designated areas it is obligated to preserve.
I have an eight-year-old daughter. She has backpacked in Desolation Wilderness, Yosemite, and out of Mammoth Lakes, reaching those places through roadless areas in the Eldorado, Stanislaus, and Inyo National Forests. She may be the first generation in twenty-five years to inherit the absence of these protections.
That asymmetry is the heart of my objection. The projected benefits are annual, modest, and reversible: a few million dollars in timber revenue and some administrative flexibility. The costs are permanent. A road cut into an unroaded drainage persists for generations through hydrologic change, sediment delivery, invasive species vectors, and fragmentation, long after the timber that justified it is gone. My daughter’s generation will inherit the roads. It will not inherit the revenue. The DEIS does not seriously analyze these irreversible and irretrievable commitments of resources, as NEPA requires at 42 U.S.C. 4332(C)(v), nor engage the policy Congress set at 42 U.S.C. 4331(b)(1), directing each generation to act as trustee of the environment for those that follow.

I ask the agency to strongly withdraw the proposed rescission.

The agency justifies rescission in part on wildfire and fuels management grounds, but its own record says the opposite of what that justification requires. The DEIS 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." That finding is in the agency's own draft environmental impact statement, and the proposal does not explain why it departs from it. I ask that the agency reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain in plain language why its own ignition data does not control here.

The agency also claims the rule creates permitting and administrative burdens. But the rule as written already accommodates the things the agency says it cannot do. The agency's own analysis acknowledges: "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. § 294.12(b)(1),(3)." If exceptions for public health, safety, existing mineral leases, and community wildfire protection are already built into the rule, the agency must say, specifically and by category, which burdens remain unaddressed by those exceptions and quantify them. A general claim of burden is not enough.

My family's connection to these places rests in part on clean water. The watersheds feeding the national forests around Telluride and across the Rocky Mountain region supply 325 municipal water intakes according to DEIS Table 35. The agency's own analysis links road construction to sediment loading in timber sales. Everyone has a right to clean water. That should never be negotiated or compromised under any circumstances. I ask that the agency explain how rescission is consistent with protecting the drinking water that communities in this region depend on, and that it put that explanation into the record where it can be examined.

We have a moral and legal responsibility to pass a better life onto our children so they can access the sacred spaces we have been able to call home. The 2001 rule was built on more than 600 public meetings and 1.6 million comments. No comparable process has been held to undo it. Colorado holds 326 inventoried roadless areas totaling 4,407,277 acres. Whether Colorado's areas sit under the 2012 Colorado Roadless Rule or the national rule, the question of what changes in their management deserves an honest answer in this record. I ask the agency to state clearly what, if anything, changes for Colorado roadless areas under this proposal and why the public is owed no equivalent deliberative process to the one that produced the rule being rescinded.

The regulatory flexibility certification reaches a no-significant-impact conclusion by distributing costs across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators who actually hold permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year and acknowledges some firms may lose those receipts. The agency must withdraw that certification and assess the impact on the small entities actually operating in these areas, not the national average firm.

Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My family's connection to Wilson Mesa, Lizard Head, and Sunshine Mesa, and the expectations we have built around their continued protection, are exactly the kind of reliance interest the agency invited and is legally required to weigh before changing course. This comment is such an interest, and the agency must identify and weigh it.

Sincerely,
Erin Kelly
Telluride, CO

The McDonald Peak IRA in the Rogue River NF is practically in my backyard. I can literally walk there from my house. I have spent hundreds of hours there performing wildlife surveys, mountain bike riding, hunting and hiking. Little Grayback, also on the Rogue River NF, is one of my favorite places to deer hunt, one of the last intact, functioning examples of a once vast bio region, notable for its unique geology and plant communities. The Kinney IRA is the last 7,505-acre chunk of land in a sea of roads that is still a semi-functional ecosystem. The public lands surrounding Kinney contain some of the highest road density in the region. Leave the Kinney roadless area alone. The Kangaroo IRA, 14,390 on the Rogue River NF, is where I documented several colonies of rare Townsend's big-eared bats in a little-known cave system near Swan Mountain. That rugged forest is a biological treasure trove and would be lost forever if entered.

I chose to live in this region because of the roadless areas. They serve as a biological and genetic reserve for Coho and Chinook salmon, Martens, Fishers, Bears, Wolves, and many other species. The Rogue, Klamath and Illinois rivers tributaries depend on intact roadless watersheds for the water quality and temperature that keep fish populations viable. Removing vegetation raises stream temperatures, and warmer temps reduce egg survival, of Coho & Chinook salmon, Steelhead & resident Trout. The agency's own record says so.

What will the agency project for salmon populations in Essential Fish Habitat downstream of roadless areas it opens to road building and timber operations, and how will it answer for those projections?

For Elk specifically, the agency's acknowledges that roads & extraction may alter migration routes and increase movement speed, and that the protection of unroaded security areas is central to Elk welfare. I have hunted deer and Elk for 36 years in the roadless areas around the Rogue Siskiyou NF and in places like Little Grayback precisely because that security cover exists. The agency's own DEIS states: "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." No population-level effect on big game is projected anywhere in that document. I ask that the agency project the actual effects on deer & elk populations and on hunter opportunity, & place that projection in the record before finalizing any rescission.

On fire, the agency claims rescission serves fuels and wildfire management. Its own record says otherwise: "Building a road into a forest could increase the incidence of human-caused fires. A human-caused wildland fire is nearly 5 times more likely to occur on essentially roaded lands than on unroaded lands." The agency must explain how the proposal departs from that finding, and reconcile the rescission with its own ignition data showing far higher fire density on roaded land.

On economics, my tax dollars should go toward research and wildlife habitat management and preservation, not toward subsidizing private industry. The agency's own record states: "the total timber volume affected by this rule is less than 0.5% of total US production, and the total oil and gas production from all USFS lands is currently about 0.4% of the current national production." The agency must reconcile that with a road maintenance backlog already at $6.9 billion and explain how an action whose own cost-benefit analysis cannot establish a net benefit justifies expanding that failing road system further.

Finally, the roadless rule already contains exceptions. The record states it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights. The agency has not identified which specific administrative burdens fall outside those existing exceptions. It must do so, with specifics and numbers, before it proceeds.

These roadless areas are the reason I live here, the reason rare species persist, and the reason rivers still run clean.

Sincerely,
Todd A Kemp
Ashland, Oregon

“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 (https://doi.org/10.1073/pnas.2113416118)”

Uncited Methodology for Historical Timber Harvest Baseline in IRAs

The Draft EIS's timber harvest baseline for inventoried roadless areas rests on an uncited data pull. The document states that "the best available information on activities that have been implemented within IRAs over the last decade comes from the Forest Service Activity Tracking System" and reports "an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction," but nowhere identifies the specific FACTS query, parameters, or extraction date used to generate these numbers. The phrase "best available information" itself concedes limitations without disclosing their scope, and a single ten-year average obscures whether harvest activity is increasing, decreasing, or concentrated in particular years or forests — information directly relevant to evaluating the current Rule's effect on management flexibility. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), and APA 5 U.S.C. § 706(2)(A), unsupported general statements do not satisfy the hard-look standard. I request the agency cite the specific FACTS query and extraction date and disaggregate the average by year.

Absence of Quantified Nationwide Cumulative Timber Harvest, Road Construction, Sedimentation, and Fragmentation Analysis

The Draft EIS justifies rescinding roadless protections across up to 58 million acres nationwide based on generalized narrative about "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface," and elsewhere asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests." Nowhere does the DEIS convert this narrative into a quantified nationwide or regionally stratified projection of harvest volume, road-mile construction, sedimentation, or fragmentation, even though it performs comparable granular quantitative analysis for the Tongass National Forest alone. NEPA requires "a detailed statement… on… reasonably foreseeable environmental effects of the proposed agency action," 42 U.S.C. § 4332(2)(C), and while Seven County Infrastructure Coalition v. Eagle County, No. 23-975, 605 U.S. ___ (2025), narrows review of effects outside agency authority, it does not excuse omitting cumulative effects of actions the agency itself controls. Tiering under 42 U.S.C. § 4336e(11) requires specific commitments, not open-ended deferral. I request a quantified nationwide analysis or an explicit, enforceable tiered commitment to project-level review.

Twenty-five years of it working ought to count for something. Do not move forward with rescission.

Respectfully submitted,

CommentID: RLC-20260906-3PPQS4

are primary drivers of aquatic degradation, increasing erosion rates exponentially and introducing destructive sediment loads into native fisheries.
Wildfire Ignition Risks: Empirical data contradicts the claim that road building and commercial logging enhance forest health; in reality, over 90% of human-started wildfires occur within a half-mile of a forest road. Roads additionally act as corridors for invasive plant species, which dry out quickly and provide volatile, highly flammable fine fuels.
Opening intact backcountry to industrial activity compromises ecological integrity, fragments critical migration corridors for species like elk, grizzly bears, and native trout, and degrades municipal watersheds relied upon by millions of downstream residents.
I urge the agency to uphold the Roadless Rule in its entirety to safeguard our remaining wild places, protect public resources, and honor the empirical science that proves intact forests are safer and ecologically richer when left undisturbed.
Respectfully submitted,
Angela Schuster
Minneapolis, Minnesota 55407

By the Assessment's Own Definition, Grizzly Core Habitat Is Lost the Moment a Road Is Built

The USFWS Biological Assessment states at page 125: "By definition core habitat for grizzly bears is lost when a road is constructed, unless it is mitigated by the creation of new secure habitat elsewhere through road decommissioning or other actions." This is not a prediction subject to project-level uncertainty; it is a definitional identity: road construction in grizzly core habitat equals core habitat loss, full stop, absent compensatory decommissioning. The rescission makes road construction newly possible across previously protected portions of grizzly recovery zones (see the SSA reliance finding at p. 122), yet the DEIS neither quantifies the core habitat placed at risk nor identifies any mechanism ensuring the compensatory mitigation the definition requires. Where the agency's own document establishes a per-se loss mechanism, NEPA requires the acreage exposed to that mechanism be disclosed and analyzed by alternative. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). I request the FEIS map and quantify grizzly core habitat within potentially affected IRAs by recovery zone, and state whether and how compensatory secure-habitat creation would be assured.

and allotments where grazing conflicts with roadless-area values.
The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies.
The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use.

We need natural, undeveloped land for our survival. That is not a philosophical position; it is a practical one. The agency's own record undermines the case for rescission at every turn.

The proposal justifies rescission in part on wildfire and fuels management grounds. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The proposal justifies rescission in part on timber economics and employment. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency needs to explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

The agency has tried replacing this rule with local decision-making before, and that attempt failed in court. The record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency must explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time it substituted a state-by-state approach for one national rule, and address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values.

The proposal argues the 2001 rule exceeded the agency's authority. That question has already been litigated. The Tenth Circuit 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." The agency must 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 explain the basis for any contrary position it now takes.

We need clean water for the survival of every living species on this planet. Across the Southern region, which includes Tennessee, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of the watersheds fed by these roadless areas have impaired streams today. Rescinding this rule puts that record at risk. The agency must address what happens to those intakes and to water quality in these specific watersheds if the protections fall.

Sincerely,
Suzanne Peters
[Knoxville, TN]

The proposal argues that the 2001 rule exceeded the agency's statutory authority, but the courts that actually reviewed that question reached the opposite conclusion. The Tenth Circuit held, in language I ask be entered against this record: "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." The agency must address that holding, explain why it believes the 2001 rule exceeded the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and set out on the record the full legal basis for any position that contradicts the Tenth Circuit's conclusion that the rule did not create de facto wilderness.

My connection to the Salmon River is inseparable from the health of its water. It is inevitable that building new roads creates runoff and additional sediment into streams and rivers, and that sediment buries salmon spawning beds. The scientific record already confirms the mechanism: 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, with the affected area including Essential Fish Habitat and critical habitats managed by NMFS (DEIS; Carter 2005). Oregon alone holds 1,522 municipal water intakes in watersheds containing affected roadless areas (DEIS Table 35), and the state contains 211 inventoried roadless areas totaling 1,937,741 acres. Rescinding the rule in that landscape is not an abstraction. What analysis has the agency conducted of sediment and thermal loading to salmon spawning habitat specifically within the roadless areas of Mt. Hood National Forest, and what does that analysis show?

The agency's own document acknowledges that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet no projection of that range across the 40.1 million acres of potentially affected environment appears anywhere in the record. A finding of that magnitude, applied to the old-growth forest community I have spent three decades returning to, cannot be cited and then set aside. The agency must apply that cited fragmentation range to the full extent of the potentially affected acreage before any decision is made.

The DEIS also cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat, yet nowhere does the document project what rescission means for big game populations or for the hunting opportunity that depends on them. The agency should project those effects across each alternative it considers.

Finally, the agency acknowledges that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons, and concludes these lands will continue to sequester and store carbon without analyzing what harvest and roading would actually do to that figure. The Salmon River area and the broader Mt. Hood roadless landscape are part of that carbon reservoir. The agency must quantify the change in carbon storage and sequestration under each alternative before this rulemaking proceeds.

The management of our public lands should always take into consideration how actions will affect the important wildlife habitat. I urge the agency to withdraw the proposed rescission.

Sincerely,
Carole Miles
Gresham, Oregon

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

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

Issue 1: Wildfire and fuels management

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

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

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

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

Issue 2: Timber economics and jobs

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

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

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

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

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

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Will Rogers
Elmhurst, IL 60126

hundreds of miles of blocked roads.³ Recovery is ongoing. WNC is not entering this rulemaking from an undisturbed environmental baseline. More roads & associated timber activity can create erosion, runoff, stream crossings, culvert/drainage impacts, & long-term obligations. USFS research specifically recognizes forest roads as potentially major sources of erosion & stream sediment.⁴ Risks are particularly consequential in this area following Helene’s landslides, debris flows, erosion, stream alteration, & slope disturbance. These forests are drinking-water infrastructure. USFS’ current plan states that many WNC communities obtain more than 50% of their municipal water from the Nantahala & Pisgah National Forests.**² USDA should specifically evaluate overlap between IRAs & source-water watersheds & analyze the cumulative effects of new roads, timber ops, & associated soil disturbance with Helene watershed damage. APA also requires reasoned decisionmaking when an agency rescinds existing regulation. Motor Vehicle Manufacturers Ass’n v. State Farm, 463 U.S. 29 (‘83),Supreme Court held regulatory rescission subject to arbitrary-&-capricious review & requires the agency to consider important aspects of the problem & provide reasoned explanation.⁵ FCC v. Fox Television Stations, 556 U.S. 502 (‘09), Court further explains when a policy change contradicts prior factual findings or implicates serious reliance interests, those matters must be addressed.⁵ That principle has been applied specifically to the RR. Organized Village of Kake v. USDA, 795 F.3d 956 (9th Cir. ‘15)(en banc), USDA’s Tongass exemption was invalidated due to the agency failed adequately to explain its reversal of previous facts.⁶ Although persuasive rather than controlling precedent in North Carolina, Kake applies State Farm & Fox to this same agency & same RR. Existing RR also contains exceptions for public health/safety, catastrophe, restoration, existing rights, & other specified circumstances.² If USDA believes provisions impede necessary forest-health or emergency work, it should consider targeted amendments, not wholesale rescission of nationwide protections. I also ask USDA to consider my interest personally. I continue weekly use. If these forests lose their roadlessness, my injury would be direct & cannot be remedied by the existence of other public land. A roadless forest is itself a public resource. Solitude is a use. Backcountry recreation is a use. Clean water is a use. Wildlife habitat is a use. Multiple use does not require every use on every acre. For these reasons, as a WNC resident with documented, longstanding use, I strongly urge USDA to retain 2001 Roadless Area Conservation Rule. ¹ USDA Forest Service, Assessment for the Nantahala and Pisgah National Forests (2014) (152,488 IRA acres). ² USDA Forest Service, Final Land Management Plan, Nantahala and Pisgah National Forests, R8-MB-160 (2023). ³ USDA Forest Service, Wildfire in Wake of Hurricane Helene (2025). ⁴ USDA Forest Service, Southern Research Station, Grace, Modeling Erosion from Forest Roads with WEPP (2007); Kochenderfer, Erosion Control on Logging Roads in the Appalachians, RP NE-158 (1970). ⁵ Motor Vehicle Mfrs. Ass’n v. State Farm, 463 U.S. 29, 41–57 (1983); FCC v. Fox Television Stations, 556 U.S. 502, 514–16 (2009). ⁶ Organized Village of Kake v. USDA, 795 F.3d 956, 966–70 (9th Cir. 2015) (en banc). ⁷https://www.instagram.com/j_mess91

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.

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

Road effects on fisheries are among the best-documented findings in aquatic science: fine sediment in spawning gravels suppressing egg-to-fry survival, undersized culverts fragmenting habitat, altered peak flows destabilizing channels, riparian loss raising water temperature. These effects persist for decades and are worst where roads go unmaintained. The preamble acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges (91 FR 53830). An agency that cannot maintain its existing system should not add permanent mileage in steep, remote, high-value watersheds. The final EIS should analyze aquatic effects assuming that shortfall continues, not design standards the agency's budget history shows it cannot fund.

3. The wildfire rationale is not narrowly tailored.

By the Department's own figures, 9.8 million acres — 24 percent of affected roadless area — overlap the wildland-urban interface. Roughly three-quarters does not. Rescinding protection across all 58.5 million acres to reach fuels work in that subset is poorly fitted to the stated purpose. Moreover, 36 CFR 294.13(b) already permits cutting to reduce hazardous fuels, and the 2001 Rule has never restricted suppression. If those exceptions are administratively unworkable (91 FR 53828), the remedy is to streamline them, not eliminate the protection. The EIS should analyze that alternative, and should quantify the net wildfire effect, since the preamble concedes greater access can raise human-caused ignition potential (91 FR 53830) and ignitions track road access.

4. The economic analysis is asymmetric.

The rule weighs $5.2-11.4 million in annual timber revenue to the Treasury and Forest Service, plus $4.6-10.6 million to industry, against roughly $6.1 million in lost recreationist benefit. The timber figure is itself described as unlikely to be realized; the recreation figure appears to capture only lost use value in currently operable areas. Recreational fishing supports guides, outfitters, lodges, fly shops, and rural service economies that depend on habitat quality, not access alone — and habitat degradation is a decades-long reduction in the asset generating that revenue, not a construction inconvenience. The analysis should value habitat quality, include recreational fishing explicitly, and apply a consistent time horizon to benefits and losses. The finding of no significant effect on commercial fishing also cannot rest on limited current operability when the preamble concedes later plan amendments could expand where roads and harvest are allowed.

5. Reliance interests.

For twenty-five years anglers, guides, outfitters, and donors have relied on roadless protection when siting businesses and directing restoration dollars and easements; downstream restoration loses value if the headwaters above it are opened to roads. The final rule must consider these reliance interests and explain its reversal of longstanding policy.

Requested action:

1. Retain 36 CFR part 294 Subpart B in full.
2. If the Department proceeds, adopt a narrowly tailored alternative permitting WUI and infrastructure-adjacent fuels treatment and streamlining the 294.13(b) exceptions, while continuing to prohibit new permanent roads and commercial harvest elsewhere, and excluding salmonid stronghold watersheds, watersheds with ESA-listed fish or critical habitat, and municipal source-water watersheds.

Thomas Orndorff, Brevard NC

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

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

Issue 1: The small-business certification contradicts the analysis beside it

I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm.

Issue 2: Reliance interests are invited and never assessed

I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none.

Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one.

Issue 3: The agency’s own fire data cuts against the proposal

I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. 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.

The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Anika Anderson
Wenatchee, WA

Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The proposal would expose all of them to road construction, including the areas I have named. The agency defends rescission in part on wildfire and fuels management grounds, but its own draft environmental impact statement 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." That finding sits in the same record as the proposal to eliminate the protections that kept roads out. I ask that the agency explain why the proposal departs from this finding, and reconcile the rescission with the ignition data in its own DEIS Table 21.

The same ignition data makes the contradiction precise: "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." The forests I hike in are part of the Pacific Northwest region where I depend on these landscapes remaining unroaded and intact. The agency has not quantified the expected increase in human-caused ignitions from new road access or weighed that increase against the claimed reduction in wildfire hazard. It must do so.

Access to clean water is a basic human right and one the government should be striving to protect. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Roads lead to increased pollution and threaten public health and wellness. As drought conditions become more common in the American West, we cannot thoughtlessly contaminate more of our precious drinking water by building roads through important watersheds. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must address, specifically and on the record, what the rescission means for the 1,522 intakes in the Pacific Northwest region and the communities downstream of the roadless areas in Washington.

The proposal's regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and the analysis concedes some firms may lose these receipts entirely. That certification cannot stand alongside the analysis that produced it. I ask that the agency withdraw the certification and assess impacts on the small entities actually operating in the potentially affected roadless areas, not the national average firm.

Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is precisely such an interest. My use of the Mt. Baker-Snoqualmie roadless areas, and my expectation that public lands will be managed for the preservation of native plants and animals and for the conservation of valuable ecosystem services, developed in reliance on the protections the 2001 rule established. An agency changing course must assess the reliance interests its prior policy created. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken.

Sincerely,
Autumn Maust
Clinton, Washington

The economic case for rescission is just as weak. The record the agency itself compiled states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those numbers, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service while projecting recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. The high mountain meadows and lakes and rivers my family has photographed for decades contribute to that recreation economy. How does an action whose own Cost Benefit Analysis cannot establish a net benefit justify expanding a road system that the agency already cannot afford to maintain?

The proposal also claims the rule creates permitting and administrative burdens. But the rule as written already accommodates the situations the agency points to. 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. § 294.12(b)(1),(3)." Exceptions for existing mineral leases and community wildfire protection are also part of the existing framework. The agency has not identified which specific burdens fall outside those provisions. I ask it to do exactly that, naming the burdens that the current exceptions genuinely fail to address, and to put a number on them in the record.

Finally, the regulatory flexibility analysis accompanying this proposal certifies no significant impact on small entities. That conclusion cannot be squared with what the rest of the record says. "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 analysis reaches its no-impact conclusion by spreading an annual expenditure loss of $9 million across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. The backcountry my family has documented for decades supports exactly those kinds of small operators. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating inside the potentially affected roadless areas, not a national average that obscures the real harm.

The Colorado backcountry is not an abstraction for my family. It is where we have spent fifty years. The agency's own data does not support this rescission, and the public record should reflect that clearly.

Sincerely,
Leigh Jardine
Viola, Wisconsin

Issue 1: The small-business certification contradicts the analysis beside it.

I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm.

Issue 2: Reliance interests are invited and never assessed.

I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none.

Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one.

Issue 3: The agency’s own fire data cuts against the proposal.

I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. 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.

The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard.

Issue 4: Fragmentation is quantified and not applied

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

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

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Janet Jose
Highlands Ranch, Colorado

The draft EIS states that "losses in economic benefit to recreationists are most likely to be associated with the operable areas of current IRAs and could be an estimated $6.1 million annually," while conceding that road expansion "would result in tradeoffs with opportunities for quiet, remote and self-reliant recreation and may increase user conflicts." Roads do not confine their effects to acres where timber is cut. Noise, sediment, traffic, and displacement of non-motorized users extend well past any operable boundary. A figure derived from that narrower footprint cannot honestly be set against the $4.6 to $10.6 million in annual timber industry revenue the Department estimates. The final EIS should rescope the recreation estimate to the full affected environment or state plainly that the two figures are not comparable.

2. The $6.1 million national figure fails an order-of-magnitude check.

Multnomah Falls, whose headwaters lie inside this roadless area, draws over two million visitors a year and is the most-visited natural recreation site in the Pacific Northwest. A published contingent valuation study estimated its annual benefit at no less than $11.23 million. Total benefit and marginal loss are different measures and I am not equating them. But when one waterfall's estimated annual value nearly doubles the Department's estimated recreation loss across all 45 million affected acres, the national figure is not credible as a bound. The final EIS should reconcile it against site-level valuation literature or explain why that literature does not apply.

3. The Endangered Species Act backstop does not reach the species most at risk here.

The proposal states that local decisionmaking "would remain subject to the substantive requirements of the Endangered Species Act." The Larch Mountain salamander (Plethodon larselli), whose range is largely confined to the Columbia River Gorge, is a federal species of concern and a Forest Service sensitive species. It is not listed under the ESA. The Cascade torrent salamander occupies the same headwater system. Both depend on cold, thin-film seeps and wet streamside litter, the microhabitats that road construction and sedimentation degrade first.

The Department has already designated this salamander as sensitive. It then rests this proposal on a statute that by its own terms does not reach it. Sensitive-species status carries no independent protection once national prohibitions are removed and management reverts to individual forest plans. The final EIS should analyze effects on federal species of concern and Forest Service sensitive species in headwater systems.

4. Organized youth and educational use is not an analyzed category.

The draft describes these lands as used by "outfitters, guides, tour operators, visitors, and the general public." That omits organized youth, educational, and volunteer stewardship groups, and ignores what these places produce beyond visitor spending. Six girls walked out of this drainage committed to protecting it and then taught a younger troop why. That outcome appears nowhere in a $6.1 million figure, and it is the outcome most directly relevant to a resource the Department is obligated to pass to future generations. It also depends on a specific condition: road-free country still close enough to reach and return from in a single day. The final EIS should analyze organized youth, educational, and volunteer stewardship use as a distinct category of recreation.

I ask the Department to retain the 2001 Roadless Rule. If it proceeds, the final EIS should at minimum correct the recreation scope mismatch, reconcile that estimate against site-level valuation, analyze non-listed sensitive headwater species, and account for organized youth and educational use.

Thank you for your consideration.

Angie Lake
White Salmon, Washington

The proposal argues that rescission supports wildfire and fuels management. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding is in the agency's own draft environmental impact statement. The proposal moves in the opposite direction from what that data supports. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas.

On economics, the agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." These are not numbers that justify a major policy reversal. The agency is already carrying a $6.9 billion maintenance backlog on the roads it has, against a road budget of roughly $73 million a year. Building new roads into areas that currently have none deepens that problem. Fix what we already have instead of adding infrastructure we cannot afford to maintain. The agency must reconcile this proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value ranging from negative to uncertain positive, and explain how an action whose own analysis cannot establish a net benefit justifies expanding that already-deferred road system.

The watersheds feeding into forests like the Huron-Manistee supply drinking water to communities across the region. The agency's own data shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of the watersheds in these roadless areas have impaired streams today. That condition exists because roads have not been pushed into them. Rescission changes that calculus directly. The agency has not adequately addressed what sediment loading from new road construction would mean for water quality in these watersheds, and it needs to.

Finally, 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. That certification was reached by spreading losses across every small firm in the sector nationally rather than examining the specific outfitters and guides holding permits in the affected areas. The agency must withdraw that certification and conduct the analysis on the businesses actually operating in these places.

The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That process produced something worth protecting. My son should be able to bring his children to these same quiet forests, photograph the same birds, and drink clean water from the same watersheds. The agency has not made the case that rescission serves the public interest, and the record it has assembled undermines that case at nearly every turn.

Sincerely,
Josie Lucas
Bay City, MI

The wildfire rationale offered for this rescission does not survive contact with the agency's own findings. The proposal treats new road access as a tool for fire management, but the record contains this admission: "It is doubtful, however, that a fire manager would know where to place a road before a large fire occurs, or how to pre-design a road for an effective access route to a future, potentially large fire." Vermont holds 6 inventoried roadless areas totaling 25,096 acres, including the 9,169 acres of Devil's Den where I hiked as a child and the 8,759 acres of Wilder Mountain where I now go to photograph. I want the agency to explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and to reconcile the rescission with the ignition data in its own draft environmental impact statement at Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The economics offered in support of rescission are similarly troubled. The agency's record states plainly: "The agency receives less than 20% of the funds needed annually to maintain the existing road infrastructure. As funding needs remain unmet, the cost of fixing deteriorating roads increases exponentially every year." The proposal's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. Bread Loaf's four-season economy for local outfitters and small businesses sits inside that recreation figure. The agency carries a $6.9 billion maintenance backlog on its existing road system and cannot demonstrate a net benefit from adding to it.

The rule as written already permits the activities the proposal claims the rescission is needed to enable. The record states: "The rule recognizes the need for tree cutting to reduce the risk of wildfire to at-risk communities. It allows tree cutting in non-upper tier within 0.5 miles from the boundary of an at-risk community, or up to 1.5 miles if certain conditions exist and the area is within a Community Wildfire Protection Plan (CWPP). A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." The existing rule also contains exceptions for public health and safety and for existing mineral leases. The agency must identify, specifically and on the record, which administrative burdens are not already addressed by these exceptions, and must quantify them rather than assert them.

Finally, the regulatory flexibility certification accompanying this proposal is irreconcilable with the analysis sitting beside it. The proposal 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. Across the Eastern region, which includes Vermont, 286 municipal water intakes sit in watersheds containing affected roadless areas, meaning the communities whose small businesses depend on clean water and clean landscapes are not abstractions. The agency reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas, and it concedes some firms may lose these receipts. The certification should be withdrawn and replaced with an analysis of the small entities actually operating in and around these roadless areas.

Sincerely,
Lisa Theiss
Los Angeles, CA 90036

Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values.
The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies.
The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use. Thank you

Newman and Cragg found that roughly 65 percent of approved small-molecule anticancer agents were natural products, derivatives of natural products, or natural product mimics. Paclitaxel came from Pacific yew, an understory tree which Forest Service timber programs treated as slash of no value. Bristol-Myers Squibb reported Taxol sales of $1.5 billion in 1999 alone.

One year of sales from a single product at that scale is worth approximately 68 years of maximum timber output from all inventoried roadless areas combined. If one discovery of that scale arises from these lands every 5 to 10 years, the annualized value is $150 to $300 million per year, which is 7 to 30 times the Department's own upper bound for timber. Most discoveries are smaller than paclitaxel and not all originate on roadless land, so I ask the Department to run this calculation with whatever assumptions it considers defensible rather than omitting the category.

ROADS SELECT AGAINST THE SPECIES WE HAVE NOT DESCRIBED

Mora and colleagues estimate that about 86 percent of the roughly 8.7 million species on Earth have never been described. Narrow-range endemics are disproportionately undescribed, and they are concentrated in the remote unroaded terrain this rule protects. Fragmenting that terrain does not remove a random sample of the biological inventory, because it removes the smallest-range species first, and those are the species most likely to be both scientifically novel and commercially significant.

Calanolide A, active against HIV-1, was isolated from a tree collected in Sarawak in 1987. Researchers returned for more material and found the tree gone, and later collections of the same species elsewhere did not reproduce the compound. The chemistry belonged to that population, which was destroyed before anyone knew what it contained.

THE WILDFIRE RATIONALE CONFLICTS WITH THE AGENCY'S OWN DATA

An analysis of every recorded national forest ignition from 1992 through 2024 found 7.99 fires per 1,000 hectares within 50 meters of a road, compared with 1.97 in inventoried roadless areas. The pattern held in all eight contiguous-US regions, and among the largest two percent of fires mean size was similar regardless of ignition location. Building roads into roadless areas would increase the number of fires requiring suppression without meaningfully reducing large-fire risk.

RECOMMENDATIONS

1. Disclose whether foregone genetic, pharmaceutical, and agricultural discovery value was assigned a value in the cost-benefit analysis, and state the basis if it was zero.
2. Run the discovery-value comparison above using assumptions the Department considers defensible, and publish them.
3. Withdraw the Regulatory Flexibility Act certification, or amend the analysis to identify affected small entities.
4. Analyze a full alternative which retains Subpart B with targeted amendments authorizing fuels treatment adjacent to at-risk communities.

The Department retains the Idaho and Colorado rules and preserves the petition process, so it already accepts that place-based calibration works within the existing framework.

For this brief moment, we have an opportunity to profit and prosper by seeing wilderness as an asset and not an obstacle. I urge the Department to withdraw the proposed rescission. An attached file contains my full letter and references for the claims stated here.

and allotments where grazing conflicts with roadless-area values.
The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies.
The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use.

Rescinding the roadless rule will also result in increased mining and logging. These destructive activities will impact plants and wildlife and change the ecology of these areas. The US Forest Service has lost money in managing the logging of national forests and there is already a backlog of roads needing maintenance and creating more roads will only add to that backlog. Unmaintained roads cause erosion, resulting in siltation of streams and reduction of fisheries, many species of which are already imperiled by habitat destruction. Destroying their habitat by increasing silt will further reduce their numbers.

In summary, the roadless rule should not be rescinded because it will destroy habitat, adversely affect rare species, increase garbage in our wildlands, and further strain the federal budget because the federal agencies are not able to keep up with necessary road maintenance without the addition of additional roads.

What’s missing is the ecosystem services these lands produce continuously and at no cost to the taxpayer. The White Mountains are the headwaters of the Saco, Androscoggin, Pemigewasset, and Connecticut rivers. Undisturbed roadless watersheds filter drinking water, hold sediment, store carbon, buffer flooding, and keep habitat connected. Those services have dollar values and the Forest Service has published methods for estimating them. Leaving them out makes rescission look cheaper than it is.
The omission matters more, not less, under the proposal’s localization rationale. Ecosystem services don’t stop at a forest boundary. Water leaving a White Mountain drainage is used by communities across two states who will never attend a forest plan meeting. Forest-by-forest planning will systematically undervalue benefits whose recipients aren’t local.

I’d also point to the agency’s own $6.9 billion deferred maintenance backlog for roads and bridges. Roads are among the largest human sources of sediment in forested watersheds. Adding mileage the agency already can’t maintain turns a functioning natural asset into a long-term liability.

I ask that USDA quantify non-market ecosystem service values in the final EIS, and retain Subpart B.

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

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

With respect,

CommentID: RLC-20260820-3TETDT

The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience.

Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed 13 of Southeast's 16 hydroelectric projects are located in Roadless areas.

The Forest Service primary focus should be on supporting fishing, tourism and traditional cultural and subsistence activities. Some small scale logging to support communities and local construction should also be supported using existing roads.
Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure.

If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1.

Jon R Martin

should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values.
The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies.
The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use.

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

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.

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

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

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

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

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.

My strongest professional concern is sediment. The DEIS states that skid roads, trails, log landings, and similar disturbances are the primary sources of timber-sale erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.” Yet the analysis does not translate this finding into projected sediment delivery to downstream waters or the more than 7,000 municipal intakes. Sedimentation reduces reservoir capacity, clogs intake screens, raises treatment costs, and can interrupt service in systems without redundancy. Before proceeding, the agency should quantify projected sediment delivery to affected municipal intakes and water-supply infrastructure.

Road maintenance compounds this risk. The analysis acknowledges that “lack of maintenance commonly has detrimental effects on water quality” and that insufficient funding is a key cause of inadequate maintenance. Nevertheless, the proposed rescission would allow expansion of the road network despite the agency’s existing maintenance deficit. The agency must reconcile any projected increase in road mileage with the acknowledged lack of funds to maintain those roads and prevent water-quality damage.

I also value the opportunity to enter roadless country without motor vehicles. The wilderness character of these areas is inseparable from their ecological function. The DEIS cites research finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, but it does not evaluate what that range could mean across the 40.1 million acres potentially affected. Citing a finding without applying it is not adequate analysis. The agency should quantify the potential fragmentation and biodiversity consequences across the affected acreage and present the results for public review.

Taken together, this rescission would weaken drinking-water protections, permit road-driven sedimentation without modeling its downstream consequences, expand a road network the agency cannot adequately maintain, and acknowledge biodiversity risks without quantifying them. I oppose the rescission and ask the agency to address each of these deficiencies in the administrative record before taking final action.

Sincerely,

Theodore Endreny, PE, PH, PhD
Syracuse, NY

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

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

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

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

Sincerely,
Sean Eagan
Manchester, MD

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

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

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

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.

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

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

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

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

2. THE ECONOMICS DO NOT CLEAR THE TAXPAYER BAR.
Preamble figures: $5.2M-$11.4M per year to the Treasury and Forest Service, $4.6M-$10.6M per year to the timber industry, against an acknowledged $6.9 billion deferred maintenance backlog on roads and bridges and roughly $6.1M per year in lost recreation benefit. Best case, the timber upside is a rounding error against the backlog and is largely cancelled by the recreation loss. At the low end of the agency's own range it is net negative. Request: model full lifecycle cost per new road mile (construction, maintenance, culverts, decommissioning) and disclose the net fiscal position. Adding assets we cannot maintain is how the backlog reached $6.9 billion.

3. ROADS CARRY IGNITIONS. THAT IS THE AGENCY'S OWN SCIENCE.
Roughly nine in ten wildfires are human-caused. Forest Service researchers mapped 26 years of ignitions along about 850 miles of road in the Angeles, San Bernardino, Los Padres and Cleveland National Forests. The preamble itself concedes that greater access "can increase human-caused ignition potential." Request: quantify it. Model expected additional ignitions per new road mile against expected acres treated and show the net change in community risk. Right now the fire rationale is asserted, not calculated.

4. THIS REDUCES LOCAL CONTROL. IT DOES NOT INCREASE IT.
Idaho and Colorado already built their own roadless rules by petition under 5 U.S.C. 553(e), and this proposal leaves both intact. That is proof the current framework is not one-size-fits-all. States that wanted tailoring got it. Full rescission does not hand decisions to local officials. It removes the floor and pushes every acre into plan revisions and project-level NEPA: more federal process, more litigation, more delay. That runs against the stated deregulatory purpose of E.O. 14192.

5. RELIANCE INTERESTS, SINCE THE PREAMBLE ASKS FOR THEM.
Twenty-five years of private investment sits on this rule. Outfitters, guides, ranchers whose operations depend on intact headwaters, and the lodging, fuel, food and retail businesses in gateway towns whose product is the country next door. I am on the customer side of that economy, and my money goes to those towns because of what surrounds them. In 2024 outdoor recreation was $1.3 trillion in output, 2.4% of GDP and 5.2 million jobs, and hunting and shooting was the fastest-growing category in it at 16.5%. A projected $6.1M annual recreation loss does not credibly describe that exposure. It is a placeholder.

6. TAILORING.
The community-protection rationale rests on WUI overlap: 9.8 million acres, 24%. Rescinding 100% of the rule to reach 24% of the acres is not narrow tailoring. A WUI-scoped alternative delivers the fire benefit without the rest, and I would support it.

7. PROCESS.
The 2001 rule came out of 600 public meetings and 1.6 million comments. This round is 30 days with no public meetings, on a proposal the preamble concedes could exceed $100 million in annual effects. That gap will be the first thing a court looks at.

One last thing. I camp on Forest Service ground, dispersed sites off forest roads across the Eastern Sierra, the Great Basin and the Northern Rockies. I photograph the night sky out there because dark sky has a hard boundary: it exists where roads and lights do not, and there is less of it every year. That country is an asset on the national balance sheet, and it took 25 years to stop borrowing against it. Roosevelt understood you do not liquidate the principal to make a quarter.

Keep the rule. Fund the treatments. Use petitions where states want something different.

A supporting statement with citations and a fiscal table is attached.

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

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.

"Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups."
— Landscape Ecology (Springer Nature), 2025

A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this proposal gives it.

Respectfully submitted,

CommentID: RLC-20260902-IP0AIZ

Alternative 2 removes the nationwide restrictions that have limited new road construction, and
the DEIS itself describes an increase in road construction, reconstruction, and timber harvest
under Alternative 2 as “reasonably foreseeable” (Vol. I, p. 140). I am concerned that USDA is
proposing to expand a road network it has demonstrated a declining capacity to maintain, at
the same time funding for that system has fallen by nearly 70 percent. New roads do not fund
themselves once built — they become part of the same maintenance backlog already
measured in the billions. I ask USDA to explain how it intends to fund and maintain any
additional roads resulting from rescission, given the agency's own documented funding trend,
and to account for this fiscal reality in choosing among the alternatives.

I ask USDA to reject Alternative 2 and adopt Alternative 1, keeping the 2001 Roadless Rule
fully in place nationwide.

Thank you.

Adding road miles to a system that cannot maintain the roads it has is fiscally irresponsible. The proposal itself acknowledges a $6.9 billion deferred maintenance backlog for Forest Service roads and bridges. New construction converts a one-time appropriation into a permanent maintenance liability the agency already cannot meet. Unmaintained roads are the primary source of sediment delivery to streams on national forest lands, which imposes downstream costs on municipal water systems and fisheries that the cost-benefit analysis does not adequately quantify.

The wildfire rationale does not match the geography. USDA states that 9.8 million acres — 24 percent of affected roadless area — overlap the wildland-urban interface. The remaining 76 percent is not adjacent to communities. If the purpose is community protection, a targeted amendment addressing WUI-adjacent acreage would accomplish it. USDA has not explained why full rescission is necessary to achieve a stated purpose that applies to less than a quarter of the affected land, and the failure to analyze a WUI-focused alternative is a defect in the range of alternatives under NEPA. The proposal also acknowledges that increased access raises human-caused ignition potential, without weighing that against the claimed suppression benefits. The existing rule already permits vegetation treatment and imposes no restriction whatsoever on fire suppression.

Reliance interests weigh against rescission. USDA has specifically invited comment on this point. For twenty-five years, outfitters, guides, recreation businesses, hunting and fishing operations, and communities whose economies depend on backcountry character have made investments in reliance on these protections. Under Encino Motorcars v. Navarro and DHS v. Regents, an agency reversing a longstanding policy must confront these interests directly rather than assert that local planning will address them.

The Regulatory Flexibility Act certification appears inconsistent with the record. USDA certifies no significant impact on a substantial number of small entities while simultaneously stating that annual effects could exceed $100 million and that recreation and tourism businesses — overwhelmingly small entities — will experience losses. These findings cannot both stand.

The 2001 rule was adopted after more than 600 public meetings and 1.6 million comments. More than 220,000 letters representing over 625,000 people were submitted on the notice of intent alone. Please retain it.

Jaffer Syed
Tampa, Florida

I am particularly concerned by the proposal to rely instead on individual forest land management plans and project-level decision-making. Existing forest plans were developed within a regulatory framework in which the Roadless Rule already protected inventoried roadless areas. Those plans therefore did not necessarily need to provide equivalent protections themselves. Removing the overarching rule and then relying on existing forest plans to protect these areas risks creating a significant gap in protection.

More broadly, I support meaningful local participation in forest management, and local Forest Service staff certainly have knowledge of conditions that cannot be captured perfectly by a national rule. But local decision-making and a national conservation baseline are not mutually exclusive. Forest-level plans and project decisions are also more susceptible to changes in agency leadership, federal policy, funding, and local economic and political pressures over time. A national rule establishes a durable presumption that these remaining roadless lands should stay roadless unless there is a compelling reason otherwise.

I am also concerned that the rationale for rescission extends beyond wildfire and forest health. The Forest Service’s own materials describe rescission as a means of facilitating timber production, jobs and economic development in addition to wildfire risk reduction. Those may be legitimate multiple-use considerations on National Forest System lands, but they are quite different from an argument that the Roadless Rule prevents necessary wildfire management. They should not be conflated.

Most importantly, the consequences of these decisions are asymmetric. A restrictive management policy can be changed later when a specific need is demonstrated. Once a road is constructed into an intact roadless landscape, however, the effects can be much more difficult to reverse. Roads can fragment habitat, affect watersheds, create ongoing maintenance obligations, and make additional timber harvest, mineral development, motorized access, and infrastructure development possible. It is difficult, if not impossible, to restore the same roadless character afterward.

For these reasons, I urge the Forest Service to retain a strong national conservation standard for inventoried roadless areas. If experience since 2001 demonstrates that particular provisions prevent necessary wildfire mitigation, ecological restoration, community protection, or other legitimate management activities, the agency should consider carefully tailored changes or exceptions to address those problems. It should not eliminate the national protection for all affected roadless areas simply because greater flexibility may be warranted in some of them.

The burden should remain on proposed development to demonstrate why an exception is warranted, rather than on each roadless landscape to repeatedly demonstrate why it should remain intact.

The wildfire rationale the agency offers does not survive contact with its own record. The DEIS states plainly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal points to fuels management as a reason to open roadless areas. The agency's own data point the other way. I want to know why the proposal departs from those prior findings, and how it reconciles the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The economics do not add up either. The agency's own 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." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. The agency cannot establish a net benefit from its own numbers. It should explain how an action with that level of uncertainty in its favor justifies the permanent loss of roadless character.

The agency also argues that state-specific approaches can replace a single national rule. The last time the agency made that argument and acted on it, the courts rejected the result. Rather than reproduce language the prior rulemaking used to characterize that position, I will say plainly that the agency's own record acknowledges its previous dissatisfaction with the national rule and its preference for flexible, local approaches. What it does not address is its own prior finding that local decision-making can incrementally erode nationally significant roadless values, or how this proposal avoids the legal deficiencies identified when the agency last tried a state-by-state replacement. The agency should answer both of those questions.

Finally, the agency questions its own statutory authority to maintain the 2001 rule. The Tenth Circuit addressed that question directly. It 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." The court found the rule within the authority Congress granted and did not treat it as creating de facto wilderness. The agency should state clearly, on this record, what legal basis supports a contrary position today.

I hike to hear birds and breathe fresh air. I want those things to exist for people who come after me. Rescinding this rule puts that future at risk, and the agency's own record does not justify it.

Sincerely,
Indy Kahn
Los Angeles, CA

named the direction of a dozen effects and given the magnitude of almost none of them. A record like that cannot support an irreversible decision. A road, once cut, is there for decades. A tree left standing can be cut next year.
The same is true of the finding that the plan is “likely to adversely affect” 327 listed species and 71 critical habitats (p. 25, 161-162). That tells the public harm is expected, not how much. An analysis that identifies harm and then declines to measure it is not a basis for going forward. It is a reason to stop.
One more thing on the analysis. Idaho, where I grew up, is exempt from this proposal because it has its own state-specific roadless rule. So does Colorado. That undercuts the argument that the 2001 rule is an inflexible national mandate. States that wanted something tailored to their forests got it, through a process that already exists. Repealing the rule everywhere else is not necessary to give local managers flexibility.
On the places. Washington has about two million acres of inventoried roadless area across eight national forests — roughly a fifth of the state’s national forest land, holding some 830 trails and 4,000 miles of trail. I use them. Not once a summer, but most weeks of the year, and I have organized a lot of my adult life around being able to. The fishing I care about is in water that starts in those areas, and it is cold and clean because nothing has been cut above it. Roads would change all of that, and the change would not be reversible in my lifetime.
Last fall’s comment period drew more than 625,000 comments, over 99 percent of them opposed. I know I’m one more. I am asking you to withdraw this proposal and leave the 2001 Roadless Rule in place.
Thank you for your time.
Nolan Cole

Regarding the Graveyard Ridge (addition) in the Pisgah National Forest, North Carolina:

The threat mechanism classified as 4.1 - Roads & railroads (IUCN-CMP 4.1) is actively degrading habitat for Bog Turtle (Glyptemys muhlenbergii, G2) in the Graveyard Ridge (addition) Inventoried Roadless Area, Pisgah National Forest, at Negligible or <1% pop. decline severity across Small (1-10%) scope.

Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 4.1 - Roads & railroads on Bog Turtle.

Analysis of 4.1 - Roads & railroads effects on Bog Turtle (Glyptemys muhlenbergii) in Graveyard Ridge (addition) must reference the species' G2 conservation status and the documented Negligible or <1% pop. decline severity. The DEIS lacks scientific integrity without this baseline data.

"Mammal and bird population densities declined with their proximity to infrastructure. The effect of infrastructure on bird populations extended over distances up to about 1 km, and for mammal populations up to about 5 km. Data were gathered from 49 studies on 234 mammal and bird species. The main response by mammals and birds in the vicinity of infrastructure was either avoidance or a reduced population density."
— Biological Conservation (ScienceDirect), 2010

“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 (https://doi.org/10.1073/pnas.2113416118)”

Withdrawal of the proposed rescission is the appropriate administrative outcome.

Best regards,
Carolyn Baker

CommentID: RLC-20260829-RHKD1D

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

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

Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values.
The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies.
The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use. Thank you

The economic justification fares no better under scrutiny of the agency's own numbers. 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 a contribution that small, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The Forest Service road system already carries a $6.9 billion maintenance backlog. How does the agency justify expanding that system when its own analysis cannot establish that the action produces a net benefit?

The proposal argues that state-specific rulemaking can replace a single national standard, but the agency has pursued that path before and the courts found it wanting. Rather than reproduce the agency's own prior characterization of that episode, I will state the point plainly: the Ninth Circuit previously rejected the agency's attempt to substitute a state-by-state approach for the 2001 rule, and the record contains the agency's own acknowledgment that local decision-making can incrementally erode roadless values that are nationally significant. The agency must address, specifically and on the record, how the current proposal avoids the legal and substantive deficiencies that doomed the prior attempt.

On the question of statutory authority, the proposal suggests the 2001 rule exceeded what Congress granted. A federal appellate court has already examined that claim. 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 provided under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain the legal basis for any position to the contrary.

The quiet and the clean air I found during that week of hiking exist because roads have not been cut through those places. The agency's own data on fire risk, its own economic projections, the history of failed litigation, and a binding appellate ruling all point in the same direction. This rescission should not proceed.

Sincerely,
Jordan Sale
Los Angeles, CA

This proposal centers timber interests and overlooks others: hunters, anglers, and birders whose recreation supports local economies; downstream communities whose water quality depends on these watersheds; and small, recreation-dependent businesses with as much at stake as the timber industry.

The trade-off is lopsided. The agency's own estimate is a 5–10% rise in timber harvest, worth $4.6–$10.6 million a year — a modest, narrowly held gain against permanently losing protection for 45 million acres of the last intact backcountry in the system. The benefits go to industry and to managers wanting fewer procedural steps; the costs, fragmented habitat, degraded water, lost backcountry character, fall on downstream communities, already-stressed wildlife, and a public that has strongly supported this rule from the start (95% of comments in 2000, and reportedly similar opposition now). Much of that loss can't be priced: what intact backcountry is worth to future generations, or the stability of one national standard instead of the same fight recurring forest by forest.

I urge the Forest Service to withdraw the full rescission and instead streamline the existing fire-mitigation exceptions, preserving national-level protection while addressing the stated wildfire concerns.

Thank you for the opportunity to comment.

Respectfully submitted, Jennifer G Turner Tucson, Arizona

Road construction and use produce various direct or indirect impacts on ecosystems. These impacts include, but are not limited to, habitat loss and fragmentation, wildlife mortality, exhaust emissions, and noise pollution, according to a study in 2019 (Roadless Areas as Key Approach to Conservation of Functional Forest Ecosystems, Hoffman, et al). These impacts are important to consider as they will be a huge environmental and economical loss to society. Directly stated on the fs.usda.gov website, under the Natural Resources webpage, is that “the health of our nation depends, in many ways, on the vitality of our nation’s forests and grasslands. These natural resources contribute a variety of essential elements to our well-being, including clean air, water and soil.” Healthy ecosystems provide an enormous monetary value through providing these services. According to the United States Environmental Protection Agency’s Environmental Investments: The Cost of A Clean Environment estimates “an investment of $115 billion a year in current dollars to protect and restore our nation’s air, water, and land.” This report was written in 1990, indicating that it would be an investment of about $300 billion dollars a year in 2026. This is an enormous cost that the National Forest Systems are currently helping to offset. Road construction through this area will just continue to increase a cost that we are already fighting to address.

My recommendations include retaining the 2001 Roadless Rule and maintaining existing protections for inventoried roadless areas. Additionally, I recommend a full evaluation on the cumulative and indirect impacts from road network expansion and timber harvesting.

Rescinding the Roadless Rule is also dangerous. More roads mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas kills people, is expensive (more wasted money!) and diverts resources from protecting our communities. More roads will also degrade drinking watersheds. National Forests and Grasslands are the single most important source of municipal water supply in the United States, and Roadless Areas filter drinking water for over 2 million Oregonians. In Central Oregon, the Bend Municipal Watershed begins in the headwaters of Bridge Creek and Tumalo Creek in the Deschutes National Forest. Losing Roadless protections will threaten water quality for fish species and the drinking water supply for more than 100,000 people in Bend, and tens of millions of people across the country.

Rescinding the Roadless Rule makes our forests less resilient. Roads spread invasive species, disrupt wildlife corridors, and erode forest resilience in the face of rapidly shifting wildfire regimes. Logging these roadless forests would also directly eliminate overstory and understory habitats, harm First Foods, and reduce the carbon storage we need to combat climate change.

This rescission would not, as the DEIS claims, restore the decision-making power of our local forest managers. Instead, as the DEIS expressly admits, it would further the misguided goal of ramping up timber production on public lands while disempowering the Forest Service staff and Central Oregonians who care for these roadless areas.

Sacrificing our local values for short-term logging profits is not sound policy; it is a net loss for communities, economies, and future generations. Roadless forests represent some of the most intact, resilient ecosystems left in our country, but once roads and clearcuts fragment our landscapes, the damage is permanent.

Despite the clear consequences of rescission and the vocal majority opposing the Proposed Rule, the USDA continues this rollback through an abridged and inadequate public comment process. The original Roadless Rule resulted from the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. Now, the agency is attempting to dismantle these protections with zero public meetings, shortened comment periods, and a disregard for the public input received during scoping. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence.

For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Weakening or repealing it would be a grave mistake. Both Alternatives 2 and 3 will have severe consequences for wildlife, biodiversity, clean water sources, climate resilience, cultural resources, local economies, outdoor recreation, and the health of our nation's wildest forests.

The USDA should abandon this damaging effort and instead strengthen its commitment to protecting the clean water, climate resilience, recreation, and biodiversity that roadless forests provide. I urge the agency to take the No Action alternative and maintain full Roadless Rule protections for America's wild forests.

Sincerely,

Unfragmented forests are essential for many increasingly threatened and endangered species of animals, plants, and fungi as well as serving climate and biodiversity needs of our rapidly deteriorating biomes. I strongly oppose the U.S. Department of Agriculture’s proposal to repeal or weaken the landmark Roadless Area Conservation Rule that has protected wild, unfragmented forests for more than 25 years The rationale offered for doing so isn’t supported by science. This action would harm rather than protect our national forests.

The case for prohibiting road construction and commercial logging in intact forests is just as strong today when U.S.F.S. first enacted this conservation rule. The rule recognizes that roadless areas serve as biological strongholds for imperiled species, that habitat fragmentation harms wildlife, and that intact forests act as essential buffers against the spread of invasive plant species. With more species endangered today and with wildlands disappearing at an increasingly rapid pace, roadless areas are more important than ever to address ongoing wildlife decline and the extinction crisis.

Roadless areas within the national forest system also contain all or part of 354 municipal watersheds, supplying drinking water to millions of Americans and saving downstream communities millions of dollars in water-filtration costs. These lands provide outstanding recreation opportunities — hiking, camping, experiencing wildlife, fishing, cross-country skiing, and canoeing. Furthermore, when the original rule was adopted, the agency was already grappling with a multi-billion dollar deferred maintenance backlog on its expansive road system. That backlog remains roughly the same today. Building more roads on top of the nearly 370,000 miles the agency currently manages would only deepen a problem that remains unsolved after 25 years.

Importantly, expanding roads into forested landscapes will increase, not decrease, wildfire risk. Research has shown that human-caused ignitions are responsible for the vast majority of wildfires, and are roughly four times more likely to start near roads, due to causes like sparks from vehicles and unattended campfires.

I urge the USDA to abandon this misguided proposal and instead reaffirm its commitment to protecting America's roadless forests for the wildlife habitat, clean water, climate resilience, and recreation values they provide to us all.

Maintaining connectivity is also increasingly important as the climate changes. Species are responding to changes in temperature, precipitation, fire regimes, and other environmental conditions. Connected landscapes can facilitate movement as species respond to changing conditions. Forested roadless areas can also contribute to watershed function and carbon storage, benefits that should be considered alongside the potential benefits of additional management access.

I also encourage the Forest Service to consider this decision through the lens of human health. Human health ultimately depends on functioning natural systems, including clean air and water and a stable climate. My own field of disease ecology offers an additional reason for caution. Land-use change does not uniformly increase infectious disease risk, and I would not suggest otherwise. The evidence does show, however, that land-use change and habitat fragmentation can alter ecological communities and interactions among wildlife, vectors, domestic animals, and people. In some circumstances, these changes affect pathogen transmission and opportunities for zoonotic spillover. These relationships are complex and context dependent, but they are part of the consequences of land-use change that deserve consideration.

Most importantly, I question whether complete rescission is proportional to the management problem the Forest Service is seeking to solve. If provisions of the Roadless Rule are preventing necessary wildfire mitigation, ecological restoration, or forest-health work, those constraints should be identified and addressed directly. The existing rule already allows exceptions under specified circumstances, including certain activities related to public safety, ecosystem restoration, and reducing the likelihood of uncharacteristic wildfire. The agency should establish why targeted changes or additional flexibility cannot address demonstrated management needs before eliminating the national framework.

There is also an important asymmetry in this decision. Management rules can be changed as conditions and scientific understanding evolve. Restoring connectivity and other ecological characteristics after a landscape has been fragmented can be difficult, costly, and slow.

I therefore urge the Department of Agriculture and the Forest Service to retain the Roadless Rule and, where specific provisions can be shown to interfere with necessary and scientifically justified management, address those problems narrowly. The alternatives considered should account for potential cumulative effects on biodiversity, landscape connectivity, watershed and aquatic processes, carbon storage, invasive species, wildlife, and relevant pathways affecting human health, rather than evaluating these considerations only through future project-level decisions.

At a time of rapid environmental change, large, connected landscapes are an important component of ecological resilience. Removing broad protections should require compelling evidence that the benefits cannot be achieved through more targeted means. I do not believe that case has been established.

Thank you for considering my comments.

Katherine F. Smith, PhD
Ecologist

Submitted in an individual capacity.

A programmatic analysis is insufficient. The DEIS must evaluate 7.1 - Fire & fire suppression impacts to Monarch (Danaus plexippus, G4) at the scale of the Mogan Ridge Inventoried Roadless Area, Hoosier National Forest, with specificity adequate to inform the decision.

"Of the 537 wildlife species of conservation concern in CONUS, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas (IRAs). The median IRA contains suitable habitat for 10 wildlife species of conservation concern, with a maximum of 62 wildlife SCCs. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA CONUS lands. If all IRAs were added to the protected-area system in CONUS, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas."
— Global Ecology and Conservation (ScienceDirect), 2021

A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this proposal gives it.

With urgency,

CommentID: RLC-20260826-0OMYEP

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

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

2. THE ECONOMICS DO NOT CLEAR THE TAXPAYER BAR.
Preamble figures: $5.2M-$11.4M per year to the Treasury and Forest Service, $4.6M-$10.6M per year to the timber industry, against an acknowledged $6.9 billion deferred maintenance backlog on roads and bridges and roughly $6.1M per year in lost recreation benefit. Best case, the timber upside is a rounding error against the backlog and is largely cancelled by the recreation loss. At the low end of the agency's own range it is net negative. Request: model full lifecycle cost per new road mile (construction, maintenance, culverts, decommissioning) and disclose the net fiscal position. Adding assets we cannot maintain is how the backlog reached $6.9 billion.

3. ROADS CARRY IGNITIONS. THAT IS THE AGENCY'S OWN SCIENCE.
Roughly nine in ten wildfires are human-caused. Forest Service researchers mapped 26 years of ignitions along about 850 miles of road in the Angeles, San Bernardino, Los Padres and Cleveland National Forests. The preamble itself concedes that greater access "can increase human-caused ignition potential." Request: quantify it. Model expected additional ignitions per new road mile against expected acres treated and show the net change in community risk. Right now the fire rationale is asserted, not calculated.

4. THIS REDUCES LOCAL CONTROL. IT DOES NOT INCREASE IT.
Idaho and Colorado already built their own roadless rules by petition under 5 U.S.C. 553(e), and this proposal leaves both intact. That is proof the current framework is not one-size-fits-all. States that wanted tailoring got it. Full rescission does not hand decisions to local officials. It removes the floor and pushes every acre into plan revisions and project-level NEPA: more federal process, more litigation, more delay. That runs against the stated deregulatory purpose of E.O. 14192.

5. RELIANCE INTERESTS, SINCE THE PREAMBLE ASKS FOR THEM.
Twenty-five years of private investment sits on this rule. Outfitters, guides, ranchers whose operations depend on intact headwaters, and the lodging, fuel, food and retail businesses in gateway towns whose product is the country next door. I am on the customer side of that economy, and my money goes to those towns because of what surrounds them. In 2024 outdoor recreation was $1.3 trillion in output, 2.4% of GDP and 5.2 million jobs, and hunting and shooting was the fastest-growing category in it at 16.5%. A projected $6.1M annual recreation loss does not credibly describe that exposure. It is a placeholder.

6. TAILORING.
The community-protection rationale rests on WUI overlap: 9.8 million acres, 24%. Rescinding 100% of the rule to reach 24% of the acres is not narrow tailoring. A WUI-scoped alternative delivers the fire benefit without the rest, and I would support it.

7. PROCESS.
The 2001 rule came out of 600 public meetings and 1.6 million comments. This round is 30 days with no public meetings, on a proposal the preamble concedes could exceed $100 million in annual effects. That gap will be the first thing a court looks at.

One last thing. I camp on Forest Service ground, dispersed sites off forest roads across the Eastern Sierra, the Great Basin and the Northern Rockies. I photograph the night sky out there because dark sky has a hard boundary: it exists where roads and lights do not, and there is less of it every year. That country is an asset on the national balance sheet, and it took 25 years to stop borrowing against it. Roosevelt understood you do not liquidate the principal to make a quarter.

Keep the rule. Fund the treatments. Use petitions where states want something different.

A supporting statement with citations and a fiscal table is attached.

My strongest professional concern is sediment. The DEIS states that skid roads, trails, log landings, and similar disturbances are the primary sources of timber-sale erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.” Yet the analysis does not translate this finding into projected sediment delivery to downstream waters or the more than 7,000 municipal intakes. Sedimentation reduces reservoir capacity, clogs intake screens, raises treatment costs, and can interrupt service in systems without redundancy. Before proceeding, the agency should quantify projected sediment delivery to affected municipal intakes and water-supply infrastructure.

Road maintenance compounds this risk. The analysis acknowledges that “lack of maintenance commonly has detrimental effects on water quality” and that insufficient funding is a key cause of inadequate maintenance. Nevertheless, the proposed rescission would allow expansion of the road network despite the agency’s existing maintenance deficit. The agency must reconcile any projected increase in road mileage with the acknowledged lack of funds to maintain those roads and prevent water-quality damage.

I also value the opportunity to enter roadless country without motor vehicles. The wilderness character of these areas is inseparable from their ecological function. The DEIS cites research finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, but it does not evaluate what that range could mean across the 40.1 million acres potentially affected. Citing a finding without applying it is not adequate analysis. The agency should quantify the potential fragmentation and biodiversity consequences across the affected acreage and present the results for public review.

Taken together, this rescission would weaken drinking-water protections, permit road-driven sedimentation without modeling its downstream consequences, expand a road network the agency cannot adequately maintain, and acknowledge biodiversity risks without quantifying them. I oppose the rescission and ask the agency to address each of these deficiencies in the administrative record before taking final action.

Sincerely,

Theodore Endreny, PE, PH, PhD
Syracuse, NY

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

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,

Joe Hermann
Denver, Colorado

The fire argument cuts against the proposal, not for it. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Roading the Quinault region would increase the possibility of fire. That is not my speculation. That is what the agency's own draft environmental impact statement shows. I ask that the agency explain why the proposal departs from those findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The proposal cannot establish that the economics add up. The agency's own record states 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 production figure, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. A road system already carrying a $6.9 billion maintenance backlog would be expanded for a return the agency cannot demonstrate is positive. Roading the South Quinault area would destroy my business as a tour guide in a currently unroaded area and would negatively affect the hiking trails my customers rely on. The agency must reconcile those numbers on the record and explain how an action whose own analysis cannot establish a net benefit justifies this rescission.

The proposal also must reckon with what the existing rule already allows. The 2001 rule did not ban all road construction. It included exceptions for public health and safety, for reserved or outstanding rights, and for existing uses. The proposal justifies rescission on permitting and administrative burden grounds, but it does not identify which specific burdens are not already addressed by those exceptions. Our community gets its drinking water from the Quinault region. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The public health and safety exception was written for exactly those stakes. The agency should identify on the record which burdens it claims are unmet by existing exceptions, and it should quantify them.

Finally, the agency's own record documents 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 proposal offers no population-level projection for big game. The South Quinault area is part of a functioning ecosystem. A rule change with documented effects on wildlife behavior demands that the agency project what those effects mean at the population level before any final action is taken.

I make my livelihood in this region. The mushrooms I forage and the tours I lead depend on this place staying whole. What the agency treats as an administrative question is, for me and for my community, a practical one: whether the water is clean, whether the forest stands, whether the business survives. I expect a substantive response in this docket.

Sincerely,
Matt Houghton
Quinault, WA

The economic case for rescission is also weaker than the proposal lets on. The agency's own 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 projected timber revenue of $5.2 to $11.4 million a year, the agency's own Cost Benefit Analysis projects recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. I do not want my tax dollars to support expanding a road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year when the agency's own numbers cannot establish that the action produces a net benefit. The agency must explain how that arithmetic justifies this rescission.

The proposal also argues that state-by-state approaches can replace a national rule. The agency has previously tried exactly that substitution and the courts rejected it. That prior effort was grounded in the position that the 2001 rule took an inflexible one-size-fits-all nationwide approach, a characterization the agency itself offered. What the agency has not grappled with in this proposal is its own earlier finding that local decision-making can incrementally erode nationally significant roadless values, and the deficiencies the Ninth Circuit identified when it reviewed the state-specific alternative. The agency should address those deficiencies directly and explain how this proposal avoids repeating them.

On the question of statutory authority, the proposal suggests the 2001 rule exceeded what Congress granted. The Tenth Circuit addressed that question and held otherwise, reversing the district court that had enjoined the rule: "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 should state plainly, on this record, what legal basis it has for any position contrary to the Tenth Circuit's holding that the 2001 rule fell within the authority Congress provided under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness.

Clean water is a human right. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. That number will not hold if road building introduces the sediment load the agency's own record associates with roaded timber operations. What specific finding does the agency offer to show that rescission will not degrade those water sources?

Sincerely,
Meredith Carver
Gilford, New Hampshire

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

Our public land should be managed for now and for our children's children. Abolishing roadless areas and allowing ATVs and dirt bikes everywhere completely ruins what makes them worth visiting. I already see plenty of drunk idiots on Razors nearer to the accessible roads, starting illegal campfires and littering everywhere. I do not want that driven up into roadless backcountry. If you remove the roadless rule, the dregs of society will come for the Lost Rivers backcountry around Borah Peak. The Borah Peak roadless area covers more than 130k acres in the Salmon-Challis National Forest. That NF contains the largest roadless complex outside of designated wilderness in the lower 48, and it supports Chinook salmon, steelhead, bull trout, wolverine, mountain goat, bighorn sheep, and gray wolf. The Angel Peak North roadless area covers 12,577 acres in the Humboldt-Toiyabe National Forest, the largest national forest in the lower 48, where each roadless range rises from the Great Basin like a sky island with its own ecology, its own water, its own wildlife. The Humboldt-Toiyabe holds 354 inventoried roadless areas totaling 3,383,849 acres, and verified species there include Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and elk. Stop trying to ruin what little we have.

The proposal justifies rescission partly on wildfire and fuels management grounds. That argument contradicts the agency's own findings. According to the Forest Service, "more than 90 percent of wildland fires are the result of human activity, and ignitions are almost twice as likely to occur in roaded areas as they are in roadless areas (USDA Forest Service 1998, 2000)." Opening these landscapes to roads and motorized access does not reduce fire risk. It imports the ignition sources the agency's own data identify. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.

The agency also claims administrative burden justifies rescission, but its own record states: "It makes little fiscal or environmental sense to build additional roads in inventoried roadless areas that have irretrievable values at risk when the agency is struggling to maintain its existing extensive road system (FEIS Vol. 1, 1-5 and 3-22)." The rule as written already contains exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which burdens those exceptions fail to address. I ask that it do so specifically, and that it quantify those claimed burdens on the record rather than assert them.

The proposal's regulatory flexibility analysis certifies no significant impact on small entities. The agency's own CBA analyzes lost recreation benefit at a minimum of $6.1 million per year and names outfitters, guides, and tour operators among the affected parties, yet the certification is reached by spreading the $9 million annual expenditure loss across every small firm in the sector nationally (no case-by-case analysis whatsoever). The analysis even concedes some firms may lose these receipts. That is not a no-impact finding. The agency should withdraw the certification and assess the small entities actually operating in the potentially affected roadless areas, not the national average firm.

Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have planned repeated fall trips into the Angel Peak North roadless area in the Humboldt-Toiyabe based on the protections the 2001 rule provides. That is a reliance interest. The agency invited these comments and must weigh what it receives. I ask that it identify and assess the reliance interests described in the record before reaching any final decision.

Thanks,
Maxwell Erickson
North Las Vegas, NV

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

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,

Joe Hermann
Denver, Colorado

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

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

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

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

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

Issue 3: Carbon is stated and dropped

The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons.

The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative.

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

I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats.

Not may: will increase the likelihood, and the agency anticipates the harm. The phrase "likely to adversely affect" appears more than 150 times across the USFWS assessment alone, and the proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Mary Katherine Ray
Winstom, NM

The standing forests where I watch wildlife are doing quiet work the whole time, holding carbon. The agency states what these lands store and then drops the analysis. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons.

The DEIS concludes these lands will continue to sequester and store carbon, with no analysis of harvest and roading. I ask that the agency quantify the change in carbon storage and sequestration under each alternative.

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

I spend my time looking for wildlife in these forests, and the rarest of it is exactly what the agency's own assessments say this action is likely to harm. The agency’s 428-page draft biological assessment closes: “Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.” The DEIS tallies the determinations: “may affect, likely to adversely affect” for 327 ESA-listed species and 71 designated critical habitats.

Not may: will increase the likelihood, and the agency anticipates the harm. The phrase “likely to adversely affect” appears more than 150 times across the USFWS assessment alone, and the proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule.

Issue 5: Every conservation alternative was eliminated by how the purpose was written

I want this land managed responsibly, and responsible management starts with an honest comparison of the options. The agency wrote its purpose so that comparison could not happen. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it “would continue to restrict local decision-making discretion” and because analysing roadless values is “an administrative and legal burden for the agency.”

A purpose written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full.

I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

Sincerely,
Mariel Dryl
Denville, NJ 07834

The 2001 Roadless Rule does not address livestock-grazing impacts, and grazing has continued uninterrupted in Inventoried Roadless Areas. A mapping analysis estimates that between 10 million and 15 million acres of these lands are actively grazed by domestic livestock each year. Livestock can damage streams and springs, remove riparian vegetation, compact soils, spread invasive plants, and displace native wildlife. New road construction would enable harmful livestock grazing to expand. And those grazing their livestock aren't even paying for their impacts or paying a fair price for their leases.

The Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values. The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights.

The Forest Service should also prohibit new mineral leasing within these lands. More than 9,000 miles of mapped motorized trails cross roadless areas. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk! Road raise the risks to rural communities!

Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies. I ask that the Forest Service withdraw the proposed rescission and adopt a stricter national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use.

We must preserve these tracts for future generations. Making them more prone to wildfire and other use-related abuses that scar the land and take away dwindling habitats harms everyone. Please withdraw the proposed rescission, and make a stricter national rule. Monied interests should not offset the greater good, or trump our commitments to future generations while making our wild lands more susceptible to human-caused wildfire.

"In an 18-year experimental study, connected plots showed rates of plant extinction decreased by 2 percent per year, and rates of plant colonization (new plant species coming in) increased by 5 percent per year over the duration of the study. The effects compound over time — plant biodiversity has increased by 14 percent over 18 years and is still going up. Connecting habitat fragments via corridors can not only stave off biodiversity loss, but also encourage biodiversity gain that compounds over time."
— Save the Redwoods League, 2019

Failure to Substantively Respond to Content of Majority-Opposition Comments
[challenge-008]

The Notice of Intent section reduces overwhelming public opposition to a bare percentage, stating that "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support," without any accompanying discussion of what those commenters actually said. No substantive response section addressing the content categories raised — water quality, carbon storage, invasive species spread — appears associated with this passage. Independent research the agency should engage directly documents that roads cause "increased mortality from road construction," "spread of exotic species," and sediment delivery that is "long-lasting and cumulative and cannot be effectively mitigated" (Trombulak & Frissell 2000). Did the agency consider comments raising these documented mechanisms, and if so, where in the record is that consideration explained? Reducing majority opposition to a percentage without engaging its substance violates the requirement that agencies give reasoned consideration to public comment under Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978), and is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request a substantive, topic-by-topic response to the content of majority-opposition comments before this rescission is finalized.

Failure to Address Confounding Causal Factors for Forest Health Decline
[challenge-021]

The Rationale for the Proposed Rule attributes forest health decline to the 2001 Rule's limits on active management, stating that the Rule "has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns" (pp. 18-19). This single-cause narrative ignores other well-documented drivers of the same trend, including decades of fire suppression policy, climate-driven drought and insect mortality, and wildland-urban interface development pressure that independently affect forest health regardless of roadless status. Nowhere in this section does the agency analyze or rule out these confounding factors, or explain why roadless designation, rather than these alternative causes, should bear responsibility for the observed conditions. Under State Farm, 463 U.S. at 43, an agency cannot ignore an important aspect of the problem, and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), requires reasoned engagement with contrary explanations. I request that the agency add an express analysis distinguishing roadless-attributable effects from these confounding causes, consistent with APA 5 U.S.C. § 706(2)(A).

Rescission should not be finalized; the Roadless Area Conservation Rule should remain effective.

Hopefully,

CommentID: RLC-20260904-W5VTDL

I have built years of hunting and recreation around the protections provided by the Roadless Area Conservation Rule. The proposal specifically solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), yet the Cost Benefit Analysis does not meaningfully account for them.

Under Encino Motorcars and Regents, an agency changing an established policy must consider serious reliance interests created by its prior policy. My recreational use and planning around continued roadless protections are such interests.

I ask that the agency identify and evaluate the reliance interests described in the comments it receives, including this comment, and explain how they affect the decision.

Issue 4: Road sediment

I fish these waters, and clean gravel and functioning streams are part of what makes them valuable. The DEIS states that skid roads, trails, log landings, and similar disturbances are the main cause of soil erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.”

The DEIS does not appear to carry this finding into a quantitative projection of sediment delivery. I ask that the agency quantify projected sediment delivery and water-quality effects, including effects on the more than 7,000 municipal water intakes downstream.

Issue 5: Drinking water

I fish for salmon, and the water they depend on is the same water people downstream depend on for drinking water.

The agency identifies approximately 24 million people using water originating within potentially affected roadless areas through more than 7,000 municipal intakes. The DEIS also states that less than 12 percent of these watersheds are currently impaired.

The DEIS relies on forest plans to address drinking-water sources without identifying specific protections equivalent to the Roadless Rule. I ask that the agency identify, forest by forest, the specific provisions that would provide protections equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. If the agency considers them equivalent, it should explain why and identify the enforceable mechanisms supporting that conclusion.

Issue 6: Carbon storage

The DEIS cites the estimate that inventoried roadless areas contain approximately 5 percent of the stored forest carbon in the contiguous United States, or roughly 0.9 billion metric tons.

The DEIS concludes these lands will continue to store and sequester carbon but does not adequately quantify how that changes if protections against road construction and timber harvesting are removed. I ask that the agency quantify changes in carbon storage and sequestration under each alternative, including potential timber harvest, road construction, disturbance, and loss of standing forest.

Conclusion

I request that the agency respond in the administrative record to each issue raised above and analyze an alternative that retains the protections established by the 2001 Roadless Area Conservation Rule.

Where the proposal relies on conclusions that differ from the agency’s own prior findings, the agency should identify those changes, explain why its conclusions have changed, and provide a reasoned explanation supported by the record.

These lands are not simply acreage on a map. They are connected wildlife habitat, hunting country, fishing watersheds, drinking-water sources, and functioning forests. Those values should be quantitatively evaluated rather than acknowledged and then left out of the analysis.

Sincerely,

Chela Choisne
Fairview, Oregon

expand.
The Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values.
The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies.
The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use.

Thank you very much in advance for heeding my request.

Respectfully yours,

Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values.
The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies.
The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use. Thank you

are primary drivers of aquatic degradation, increasing erosion rates exponentially and introducing destructive sediment loads into native fisheries.
Wildfire Ignition Risks: Empirical data contradicts the claim that road building and commercial logging enhance forest health; in reality, over 90% of human-started wildfires occur within a half-mile of a forest road. Roads additionally act as corridors for invasive plant species, which dry out quickly and provide volatile, highly flammable fine fuels.
Opening intact backcountry to industrial activity compromises ecological integrity, fragments critical migration corridors for species like elk, grizzly bears, and native trout, and degrades municipal watersheds relied upon by millions of downstream residents.
I urge the agency to uphold the Roadless Rule in its entirety to safeguard our remaining wild places, protect public resources, and honor the empirical science that proves intact forests are safer and ecologically richer when left undisturbed.
Respectfully submitted,
Angela Schuster
Minneapolis, Minnesota 55407

By the Assessment's Own Definition, Grizzly Core Habitat Is Lost the Moment a Road Is Built

The USFWS Biological Assessment states at page 125: "By definition core habitat for grizzly bears is lost when a road is constructed, unless it is mitigated by the creation of new secure habitat elsewhere through road decommissioning or other actions." This is not a prediction subject to project-level uncertainty; it is a definitional identity: road construction in grizzly core habitat equals core habitat loss, full stop, absent compensatory decommissioning. The rescission makes road construction newly possible across previously protected portions of grizzly recovery zones (see the SSA reliance finding at p. 122), yet the DEIS neither quantifies the core habitat placed at risk nor identifies any mechanism ensuring the compensatory mitigation the definition requires. Where the agency's own document establishes a per-se loss mechanism, NEPA requires the acreage exposed to that mechanism be disclosed and analyzed by alternative. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). I request the FEIS map and quantify grizzly core habitat within potentially affected IRAs by recovery zone, and state whether and how compensatory secure-habitat creation would be assured.

"In an 18-year experimental study, connected plots showed rates of plant extinction decreased by 2 percent per year, and rates of plant colonization (new plant species coming in) increased by 5 percent per year over the duration of the study. The effects compound over time — plant biodiversity has increased by 14 percent over 18 years and is still going up. Connecting habitat fragments via corridors can not only stave off biodiversity loss, but also encourage biodiversity gain that compounds over time."
— Save the Redwoods League, 2019

Failure to Substantively Respond to Content of Majority-Opposition Comments
[challenge-008]

The Notice of Intent section reduces overwhelming public opposition to a bare percentage, stating that "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support," without any accompanying discussion of what those commenters actually said. No substantive response section addressing the content categories raised — water quality, carbon storage, invasive species spread — appears associated with this passage. Independent research the agency should engage directly documents that roads cause "increased mortality from road construction," "spread of exotic species," and sediment delivery that is "long-lasting and cumulative and cannot be effectively mitigated" (Trombulak & Frissell 2000). Did the agency consider comments raising these documented mechanisms, and if so, where in the record is that consideration explained? Reducing majority opposition to a percentage without engaging its substance violates the requirement that agencies give reasoned consideration to public comment under Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978), and is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request a substantive, topic-by-topic response to the content of majority-opposition comments before this rescission is finalized.

Failure to Address Confounding Causal Factors for Forest Health Decline
[challenge-021]

The Rationale for the Proposed Rule attributes forest health decline to the 2001 Rule's limits on active management, stating that the Rule "has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns" (pp. 18-19). This single-cause narrative ignores other well-documented drivers of the same trend, including decades of fire suppression policy, climate-driven drought and insect mortality, and wildland-urban interface development pressure that independently affect forest health regardless of roadless status. Nowhere in this section does the agency analyze or rule out these confounding factors, or explain why roadless designation, rather than these alternative causes, should bear responsibility for the observed conditions. Under State Farm, 463 U.S. at 43, an agency cannot ignore an important aspect of the problem, and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), requires reasoned engagement with contrary explanations. I request that the agency add an express analysis distinguishing roadless-attributable effects from these confounding causes, consistent with APA 5 U.S.C. § 706(2)(A).

Rescission should not be finalized; the Roadless Area Conservation Rule should remain effective.

Hopefully,

CommentID: RLC-20260904-W5VTDL

REQUEST: identify, by unit, year, and acreage, every fuels, insect and disease, or hazard-tree project the Forest Service declined to propose or could not approve solely because of 294.12 or 294.13, and explain why 294.13(b)(1)(ii) was insufficient. The notice has no such list. Without one, the need is unsupported.

2. THE MEANS ARE NOT MATCHED TO THE STATED END

The notice reports 9.8 million acres of wildland-urban interface overlap and 18.2 million acres where plans would permit permanent roads. It removes the prohibition across all of it, not the acreage where the stated risk is documented. A rescission scoped to documented risk would serve the stated purpose. This one reaches further.

The record also points elsewhere for cause. Acres treated for wildfire risk fell from roughly 4.1 million in FY2024 to roughly 2.6 million in FY2025 -- 35 percent, with the rule unchanged in both years -- amid the loss of roughly 5,000 staff. Rescission adds no crews and no appropriations. If the constraint is workforce, a rule change cannot relieve it.

3. THE EXECUTIVE ORDERS ARE NARROWER THAN THE USE MADE OF THEM

E.O. 14153 section 3(c), 90 Fed. Reg. 8351, directs the Secretary to address the 2023 Alaska Roadless Rule and reinstate the 2020 Alaska rule. It is Alaska-specific on its face and cannot support a nationwide rescission reaching some 45 million acres -- 58.5 million less the retained Idaho and Colorado rules (9.3M and 4.2M).

More fundamentally, each cited order states that it creates no right or benefit enforceable at law and is to be implemented consistent with applicable law. That clause cuts both ways: it defeats a challenge to the orders, and equally defeats any suggestion that the Department was compelled. Authority over National Forest System lands is delegated by statute. An order may direct how the Secretary exercises discretion; it cannot enlarge it or substitute for the findings NFMA and MUSYA require. See also 16 U.S.C. 531(a): multiple use does not mean the combination of uses giving "the greatest dollar return or the greatest unit output."

4. THE DEPARTMENT ALREADY BUILT THE ALTERNATIVE

Subparts C and D answer the notice's own premise. Idaho's management themes and Colorado's upper-tier structure deliver graduated, place-based flexibility -- community protection zone treatment, temporary road authority -- inside a retained roadless rule. Both have stood since 2008 and 2012, and are being kept. Explain why that model cannot be extended, and why targeted amendments to 294.12 and 294.13, drawn from 294.42-.43, were not analyzed.

5. REQUESTS FOR THE RECORD

a. State whether ESA section 7 consultation on this rescission has been initiated, with whom, and when. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), set aside the identical 2005 repeal for failing to consult before effecting it. This notice mentions the Act once, in a savings clause.

b. Publish the models behind the harvest, revenue, and recreation figures, or omit them from any final rule; data relied on must be exposed to comment. State the "potentially affected environment" acreage and reconcile it to 58.5M, or another figure as apporpirate.

c. Place the ANILCA section 810 evaluation, notice, hearing, and findings inside the EIS, as 16 U.S.C. 3120(b) requires.

d. Add monitoring, reporting on acres roaded, and a scheduled reassessment -- rescission is reversible on paper; installed roads are virtually irreversible.

Thank you for your service to the People of the United States.

The rule states that 24% of affected roadless areas overlap the wildland-urban interface. Roughly 76% do not. Rescission would expand management opportunity on about 4.8 million acres, a gain the rule itself calls modest. Cohen (2000) and Calkin et al. (2014) show structure ignition is governed by the home ignition zone, not stands kilometers upslope. An alternative scoped to the interface would capture nearly all that benefit at a fraction of the ecological cost.

3. The forest plan backstop assumption is not supported.

The rule identifies 18.2 million acres where plans already permit permanent roads and only the 2001 Rule prohibits them, measuring how much protection rests on the rule, not on plans. Where a plan is silent, rescission removes the only constraint, and plans are amendable by the same officials proposing the projects. The rule concedes amendments could expand effects beyond those analyzed, then treats that foreseeable consequence as outside scope. Under NEPA it is not.

4. The economics do not close.

Under the Department's own upper bound, harvesting all newly operable acreage annually yields $4.6 to $10.6 million per year to industry, against roughly $6.1 million in lost recreation benefit, a DEIS finding that timber revenue would not cover building and maintaining new project roads, and a $6.9 billion road maintenance backlog. The Final EIS should present net fiscal effect inclusive of maintenance liability.

5. On access, the diagnosis is misplaced.

The 2001 Rule closes nothing and does not prohibit fire suppression, prescribed fire, non-commercial thinning requiring no new road, or motorized use of existing routes. Access lost over two decades has gone to travel management and deferred maintenance on the existing road system.

6. Requested alternative.

Retain 36 CFR 294 Subpart B and amend it: (a) authorize treatment and roads within the wildland-urban interface or 1.5 miles of an at-risk community, temporary roads only absent Regional Forester approval, restored within three years; (b) delegate 294.13(b)(1) determinations to forest supervisors with national guidance and decision timelines; (c) require road-density neutrality, offsetting each new permanent mile with one decommissioned on the same unit; (d) use the Idaho (2008) and Colorado (2012) rules as the model for place-based variation through petitions under 5 U.S.C. 553(e), which already show flexibility does not require repeal; (e) carry forward co-stewardship concepts raised in Tribal consultation; (f) require annual reporting of miles built, miles decommissioned, and acres treated.

7. Procedural requests.

Extend the comment period to 90 days; thirty is well below the 60-90 customary for a 333-page Draft EIS. Complete ESA Section 7 consultation before a final rule, given the preliminary determination of likely adverse effect to 327 listed species and 71 critical habitats. Complete ANILCA Section 810 findings before the decision. Address reliance interests built over 25 years by outfitters, state agencies, and community wildfire planning.

Virginia's roughly 394,000 roadless acres on the George Washington and Jefferson National Forests are not fire-deficit western systems. They matter for interior forest birds, wild brook trout, and the world's richest plethodontid salamander fauna. The Final EIS should analyze Eastern Region roadless areas separately.

Thank you for considering these comments.

Ryan Pranschke
Wildlife & Landscape Photographer and Conservationist
Aldie, Virginia

have burned at rates similar to or lower than roaded forests over the past decade. Roads themselves are a leading cause of human-ignited wildfires. If wildfire risk is the real concern, targeted, science-based fuel treatments — not a blanket repeal of protections on tens of millions of acres — is the appropriate tool.
4. This is a wholesale repeal of a rule the public strongly supports.
The 2001 Roadless Rule was the product of one of the most extensive public engagement processes in federal rulemaking history, with the overwhelming majority of the more than 1.6 million comments received in support of it. Comments submitted during the 2025 notice of intent to repeal likewise overwhelmingly opposed rescission. Replacing a durable, science-based national standard with ad hoc, forest-by-forest planning removes a consistent baseline of protection and instead exposes these lands to inconsistent management and the political pressures of the moment.
5. “Local flexibility” does not require full repeal.
Land managers already have mechanisms to address genuine local needs — including existing exceptions in the 2001 rule itself for activities like fire risk reduction. A full national rescission goes far beyond what is needed to address legitimate local circumstances, and instead removes durable protection for wild, undeveloped forest land across 38 states.
For these reasons, I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule in full.

The Boise National Forest, which starts not far from where I live, is already protected under Idaho’s own state-specific roadless rule. While I certainly appreciate this, our country’s beautiful forests and public lands deserve federal, not just state, protection.

2. Wildfire Risk
Despite USDA’s claim that rescission will reduce fire risk, the science says otherwise. Nearly 85% of wildfires are human-caused (National Park Service), and most start within a few hundred feet of roads (Short, 2026, Forest Service Research Data Archive). New research finds wildfires are four times more likely to start in roaded areas than roadless ones (Aplet et al., 2026, Fire Ecology; Wilderness Society, 2025). The current rule already permits road-building and small-tree logging for fire mitigation, so full rescission isn’t necessary for safety — especially when the administration has simultaneously eliminated wildfire suppression funding.

3. Clean Water
National forests supply drinking water to 60 million Americans, including over 1 million Oregonians like me who depend on Mt. Hood National Forest. Forested watersheds filter and store water more effectively than developed land (Caldwell et al., 2023, Science of the Total Environment). Roads undermine this natural filtration and threaten safe drinking water access.

4. Habitat Protection
Only 3% of the world’s ecosystems remain intact. Combined with climate change and development, rescinding the Roadless Rule would jeopardize some of the last large, undeveloped lands in the U.S. — land we can’t afford to lose.

5. Economic Impacts
The Forest Service manages more roads than any federal agency and already can’t maintain them, facing an $8.6 billion maintenance backlog as of 2023 (USFS). The Roadless Rule itself acknowledges this maintenance shortfall, which has worsened as budgets shrink — the FY26 budget cut agency funding over 60% and zeroed out Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale (wildfire risk, state control) rings hollow without funding to match. Meanwhile, forest revenue now comes primarily from recreation, not logging — more roads would degrade recreation and hurt revenue.

6. Public Opinion
The Roadless Rule is the most popular rule in USDA history: it drew 1.6 million public comments in 2001, over 95% in support. Tribes, including the Confederated Tribes of Warm Springs (whose ceded lands and reservation border Mt. Hood, Deschutes, and Willamette National Forests), strongly support the rule as essential to ecosystem health and view rescission as a threat to Tribal sovereignty and cultural survival. A Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, with only 16% opposed (https://www.pew.org/en/research-and-analysis/articles/2019/03/13/americans-support-roadless-rule-to-protect-remarkable-forests) The USDA calls itself “The People’s Department,” yet rescission would ignore the will of the American people.

For all these reasons, I strongly oppose rescinding the 2001 Roadless Rule. I ask the agency to:

1. Guarantee no watersheds will be negatively affected by rescission
2. Develop and share a detailed plan addressing the existing road maintenance backlog
3. Commit to full transparency, including how public comments were considered

Please follow Alternative 1 (No Action), leave the Roadless Rule intact, and protect America’s remaining roadless areas for current and future generations. Thank you for considering these comments.

The proposal admits its own analysis is incomplete. Under Summary of Potential Impacts, the Department says that later land management plan amendments and revisions could increase the area where timber harvest and road construction would be allowed, and could produce impacts beyond what is summarized in the analysis. It then sets those changes aside as outside the scope. That is the heart of my objection. Rescission does not approve any project on its own. It removes the floor, and the proposal states plainly that the new floor is whatever each forest plan says at the time, and that plans can be amended. An analysis that leaves out the foreseeable results of the action is not a good enough basis for taking it.

The economics in the proposal do not support the stated purpose. The Department estimates $5.2 to $11.4 million a year in revenue to the Treasury and Forest Service, and $4.6 to $10.6 million a year to the timber industry. That is about $22 million a year at the top end. The same document cites a $6.9 billion deferred maintenance backlog on roads and bridges, and about $6.1 million a year in lost economic benefit to recreationists. Even using the most favorable numbers in the proposal, the yearly upside comes to roughly three tenths of one percent of a road maintenance bill the agency already cannot pay. Adding road miles on top of that backlog is not deregulation. It is a cost pushed down the road. Anybody who runs equipment for a living knows what an unmaintained road turns into, and what it does to the drainage below it.

The wildfire argument does not match what I see in the field. The proposal treats the 2001 rule as the thing limiting mechanical thinning and fire control options. In this region the real limits are crew availability, contracting capacity, appropriated funding, burn windows, and the fact that there is almost no market for small diameter material. Making 4.8 million acres eligible, which is 16 percent of the forested area in the potentially affected roadless areas, does not create crews or contracts or mills. The proposal concedes as much when it says harvest across all of it is unlikely because of budgets, operability limits, and market conditions. The proposal also acknowledges that more public access can raise the chance of human caused ignitions. In a county where roadside starts are routine, that is not a small thing to trade away.

The small business certification does not line up with the rest of the document. The Department certifies that the rule will not have a significant economic impact on a substantial number of small entities. Elsewhere the same document says additional annual impacts could exceed $100 million and that recreation and tourism could see trade offs. Recreation dependent small businesses in the Methow Valley and across the eastern Cascades are exactly the kind of small entities that certification is supposed to account for. I think it should be withdrawn and a full analysis prepared.

What I am asking for is that the Department choose the No Action alternative and keep 36 CFR part 294, Subpart B as it stands. If certain roadless areas genuinely need more flexibility for community protection in the wildland urban interface, the existing petition process under 5 U.S.C. 553(e) and 7 CFR 1.28 is still available. That is the process that produced the Idaho and Colorado rules. Targeted exceptions for specific places are defensible. Rescinding the whole thing nationwide to get them is not.

I will add that the proposal itself reports that most of the Tribal governments consulted oppose the rescission, and that the earlier comment period drew more than 220,000 letters on behalf of over 625,000 individuals. That record should count for something.

Respectfully,

Chris Moore - Owner, HingePoint Tree Service, Inc. Winthrop, Washington

exceptions for fuel reduction. A full, nationwide rescission seems like a much bigger swing than the stated problem requires. As an aside, over 220,000 comment letters already came in on the 2025 notice, and independent review found about 99.8% opposed rescinding the rule. A February 2026 Pew survey found 76% of voters, across parties, want to keep it. That's a pretty clear signal that the people heavily oppose this change. Finally, my personal love for these lands won’t let me sit by and watch them be destroyed. I spent many a night of my youth with my dad or my boy scout troop in the national forests of this beautiful state. Be it camping trips, or hiking I love being on these lands, and having roads cut through them hurts me, especially since I can no longer do those things with the parties I mentioned.
For these reasons, I'm asking USDA to withdraw this proposal and keep the 2001 Roadless Rule in place, addressing any real, localized wildfire or access needs through the existing exception process instead of a blanket repeal.
Thank you for considering my comment.

The agency's own document acknowledges what roads do to habitat more broadly. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is cited and then set down. No projection across the 40.1 million acres of potentially affected environment follows anywhere in the document. I ask that the agency apply that cited fragmentation range to the full 40.1 million acres before any final rule issues.

Water is not abstract to me either. I live in Oklahoma, where fracking, runoff, drilling, and oil spills have polluted lakes, rivers, and streams. I believe groundwater is already being ruined here. Across the Southern region, which includes Oklahoma, 378 municipal water intakes sit in watersheds containing affected roadless areas. Roads produce sediment. The agency knows this. What happens to those intakes when the rule protecting these watersheds is gone deserves a direct answer from the agency.

Our public land is our heritage for the kids. Children must be able to see their native land in its native habitat, not just cities. I think about what is being handed down and what is being taken away without any public meeting, without any comment period to undo rules that took more than 600 public meetings and 1.6 million comments to write. Why are there no comments and meetings before undoing the old rules? The agency's own biological record makes the stakes plain. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. The agency anticipates harm and names no mitigation. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule.

I know what it looks like when governments find money for the wrong things. Oklahoma has potholes everywhere, bridges falling apart, roads being patched in cycles that go on for years, and the agency is already billions behind on maintaining the roads it has. Building new roads into country that has none, when existing infrastructure is collapsing, follows the same logic I watch fail here at home. Irreplaceable public land ruined forever by decisions made without the people who depend on it. We the people have to have a say. The agency has not explained why this decision required none of the public process that created the rule it rescinds. That question deserves a direct answer before this goes any further.

Sincerely, Berit MorphewOklahoma City, Oklahoma

The proposal's economic analysis carries a contradiction the agency has not resolved. 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 flexibility analysis reaches its no-impact conclusion by averaging the loss across every small firm in the sector nationally, not the guides and permit holders who actually operate in the areas that would be affected. That method conceals the very harm the statute requires the agency to assess. The certification should be withdrawn and replaced with an analysis focused on the small businesses actually holding permits in the potentially affected roadless areas.

The agency invited public reliance interests and then set them aside. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My own decision to seek out roadless forest for bird identification and for relief from the city rests on a reasonable expectation that those places remain intact. Under the legal standards governing agency change of course, that kind of interest is precisely what must be identified and weighed before the rule is undone. I am stating mine here, and I ask that the agency treat the reliance interests described in comments it receives as part of the balancing it is required to perform.

I have lived through massive destruction and evacuations during fire season, and the agency's own fire data makes the proposal's wildfire rationale harder to accept, not easier. 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. The effects analysis itself acknowledges that new road access could increase the number and frequency of wildfires. Having seen what fire does to communities and landscapes, I cannot read those numbers and accept that opening these areas to roads reduces risk in any net sense. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access and place that figure alongside whatever reduction in hazard it claims, so that the tradeoff is visible.

Finally, the agency cites a fragmentation finding and then stops short of applying it. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the record; no projection across the 40.1 million acres of potentially affected environment follows from it. A cited number that is never applied is not analysis. The agency should apply that fragmentation range to the 40.1 million acres at stake and show what the result means for the rule's overall environmental effects determination.

Sincerely,
Brandon A.
Tucson, AZ

The proposal also overstates the constraint it claims to relieve. The 2001 rule does not prohibit the fuel-reduction and forest-health treatments the Secretary describes; it restricts road construction, reconstruction, and commercial timber harvest, and it contains existing exceptions for such work. Mechanical treatment and prescribed fire near communities are not what this rescission unlocks. What it unlocks, by the agency's own estimate, is permanent road construction across as much as 18.2 million acres and temporary roads across another 11.3 million, alongside a projected 5–10 percent increase in national timber harvest. The stated rationale and the actual effect are not the same thing.

The "one-size-fits-all" characterization is also misleading. The 2001 rule already accommodates local variation: Idaho and Colorado operate under negotiated state-specific rules, expressly unaffected by this proposal. The mechanism for tailored, locally responsive management already exists. Rescinding the national backstop entirely does not add flexibility; it removes a floor.

These are functioning watersheds, intact wildlife habitat, and the backcountry that sustains hunting, fishing, and recreation economies across 37 states. Roads fragment habitat, impede wildlife movement, and degrade water quality — effects the draft EIS acknowledges and then subordinates to a wildfire rationale its own cited science undercuts. The 2001 rule was finalized after some 600 public meetings and 1.6 million comments, and the notice of intent for this rescission drew more than 600,000 comments, the overwhelming majority opposed. That record reflects a durable public judgment, not a regulatory burden to be cleared.

I have spent years hiking and hunting the backcountry of the George Washington National Forest, walking miles from the nearest road into its inventoried roadless areas. That distance is the point. Unlike the St. Mary's and Ramsey's Draft Wilderness Areas, which Congress protected by statute in 1984, these roadless areas carry no Wilderness designation. The 2001 rule is the only thing standing between them and the road network. What makes them worth the walk—intact headwater streams, unfragmented habitat, native trout water, game that has room to move—exists precisely because no road reaches them. A road does not lightly modify that character; it ends it. You cannot build a logging road into a roadless drainage and preserve what made it roadless. And by the Forest Service's own ignition data, putting a road there raises the fire risk rather than lowering it. These are not places that need saving from a lack of management. They need the one protection that has kept them whole for twenty-five years.

I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule.

– Timothy C. Truxell