2001 Roadless Rule Revision

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you.

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

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

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

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

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

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

Respectfully,

CommentID: RLC-20260909-YP9YL1

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

Wildfire. Rescission has been justified partly on wildfire grounds, but the DEIS's own data
points the other way. Table 21 (Vol. I, p. 90) reports a human-caused ignition density of 22.4
fires per million acres per year on other National Forest lands, compared with 3.0 in potentially
affected roadless areas and 2.7 in wilderness — roughly four times higher outside roadless
areas, driven mostly by human-caused ignitions (Vol. I, p. 89). The DEIS also states that
human-caused ignitions increase with proximity to roads (Vol. I, p. 90), directly linking road
access to elevated fire risk. USDA's own analysis therefore undermines the argument that
removing nationwide road-building restrictions would reduce wildfire risk. I ask USDA to
reconcile this contradiction before finalizing its decision.

Wildlife and biodiversity. The DEIS concludes that road construction, reconstruction, and
timber harvest cause long-term adverse effects on biodiversity through habitat fragmentation,
lost connectivity, negative edge effects, and human disturbance, and that these impacts
would be most frequent and widespread under Alternative 2 and least under Alternative 1
(Vol. I, p. 157). The agency's own preliminary biological assessments reached “may affect,
likely to adversely affect” determinations for 327 ESA-listed species and 71 designated critical
habitats under Alternative 2 (Vol. I, p. 161–162). Alternative 1 remains available and avoids
these impacts entirely. When an agency's proposed action is the one its own analysis
identifies as most harmful to listed species and critical habitat, and a less-harmful alternative
is on the table, that is a contradiction USDA needs to explain, not proceed past.
These are not isolated gaps — they are examples of a broader pattern in which the DEIS's
findings do not support the proposed action. I ask USDA to reject Alternative 2, reconcile
these contradictions in its own record, and adopt Alternative 1, keeping the 2001 Roadless
Rule fully in place nationwide.

Thank you for considering this comment.

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

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

The Draft EIS states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected Inventories Roadless Areas compared to other NFS lands" and acknowledges that "if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads" (Comparison of Alternatives, pp. 20-36). This ignition-density comparison is uncited, and the agency's own admission that road access correlates with human-caused ignition is never reconciled with any fire-risk rationale for expanding road access under Alternatives 2 and 3. A peer-reviewed three-decade national forest fire record found ignition density near roads reaching 7.99 fires/1000 ha versus 1.97 fires/1000 ha in Inventoried Roadless Areas — evidence squarely on point that the agency should engage. Under Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998), and Sierra Club v. Marsh, 872 F.2d 497 (1st Cir. 1989), the agency must confront contrary evidence rather than ignore it. I request the agency cite its ignition-density source and add explicit reconciliation analysis before finalizing this document.

In addition, Forest Service Chief Tom Schultz recently testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area.
The argument that rescission is needed for more fuels management and is false.

The current roadless rules allows for fuels management under certain circumstances, including to reduce fuel loads in the wildland-urban interface and to improve habitat for threatened, endangered, or sensitive species. This already has been done in multiple roadless areas in the Tahoe Basin. The Forest Service’s own research shows that roadless areas have historically received a larger proportion of fuels management projects than other areas of the National Forest System. (Sean P. Healy, Long-term forest health implications of roadlessness, Environmental Research Letters. September 2020. https://doi.org/10.1088/1748-9326/aba031).

As a property owner and business owner near wildfire-prone areas in two parts of California, your decision impacts me personally and professionally if a fire starts off a newly built road because Alternative 2 or 3 was approved. I could lose my home and my business. Please choose Alternative 1. Thank you for considering my comment.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Thank you.

Wildfire. Rescission has been justified partly on wildfire grounds, but the DEIS's own data
points the other way. Table 21 (Vol. I, p. 90) reports a human-caused ignition density of 22.4
fires per million acres per year on other National Forest lands, compared with 3.0 in potentially
affected roadless areas and 2.7 in wilderness — roughly four times higher outside roadless
areas, driven mostly by human-caused ignitions (Vol. I, p. 89). The DEIS also states that
human-caused ignitions increase with proximity to roads (Vol. I, p. 90), directly linking road
access to elevated fire risk. USDA's own analysis therefore undermines the argument that
removing nationwide road-building restrictions would reduce wildfire risk. I ask USDA to
reconcile this contradiction before finalizing its decision.

Wildlife and biodiversity. The DEIS concludes that road construction, reconstruction, and
timber harvest cause long-term adverse effects on biodiversity through habitat fragmentation,
lost connectivity, negative edge effects, and human disturbance, and that these impacts
would be most frequent and widespread under Alternative 2 and least under Alternative 1
(Vol. I, p. 157). The agency's own preliminary biological assessments reached “may affect,
likely to adversely affect” determinations for 327 ESA-listed species and 71 designated critical
habitats under Alternative 2 (Vol. I, p. 161–162). Alternative 1 remains available and avoids
these impacts entirely. When an agency's proposed action is the one its own analysis
identifies as most harmful to listed species and critical habitat, and a less-harmful alternative
is on the table, that is a contradiction USDA needs to explain, not proceed past.
These are not isolated gaps — they are examples of a broader pattern in which the DEIS's
findings do not support the proposed action. I ask USDA to reject Alternative 2, reconcile
these contradictions in its own record, and adopt Alternative 1, keeping the 2001 Roadless
Rule fully in place nationwide.

Thank you for considering this comment.

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

The Draft EIS states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected Inventories Roadless Areas compared to other NFS lands" and acknowledges that "if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads" (Comparison of Alternatives, pp. 20-36). This ignition-density comparison is uncited, and the agency's own admission that road access correlates with human-caused ignition is never reconciled with any fire-risk rationale for expanding road access under Alternatives 2 and 3. A peer-reviewed three-decade national forest fire record found ignition density near roads reaching 7.99 fires/1000 ha versus 1.97 fires/1000 ha in Inventoried Roadless Areas — evidence squarely on point that the agency should engage. Under Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998), and Sierra Club v. Marsh, 872 F.2d 497 (1st Cir. 1989), the agency must confront contrary evidence rather than ignore it. I request the agency cite its ignition-density source and add explicit reconciliation analysis before finalizing this document.

In addition, Forest Service Chief Tom Schultz recently testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area.
The argument that rescission is needed for more fuels management and is false.

The current roadless rules allows for fuels management under certain circumstances, including to reduce fuel loads in the wildland-urban interface and to improve habitat for threatened, endangered, or sensitive species. This already has been done in multiple roadless areas in the Tahoe Basin. The Forest Service’s own research shows that roadless areas have historically received a larger proportion of fuels management projects than other areas of the National Forest System. (Sean P. Healy, Long-term forest health implications of roadlessness, Environmental Research Letters. September 2020. https://doi.org/10.1088/1748-9326/aba031).

As a property owner and business owner near wildfire-prone areas in two parts of California, your decision impacts me personally and professionally if a fire starts off a newly built road because Alternative 2 or 3 was approved. I could lose my home and my business. Please choose Alternative 1. Thank you for considering my comment.

1. THE AGENCY'S OWN ECONOMIC ANALYSIS DOES NOT SUPPORT THE ACTION. USFS projects 4.8 million acres opened to timber production, a maximum 5-10% harvest increase, and $5.2-$11.4 million in annual revenue. It puts new dirt road construction at $80,000-$100,000 per mile against a $6.9 billion maintenance backlog, so the entire projected annual revenue is consumed by roughly 52-142 miles of road. The agency concedes gains will be limited by road costs and the backlog, and leaves the wildfire benefit unquantified. An action cannot be justified where the quantified record shows net cost and the leading benefit is asserted without analysis. I request the final rule quantify that benefit or explain how the action stands without it.

2. THE DEIS DECLINES TO QUANTIFY ROAD MILEAGE, THE ACTION'S PRIMARY PHYSICAL EFFECT. The agency states it is not reasonable to anticipate specific mileage changes. Sediment delivery, fragmentation, ignition density, and invasive introduction all scale with mileage; an analysis that will not estimate mileage cannot analyze them. I request supplemental analysis presenting low, expected, and high mileage scenarios with effects modeled for each.

3. THE WILDFIRE RATIONALE IS CONTRADICTED BY THE AGENCY'S OWN RESEARCH. The 2001 rule already permits prescribed fire, habitat restoration, many small-diameter treatments, and emergency access. Forest Service research has found fuel treatments occur more frequently per unit area in roadless lands than in roaded forests. I request the final rule identify, with acreage, which treatments the 2001 rule prohibits and its exemptions do not reach.

4. ROADS INCREASE IGNITION RISK IN THE LANDS LEAST LIKELY TO IGNITE. A 2026 peer-reviewed national study found ignition density within ~164 feet of roads to be about four times that within inventoried roadless areas. Roads are also the primary corridor for invasive annual grasses, which create continuous fine fuel and shorten fire return intervals. I request the DEIS quantify added ignitions and invasive-driven fuel conversion against any claimed treatment benefit.

5. TREATMENT EFFECTIVENESS DEPENDS ON LOCATION, NOT ACCESS. Structure survival is determined principally by the home ignition zone. Roadless areas are by definition remote from communities, and treatments decay within 5-15 years, requiring reentry. I request a cost-per-acre and cost-per-structure-protected comparison against equivalent wildland-urban interface treatment and home hardening.

6. WATERSHED AND CUMULATIVE EFFECTS ARE INADEQUATELY ANALYZED. Roads are the dominant anthropogenic sediment source in managed forest watersheds, and roadless areas sit on steeper terrain carrying above-average erosion and failure risk per mile. Crossings sized to historical flows are increasingly undersized. These lands are thermal refugia for native salmonids, and their value rises as lower reaches warm. I request cumulative assessment alongside concurrent changes to ESA implementation, monument boundaries, and environmental review procedures.

7. NO REASONABLE RANGE OF ALTERNATIVES WAS CONSIDERED. Full rescission versus no action is not a range. The Idaho and Colorado Roadless Rules show state-specific flexibility is achievable through the existing petition process without national rescission. I request analysis of at minimum: treatment authority near the wildland-urban interface using temporary roads with mandatory decommissioning; expanded use of the state petition process; and a treatment-authority alternative conveying no commercial harvest or mineral access. The last is diagnostic of the rule's purpose.

8. REVERSING A 25-YEAR RULE REQUIRES HEIGHTENED JUSTIFICATION. The 2001 rule rested on extensive findings on maintenance capacity, sediment, and fragmentation. Those findings have not weakened; the backlog cited here is larger now. The proposal explains what changed in policy preference, not in the evidence. The 2025 scoping drew over 220,000 comments, roughly 99% opposed.

I request withdrawal of the proposed rule, or a supplemental DEIS addressing items 1-8, and reopening of the comment period for no fewer than 90 days with hearings in each affected state.

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

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

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

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

The contradiction deepens when the document's own data are examined directly. At Table 14, the agency acknowledges that "Insect and disease risk is generally higher in western regions; in western forests, the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas." The agency uses insect and disease pressure as a primary driver of this proposal, yet its own figures show that already-roaded, already-accessible non-designated National Forest System lands carry greater risk. I want the agency to explain, in the final rule, why rescinding protections for inventoried roadless areas is the preferred remedy when the risk is demonstrably higher on lands where active management is already permitted, and to analyze whether directing increased management to those non-designated lands would achieve the same objectives at lower ecological cost.

The range of alternatives the agency chose to study also warrants scrutiny. The document states that "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need," as noted in the Alternatives Considered but Eliminated from Detailed Study section. That rationale is circular: a purpose and need written to require deregulation will, by definition, exclude any alternative that retains meaningful protection. The agency should provide a non-circular justification, grounded in its actual fire and forest health objectives, for why an approach allowing temporary-road-based hazardous fuel treatment and selective harvest without permanent road construction cannot meet those objectives, and should consider adding such an alternative to the range of detailed study in the final environmental impact statement.

It is easy to see the impact of roads and tree clearing on shared water sources in the Augusta and West Augusta regions, where protected waters and farmland with agricultural runoff are already under pressure. The opportunity to experience wildness in undeveloped spaces that can only be reached on foot is something I bring my grandchildren to these forests for, and it is not possible in a highly developed landscape. The agency should address each of these points fully before this rule proceeds.

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.

Sustainable forestry and sustainable tourism could be the two main drivers here in the Tongass.
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.

Gordon Chew

I do not want my tax dollars as part of public monies to be used to build roads to subsidize private interests such as mining and logging. I dont want rich people and big corporations to profit off our public lands. For me the riches of our public lands is the intact, unfragmented habitat of temperate rainforest that supports healthy populations of mammals, fish, pollinators, and invertebrates. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity.

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.

Restoring habitat especially stream beds that has been impacted by roads. Maintaining trails
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.

Mary Barrett

I do not want my tax dollars as part of public monies to be used to build roads to subsidize private interests such as mining and logging. I dont want rich people and big corporations to profit off our public lands. For me the riches of our public lands is the intact, unfragmented habitat of temperate rainforest that supports healthy populations of mammals, fish, pollinators, and invertebrates. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity.

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.

Restoring habitat especially stream beds that has been impacted by roads. Maintaining trails
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.

Mary Barrett

I do not want my tax dollars as part of public monies to be used to build roads to subsidize private interests such as mining and logging. I dont want rich people and big corporations to profit off our public lands. For me the riches of our public lands is the intact, unfragmented habitat of temperate rainforest that supports healthy populations of mammals, fish, pollinators, and invertebrates. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity.

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.

Restoring habitat especially stream beds that has been impacted by roads. Maintaining trails
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.

Mary Barrett

I do not want my tax dollars as part of public monies to be used to build roads to subsidize private interests such as mining and logging. I dont want rich people and big corporations to profit off our public lands. For me the riches of our public lands is the intact, unfragmented habitat of temperate rainforest that supports healthy populations of mammals, fish, pollinators, and invertebrates. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity.

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.

Restoring habitat especially stream beds that has been impacted by roads. Maintaining trails
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.

Mary Barrett

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.

Invest in protecting the wild landscapes and wildlife habitat.
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.

Alden Whittaker

Alaska native communities by undermining subsistence practices. The DEIS states “Timber harvest and road construction can degrade these resources, undermining subsistence practices, economic development, and Tribal restoration goals.” The DEIS also recognizes “Subsistence use of fish and wildlife has been and continues to be an important component of the economies of Southeast Alaska communities. Removing the Roadless Rule could have impacts on the amount and distribution of subsistence resources”. But these impacts were not properly analyzed and addressed in the DEIS which stated “Roadless Rule (85 FR 68692) voluntarily considered a forest-wide evaluation in accordance with ANILCA Section 810. ANILCA subsistence hearings were conducted for the DEIS and proposed rule, consistent with Section 810 in 2019”. Neither during these hearings in 2019 nor in the DEIS was Executive Order 12898 explicitly mentioned or considered as it pertains to the legality of this decision. Executive Order 12898 requires federal agencies to identify and address disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority and low-income populations. Nowhere in the DEIS are the potential impacts to subsistence communities quantified and no alternatives are presented to minimize these impacts. Stripping protections from Inventoried Roadless Areas and opening them up to large scale resource extraction would have major consequences for Alaksa fish and wildlife resources with associated degradation to the livelihood of subsistence communities. These communities are particularly vulnerable to social and environmental change and are disproportionately impacted by the effects of climate change which threatens their food security and way of life (Brinkman et al. 2016; Herman-Mercer et al. 2019; Savo et al. 2016). For these reasons I urge the USDA Forest Service to consider the impacts the revocation of the 2001 Roadless Rule would have on Alaska native communities.
Why it’s important to me:
As a scientist, wildland firefighter, and nature lover forest are central to my way of life. Some of my most fond memories come from times exploring roadless areas while backpacking, backcountry skiing, and hiking. I know the importance of being able to find solitude and peace in untouched forests. So, I urge you to maintain the roadless rule and protect these forests, as we all have a right to clean air, fresh water, and the chance to sit under an ancient tree.
References:
Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-US national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(1), 8.
Brinkman, T. J., Hansen, W. D., Chapin, F. S., Kofinas, G., BurnSilver, S., & Rupp, T. S. (2016). Arctic communities perceive climate impacts on access as a critical challenge to availability of subsistence resources. Climatic Change, 139, 413-427.
Herman-Mercer, N. M., Laituri, M., Massey, M., Matkin, E., Toohey, R. C., Elder, K., ... & Mutter, E. (2019). Vulnerability of subsistence systems due to social and environmental change. Arctic, 72(3), 258-272.
Savo, V., Lepofsky, D., Benner, J. P., Kohfeld, K. E., Bailey, J., & Lertzman, K. (2016). Observations of climate change among subsistence-oriented communities around the world. Nature Climate Change, 6(5), 462-473.

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.

Invest in sustainable forest management, climate adaptation, and species habitat protection
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.

Madeline Baroli

Drinking water and watersheds. According to the Forest Service's own Forest to Faucets
analysis, there are more than 7,000 municipal water intakes within watersheds containing
potentially affected roadless areas, and approximately 24 million people outside Alaska use
water originating within potentially affected inventoried roadless areas (Vol. I, p. 121, Table
35). The DEIS further notes that nearly 5 million people in the Pacific Southwest alone receive
drinking water from municipal intakes within watersheds containing potentially affected
roadless areas (Vol. I, p. 121). National Forests function as watersheds regardless of whether
the people downstream ever set foot on them, and increased road construction and timber
harvest under Alternative 2 introduce long-term risk to water quality that this analysis does not
appear to weigh against the scale of the population served. I ask USDA to more fully account
for these downstream risks before proceeding with rescission.

Tribal rights and Tribal opposition. The DEIS documents 64 requests for Tribal
consultation, with 29 consultations held and five more scheduled at the time the document
was prepared (Vol. I, p. 9). Later in the document, USDA itself describes “clear and consistent
strong opposition” to Roadless Rule rescission from Tribal responses, consultation requests,
and consultation documentation, with few exceptions (Vol. I, p. 198). The agency also
acknowledges that additional timber harvest and road construction under Alternatives 2 and 3
are reasonably foreseeable and could have long-term negative effects on Tribal rights and
interests, including unauthorized public access, vandalism, or desecration of sacred sites and
traditional cultural places, and impacts to areas used for ceremony, prayer, hunting, fishing,
gathering, and other treaty-reserved activities (Vol. I, pp. 201–202). Given that USDA's own
record documents consistent, strong Tribal opposition and identifies these specific risks to
treaty rights and cultural resources, I ask USDA to explain how it weighed that opposition,
along with its federal trust responsibilities, in selecting full rescission as its proposed action
rather than the No Action Alternative.

Taken together, these two areas — water supplies relied on by millions of people, and treaty
rights and sacred sites Tribal nations have consistently opposed putting at risk — represent
exactly the kind of impacts the Roadless Rule was designed to prevent. I ask USDA to reject
Alternative 2 and adopt Alternative 1, keeping the 2001 Roadless Rule fully in place
nationwide.

Please oppose the Roadless Rule

Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.Speaking for Myself Tod Marvell.Hiking, swimming, and skiing in the White Mountain National Forest, and surrounding areas are the most enjoyable, invigorating, and peaceful activities that I partake of. Please protect our resources and watersheds as if our lives depend on them, as they surely do. Respectfully,Tod Marvell TodNew Hampshire

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

NEPA requires that cumulative impacts be assessed across connected resources, not within arbitrary administrative boundaries. Grouse Lakes and East Yuba in Tahoe National Forest — 21.0 miles apart, sharing 5 climate-threatened species and 23,648 acres of 2 ecosystem types — constitute a single climate refugia network that must be evaluated as such.

The connected roadless landscape between Grouse Lakes and East Yuba in Tahoe National Forest currently provides exactly the climate refugia function that the agency's own NOI identifies as at risk. 5 climate-threatened species occupy 2 undisturbed ecosystem types spanning ~23,648 acres. This is not theoretical refugia — it is functioning refugia that roadless protection maintains.

Without network-level analysis of the Grouse Lakes–East Yuba refugia corridor in Tahoe National Forest, the DEIS cannot accurately assess what rescission costs. The 5 shared climate-threatened species, the 2 shared ecosystem types, and the ~23,648 acres of connected refugia represent a climate adaptation resource that area-by-area review will systematically fail to account for.

"Seed dispersal over sufficiently large distances can maintain ecological resilience in fragmented landscapes and buffer changes in local-scale functional diversity. Otherwise, functional diversity is maintained by local processes, meaning that ecological resilience of isolated forest fragments depends strongly on land use type and intensity. Habitat fragmentation and local disturbances jointly operate on ecological resilience at different scales. Forest fragments acting as intermediate stepping stones in the transfer of seeds maintained functional diversity across the landscape."
— Diversity and Distributions (Wiley), 2016

Failure to Substantively Respond to Content of Majority-Opposition Comments

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.

What the Roadless Rule has preserved over the past two-plus decades can't be rebuilt once it's gone. Please don't rescind it.

Yours sincerely,

CommentID: RLC-20260907-DCQ5KU

The agency eliminated from detailed study an alternative that would have maintained existing inventoried roadless area boundaries and prohibitions on permanent road construction while still permitting temporary road construction and timber harvest. The stated reason was that such an alternative was not responsive to the purpose and need. That rationale is circular. The purpose and need was written to require deregulation, so any alternative that retains meaningful protections is defined out of existence before analysis begins. The agency's own document confirms this at the Alternatives Considered but Eliminated from Detailed Study section: "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." The agency must explain, in non-circular terms, why an alternative structured around temporary-road-based hazardous fuel treatment and selective harvest cannot meet the stated fire and forest-health objectives, and must consider whether such an alternative belongs in the final EIS.

The agency's own recreation analysis makes the stakes concrete for people like me. The document states at Table 41 that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." These are the conditions that make wildlife watching and photography meaningful, and that draw my family and friends to these forests year after year. The Social and Economic section documents substantial visitor expenditures tied to those settings, yet the purpose and need statement treats reduced regulatory burden as the governing value without weighing it against the risk of degrading the recreation character that sustains both visits and local economies. I want to know how many primitive and semi-primitive acres are projected to shift to roaded or more developed settings under the alternatives being analyzed, and what economic loss to recreation-dependent communities that shift would represent. The agency should provide that analysis in the final EIS.

Clean water, responsible land stewardship, and wild country my children can experience are not abstractions to me. They are what I am asking the agency to protect. I ask that the agency address both of these points in its response to public comment.

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

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

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

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

explain in the final EIS, in non-circular terms, why such an alternative cannot meet those objectives, and add it to the detailed study range.

The recreation impacts of this decision are also inadequately analyzed. The document's own Table 41 shows that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." These are the conditions that draw millions of visitors, support local economies, and sustain the kind of quiet, wildlife-rich camping I value in the Coronado. Yet the purpose and need statement does not weigh regulatory relief against the risk of degrading the recreation settings that produce those visits and that spending. The final EIS should analyze how many primitive and semi-primitive acres are projected to shift to roaded or more developed recreation opportunity spectrum classes under each alternative over a 20-year horizon, and should quantify the economic consequences for communities whose livelihoods depend on those settings. The agency should explain how it accounts for those losses.

The plan-reliance rationale that anchors alternatives 2 and 3 is also unsupported. The agency acknowledges in the Potentially Affected Environment section that "45 of those were revised between 2001 to 2011 when the status of the Roadless Rule was uncertain due to litigation. Therefore, these plans are less likely to have incorporated IRAs into their management areas or provided specific direction for these areas." The agency simultaneously offers land management plans as the primary safeguard replacing the roadless rule while conceding that most plans were built without adequate inventoried roadless area direction. That is not a safety net. The final EIS should identify which specific plan amendments or revisions would be required to provide equivalent protection in each affected region, and rescission should not be finalized before those updates are either in place or secured by a binding completion schedule.

The forests and lands, once destroyed, cannot be resurrected, and the accompanying loss of wildlife, waters, and biodiversity affects the natural circle of life which we humans are a part of. The wildflowers and birds I photograph at Mount Lemmon, and the places like the Grand Canyon, Ironwood Forest Monument, Imperial National Wildlife Refuge, and San Pedro Riparian National Conservation Area that I care about, deserve analysis that looks past short-term regulatory convenience and reckons honestly with what is at stake for future generations.

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.

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 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.

Analysis of 6.1 - Recreational activities effects on Mount Rainier White-tailed Ptarmigan (Lagopus leucura rainierensis) in Sawtooth must reference the species' T2 conservation status and the documented Slight or 1-10% pop. decline severity. The DEIS lacks scientific integrity without this baseline data.

"On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches)."
— Iranian Journal of Environmental Health Science & Engineering (PMC), 2013

Failure to Substantively Respond to Content of Majority-Opposition Comments

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.

People travel from all over the world to visit our country because of the incredible wild, beautiful spaces we are lucky to live among. We have protected these places for great reason and the vast majority of people in this country do not want to see this change, myself included. Twenty-plus years of protection shouldn't end here. Keep the Rule.

Sincerely,

CommentID: RLC-20260908-92QQJG

Road construction in the Wolfpen IRA reduces hunting visitation by degrading the qualities visitors seek — solitude, clean water, intact wildlife, backcountry character. Every lost visitor represents lost spending at local outfitters, guides, lodges, restaurants, and gas stations. The recreation economy near Daniel Boone National Forest depends on the roadless condition, and road construction undermines it directly.

The DEIS must analyze how road construction degrades the specific qualities that support hunting in the Wolfpen IRA — solitude, natural soundscape, water quality, wildlife habitat, and backcountry character — and assess the resulting decline in recreational quality and visitation. A generic statement about recreation impacts is insufficient; the analysis must address hunting conditions in this specific area.

"Using continental-scale sound models, we found that anthropogenic noise doubled background sound levels in 63% of U.S. protected area units and caused a 10-fold increase in 21% of protected area units. Elevated noise was also found in critical habitats of endangered species, with 14% experiencing a 10-fold increase in sound levels. Noise pollution in protected areas is closely linked with transportation, development, and extractive land use."
— Science (journal), 2017

Stale-Source Citation for FY2024 Recreation Visitation Statistic

The Draft EIS states that "the 193 million acres administered by the Forest Service received approximately 164 million recreation visits in FY2024" in its discussion of Economic Activity from Recreation in Roadless Areas, but this figure is cited to White et al. 2016 — a publication issued eight years before the reported data year. By definition, a 2016 report cannot be the source of FY2024 visitation data, and independent review confirms that White et al. 2016 is silent on this specific statistic. This is a foundational number underlying the entire recreation-economics discussion used to justify the rescission's benefits, yet it rests on no traceable source. Under Motor Vehicle Manufacturers Association v. State Farm, 463 U.S. 29 (1983), an agency must examine relevant data and articulate a rational basis for its conclusions, and agency NEPA procedures on scientific integrity and reasonably available materials require accurate sourcing. I request that the agency replace this citation with the actual current source, such as the National Visitor Use Monitoring program report, and audit related recreation statistics for the same error.

The Secretary should exercise the authority vested in the Department to preserve, not dissolve, the protections the Roadless Area Conservation legislation.
Best,
Valerie Fasimpaur

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

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

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

3. The treatment statistic does not establish causation

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

4. Reliance interests are unaddressed

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

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

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

6. The range of alternatives is inadequate

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

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

(b) a state and Tribal petition process

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

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

7. The process is inadequate

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

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

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

Respectfully submitted,
an anonymous member of the public

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

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

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

Thank you.

- Big Frog Addition (369 acres), Cherokee NF, Tennessee
- Bee Cove (3,025 acres), Sumter NF, South Carolina

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 money doesn't add up

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))

"By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, even with complete elimination of the Roadless Rule on the Tongass, the rule will not result in any new timber industry jobs on the Tongass over the next 100 years and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." (Complaint para. 54, Organized Village of Kake v. Vilsack, No. 1:20-cv-00011 (D. Alaska, filed Dec. 23, 2020), p. 23 of 50 (plaintiffs characterizing the agency's own 2020 FEIS at 3-55))

"Large trees accounted for 2.0 to 3.7% of all stems (DBH ≥ 1" or 2.54 cm) among five tree species; but held 33 to 46% of the total AGC stored by each species. Pooled across the five dominant species, large trees accounted for 3% of the 636,520 trees occurring on the inventory plots but stored 42% of the total AGC." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract (AGC is aboveground carbon; the study covers the six eastside national forests))

I ask that the agency reconcile the proposal with its own economic 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 on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

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,
Andrew Scales
Chattanooga, TN

1. THE AGENCY'S OWN ECONOMIC ANALYSIS DOES NOT SUPPORT THE ACTION. USFS projects 4.8 million acres opened to timber production, a maximum 5-10% harvest increase, and $5.2-$11.4 million in annual revenue. It puts new dirt road construction at $80,000-$100,000 per mile against a $6.9 billion maintenance backlog, so the entire projected annual revenue is consumed by roughly 52-142 miles of road. The agency concedes gains will be limited by road costs and the backlog, and leaves the wildfire benefit unquantified. An action cannot be justified where the quantified record shows net cost and the leading benefit is asserted without analysis. I request the final rule quantify that benefit or explain how the action stands without it.

2. THE DEIS DECLINES TO QUANTIFY ROAD MILEAGE, THE ACTION'S PRIMARY PHYSICAL EFFECT. The agency states it is not reasonable to anticipate specific mileage changes. Sediment delivery, fragmentation, ignition density, and invasive introduction all scale with mileage; an analysis that will not estimate mileage cannot analyze them. I request supplemental analysis presenting low, expected, and high mileage scenarios with effects modeled for each.

3. THE WILDFIRE RATIONALE IS CONTRADICTED BY THE AGENCY'S OWN RESEARCH. The 2001 rule already permits prescribed fire, habitat restoration, many small-diameter treatments, and emergency access. Forest Service research has found fuel treatments occur more frequently per unit area in roadless lands than in roaded forests. I request the final rule identify, with acreage, which treatments the 2001 rule prohibits and its exemptions do not reach.

4. ROADS INCREASE IGNITION RISK IN THE LANDS LEAST LIKELY TO IGNITE. A 2026 peer-reviewed national study found ignition density within ~164 feet of roads to be about four times that within inventoried roadless areas. Roads are also the primary corridor for invasive annual grasses, which create continuous fine fuel and shorten fire return intervals. I request the DEIS quantify added ignitions and invasive-driven fuel conversion against any claimed treatment benefit.

5. TREATMENT EFFECTIVENESS DEPENDS ON LOCATION, NOT ACCESS. Structure survival is determined principally by the home ignition zone. Roadless areas are by definition remote from communities, and treatments decay within 5-15 years, requiring reentry. I request a cost-per-acre and cost-per-structure-protected comparison against equivalent wildland-urban interface treatment and home hardening.

6. WATERSHED AND CUMULATIVE EFFECTS ARE INADEQUATELY ANALYZED. Roads are the dominant anthropogenic sediment source in managed forest watersheds, and roadless areas sit on steeper terrain carrying above-average erosion and failure risk per mile. Crossings sized to historical flows are increasingly undersized. These lands are thermal refugia for native salmonids, and their value rises as lower reaches warm. I request cumulative assessment alongside concurrent changes to ESA implementation, monument boundaries, and environmental review procedures.

7. NO REASONABLE RANGE OF ALTERNATIVES WAS CONSIDERED. Full rescission versus no action is not a range. The Idaho and Colorado Roadless Rules show state-specific flexibility is achievable through the existing petition process without national rescission. I request analysis of at minimum: treatment authority near the wildland-urban interface using temporary roads with mandatory decommissioning; expanded use of the state petition process; and a treatment-authority alternative conveying no commercial harvest or mineral access. The last is diagnostic of the rule's purpose.

8. REVERSING A 25-YEAR RULE REQUIRES HEIGHTENED JUSTIFICATION. The 2001 rule rested on extensive findings on maintenance capacity, sediment, and fragmentation. Those findings have not weakened; the backlog cited here is larger now. The proposal explains what changed in policy preference, not in the evidence. The 2025 scoping drew over 220,000 comments, roughly 99% opposed.

I request withdrawal of the proposed rule, or a supplemental DEIS addressing items 1-8, and reopening of the comment period for no fewer than 90 days with hearings in each affected state.

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.

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

The wildfire rationale offered for rescission collapses against the agency's 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 agency must explain on the record why the proposal departs from those findings, and 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 economic case for rescission is not made. 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 projected timber revenue to the Forest Service of $5.2 to $11.4 million a year, the Cost Benefit Analysis books 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. The agency must reconcile those numbers with its decision to expand a road system already carrying a $6.9 billion maintenance backlog.

The permitting burden justification also fails on the agency's own terms. The rule as written states 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)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection already exist. The agency should identify which specific burdens fall outside those exceptions and quantify them.

Finally, the small-business certification is unsupported. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. Spreading an aggregate loss across every small firm in the sector nationally, rather than assessing the permit holders actually operating in the affected areas, does not satisfy a rigorous regulatory flexibility analysis. The agency should withdraw the certification and assess the firms that actually hold permits in these areas.

I go to national forests because the absence of roads is itself the point. These are the places where wolverines still move and rare birds still hold territory. Rescinding the rule does not protect those places. It removes the only rule that has.

Sincerely,
Shelby Hamblin, Iowa

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.

for maintenance." Yet neither the DEIS nor the CBA carries the lifecycle cost of new road construction and perpetual maintenance as a quantified cost of the action alternatives. I request the FEIS quantify per-mile construction and lifecycle maintenance costs for reasonably foreseeable new roads and disclose their effect on the existing backlog, as the state agencies requested.
Your decision directly affects both my livelihood and my quality of life. I advocate for chossing Alternative 1. Thank you for considering my comment.

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

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

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

Thank you.

- Big Frog Addition (369 acres), Cherokee NF, Tennessee
- Bee Cove (3,025 acres), Sumter NF, South Carolina

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 money doesn't add up

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))

"By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, even with complete elimination of the Roadless Rule on the Tongass, the rule will not result in any new timber industry jobs on the Tongass over the next 100 years and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." (Complaint para. 54, Organized Village of Kake v. Vilsack, No. 1:20-cv-00011 (D. Alaska, filed Dec. 23, 2020), p. 23 of 50 (plaintiffs characterizing the agency's own 2020 FEIS at 3-55))

"Large trees accounted for 2.0 to 3.7% of all stems (DBH ≥ 1" or 2.54 cm) among five tree species; but held 33 to 46% of the total AGC stored by each species. Pooled across the five dominant species, large trees accounted for 3% of the 636,520 trees occurring on the inventory plots but stored 42% of the total AGC." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract (AGC is aboveground carbon; the study covers the six eastside national forests))

I ask that the agency reconcile the proposal with its own economic 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 on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

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,
Andrew Scales
Chattanooga, TN

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

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

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

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

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

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

Respectfully,

CommentID: RLC-20260909-YP9YL1

Wildfire. Rescission has been justified partly on wildfire grounds, but the DEIS's own data
points the other way. Table 21 (Vol. I, p. 90) reports a human-caused ignition density of 22.4
fires per million acres per year on other National Forest lands, compared with 3.0 in potentially
affected roadless areas and 2.7 in wilderness — roughly four times higher outside roadless
areas, driven mostly by human-caused ignitions (Vol. I, p. 89). The DEIS also states that
human-caused ignitions increase with proximity to roads (Vol. I, p. 90), directly linking road
access to elevated fire risk. USDA's own analysis therefore undermines the argument that
removing nationwide road-building restrictions would reduce wildfire risk. I ask USDA to
reconcile this contradiction before finalizing its decision.

Wildlife and biodiversity. The DEIS concludes that road construction, reconstruction, and
timber harvest cause long-term adverse effects on biodiversity through habitat fragmentation,
lost connectivity, negative edge effects, and human disturbance, and that these impacts
would be most frequent and widespread under Alternative 2 and least under Alternative 1
(Vol. I, p. 157). The agency's own preliminary biological assessments reached “may affect,
likely to adversely affect” determinations for 327 ESA-listed species and 71 designated critical
habitats under Alternative 2 (Vol. I, p. 161–162). Alternative 1 remains available and avoids
these impacts entirely. When an agency's proposed action is the one its own analysis
identifies as most harmful to listed species and critical habitat, and a less-harmful alternative
is on the table, that is a contradiction USDA needs to explain, not proceed past.
These are not isolated gaps — they are examples of a broader pattern in which the DEIS's
findings do not support the proposed action. I ask USDA to reject Alternative 2, reconcile
these contradictions in its own record, and adopt Alternative 1, keeping the 2001 Roadless
Rule fully in place nationwide.

Thank you for considering this comment.

NEPA requires that cumulative impacts be assessed across connected resources, not within arbitrary administrative boundaries. Grouse Lakes and East Yuba in Tahoe National Forest — 21.0 miles apart, sharing 5 climate-threatened species and 23,648 acres of 2 ecosystem types — constitute a single climate refugia network that must be evaluated as such.

The connected roadless landscape between Grouse Lakes and East Yuba in Tahoe National Forest currently provides exactly the climate refugia function that the agency's own NOI identifies as at risk. 5 climate-threatened species occupy 2 undisturbed ecosystem types spanning ~23,648 acres. This is not theoretical refugia — it is functioning refugia that roadless protection maintains.

Without network-level analysis of the Grouse Lakes–East Yuba refugia corridor in Tahoe National Forest, the DEIS cannot accurately assess what rescission costs. The 5 shared climate-threatened species, the 2 shared ecosystem types, and the ~23,648 acres of connected refugia represent a climate adaptation resource that area-by-area review will systematically fail to account for.

"Seed dispersal over sufficiently large distances can maintain ecological resilience in fragmented landscapes and buffer changes in local-scale functional diversity. Otherwise, functional diversity is maintained by local processes, meaning that ecological resilience of isolated forest fragments depends strongly on land use type and intensity. Habitat fragmentation and local disturbances jointly operate on ecological resilience at different scales. Forest fragments acting as intermediate stepping stones in the transfer of seeds maintained functional diversity across the landscape."
— Diversity and Distributions (Wiley), 2016

Failure to Substantively Respond to Content of Majority-Opposition Comments

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.

What the Roadless Rule has preserved over the past two-plus decades can't be rebuilt once it's gone. Please don't rescind it.

Yours sincerely,

CommentID: RLC-20260907-DCQ5KU

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

Both Draft Biological Assessments open with the same acknowledgment (USFWS BA p. 10; NMFS BA p. 7): "In the promulgation of the 2001 Roadless Rule, the Forest Service found that the Rule's prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species or adversely modify designated or critical habitat; were not likely to jeopardize proposed species or adversely modify proposed critical habitat; and may beneficially affect threatened, endangered, and proposed species and critical habitat… The Services concurred with the determination." The agency thus stands on a concurred-in finding that the prohibitions it now proposes to delete benefit listed species — and the current assessments anticipate widespread adverse effects from deleting them. When an agency reverses course, it "must show that there are good reasons for the new policy," FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009), and where the prior policy rested on factual findings, it may not simply disregard them — the principle applied to this very rule's Tongass history in Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015) (en banc). Neither the DEIS nor the assessments explain what changed in the biology. I request the FEIS directly address the 2001 beneficial-effect finding and state the factual basis for departing from it.”

“Road networks cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. In natural secondary forests, species richness, density and the proportion of invasive species significantly decreased with distance from the road; natural secondary forests contained only 5 invasive versus 67 native species, yet invasive species were concentrated near road edges. Human-induced changes to environmental conditions along roadsides increase soil moisture, soil disturbance, soil nutrients, exposure to sun and soil temperature, all of which are factors known to promote plant invasions. — Diversity and Distributions / Wiley Online Library, 2025 (https://doi.org/10.1111/ddi.70002)”

The Analysis Concedes Recreation Losses Are "Most Likely," Quantifies Them as Costs, and Cannot Even Count the Visitors at Risk

The Economic Analysis concedes at page 25: "In the long-term, any changes in aggregate economic benefit to recreationists that occur under the proposed rule are most likely to be losses because timber harvest and road construction is anticipated to negatively change the recreation settings and opportunities for trail-based and dispersed area recreation within potentially affected IRAs… The magnitude of those losses is unknown." At page 30 it books real costs: "Costs include forgone recreation benefits (minimum of $6.1 million annually) and forgone passive use values ($5.3 to $11.5 million annually) from increases in timber harvest in roadless areas." At page 28 it concedes the mechanism: "The construction and use of roads can degrade the unique characteristics of roadless areas… leading to loss of conservation values… These impacts from road development could negatively impact tourism and outdoor recreation." And at page 16 it admits it cannot even measure the exposure: "The number of recreation visits to IRAs is unknown and, thus, the recreation visitor spending in local communities associated with IRA recreation cannot be directly quantified." Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires an agency to analyze rather than wave through. Robertson, 490 U.S. 332; State Farm, 463 U.S. 29. I request the FEIS quantify recreation exposure (visitation and spending) in affected IRAs before relying on an analysis that concedes losses it cannot measure.

When this process is over, I want the Roadless Rule still standing. I'm filing this comment to help make that happen.

Most respectfully,

CommentID: RLC-20260909-GQZC8R

assured.

Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves.

This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another.

The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source.

I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for.

I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on.

The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

The Rule is not the problem. Rescission is.

Very truly yours,

CommentID: RLC-20260914-0Y7HZ5

The contradiction deepens when the document's own data are examined directly. At Table 14, the agency acknowledges that "Insect and disease risk is generally higher in western regions; in western forests, the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas." The agency uses insect and disease pressure as a primary driver of this proposal, yet its own figures show that already-roaded, already-accessible non-designated National Forest System lands carry greater risk. I want the agency to explain, in the final rule, why rescinding protections for inventoried roadless areas is the preferred remedy when the risk is demonstrably higher on lands where active management is already permitted, and to analyze whether directing increased management to those non-designated lands would achieve the same objectives at lower ecological cost.

The range of alternatives the agency chose to study also warrants scrutiny. The document states that "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need," as noted in the Alternatives Considered but Eliminated from Detailed Study section. That rationale is circular: a purpose and need written to require deregulation will, by definition, exclude any alternative that retains meaningful protection. The agency should provide a non-circular justification, grounded in its actual fire and forest health objectives, for why an approach allowing temporary-road-based hazardous fuel treatment and selective harvest without permanent road construction cannot meet those objectives, and should consider adding such an alternative to the range of detailed study in the final environmental impact statement.

It is easy to see the impact of roads and tree clearing on shared water sources in the Augusta and West Augusta regions, where protected waters and farmland with agricultural runoff are already under pressure. The opportunity to experience wildness in undeveloped spaces that can only be reached on foot is something I bring my grandchildren to these forests for, and it is not possible in a highly developed landscape. The agency should address each of these points fully before this rule proceeds.

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

The document's own data undercuts another pillar of the agency's case. In Table 14, under the Vegetation and Forest Management analysis, the agency acknowledges that "Insect and disease risk is generally higher in western regions; in western forests, the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas." The agency nonetheless uses insect and disease pressure as a primary reason to open roadless areas to new road construction and timber harvest, without explaining why the remedy should fall on lands where the problem is measurably smaller. Eagles and bighorn sheep, the wildlife my family travels to see, depend on the undisturbed character of these areas. The agency must directly address why rescission of roadless protections is the preferred response when the data show that already-roaded, non-designated national forest lands carry the higher ecological burden, and whether directing management there would achieve the same forest-health goals at lower cost to places like the Rocky Mountain landscapes my family values.

This land has worth beyond what can be extracted from it. I urge the agency to keep the 2001 Roadless Area Conservation Rule in place.

In addition, the USFWS Biological Assessment concedes the limits of its own inputs. Page 26: "Species occurrence data are opportunistic and do not represent the results of exhaustive structured species surveys nor do they include negative occurrence data." Page 25: "The databases do not differentiate between DPSes of vertebrate species listed under the ESA, which causes potential inflation of exposure to these entities." Where the data runs out, the assessment substitutes assumption — page 77: "Exposure data on species occurrence are insufficient for assessment so we will assume potential exposure" — and where prediction fails, it concedes the gap outright, page 376: "currently the Forest Service does not have a reliable method to identify, describe, or analyze the likelihood and location of any future projects that may be proposed for currently inventoried roadless areas." An effects analysis assembled from opportunistic records, assumed exposure, and an admitted inability to locate the action's impacts cannot support the DEIS's conclusions about species consequences. Idaho Sporting Congress v. Thomas, 137 F.3d 1146 (9th Cir. 1998) (analysis must be supported by data, not conclusory assertions).

I request the FEIS disclose, species by species, which determinations rest on assumed exposure or unvetted occurrence data, and what structured survey or modeling work would cure the gaps before irreversible commitments are made.

2. The finding that the action alternatives do not meaningfully differ is unsupported and is contradicted by the section's own numbers. At p. 116 the DEIS concludes that "the alternatives are not expected to differ significantly in regard to their contributions to the introduction and spread of invasive species." The stated basis is that "The areas of likely operability for these activities are not expected to be significantly different under alternatives 2 and 3." No support is offered for that assumption. The same section states that "Alternative 3 has fewer acres in the potentially affected area than alternative 2" (p. 115) and reports different mapped acreages for the two - 309,000 against 270,787. A conclusion that the alternatives are indistinguishable for this resource, resting on an operability premise the analysis never demonstrates, removes invasive species from the comparison the environmental impact statement exists to make. The FEIS should either supply the operability comparison the assumption requires or withdraw the finding.

3. The listed-plant exposure the agency has already quantified appears nowhere in the DEIS. The Draft Biological Assessment for USFWS species states at p. 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At p. 344 it quantifies the stake: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive or non-native species." Neither that finding, nor the 60-percent figure, nor the 134-taxon denominator appears anywhere in the DEIS. The DEIS's invasive-plant section at pp. 114-116 does not mention listed species at all, and the DEIS's ESA discussion refers the reader away, stating that "the Biological Assessments contain the full evaluations for the ESA-listed species and designated critical habitat" (p. 169). The agency therefore holds, in one record, a quantified invasive-species threat to 60 percent of the listed plant taxa it analyzed and an invasive-species effects analysis for the action that permits the road construction - and connects them in neither document. Coffin et al. 2021 is a source the agency itself relies on. The FEIS should carry the Assessment's finding into the invasive-plant analysis and disclose the exposure of listed plant taxa by alternative.

Compliance with Executive Order 13751. The DEIS opens this section by quoting the order, which "directs all Federal agencies to address invasive species concerns and refrain from actions likely to increase invasive species problems" (p. 114). It closes the same section by finding that alternatives 2 and 3 "could potentially increase the extent or the number of invasive plant species in the affected environment area" (p. 116). The agency cannot demonstrate compliance with an executive order it has itself invoked while the record's only quantified statement of invasive-species exposure for listed plants - 81 of 134 taxa, at Biological Assessment p. 344 - is absent from the analysis supporting the decision. This is a compliance concern within the meaning of 7 CFR 1b.11(a)(53), and it is owed a reasoned explanation in the final rule as well as a corrected analysis in the FEIS.

The Roadless Rule belongs on the books.

Hopefully,

The DEIS's Own Invasive-Plant Section at Pages 114-116 Measures Existing Infestation, Declares the Action Alternatives Indistinguishable on an Unsupported Assumption, and Never Carries the Assessment's 81-of-134 Listed-Plant Figure

The DEIS analyzes non-native invasive plant species at pp. 114-116 and identifies roads as a vector at p. 150: "Road construction, routine roadside mowing, and the use of roads have been shown to facilitate the spread of non-native invasive plant species." This comment is directed at three specific defects inside that analysis, not at its absence.

1. The extent figure does not measure the risk the section is about, and the DEIS concedes as much on the same page. At p. 114 the DEIS reports that mapped invasive plants "cover approximately 309,000 acres (270,787 for alternative 3), less than 1 percent of the potentially affected environment area," derived from existing mapped occurrences in the Threatened, Endangered, and Sensitive Plant-Invasive Species database (n.44). Two sentences later it states: "It is likely that there are populations that have been undetected and have not been mapped." A magnitude framing built on an inventory the agency describes as incomplete cannot carry the weight the "less than 1 percent" phrasing gives it. Separately and more fundamentally, the figure measures current infestation, not introduction risk in areas that are currently uninfested. The North Carolina Wildlife Resources Commission put the distinction to the agency directly: "IRAs often have less non-native invasive plants due to the lack of roads and other pathways generally associated with their spread and distribution" (DEIS Vol. III, p. 210). On that record the low current percentage identifies the resource at risk; it does not bound the effect. The FEIS should correct the disclosure to state what the figure measures, what it does not, and what the acknowledged mapping gap does to it.

2. The finding that the action alternatives do not meaningfully differ is unsupported and is contradicted by the section's own numbers. At p. 116 the DEIS concludes that "the alternatives are not expected to differ significantly in regard to their contributions to the introduction and spread of invasive species." The stated basis is that "The areas of likely operability for these activities are not expected to be significantly different under alternatives 2 and 3." No support is offered for that assumption. The same section states that "Alternative 3 has fewer acres in the potentially affected area than alternative 2" (p. 115) and reports different mapped acreages for the two - 309,000 against 270,787. A conclusion that the alternatives are indistinguishable for this resource, resting on an operability premise the analysis never demonstrates, removes invasive species from the comparison the environmental impact statement exists to make. The FEIS should either supply the operability comparison the assumption requires or withdraw the finding.

3. The listed-plant exposure the agency has already quantified appears nowhere in the DEIS. The Draft Biological Assessment for USFWS species states at p. 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At p. 344 it quantifies the stake: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive species

sincerely, Heidi Sager

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.

“More than half of migratory bird species in North America are experiencing population declines. Habitat loss and the resulting fragmentation on the breeding grounds are strongly correlated with observed population declines for the Connecticut warbler, which has experienced a total population decline of 62% since 1966 and declined by −8.99% per year between 2000 and 2017. Land-use practices that retain large, forested patches within landscapes will likely benefit breeding populations of this declining songbird. — PMC / Proceedings of the Royal Society B, 2021 (https://doi.org/10.1098/rspb.2020.3164)”

“For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival rate. This model accounted for 78% of the total weight of evidence, and no other model was within 3.8 delta AICc units. From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. — PMC / Ecology and Evolution, 2014 (https://doi.org/10.1002/ece3.1049)”Edit quote

One-Sided Purpose and Need Omitting Countervailing Conservation Values:

The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values.

This comment is against rescission.

Most respectfully,

Margaret Poethig

function as demographic sources and movement corridors that sustain wildlife across the roaded matrix. Every kilometre of new road in an IRA converts core habitat into road-effect zone.
2. Temporary roads have permanent effects. The proposed rule anticipates temporary roads on 11.3 million acres and permanent roads on 18.2 million acres of IRAs. The Forest Service’s own science synthesis concluded that closed and decommissioned roads continue to carry motorized and foot traffic, deliver sediment to streams, and alter wildlife use for decades unless fully recontoured (Gucinski et al. 2001; Switalski et al. 2004). Linear features increase predator travel speed and hunting efficiency (Dickie et al. 2017) and open access for legal and illegal motorized use, the main pathway to human-caused mortality of large carnivores (Lamb et al. 2018). The agency already manages roughly 370,000 miles of road with a deferred maintenance backlog measured in billions of dollars. It has not shown the capacity to obliterate new temporary roads on schedule, and the DEIS should not assume that it will.
3. The Draft EIS does not analyze the effects that matter. The proposed rule reports acreage on which roads “could” be built but does not translate that acreage into projected road density, loss of core habitat, or loss of connectivity between protected areas at any scale. NEPA requires a hard look at reasonably foreseeable cumulative effects. At minimum, the DEIS should (a) model road density under each alternative for representative IRAs and compare it with published thresholds for sensitive species; (b) quantify core habitat loss using the road-effect zone rather than the road footprint; (c) assess connectivity losses for listed and sensitive species whose recovery depends on IRAs, including grizzly bear, Canada lynx (Lynx canadensis), and wolverine (Gulo gulo); and (d) carry the legacy effects of temporary roads through the analysis period rather than assuming they end at decommissioning. Without this analysis, the environmental consequences of rescission remain undisclosed and the record cannot support the proposed action.
The 2001 Rule already permits road construction and vegetation management where needed for wildfire risk and public safety. Rescission is not necessary to meet those needs. It would trade the nation’s last large blocks of unroaded forest habitat for roads the agency cannot afford to maintain and effects the DEIS has not disclosed. I urge the Forest Service to retain the 2001 Roadless Rule in full.

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.

2. Failure to Analyze Localized Hydrological Impacts

The DEIS broadly assumes that returning authority to local forest plans will sufficiently protect watershed health. This assumption is arbitrary and unsupported by localized data. For example, in the Sierra National Forest (specifically the San Joaquin River watershed IRAs), the highly erodible granitic soils are exceptionally vulnerable to road construction.

Actionable Request: The final EIS must include a localized hydrological impact analysis for high-risk watersheds. The Forest Service must calculate the specific estimated sediment runoff (using the Water Erosion Prediction Project or WEPP model) that will result from removing roadbuilding prohibitions on these previously roadless, steep-slope areas, and explain how this complies with the Clean Water Act.

3. Proposed Viable Alternative Omitted from the DEIS

The DEIS largely presents a binary choice: retain the 2001 Roadless Rule or completely rescind it to allow local flexibility. Under NEPA, the Forest Service is legally required to evaluate a full range of reasonable alternatives. Alternative Proposed: I formally request the agency evaluate a "Targeted Fuel Reduction Alternative." Under this alternative, the 2001 Roadless Rule's prohibition on permanent road construction would remain entirely in place. However, local line officers would be granted categorical exclusions or expedited authority to conduct prescribed burning, hand-thinning, and temporary helicopter-based operations strictly for ecological restoration and fire mitigation. This alternative meets the agency's stated "Purpose and Need" of reducing wildfire hazards while avoiding the permanent ecological and hydrological damage of road construction. If the Forest Service dismisses this alternative, it must formally explain why non-road methods are technically or economically infeasible.

The current DEIS is legally insufficient because it fails to evaluate the induced wildfire risks of road building and ignores viable, non-road alternatives to fuel management. I expect these specific points and the proposed alternative to be addressed in the final Environmental Impact Statement.

The United States is strongest when it maintains reserves—not just of minerals and timber, but of intact ecosystems that provide water security, biodiversity, carbon storage, and future economic options. Once these areas are opened to road construction or resource extraction, they cannot be fully restored. The proposal acknowledges that rescission “could increase management flexibility for access (roads), vegetation management, targeted fuels treatments, and access for minerals or energy uses.” This increased access also increases vulnerability.

I believe the safest long‑term strategy is to keep these areas roadless, ensuring that our resources remain under U.S. control and protected from pressures—economic, political, or foreign—that may arise in the future. As you note in the draft EIS, many of these areas overlap with critical watersheds, wildlife habitat, and remote landscapes that provide irreplaceable ecological services. These are national assets that grow more valuable over time.

Currently, there is no urgent need to mine, log, or develop these protected areas. Because the resources are not needed now, they should not be taken. The country that preserves its reserves the longest will have the most strategic power in the future. Maintaining roadless protections ensures that America retains control over its natural wealth rather than risking depletion or external influence.

Recommendations:

Retain the 2001 Roadless Rule as a national baseline to ensure long‑term resource security.

Do not rescind Subpart B; instead, consider strengthening national protections for inventoried roadless areas.

If flexibility is needed, allow limited, narrowly tailored exceptions rather than removing the national rule entirely.

Explicitly analyze the national security implications of resource depletion and foreign market pressures—an area not addressed in the draft EIS.

Recognize that long‑term conservation of intact landscapes is itself a strategic economic and security asset.

Conclusion
America’s roadless areas are part of our national reserve system—ecological, economic, and strategic. Because these resources are not needed now, they should remain protected for the future. I urge USDA to keep the 2001 Roadless Rule in place to ensure that our country remains secure, our forests remain intact, and our natural resources remain protected for generations to come.

area to another or leave homeowners dealing with increasing wildlife conflicts without adequate planning.
I urge New Hampshire decision-makers to conduct comprehensive environmental and wildlife-impact assessments before expanding roadless-area protections. These assessments should consider both the benefits of forest preservation and the potential effects on surrounding communities, including wildlife encroachment, public safety, pets, property, and quality of life.
As a Nashua homeowner, I believe New Hampshire can pursue meaningful conservation while also reducing our dependence on forest resources through recycling, reuse, alternative materials, and responsible resource management. We should protect our forests for future generations while making thoughtful, science-based decisions that recognize the legitimate concerns of the people who live alongside them

First, new roads will guarantee increased human access, which will inevitably lead to more human-caused wildfire ignitions. Humans are a primary (if not the primary) cause of wildfire ignitions, and the locations for these starts are not random. They follow established patterns. Human caused fires typically start along roads, near vehicles, around recreation sites, and nearby other places where humans are located. These are the types of places that would increase if roadless areas were opened to new road construction. The increase in human activity in these areas will create more wildfire starts, which in turn will create more firefighter exposure to the safety risks and health hazards which are inseparable from fighting fires. The increase in ignitions will cause more demand for overextended wildland firefighting resources.

Next, the areas where roads would be constructed would likely be in steep backcountry areas that are bad tactical ground for holding firelines or staging crews. The types of roads that would be constructed would likely be narrow roads that cross the middles of slope with tight switchbacks. These often have limited opportunity to turn around, and offer limited safety zones. In fact, they become some of the most dangerous areas for firefighters. During my career, I actually witnessed a rollover accident on this type of road. The kicker was that this accident didn’t even occur during an active fire - it occurred during suppression repair, a period of wildland fire management that has far less adrenaline and opportunity for distraction. During a fire, the locations and designs of these roads could expose crews not just to the risk of a rollover, but to rolling fuel from above or spotting from below that can lead to rapid fire runs. The way these roads are designed, they can become death traps in many active fire situations.

Next, the existing Roadless Rule does not prevent wildfire response or fuels work. Firefighters can and do suppress wildfires in roadless areas. Agencies can and do conduct fuels treatments there - I know because I have helped implement them in these places myself. Given their remote locations, roadless areas offer some of the best places to safely use large-scale prescribed burning and managed wildfire because they have fewer homes or communities at risk. The Roadless Rule does not bar suppression or fuels work, especially using fire treatments. If anything, opening up roadless areas would increase the unecessary risk that firefighters take on. We need to focus fuel treatments on areas near communities, not remote areas. Rescinding the Roadless Rule is counterproductive to what our focus should be.

Finally, rescinding the Roadless Rule will push more firefighters into high-exposure, low-value suppression assignments while pulling resources away from at-risk communities. Suppressing the lightning ignitions that currently dominate landscapes affected by this proposed rule should not be our priority - the ignitions that start near communities pose the most immediate risk by far. In a time of a shrinking, exhausted workforce, the USDA should not implement a policy that creates more wildfire ignitions and adds more pressure for aggressive suppression actions in remote rugged terrain.

Ending the Roadless Rule and building more roads into roadless areas will not make firefighters safer. If anything, it will significantly increase the risks that firefighters face over the course of their careers by encouraging them to be placed into dangerous areas without significant Values at Risk. New roads will create more human-caused wildfire ignitions in remote steep terrain, increasing firefighter exposure to hazardous suppression efforts with low probabilities of success. This will also pull scarce resources away from the priority of protecting communities. For all the above reasons, I strongly urge you not to rescind the Roadless Area Conservation Rule.

Wind corridors: Roads cut linear openings through dense canopy which create a venturi effect by funneling air flow into a narrow corridor. The roads then become wind tunnels, acting like a bellows to fan the flames during a wildfire event and making it more likely that a spark from an exhaust pipe will become an inferno.

Firefighter safety: These same wind tunnels are exactly where the fire crews are going to be deployed to access their drop points or set up hose lays. Counter to the argument that road access is beneficial to the suppression effort, they in fact create a false sense of safety. Roads lure resources into dangerous and remote terrain during initial attack, setting crews up in mid-slope wind tunnels with no escape route.

Building more roads at taxpayers' expense so that resource extraction corporations run by private equity firms can turn intact ecosystems into tinder boxes, while offering the primary source of wildfire ignitions easy access into remote locations, then sending firefighters miles up dead-end roads to battle the infernos that predictably result, is pure madness. I urge you to listen to the vast majority of citizen comments on this issue, follow the best available science, and show through your actions that you care about firefighter safety. KEEP the few remaining intact ecosystems on public lands and KEEP the Roadless Rule.

Sincerely,

Heather Koon Swanson
Maple Falls, WA

RETIRED, NPS Animal Caretaker/Packer and Trails Work Leader, 1996-2024;
USFS Trail Crew, 1986-1995
Interagency red-carded Wildland Firefighter, 1986-2011

Helicopter Manager, Licensed Blaster, Class A CDL (HazMat), MOCC, Sawyer, Heavy Equipment Operator.

USDA has justified this rescission as relief from a "one-size-fits-all" rule, citing wildfire risk that is concentrated in arid Western forests. But applying that same Western-driven rationale to the Southern Appalachians — a wet, temperate rainforest region with a fundamentally different fire regime — is itself a one-size-fits-all approach that ignores the specific character of these lands.

I urge you to preserve the 2001 Roadless Rule's protections for North Carolina's national forests. Twenty-five years of conservation, and the water, jobs, and safety of this region, depend on it.

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

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

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 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.

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)
Issue 3: Watershed Protection: The proposal does not address the impact of rescinding the Roadless Rule on watershed management and the impact on habitat.
•The Gifford Pinchot National Forest contains and estimated 213,000 acres of old-growth and recovering forest which would be opened to road building if this rule is rescinded. This area is already one of the most heavily roaded national forests in the system and is the watershed for the Lewis River, Wind River, Cispu River and Cowlitz River systems.
Issue 4: Carbon Capture capacity: The proposal does not address the impact of rescinding the Roadless Rule on the capacity of mature and old growth forest stands to capture carbon and mitigate climate change.
•Western Washington’s old-growth forests guard over 100 tons per hectare of what scientists call “irrecoverable carbon.” If lost to the atmosphere, this carbon cannot be recovered in time to avoid the worst impacts of climate change. Old-growth forests also do double duty as refuges for heat-sensitive species. (Originally published in the "Perspectives" section of Park Science magazine, Volume 37, Number 2, Winter 2023 (December 29, 2023).
Issue 5: Permitting and administrative burden: The proposal justifies rescission in part on permitting and administrative burden grounds.
•The rule as written, and the agency’s own analysis of it, state: "Development activities in inventoried roadless areas often cost more to plan and implement than on other National Forest System lands. Some planned timber sales in inventoried roadless areas are likely to cost more to prepare and sell than they realize in revenues received. Because of the level of public controversy and analytical complexity, projects in roadless areas often require development of costly environmental impact statements for most resource development activities, including timber harvesting, in inventoried roadless areas. In some cases, road construction costs are higher due to rugged terrain or sensitive ecological factors. Many development projects in inventoried roadless areas are appealed or litigated." (66 FR 3244, "Fiscal Considerations", printed p. 3246)

I ask that the agency identify in the DEIS which specific burdens are not already addressed by the rule’s existing exceptions. 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,
Nancy Adamson,
Battle Ground, Washington

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

The agency eliminated from detailed study an alternative that would have maintained existing inventoried roadless area boundaries and prohibitions on permanent road construction while still permitting temporary road construction and timber harvest. The stated reason was that such an alternative was not responsive to the purpose and need. That rationale is circular. The purpose and need was written to require deregulation, so any alternative that retains meaningful protections is defined out of existence before analysis begins. The agency's own document confirms this at the Alternatives Considered but Eliminated from Detailed Study section: "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." The agency must explain, in non-circular terms, why an alternative structured around temporary-road-based hazardous fuel treatment and selective harvest cannot meet the stated fire and forest-health objectives, and must consider whether such an alternative belongs in the final EIS.

The agency's own recreation analysis makes the stakes concrete for people like me. The document states at Table 41 that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." These are the conditions that make wildlife watching and photography meaningful, and that draw my family and friends to these forests year after year. The Social and Economic section documents substantial visitor expenditures tied to those settings, yet the purpose and need statement treats reduced regulatory burden as the governing value without weighing it against the risk of degrading the recreation character that sustains both visits and local economies. I want to know how many primitive and semi-primitive acres are projected to shift to roaded or more developed settings under the alternatives being analyzed, and what economic loss to recreation-dependent communities that shift would represent. The agency should provide that analysis in the final EIS.

Clean water, responsible land stewardship, and wild country my children can experience are not abstractions to me. They are what I am asking the agency to protect. I ask that the agency address both of these points in its response to public comment.

1. THE AGENCY'S OWN ECONOMIC ANALYSIS DOES NOT SUPPORT THE ACTION. USFS projects 4.8 million acres opened to timber production, a maximum 5-10% harvest increase, and $5.2-$11.4 million in annual revenue. It puts new dirt road construction at $80,000-$100,000 per mile against a $6.9 billion maintenance backlog, so the entire projected annual revenue is consumed by roughly 52-142 miles of road. The agency concedes gains will be limited by road costs and the backlog, and leaves the wildfire benefit unquantified. An action cannot be justified where the quantified record shows net cost and the leading benefit is asserted without analysis. I request the final rule quantify that benefit or explain how the action stands without it.

2. THE DEIS DECLINES TO QUANTIFY ROAD MILEAGE, THE ACTION'S PRIMARY PHYSICAL EFFECT. The agency states it is not reasonable to anticipate specific mileage changes. Sediment delivery, fragmentation, ignition density, and invasive introduction all scale with mileage; an analysis that will not estimate mileage cannot analyze them. I request supplemental analysis presenting low, expected, and high mileage scenarios with effects modeled for each.

3. THE WILDFIRE RATIONALE IS CONTRADICTED BY THE AGENCY'S OWN RESEARCH. The 2001 rule already permits prescribed fire, habitat restoration, many small-diameter treatments, and emergency access. Forest Service research has found fuel treatments occur more frequently per unit area in roadless lands than in roaded forests. I request the final rule identify, with acreage, which treatments the 2001 rule prohibits and its exemptions do not reach.

4. ROADS INCREASE IGNITION RISK IN THE LANDS LEAST LIKELY TO IGNITE. A 2026 peer-reviewed national study found ignition density within ~164 feet of roads to be about four times that within inventoried roadless areas. Roads are also the primary corridor for invasive annual grasses, which create continuous fine fuel and shorten fire return intervals. I request the DEIS quantify added ignitions and invasive-driven fuel conversion against any claimed treatment benefit.

5. TREATMENT EFFECTIVENESS DEPENDS ON LOCATION, NOT ACCESS. Structure survival is determined principally by the home ignition zone. Roadless areas are by definition remote from communities, and treatments decay within 5-15 years, requiring reentry. I request a cost-per-acre and cost-per-structure-protected comparison against equivalent wildland-urban interface treatment and home hardening.

6. WATERSHED AND CUMULATIVE EFFECTS ARE INADEQUATELY ANALYZED. Roads are the dominant anthropogenic sediment source in managed forest watersheds, and roadless areas sit on steeper terrain carrying above-average erosion and failure risk per mile. Crossings sized to historical flows are increasingly undersized. These lands are thermal refugia for native salmonids, and their value rises as lower reaches warm. I request cumulative assessment alongside concurrent changes to ESA implementation, monument boundaries, and environmental review procedures.

7. NO REASONABLE RANGE OF ALTERNATIVES WAS CONSIDERED. Full rescission versus no action is not a range. The Idaho and Colorado Roadless Rules show state-specific flexibility is achievable through the existing petition process without national rescission. I request analysis of at minimum: treatment authority near the wildland-urban interface using temporary roads with mandatory decommissioning; expanded use of the state petition process; and a treatment-authority alternative conveying no commercial harvest or mineral access. The last is diagnostic of the rule's purpose.

8. REVERSING A 25-YEAR RULE REQUIRES HEIGHTENED JUSTIFICATION. The 2001 rule rested on extensive findings on maintenance capacity, sediment, and fragmentation. Those findings have not weakened; the backlog cited here is larger now. The proposal explains what changed in policy preference, not in the evidence. The 2025 scoping drew over 220,000 comments, roughly 99% opposed.

I request withdrawal of the proposed rule, or a supplemental DEIS addressing items 1-8, and reopening of the comment period for no fewer than 90 days with hearings in each affected state.

The DEIS must disclose the number and location of jurisdictional waters in the Suntop IRA, quantify fill discharges at each potential crossing, and document the Section 404 permitting pathway for each. Deferring CWA impacts to site-specific analysis is not adequate when the programmatic decision itself changes watershed protection status.

2. DEIS Materially Alters the 2020 Alaska FEIS Fish Habitat Finding

At page 318 (Appendix 4), the DEIS states: "The 2020 FEIS evaluated effects to fish habitat and found that there would be overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy (page 3-138)."

The page cite is right, but the text is altered. The 2020 FEIS reads: "Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including the riparian management strategy, and the lack of old-growth harvest or associated road construction allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas."

Three material alterations:

It deletes the third ground entirely: no old-growth harvest or road construction in T77 watersheds and Conservation Priority Areas, the only constraint on roads in high-value salmon watersheds.
It deletes "LUDs." LUDs allocate management prescriptions; standards condition activity. They are distinct protections.
It substitutes "whether the Roadless Rule is in place or not" for "under all alternatives." The 2020 FEIS noted protective differences among alternatives for these waters.

At page 243, the DEIS repeats this conclusion without attribution, presenting it as its own finding. Yet the same page states: "Roads pose the greatest risk to fish resources on the Tongass, partly because they pose the largest risk of management-caused sediment input to streams."

The DEIS can't name road sediment the greatest risk while resting a minimal-effects conclusion on protections stripped of the road ban in high-value watersheds. Appendix 4 discloses that the Tongass Plan Revision will consider alternatives without IRA designations, so the DEIS relies on a finding predicated on protections this rulemaking removes.

Requested Actions

Under 7 CFR 1b.7(f)(2)(v) and 1b.7(f)(3), I request that the Forest Service:

Correct the restatements at pages 318 and 243 to reproduce the full 2020 FEIS basis, including Forest Plan LUDs and the T77/Conservation Priority Area prohibition, and restore "under all alternatives."
Supply attribution and a page citation at page 243.
Supplement the Tongass aquatic analysis under 7 CFR 1b.7(f)(2)(iii) to state whether "minimal effects" holds without the T77/Conservation Priority Area restrictions, with a road-mileage and stream-crossing basis.

These are programmatic questions that can't be deferred. A conclusion without record support fails NEPA's hard-look requirement. (See Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002).)

The 2001 Roadless Rule has withstood a quarter-century of litigation, review, and administration changes. That durability warrants leaving it in place. Please abandon this proposed rescission.

Sincerely,

Toby

The contradiction deepens when the document's own data are examined directly. At Table 14, the agency acknowledges that "Insect and disease risk is generally higher in western regions; in western forests, the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas." The agency uses insect and disease pressure as a primary driver of this proposal, yet its own figures show that already-roaded, already-accessible non-designated National Forest System lands carry greater risk. I want the agency to explain, in the final rule, why rescinding protections for inventoried roadless areas is the preferred remedy when the risk is demonstrably higher on lands where active management is already permitted, and to analyze whether directing increased management to those non-designated lands would achieve the same objectives at lower ecological cost.

The range of alternatives the agency chose to study also warrants scrutiny. The document states that "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need," as noted in the Alternatives Considered but Eliminated from Detailed Study section. That rationale is circular: a purpose and need written to require deregulation will, by definition, exclude any alternative that retains meaningful protection. The agency should provide a non-circular justification, grounded in its actual fire and forest health objectives, for why an approach allowing temporary-road-based hazardous fuel treatment and selective harvest without permanent road construction cannot meet those objectives, and should consider adding such an alternative to the range of detailed study in the final environmental impact statement.

It is easy to see the impact of roads and tree clearing on shared water sources in the Augusta and West Augusta regions, where protected waters and farmland with agricultural runoff are already under pressure. The opportunity to experience wildness in undeveloped spaces that can only be reached on foot is something I bring my grandchildren to these forests for, and it is not possible in a highly developed landscape. The agency should address each of these points fully before this rule proceeds.

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

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

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

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

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

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

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

Respectfully,

CommentID: RLC-20260909-YP9YL1

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)
Issue 3: Watershed Protection: The proposal does not address the impact of rescinding the Roadless Rule on watershed management and the impact on habitat.
•The Gifford Pinchot National Forest contains and estimated 213,000 acres of old-growth and recovering forest which would be opened to road building if this rule is rescinded. This area is already one of the most heavily roaded national forests in the system and is the watershed for the Lewis River, Wind River, Cispu River and Cowlitz River systems.
Issue 4: Carbon Capture capacity: The proposal does not address the impact of rescinding the Roadless Rule on the capacity of mature and old growth forest stands to capture carbon and mitigate climate change.
•Western Washington’s old-growth forests guard over 100 tons per hectare of what scientists call “irrecoverable carbon.” If lost to the atmosphere, this carbon cannot be recovered in time to avoid the worst impacts of climate change. Old-growth forests also do double duty as refuges for heat-sensitive species. (Originally published in the "Perspectives" section of Park Science magazine, Volume 37, Number 2, Winter 2023 (December 29, 2023).
Issue 5: Permitting and administrative burden: The proposal justifies rescission in part on permitting and administrative burden grounds.
•The rule as written, and the agency’s own analysis of it, state: "Development activities in inventoried roadless areas often cost more to plan and implement than on other National Forest System lands. Some planned timber sales in inventoried roadless areas are likely to cost more to prepare and sell than they realize in revenues received. Because of the level of public controversy and analytical complexity, projects in roadless areas often require development of costly environmental impact statements for most resource development activities, including timber harvesting, in inventoried roadless areas. In some cases, road construction costs are higher due to rugged terrain or sensitive ecological factors. Many development projects in inventoried roadless areas are appealed or litigated." (66 FR 3244, "Fiscal Considerations", printed p. 3246)

I ask that the agency identify in the DEIS which specific burdens are not already addressed by the rule’s existing exceptions. 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,
Nancy Adamson,
Battle Ground, Washington

Wildfire. Rescission has been justified partly on wildfire grounds, but the DEIS's own data
points the other way. Table 21 (Vol. I, p. 90) reports a human-caused ignition density of 22.4
fires per million acres per year on other National Forest lands, compared with 3.0 in potentially
affected roadless areas and 2.7 in wilderness — roughly four times higher outside roadless
areas, driven mostly by human-caused ignitions (Vol. I, p. 89). The DEIS also states that
human-caused ignitions increase with proximity to roads (Vol. I, p. 90), directly linking road
access to elevated fire risk. USDA's own analysis therefore undermines the argument that
removing nationwide road-building restrictions would reduce wildfire risk. I ask USDA to
reconcile this contradiction before finalizing its decision.

Wildlife and biodiversity. The DEIS concludes that road construction, reconstruction, and
timber harvest cause long-term adverse effects on biodiversity through habitat fragmentation,
lost connectivity, negative edge effects, and human disturbance, and that these impacts
would be most frequent and widespread under Alternative 2 and least under Alternative 1
(Vol. I, p. 157). The agency's own preliminary biological assessments reached “may affect,
likely to adversely affect” determinations for 327 ESA-listed species and 71 designated critical
habitats under Alternative 2 (Vol. I, p. 161–162). Alternative 1 remains available and avoids
these impacts entirely. When an agency's proposed action is the one its own analysis
identifies as most harmful to listed species and critical habitat, and a less-harmful alternative
is on the table, that is a contradiction USDA needs to explain, not proceed past.
These are not isolated gaps — they are examples of a broader pattern in which the DEIS's
findings do not support the proposed action. I ask USDA to reject Alternative 2, reconcile
these contradictions in its own record, and adopt Alternative 1, keeping the 2001 Roadless
Rule fully in place nationwide.

Thank you for considering this comment.

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

assured.

The agency eliminated from detailed study an alternative that would have maintained existing inventoried roadless area boundaries and prohibitions on permanent road construction while still permitting temporary road construction and timber harvest. The stated reason was that such an alternative was not responsive to the purpose and need. That rationale is circular. The purpose and need was written to require deregulation, so any alternative that retains meaningful protections is defined out of existence before analysis begins. The agency's own document confirms this at the Alternatives Considered but Eliminated from Detailed Study section: "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." The agency must explain, in non-circular terms, why an alternative structured around temporary-road-based hazardous fuel treatment and selective harvest cannot meet the stated fire and forest-health objectives, and must consider whether such an alternative belongs in the final EIS.

The agency's own recreation analysis makes the stakes concrete for people like me. The document states at Table 41 that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." These are the conditions that make wildlife watching and photography meaningful, and that draw my family and friends to these forests year after year. The Social and Economic section documents substantial visitor expenditures tied to those settings, yet the purpose and need statement treats reduced regulatory burden as the governing value without weighing it against the risk of degrading the recreation character that sustains both visits and local economies. I want to know how many primitive and semi-primitive acres are projected to shift to roaded or more developed settings under the alternatives being analyzed, and what economic loss to recreation-dependent communities that shift would represent. The agency should provide that analysis in the final EIS.

Clean water, responsible land stewardship, and wild country my children can experience are not abstractions to me. They are what I am asking the agency to protect. I ask that the agency address both of these points in its response to public comment.

The DEIS must disclose the number and location of jurisdictional waters in the Suntop IRA, quantify fill discharges at each potential crossing, and document the Section 404 permitting pathway for each. Deferring CWA impacts to site-specific analysis is not adequate when the programmatic decision itself changes watershed protection status.

2. DEIS Materially Alters the 2020 Alaska FEIS Fish Habitat Finding

At page 318 (Appendix 4), the DEIS states: "The 2020 FEIS evaluated effects to fish habitat and found that there would be overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy (page 3-138)."

The page cite is right, but the text is altered. The 2020 FEIS reads: "Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including the riparian management strategy, and the lack of old-growth harvest or associated road construction allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas."

Three material alterations:

It deletes the third ground entirely: no old-growth harvest or road construction in T77 watersheds and Conservation Priority Areas, the only constraint on roads in high-value salmon watersheds.
It deletes "LUDs." LUDs allocate management prescriptions; standards condition activity. They are distinct protections.
It substitutes "whether the Roadless Rule is in place or not" for "under all alternatives." The 2020 FEIS noted protective differences among alternatives for these waters.

At page 243, the DEIS repeats this conclusion without attribution, presenting it as its own finding. Yet the same page states: "Roads pose the greatest risk to fish resources on the Tongass, partly because they pose the largest risk of management-caused sediment input to streams."

The DEIS can't name road sediment the greatest risk while resting a minimal-effects conclusion on protections stripped of the road ban in high-value watersheds. Appendix 4 discloses that the Tongass Plan Revision will consider alternatives without IRA designations, so the DEIS relies on a finding predicated on protections this rulemaking removes.

Requested Actions

Under 7 CFR 1b.7(f)(2)(v) and 1b.7(f)(3), I request that the Forest Service:

Correct the restatements at pages 318 and 243 to reproduce the full 2020 FEIS basis, including Forest Plan LUDs and the T77/Conservation Priority Area prohibition, and restore "under all alternatives."
Supply attribution and a page citation at page 243.
Supplement the Tongass aquatic analysis under 7 CFR 1b.7(f)(2)(iii) to state whether "minimal effects" holds without the T77/Conservation Priority Area restrictions, with a road-mileage and stream-crossing basis.

These are programmatic questions that can't be deferred. A conclusion without record support fails NEPA's hard-look requirement. (See Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002).)

The 2001 Roadless Rule has withstood a quarter-century of litigation, review, and administration changes. That durability warrants leaving it in place. Please abandon this proposed rescission.

Sincerely,

Toby

The evidence on fire contradicts the rationale for this rescission. Forest Service records from 1992 to 2024 across all eight contiguous regions show ignition density lowest in wilderness (1.75 fires per 1,000 hectares) and next lowest in roadless areas (1.97), rising as distance to a road falls. Aplet, Hartger, and Dietz, Fire Ecology 22(1):8 (2026). The proposal concedes that greater access can increase human-caused ignition potential. The Department also reports high or very high wildfire hazard within roadless areas ranging from 60 percent in California to 5 percent in the Eastern Region.

The Department's own economics do not support the change. Roughly 4.8 million acres are operable, 16 percent of forested roadless acres. Cutting all of them annually, which the Department calls unlikely, would raise sawtimber harvest 5 to 10 percent and yield $5.2 to $11.4 million a year. Against that sit roughly $6.1 million in annual recreation losses, unquantified water costs, and a $6.9 billion maintenance backlog on existing roads and bridges. The benefit concentrates on a few operators and the Treasury, while the costs fall on recreationists, downstream water users, taxpayers, and tribes. More than 95 percent of roadless acreage lies in ten western states, so eastern forests supply almost none of the benefit while, under Alternative 3, losing nearly all protection.

Alternative 3 is not a middle course. Its screens remove land within a half-mile of a road (13.3 million acres by the agency's count), land in the wildland-urban interface (10.2 million acres), and the Tongass. Applied to the East that is a full rescission. The Shawnee is fragmented federal parcels laced with roads and bordered by towns, and nearly all of it clears one screen or both. The DEIS should disclose the acreage each criterion removes by region and forest.

Project-level review is not the backstop the proposal assumes. In August 2024 the Forest Service's own assessment found Indiana bats in the 67-acre McCormick project area in Pope County and found the project likely to adversely affect them. The agency approved it that October without waiting for the biological opinion. A contractor cut 40 of 67 acres before Judge Rosenstengel set the decision memo aside on August 31, 2026 as an ESA violation. That approval came under a prior administration. The problem is structural, not political.

The rulemaking is incomplete. The Department concedes substantial direct effects on tribes, reports consultations ongoing, and defers the Tribal Impact Summary Statement to the final rule. Its own summary shows tribes requested a strengthened rule or a co-stewardship alternative during scoping. The DEIS analyzes neither. The ANILCA Section 810 subsistence hearings run September 29 through October 1, after this comment period closes, and the agency will not accept written comments there.

If the Department's real problem is fire and forest health, the remedy does not require touching this rule. Use the existing exceptions, revise delegation and implementation direction if approvals are slow, direct fuels funding to the wildland-urban interface outside roadless areas, and pay down the road backlog so crews can use the roads that already exist.

I ask the Department to retain 36 CFR part 294, subpart B in full, extend the comment period, and complete consultation and the subsistence analysis while the public can still respond.

Rescission would change how I spend my time, where I travel, and what I plan my years around. It would change my way of life.

Please see the attached for a more complete comment with citations.

Rafael Risman Letzter, Chicago, Illinois

My experience with these specific lands: Last July, I backpacked for 4 days with my family into the Quigg Peak inventoried roadless area in the Lolo National Forest. We camped in a valley with lush green waist-high vegetation. A creek in the center of the valley tumbled and sang over the rocks. We saw no one around our campsite for miles.

As a child, I harvested deer and elk with my father in this same country and the neighboring Silver King and Quigg Peak roadless areas. Coming home to those places, unchanged, is priceless. These areas provide critical summer and winter range for elk, deer, moose, and bighorn sheep, and they feed cold, clean water into Rock Creek, which supports outfitters, trail-ride operators, and fly-fishing guides whose livelihoods depend on that fishery.

The wildfire rationale is not evidence-based and does not align with the agency's own analysis. The Summary of Potential Impacts (91 FR 53829) states that only 9.8M acres (24 percent) of potentially affected roadless acreage overlaps with the wildland-urban interface. If community protection from wildfire is the actual goal, that WUI overlap is where resources should be targeted, not a blanket rescission covering the other 76 percent of acres. The document also acknowledges (91 FR 53829) that greater public access can increase human-caused ignition potential, meaning new roads add fire risk. Separately, the same section notes a $6.9B existing deferred maintenance backlog on Forest Service roads and bridges, which undercuts the claim that new road access is a realistic fire-management tool in the near future.

The economic case for rescission is marginal and would harm recreation-dependent communities. USDA's own cost-benefit analysis (91 FR 53830, "Summary of Potential Impacts") projects $4.6M to $10.6M yearly in timber revenue gains, against an estimated $6.1M yearly loss in recreation economic benefit. This trade-off is, by the agency's own math, close to a wash and uncertain both ways. In the Rock Creek drainage, recreation losses would land on guides, outfitters, and small businesses that depend on the health and character of these areas.

Tribal consultation does not support this change. USDA's summary (91 FR 53831-53832) states that the majority of Tribes consulted oppose the rule change given how it threatens sovereignty and cultural resources, with several requesting a "Strengthened Roadless Rule" or co-management alternative instead. That should weigh heavily.

Requested alternative: I ask USDA to adopt the No Action alternative and retain the 2001 Roadless Rule nationwide. If the agency believes flexibility is warranted, I still oppose full rescission but would find a narrower alternative, limited to fuel-reduction treatment within the already-identified 9.8M-acre WUI overlap, without opening remaining acreage to road construction or timber harvest, less objectionable than the current proposal.

Broader public support: My position is not a minority view. Comments on the notice of intent (90 FR 42179) ran more than 99% opposed to rescission among over 625,000 individuals and organizations (91 FR 53831). Independent polls found broad, bipartisan public support for keeping the rule intact.

This sort of quiet and isolation is incredibly rare, too rare, today, and irreplaceable if lost. To repeal the Roadless Rule is shortsighted. Such a change does not seek to give but to take and take without reciprocity. Not to expand but to contract the gifts nature seeks to give us. We do not need more roads. We need more places to get lost, to find our way, to feel more wild.

Sincerely,
Anjeli Doty, EdM, Harvard University
Missoula/Seattle area, Montana backcountry recreationist

The U.S. Department of Agriculture is proposing to rescind the 2001 Roadless Area Conservation Rule, which has protected approximately 44.7 million acres of National Forest System lands from road construction and timber harvest for more than two decades. The single most damaging flaw in the agency's analysis is that it relies on wildfire risk as the primary practical rationale for rescission while its own data in Table 26 shows that roads were associated with successful fire containment on only 23.5 percent of road miles that encountered large wildfires, and the agency simultaneously acknowledges that most new roads built under the action alternatives would be temporary timber-harvest spur roads rather than strategically placed, higher-standard roads designed for fire suppression. No fiscal analysis is provided showing how additional road mileage would be funded given the existing $6.9 billion deferred maintenance backlog and a 70 percent decline in appropriated road funding over the last 20 years.

The draft EIS contains additional unresolved analytical gaps that require correction before a final rule is issued. First, the agency's preliminary biological assessment found 'may affect, likely to adversely affect' determinations for 327 ESA-listed species and 71 critical habitats, yet Section 7 consultation with USFWS and NMFS remains incomplete, meaning the public cannot evaluate the legal sufficiency of the proposed action (Biodiversity section). Second, the agency's own insect-and-disease risk data in Table 14 shows that IRA forests in most western regions have equal or lower mortality risk than already-roaded NFS forests outside designated areas, directly undercutting the forest-health rationale for rescission. Third, Table 35 documents that approximately 24 million people outside Alaska obtain drinking water from watersheds containing potentially affected IRAs, yet the document provides no quantitative estimate of increased sediment loading or municipal water-treatment cost increases under alternatives 2 and 3. Fourth, tribal consultation is incomplete: only 29 of 64 requested government-to-government consultations had been held at time of publication, and the Tribal Impact Summary Statement will not be available until the final rule, depriving Tribes of meaningful participation in the comment process (Agencies and Persons Consulted section).

Based on the foregoing, I request that the agency take the following specific actions before issuing a final rule: (1) extend the public comment period until all requested tribal consultations are complete and the Tribal Impact Summary Statement is published for review; (2) complete and publish the USFWS and NMFS biological opinions and make them available for public comment before the comment deadline; (3) prepare and disclose a quantitative fiscal analysis of projected new road maintenance costs under alternatives 2 and 3 against available funding sources; (4) prepare a quantitative analysis of projected increases in sediment delivery and municipal water-treatment costs for the approximately 24 million downstream water users; (5) add to the final EIS a detailed alternative that allows temporary-road-based hazardous fuel treatment and selective harvest inside IRAs without authorizing permanent road construction, and provide a non-circular explanation of why such an alternative cannot meet the stated fire and forest-health objectives; and (6) identify which specific land management plan amendments are required to provide equivalent IRA protections before rescission takes effect, given the agency's own finding that most current plans lack adequate IRA-specific direction.

justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes.
I urge the FS to explain how proposed road construction or vegetation management would demonstrably improve ecological resilience, and to fully account for the increased ignition risks and long-term maintenance burdens associated with new roads.
The agency should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks and hazards during suppression operations.
Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System. Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, and other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the RR is rescinded or revised under Alts 2 and 3.
I am particularly concerned about wildlife habitat and connectivity, soil erosion, biodiversity, and climate resilience.
The FS should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System.
The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, and other culturally significant areas.
I urge the FS to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.
Regarding Indigenous sovereignty, I am particularly concerned about sacred sites, treaty-reserved resources, and cultural forestscapes.
New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources.
Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed.
For these reasons, I urge the FS to retain the Roadless Rule under Alternative 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities.

resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes.
I urge the USFS to explain how proposed road construction or vegetation management would demonstrably improve community protection, firefighter safety, and ecological resilience, & to fully account for the increased ignition risks and long-term maintenance burdens associated with new roads.
The USFS should disclose & analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, & future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks & hazards during suppression operations.
Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction and logging, mining & drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, rec. & other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the RR is rescinded or revised under Alts. 2 & 3.
I am particularly concerned about wildlife habitat & connectivity, clean water, soil erosion, invasive species, biodiversity, climate resilience, firefighter risk, landscape fire restoration, & loss of wild places.
The USFS should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the NFS.
The DEIS recognizes that road construction & timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, & culturally significant areas.
I urge the USFS to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.
Regarding Indigenous sovereignty, I am particularly concerned about sacred sites and cultural forestscapes.
New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources.
Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed.
For these reasons, I urge the USFS to retain the RR under Alt. 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities.

extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes.
I urge the USFS to explain how proposed road construction or vegetation management would demonstrably improve ecological resilience, and to fully account for the increased ignition risks and long-term maintenance burdens associated with new roads.
The agency should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks and hazards during suppression operations.
Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, and other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the RR is rescinded or revised under Alts. 2 and 3.
I am particularly concerned about climate resilience.
The USFS should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the NFS.
The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, and other culturally significant areas.
I urge the USFS to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.
Regarding Indigenous sovereignty, I am particularly concerned about sacred sites, treaty-reserved resources, traditional gathering areas, cultural forestscapes, and increased unauthorized access.
New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources.
Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed.
For these reasons, I urge the USFS to retain the 2001 Roadless Rule under Alt. 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities.

for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes.
I urge the USFS to explain how proposed road construction or vegetation management would demonstrably improve community protection and ecological resilience, and to fully account for the increased ignition risks and long-term maintenance burdens associated with new roads.
The agency should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks and hazards during suppression operations.
Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, and other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the Roadless Rule is rescinded or revised under Alts. 2 and 3.
I am particularly concerned about wildlife habitat and connectivity, biodiversity, and climate resilience.
The USFS should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System.
The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, and other culturally significant areas.
I urge the USFS to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.
Regarding Indigenous sovereignty, I am particularly concerned about traditional gathering areas.
New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources.
Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed.
For these reasons, I urge the Forest Service to retain the 2001 Roadless Rule under Alt. 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities.

as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes.
I urge the USFS to explain how proposed road construction or vegetation management would demonstrably improve community protection and firefighter safety, and to fully account for the increased ignition risks and long-term maintenance burdens associated with new roads.
The USFS should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks & hazards during suppression operations.
Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, & other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the RR is rescinded or revised under Alts. 2 & 3.
I am particularly concerned about soil erosion, invasive species, firefighter risk, & landscape fire restoration.
The USFS should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the NFS.
The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, & other culturally significant areas.
I urge the USFS to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.
Regarding Indigenous sovereignty, I am particularly concerned about treaty-reserved resources & increased unauthorized access.
New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, & resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources.
Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed.
For these reasons, I urge the USFS to retain the 2001 Roadless Rule under Alt. 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters & communities.

justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities & firefighters, rather than broadly removing protections from remote landscapes.
I urge the USFS to explain how proposed road construction or vegetation management would demonstrably improve community protection, firefighter safety, and ecological resilience, & to fully account for the increased ignition risks and long-term maintenance burdens associated with new roads.
The USFS should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, & future human-caused fire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks & hazards during suppression operations.
Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction and logging, mining, & drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation & other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction & timber harvest are reasonably foreseeable if the RR is rescinded or revised under Alts. 2 and 3.
I am particularly concerned about wildlife habitat and connectivity, invasive species, biodiversity & climate resilience.
The USFS should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the NFS.
The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails & other culturally significant areas.
I urge the USFS to ensure meaningful government-to-government collaboration & to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.
Regarding Indigenous sovereignty, I am particularly concerned about sacred sites, treaty-reserved resources & increased unauthorized access.
New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places & treaty-reserved resources.
Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed.
For these reasons, I urge the USFS to retain the 2001 Roadless Rule under Alt. 1 & reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights & the long-term safety of firefighters & communities.

extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes.
I urge the USFS to explain how proposed road construction or vegetation management would demonstrably improve ecological resilience, and to fully account for the increased ignition risks and long-term maintenance burdens associated with new roads.
The agency should also disclose and analyze the potential for new roads to increase suppression complexity, vehicle hazards, traffic congestion, emergency evacuation challenges, invasive vegetation, and future human-caused wildfire ignitions. Claims that road construction will improve firefighter safety should be supported by a tradeoff analysis of the specific operational conditions under which new roads may provide a potential safety benefit—but also create new safety risks and hazards during suppression operations.
Roadless areas provide some of the largest remaining undeveloped landscapes in the National Forest System (NFS). Removing nationwide protections could increase opportunities for road construction and logging, mining, and drilling, with impacts degrading wildlife habitat, connectivity, water, soils, biodiversity, recreation, and other ecological values. The RR was initially implemented to protect the ecological values of these forests as a connected and biodiverse landscape that local control could not account for. The DEIS acknowledges that more road construction and timber harvest are reasonably foreseeable if the RR is rescinded or revised under Alts. 2 and 3.
I am particularly concerned about wildlife habitat and connectivity, clean water, soil erosion, and invasive species.
The USFS should not rely solely on future, site-specific project reviews to protect these values. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the NFS.
The DEIS recognizes that additional road construction and timber harvesting could have long-term negative effects on Tribal rights and interests, including impacts to treaty-reserved resources, sacred sites, ancestral trails, and other culturally significant areas.
I urge the USFS to ensure meaningful government-to-government collaboration and to fully incorporate Tribal knowledge and concerns before any decision is made to remove protections.
Regarding Indigenous sovereignty, I am particularly concerned about treaty-reserved resources.
New roads can also increase physical access to areas that have previously remained relatively protected from unauthorized entry, human-caused disturbance, and resource extraction. These consequences should be considered alongside direct impacts to culturally significant places and treaty-reserved resources.
Future consultation on individual projects is not an adequate substitute for considering these impacts before a nationwide protection is removed.
For these reasons, I urge the Forest Service to retain the 2001 Roadless Rule under Alt. 1 and reject the proposed nationwide rescission, ensuring that wildfire policy is grounded in operational reality, ecological integrity, Tribal knowledge and rights, and the long-term safety of firefighters and communities.

Executive Order 11988 requires the agency to assess flood hazard before authorizing road construction. The DEIS must quantify the increase in impervious surface, runoff volume, and peak flow resulting from road construction in the Bear Swamp IRA, Huron-Manistee National Forest, and evaluate downstream flood risk.

"Any discharge of dredged and/or fill material into waters of the U.S. incidental to any of the exempt activities must have a permit if it is part of an activity whose purpose is to convert an area of a water of the U.S. into a use to which it was not previously subject, where the flow or circulation of waters of the U.S. may be impaired or the reach of such waters be reduced (Recapture Provision, Section 404(f)(2))."
— U.S. Army Corps of Engineers, Sacramento District

The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests.

The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress.

“When a party argues that an agency action was arbitrary and capricious due to a deficiency in an EIS, the reviewing court must account for the fact that NEPA is a purely procedural statute. Under NEPA, an agency's only obligation is to prepare an adequate report. Judicial review is typically conducted under the Administrative Procedure Act's deferential arbitrary-and-capricious standard. Under that standard, a court asks not whether it agrees with the agency decision, but rather only whether the agency action was reasonable and reasonably explained. Agencies must take a 'hard look' at the environmental consequences of their actions in the context of projects under consideration. — Supreme Court of the United States (https://www.supremecourt.gov/opinions/24pdf/23-975_m648.pdf)”

Sustaining the Rule is the outcome consistent with the Department's rulemaking history, its statutory responsibilities, and the record before it.

In solidarity,

populated region [5]. Inventoried roadless areas make up just 2% of the lower 48 states; in New England, the White and Green Mountain National Forests together hold roughly 260,000 roadless acres, and reporting indicates the White Mountains alone could lose up to 235,000 protected acres under this proposal [6,7]. For a region where most residents live within a few hours of dense urban centers like Boston, Providence, and Hartford, these acres are close to irreplaceable: clear streams, unfragmented ridgelines, and forest interior habitat unlike anything else within a day's drive for millions of people. The Forest Service has already logged post-2001 roadless acreage here precisely because it lacked Roadless Rule protection; full rescission would strip that same protection from the acres that have held it since 20016. Once a road is built into a tract like this, the wildness it protected does not come back.
The public record does not support this rescission. Of the roughly 600,000 comments submitted in 2025, more than 99.8% opposed it, and a February 2026 Pew poll found 76% of voters — across party lines — support keeping the Rule [8].
Given that the rescission's own foundational documents identify resource extraction, not wildfire safety, as its purpose, I urge the Forest Service to select the “no action” alternative and retain the 2001 Roadless Rule in full.

Sources
1. USDA Forest Service, Notice of Intent / Federal Register, “Special Areas; Roadless Area Conservation; National Forest System Lands” (Aug. 29, 2025). https://www.federalregister.gov/documents/2025/08/29/2025-16581/special-areas-roadless-area-conservation-national-forest-system-lands
2. roadless.org, “The Wildfire Justification Falls Apart” (Key Facts), citing Forest Service Chief Tom Schultz's Senate testimony and a Wilderness Society GIS analysis of Forest Service WUI data. https://roadless.org/key-facts
3. Aplet, G., Hartger, K., & Dietz, M., “Three-Decade Record of Contiguous-U.S. National Forest Wildfires Indicates Increased Density of Ignitions Near Roads,” Fire Ecology (2026). https://doi.org/10.1186/s42408-026-00450-2
4. Balch, J.K., et al., “Human-started wildfires expand the fire niche across the United States,” PNAS (2017). https://www.pnas.org/doi/10.1073/pnas.1617394114
5. Center for Biological Diversity, “New England National Forest Roadless Areas” fact sheet. https://www.biologicaldiversity.org/programs/public_lands/forests/new_england_national_forest_roadless_areas/pdfs/WMNF_roadless_fact_sheet.pdf
6. Mountain Times, “Roadless Areas Are Under Attack” (Sept. 17, 2025). https://mountaintimes.info/2025/09/17/roadless-areas-are-under-attack/
7. Union Leader, “White Mountain National Forest could lose 235,000 protected acres under rule change.” https://www.unionleader.com/news/environment/white-mountain-national-forest-could-lose-235-000-protected-acres-under-rule-change/article_c9b0a991-d758-45d6-9333-e950c3a3972e.html
8. roadless.org, “Key Facts” (“Millions Support the Roadless Rule”), citing 2025 USDA comment-period results and Pew Charitable Trusts, “An Update on the ‘Roadless Rule’” (Feb. 18, 2026). https://www.pew.org/en/research-and-analysis/articles/2026/02/18/an-update-on-the-roadless-rule

Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer.

Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed.

Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars.

The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress.

Finally, these figures serve the final rule as well as the environmental impact statement. The proposal reverses findings the Department made in 2001 about the effect of roadless protections on management, and this FACTS baseline is the factual finding on which that reversal rests. Where a new position rests on factual findings that contradict those underlying the prior policy, the explanation must be more detailed, not less. FCC v. Fox Television Stations, 556 U.S. 502, 515–16 (2009); Encino Motorcars, LLC v. Navarro, 579 U.S. 211, 221–22 (2016). I request that the final rule preamble address the corrected figures and the disaggregated series directly, and not by cross-reference to the FEIS response-to-comments appendix.

Rescission serves the fewest. The Rule serves the most. Keep the Rule.

Warm regards, Daniel Volkmann

Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer.

Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole.

The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress.

Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area.

There are mountains of evidence showing that an increase in roads comes with an increase in fire danger. If the argument to rescind the Roadless Rule is primarily one of fire reduction then the case erodes immediately.

I'm asking the Department to do what the public has consistently asked it to do: maintain the Roadless Rule.

CommentID: RLC-20260823-O5M5XZ

Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Small Whorled Pogonia (Isotria medeoloides) in the Linville Gorge Addition Inventoried Roadless Area, including the documented threat of 5.3 - Logging & wood harvesting.

"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

The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress.

The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests.

The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling.

Rescinding the Roadless Area Conservation Rule would be an unjustified reversal of long-settled land management policy.

With determination,
Christian Rust

Freshwater extinction risk. Aquatic species face disproportionate extinction risk globally. A multi-taxon assessment of 23,496 freshwater species found that 24% are threatened with extinction, driven primarily by pollution, habitat fragmentation, and sediment loading from upstream disturbance (Sayer et al. 2025). — Sayer, Catherine A.; Fernando, Eresha; Jimenez, Randall R.; et al., 2025 · Nature (https://doi.org/10.1038/s41586-024-08375-z)

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

I have seen extensive evidence of human activities affecting downstream water. With the recent pollution from a new factory in the region killing large quantities of fish this impact is even more noticeable. I live across the street from our River yet I can not swim it, nor drink from it due to pollution down stream. Rescission of the roadless rule would prove to send further pollution down stream.

The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress.

The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling.

Beyond the headline fights over wildfire, recreation, and water, the Roadless Rule plays a quieter but essential role in federal land law and ecological assessment. Section 7 of the Endangered Species Act requires the Forest Service to consult before any action that may affect listed species — and the rule's road-construction prohibition has shielded countless management decisions from triggering that consultation. The rule also props up federal forest planning: peer-reviewed analyses of forest plan adequacy consistently find that forest plans alone, without the Roadless Rule's overlay, fail to provide adequate safeguards for sensitive species and intact landscapes. And state-level conservation rankings (NatureServe and others) repeatedly identify roadless areas as concentrated in the rarest, most threatened ecosystems in the lower 48 — the kinds of places where a road, once built, cannot be undone.

This comment joins the record in opposition to the proposed rescission action.

Warm regards,

Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

fire-management activity. Fuel reduction treatments already occur inside inventoried roadless areas at rates comparable to or greater than elsewhere in the National Forest System, and historical fire maps show roaded and roadless forests have burned at similar rates since 2001. In short, the Roadless Rule does not prevent responsible fuels work, and more roads are more likely to increase ignitions than reduce fire risk. Framing the removal of protections for 44 million acres as a wildfire measure is not supported by the evidence; it reads as a pretext for opening these lands to road building and commercial logging.
The economic arguments are also weak. The Forest Service already carries a road maintenance backlog on the order of $10 billion. Building new roads deepens that liability with taxpayer money, and below-cost timber sales on national forest land have historically lost the agency millions of dollars annually. Meanwhile, intact forests drive an enormous and growing economy: national forest recreation visits generated $10.1 billion in local spending and supported more than 150,000 jobs in 2019 alone, and outdoor recreation broadly is now a trillion-dollar-plus sector. Every trip I take in western North Carolina means money for local restaurants, hotels, campgrounds, and small businesses. Those gateway communities depend on the landscapes this proposal would fragment and erode. Trading that durable, broadly-shared economic base for a one-time timber cut is bad arithmetic even before counting lost water quality, wildlife habitat, and carbon storage.
The public has already spoken on this matter twice. The original rulemaking was the most extensive in federal history, drawing over 1.6 million comments with roughly 90 to 95 percent in favor of protection. This rescission has generated thousands of comments, and independent analyses suggest about 99 percent oppose the rollback. Opposition of that magnitude, across the political spectrum, should end the discussion. Proceeding anyway would signal that public comment is theater and the outcome was decided in advance.
It is hard to avoid asking who actually benefits from this. The most enthusiastic supporters of this proposal are timber industry organizations, not firefighters, not forest ecologists, and not the recreating public. When a policy is opposed by 99 percent of commenters, contradicted by the agency's own science, and applauded chiefly by the industry that stands to extract value from it, the only logical conclusion is that the government is working for private interests, rather than for the tax-paying public it is duty-bound to serve.
The Forest Service has real wildfire challenges, and the right tools for that work - targeted fuels treatment near communities, prescribed fire, wildland-urban interface planning - are all permitted under the current rules.
A blanket removal of national protections, delegated to local managers while the agency's staff, budget, and scientific capacity are being cut, is not a valid wildfire prevention strategy. It is a slow-motion land transfer, with no evidentiary basis, no coherent economics, and no public support.

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

hundred feet of roads.
New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts.
The current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary.
Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks.
National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest.
Forested watersheds filter and store water more effectively than developed lands, reducing sediment and pollutants.
Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water.

Rescinding the Roadless Rule Contradicts Public Opinion
The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections.
Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants.
Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it.
USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans.

For all these reasons—ecological health, fire safety, and clean water—I strongly oppose rescinding the 2001 Roadless Rule. I ask that the agency leave the rule in place as is. Please protect America’s remaining roadless areas for current and future generations.

Will Fett

hundreds of public meetings, and about 1.6 million public comments, roughly 90 percent of which supported the rule (Substack) .
The wildfire argument for rescission is also on shaky scientific ground. Forest ecologist Logan Berner and colleagues published research this year directly challenging the administration's premise, and as he put it, "roads are a really key avenue by which ignitions for wildfires occur." (Alaska Public) In other words, building more roads into currently roadless forest may increase fire risk rather than reduce it, since roads are a major vector for human-caused ignitions. Meanwhile, these forests provide services far beyond timber value: Berner noted they supply clean drinking water for millions of Americans and wildlife habitat (Alaska Public) — benefits that don't show up on a balance sheet but that would be difficult or impossible to restore once roads and logging fragment these landscapes.
Public sentiment reinforces the case against rescission. A national survey commissioned by The Pew Charitable Trusts and published in February showed overwhelming bipartisan support for the Roadless Rule and overwhelming bipartisan opposition to rescinding it (Substack) . This isn't a new pattern — when the first Trump administration attempted a rollback in 2020, nearly all public comments favored keeping the rule in place (Alaska Public) . When a policy draws sustained, cross-partisan public support over 25 years and multiple attempts to undo it, that consensus deserves serious weight, not dismissal as mere "administrative" cleanup.
Supporters of rescission argue that local forest managers, not a blanket federal rule, are best positioned to judge where thinning and fuel reduction are needed, and that overgrown, insect-damaged stands genuinely pose fire risk in some areas — a point worth taking seriously. But that concern could be addressed through narrower, science-based exceptions rather than eliminating protection for nearly 45 million acres outright. Given the ecological value at stake, the disputed wildfire rationale, and the strength and durability of public opposition, rescinding the Roadless Rule is not a proportionate response to the problems it claims to solve, and it should not move forward.

Leave public land alone. Let nature thrive. God has given us his best, why do you want to destroy it?

Job 12:7-10 – "Ask the animals, and they will teach you... In his hand is the life of every creature."

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: Foreseeable plan amendments are placed beyond scope

I photograph landscapes, and every frame depends on what the management plans allow next. The agency concedes where this leads and then declares it out of scope: 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 is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action.

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,
John Stapleton
Austin, TX

The thought that this wilderness area might soon be opened up to roads and the logging, mining, and drilling that is meant to accompany those roads is horrifying. The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. This process, if allowed to move forward, will compromise waterways and wildlife biodiversity, destroy recreation areas, worsen climate change, and greatly increase the risk of wildfire in states where wildfires are already a major threat. This goes far beyond the extreme negative implications of my personal enjoyment of these wilderness areas. It actually threatens the well being of communities in the rural and urban cities surrounding these areas.

Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area.

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.

With respect,

Emeline

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 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 5: 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.

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,
Stuart Schupack
Cottonwood, Arizona

populated region [5]. Inventoried roadless areas make up just 2% of the lower 48 states; in New England, the White and Green Mountain National Forests together hold roughly 260,000 roadless acres, and reporting indicates the White Mountains alone could lose up to 235,000 protected acres under this proposal [6,7]. For a region where most residents live within a few hours of dense urban centers like Boston, Providence, and Hartford, these acres are close to irreplaceable: clear streams, unfragmented ridgelines, and forest interior habitat unlike anything else within a day's drive for millions of people. The Forest Service has already logged post-2001 roadless acreage here precisely because it lacked Roadless Rule protection; full rescission would strip that same protection from the acres that have held it since 20016. Once a road is built into a tract like this, the wildness it protected does not come back.
The public record does not support this rescission. Of the roughly 600,000 comments submitted in 2025, more than 99.8% opposed it, and a February 2026 Pew poll found 76% of voters — across party lines — support keeping the Rule [8].
Given that the rescission's own foundational documents identify resource extraction, not wildfire safety, as its purpose, I urge the Forest Service to select the “no action” alternative and retain the 2001 Roadless Rule in full.

Sources
1. USDA Forest Service, Notice of Intent / Federal Register, “Special Areas; Roadless Area Conservation; National Forest System Lands” (Aug. 29, 2025). https://www.federalregister.gov/documents/2025/08/29/2025-16581/special-areas-roadless-area-conservation-national-forest-system-lands
2. roadless.org, “The Wildfire Justification Falls Apart” (Key Facts), citing Forest Service Chief Tom Schultz's Senate testimony and a Wilderness Society GIS analysis of Forest Service WUI data. https://roadless.org/key-facts
3. Aplet, G., Hartger, K., & Dietz, M., “Three-Decade Record of Contiguous-U.S. National Forest Wildfires Indicates Increased Density of Ignitions Near Roads,” Fire Ecology (2026). https://doi.org/10.1186/s42408-026-00450-2
4. Balch, J.K., et al., “Human-started wildfires expand the fire niche across the United States,” PNAS (2017). https://www.pnas.org/doi/10.1073/pnas.1617394114
5. Center for Biological Diversity, “New England National Forest Roadless Areas” fact sheet. https://www.biologicaldiversity.org/programs/public_lands/forests/new_england_national_forest_roadless_areas/pdfs/WMNF_roadless_fact_sheet.pdf
6. Mountain Times, “Roadless Areas Are Under Attack” (Sept. 17, 2025). https://mountaintimes.info/2025/09/17/roadless-areas-are-under-attack/
7. Union Leader, “White Mountain National Forest could lose 235,000 protected acres under rule change.” https://www.unionleader.com/news/environment/white-mountain-national-forest-could-lose-235-000-protected-acres-under-rule-change/article_c9b0a991-d758-45d6-9333-e950c3a3972e.html
8. roadless.org, “Key Facts” (“Millions Support the Roadless Rule”), citing 2025 USDA comment-period results and Pew Charitable Trusts, “An Update on the ‘Roadless Rule’” (Feb. 18, 2026). https://www.pew.org/en/research-and-analysis/articles/2026/02/18/an-update-on-the-roadless-rule

Fire is the second reason. I live across the Deschutes River from forest that has had four fires in the last two years, three of them human caused. The more access roads open into forest lands, the more human-caused fires will follow. Hikers and bikers rarely cause fires, but humans in vehicles do. Rescinding roadless protections is not a fire management strategy. It is an invitation to the very ignition sources already burning the land I can see from where I live. The agency should address directly how expanded road access interacts with human-caused fire risk, and put a real answer to that question in this record.

Cumulative timber pressure is the third reason. The DEIS frames the possibility that certain alternatives could increase sawtimber harvest by some margin as a benefit, while Table 4 of the same document acknowledges an ongoing reasonably foreseeable action: the One Big Beautiful Bill Act, which "Directs the Forest Service to annually, beginning in FY2026 and through FY2034, sell a quantity of timber on National Forest System land that is at least 250 million board feet greater than the quantity that was sold in the previous fiscal year." That statutory mandate runs independently of this rulemaking, yet nowhere in the document does a cumulative analysis combine both pressures and measure their joint effect on inventoried roadless area resources. The agency cannot treat a decade-long escalating harvest obligation as background noise. It must integrate that mandate with IRA-specific projections before this rule is finalized.

The national forests must be reserved for recreation, wildlife, and environmental management. Roadless areas must be maximized, not removed. I oppose logging in the federal forests anywhere except the Wildland Urban Interface, and I urge the agency to withdraw this proposal.

Forest System land that is at least 250 million board feet greater than the quantity that was sold in the previous fiscal year." The document projects that its own alternatives could increase sawtimber harvest by 4 to 10 percent nationally, but nowhere does it model both obligations operating at the same time on inventoried roadless area resources. The forests I use for hiking, wildlife watching, and photography in the Deschutes could face pressure from both mandates simultaneously, and the agency has not told the public what that means. The agency must integrate the statutory volume mandate with IRA-specific harvest projections across all resource topics and respond to that combined analysis before this rule moves forward.
This change is simply to fulfill the wishes of the corporate donors and logging and extraction industries and is not about the future, the planet, or the health of our children. It is short sighted and profit driven and is being sold as fire safety under the guise of protecting communities from wildfire and resource management while actually accomplishing the opposite.

Roadless areas also include rivers and watersheds that supply clean drinking water to 354 municipal watersheds. A 2026 University of Washington study, in partnership with Conservation Science Partners, found that the roadless rule protects drinking water for about 25 million Americans. The city of Port Townsend, WA, for example, could be particularly impacted by any new construction or logging because they rely on water that comes exclusively from roadless areas.

Repealing the Roadless Rule also doesn’t make sense financially. The Forest Service already carries a deferred maintenance backlog of roughly 6.9 billion dollars for its roads and bridges, and it is funded to maintain only about a fifth of the more than 370,000 miles of road it already manages. This rescission opens up to 18.2 million acres to new road construction the rule currently prohibits. Building more roads the agency cannot afford to maintain is fiscally reckless and shifts the long term cost onto taxpayers.

Finally, this rescission would make it far easier to route powerlines, pipelines, and water conveyance through roadless corridors by removing the road construction barrier that has kept most such infrastructure out. The Department cites Executive Order 14154 on energy as a reason for the action. The public deserves a full analysis of the industrial infrastructure this could enable, not an assurance that the effects would be modest.

For these reasons, I ask the Department to: retain the 2001 Roadless Area Conservation Rule by selecting the No Action alternative; fully analyze the fiscal, wildfire, water, wildlife, and infrastructure effects described above; and complete meaningful Tribal consultation before any decision is made.

These areas deserve our protection and reverence, not a bulldozer. I hope to see this administration listen to its constituents and retain the Roadless Area Conservation Rule. Thank you.

And the proposal is not really about timber and fire. Removing the road prohibition is what opens roadless ground to mineral exploration, and under the mining law the Forest Service can't deny a plan of operations once that road barrier is gone. That consequence should be analyzed and disclosed, not left out of the EIS.

The agency reached the opposite conclusions when it wrote the 2001 rule. It owes the public an explanation for the reversal.

Klint Cleveland
Hamilton, Montana

One place that has become especially meaningful to me is Donner Summit and the wilderness north of it, which is currently protected by the Roadless Area Conservation Rule. I have climbed and hiked there and one thing I have come to value greatly is the community of people who visit these places. Hikers pick up scraps of trash along the trail. Climbers teach and practice Leave No Trace.

Donner Summit is a good example of why the value of roadless areas is easy to misunderstand. It certainly does not feel "roadless" as I-80 runs just south of the area. But that makes the remaining undeveloped landscape feel more valuable, not less. The people that share these trails, crags, and campsites understand that we are visitors in a landscape much larger than any one of us. This is the type of community that can only exist on the periphery of our urban landscape - the farther we extend our concrete pathways the farther away these communities will migrate, depriving us of a deeply valuable cultural experience.

The USDA argues that rescinding the rule would give local managers more flexibility, improve wildfire and forest-health management, increase timber harvesting, provide access for recreation and fire suppression, and create opportunities for mineral and energy development. These are legitimate considerations, but they should not be treated as self-evident benefits. Where is the evidence?

I ask the Forest Service to distinguish between management that is actually necessary to protect communities and infrastructure and management that simply becomes possible if roadless protections are removed. If additional roads are justified for wildfire management, the analysis should demonstrate that their benefits outweigh the costs of construction and maintenance, habitat fragmentation, increased human-caused fires, and the disturbance created by new access.

The USDA estimates that rescinding the rule would expand timber production opportunities to approximately 4.8 million acres, or about 16% of forested areas within roadless areas. This is one of the clearest reasons I remain concerned about the proposal. The agency describes increased timber production as a benefit, but the economic gains appear relatively modest compared with the permanent ecological costs that can accompany road construction and timber harvest. I would ask the USDA to demonstrate why these particular roadless areas are necessary for meeting timber demand. If timber production is the objective, we should first make the best possible use of forests that are already roaded and accessible rather than assuming that the remaining undeveloped areas should become part of the timber base.

There is a massive benefit to preserving our natural lands. For me, that benefit is not abstract. It is being able to climb at Donner Summit, hike around Donner Lake, encounter wildlife, and spend time with a community of people who care deeply about leaving these places better than they found them. Before removing a protection that directly affects places I visit and value, please demonstrate that the proposed benefits are real, necessary, and greater than the costs of losing these places as they are.

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.

- Big Frog Addition (369 acres), Cherokee NF, Tennessee
- Bee Cove (3,025 acres), Sumter NF, South Carolina

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 money doesn't add up

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))

"By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, even with complete elimination of the Roadless Rule on the Tongass, the rule will not result in any new timber industry jobs on the Tongass over the next 100 years and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." (Complaint para. 54, Organized Village of Kake v. Vilsack, No. 1:20-cv-00011 (D. Alaska, filed Dec. 23, 2020), p. 23 of 50 (plaintiffs characterizing the agency's own 2020 FEIS at 3-55))

"Large trees accounted for 2.0 to 3.7% of all stems (DBH ≥ 1" or 2.54 cm) among five tree species; but held 33 to 46% of the total AGC stored by each species. Pooled across the five dominant species, large trees accounted for 3% of the 636,520 trees occurring on the inventory plots but stored 42% of the total AGC." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract (AGC is aboveground carbon; the study covers the six eastside national forests))

I ask that the agency reconcile the proposal with its own economic 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 on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

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,
Andrew Scales
Chattanooga, TN

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)
Issue 3: Watershed Protection: The proposal does not address the impact of rescinding the Roadless Rule on watershed management and the impact on habitat.
•The Gifford Pinchot National Forest contains and estimated 213,000 acres of old-growth and recovering forest which would be opened to road building if this rule is rescinded. This area is already one of the most heavily roaded national forests in the system and is the watershed for the Lewis River, Wind River, Cispu River and Cowlitz River systems.
Issue 4: Carbon Capture capacity: The proposal does not address the impact of rescinding the Roadless Rule on the capacity of mature and old growth forest stands to capture carbon and mitigate climate change.
•Western Washington’s old-growth forests guard over 100 tons per hectare of what scientists call “irrecoverable carbon.” If lost to the atmosphere, this carbon cannot be recovered in time to avoid the worst impacts of climate change. Old-growth forests also do double duty as refuges for heat-sensitive species. (Originally published in the "Perspectives" section of Park Science magazine, Volume 37, Number 2, Winter 2023 (December 29, 2023).
Issue 5: Permitting and administrative burden: The proposal justifies rescission in part on permitting and administrative burden grounds.
•The rule as written, and the agency’s own analysis of it, state: "Development activities in inventoried roadless areas often cost more to plan and implement than on other National Forest System lands. Some planned timber sales in inventoried roadless areas are likely to cost more to prepare and sell than they realize in revenues received. Because of the level of public controversy and analytical complexity, projects in roadless areas often require development of costly environmental impact statements for most resource development activities, including timber harvesting, in inventoried roadless areas. In some cases, road construction costs are higher due to rugged terrain or sensitive ecological factors. Many development projects in inventoried roadless areas are appealed or litigated." (66 FR 3244, "Fiscal Considerations", printed p. 3246)

I ask that the agency identify in the DEIS which specific burdens are not already addressed by the rule’s existing exceptions. 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,
Nancy Adamson,
Battle Ground, Washington

NEPA requires that cumulative impacts be assessed across connected resources, not within arbitrary administrative boundaries. Grouse Lakes and East Yuba in Tahoe National Forest — 21.0 miles apart, sharing 5 climate-threatened species and 23,648 acres of 2 ecosystem types — constitute a single climate refugia network that must be evaluated as such.

The connected roadless landscape between Grouse Lakes and East Yuba in Tahoe National Forest currently provides exactly the climate refugia function that the agency's own NOI identifies as at risk. 5 climate-threatened species occupy 2 undisturbed ecosystem types spanning ~23,648 acres. This is not theoretical refugia — it is functioning refugia that roadless protection maintains.

Without network-level analysis of the Grouse Lakes–East Yuba refugia corridor in Tahoe National Forest, the DEIS cannot accurately assess what rescission costs. The 5 shared climate-threatened species, the 2 shared ecosystem types, and the ~23,648 acres of connected refugia represent a climate adaptation resource that area-by-area review will systematically fail to account for.

"Seed dispersal over sufficiently large distances can maintain ecological resilience in fragmented landscapes and buffer changes in local-scale functional diversity. Otherwise, functional diversity is maintained by local processes, meaning that ecological resilience of isolated forest fragments depends strongly on land use type and intensity. Habitat fragmentation and local disturbances jointly operate on ecological resilience at different scales. Forest fragments acting as intermediate stepping stones in the transfer of seeds maintained functional diversity across the landscape."
— Diversity and Distributions (Wiley), 2016

Failure to Substantively Respond to Content of Majority-Opposition Comments

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.

What the Roadless Rule has preserved over the past two-plus decades can't be rebuilt once it's gone. Please don't rescind it.

Yours sincerely,

CommentID: RLC-20260907-DCQ5KU

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

The Draft EIS states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected Inventories Roadless Areas compared to other NFS lands" and acknowledges that "if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads" (Comparison of Alternatives, pp. 20-36). This ignition-density comparison is uncited, and the agency's own admission that road access correlates with human-caused ignition is never reconciled with any fire-risk rationale for expanding road access under Alternatives 2 and 3. A peer-reviewed three-decade national forest fire record found ignition density near roads reaching 7.99 fires/1000 ha versus 1.97 fires/1000 ha in Inventoried Roadless Areas — evidence squarely on point that the agency should engage. Under Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998), and Sierra Club v. Marsh, 872 F.2d 497 (1st Cir. 1989), the agency must confront contrary evidence rather than ignore it. I request the agency cite its ignition-density source and add explicit reconciliation analysis before finalizing this document.

In addition, Forest Service Chief Tom Schultz recently testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area.
The argument that rescission is needed for more fuels management and is false.

The current roadless rules allows for fuels management under certain circumstances, including to reduce fuel loads in the wildland-urban interface and to improve habitat for threatened, endangered, or sensitive species. This already has been done in multiple roadless areas in the Tahoe Basin. The Forest Service’s own research shows that roadless areas have historically received a larger proportion of fuels management projects than other areas of the National Forest System. (Sean P. Healy, Long-term forest health implications of roadlessness, Environmental Research Letters. September 2020. https://doi.org/10.1088/1748-9326/aba031).

As a property owner and business owner near wildfire-prone areas in two parts of California, your decision impacts me personally and professionally if a fire starts off a newly built road because Alternative 2 or 3 was approved. I could lose my home and my business. Please choose Alternative 1. Thank you for considering my comment.

Both Draft Biological Assessments open with the same acknowledgment (USFWS BA p. 10; NMFS BA p. 7): "In the promulgation of the 2001 Roadless Rule, the Forest Service found that the Rule's prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species or adversely modify designated or critical habitat; were not likely to jeopardize proposed species or adversely modify proposed critical habitat; and may beneficially affect threatened, endangered, and proposed species and critical habitat… The Services concurred with the determination." The agency thus stands on a concurred-in finding that the prohibitions it now proposes to delete benefit listed species — and the current assessments anticipate widespread adverse effects from deleting them. When an agency reverses course, it "must show that there are good reasons for the new policy," FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009), and where the prior policy rested on factual findings, it may not simply disregard them — the principle applied to this very rule's Tongass history in Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015) (en banc). Neither the DEIS nor the assessments explain what changed in the biology. I request the FEIS directly address the 2001 beneficial-effect finding and state the factual basis for departing from it.”

“Road networks cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. In natural secondary forests, species richness, density and the proportion of invasive species significantly decreased with distance from the road; natural secondary forests contained only 5 invasive versus 67 native species, yet invasive species were concentrated near road edges. Human-induced changes to environmental conditions along roadsides increase soil moisture, soil disturbance, soil nutrients, exposure to sun and soil temperature, all of which are factors known to promote plant invasions. — Diversity and Distributions / Wiley Online Library, 2025 (https://doi.org/10.1111/ddi.70002)”

The Analysis Concedes Recreation Losses Are "Most Likely," Quantifies Them as Costs, and Cannot Even Count the Visitors at Risk

The Economic Analysis concedes at page 25: "In the long-term, any changes in aggregate economic benefit to recreationists that occur under the proposed rule are most likely to be losses because timber harvest and road construction is anticipated to negatively change the recreation settings and opportunities for trail-based and dispersed area recreation within potentially affected IRAs… The magnitude of those losses is unknown." At page 30 it books real costs: "Costs include forgone recreation benefits (minimum of $6.1 million annually) and forgone passive use values ($5.3 to $11.5 million annually) from increases in timber harvest in roadless areas." At page 28 it concedes the mechanism: "The construction and use of roads can degrade the unique characteristics of roadless areas… leading to loss of conservation values… These impacts from road development could negatively impact tourism and outdoor recreation." And at page 16 it admits it cannot even measure the exposure: "The number of recreation visits to IRAs is unknown and, thus, the recreation visitor spending in local communities associated with IRA recreation cannot be directly quantified." Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires an agency to analyze rather than wave through. Robertson, 490 U.S. 332; State Farm, 463 U.S. 29. I request the FEIS quantify recreation exposure (visitation and spending) in affected IRAs before relying on an analysis that concedes losses it cannot measure.

When this process is over, I want the Roadless Rule still standing. I'm filing this comment to help make that happen.

Most respectfully,

CommentID: RLC-20260909-GQZC8R

Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves.

This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another.

The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source.

I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for.

I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on.

The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

The Rule is not the problem. Rescission is.

Very truly yours,

CommentID: RLC-20260914-0Y7HZ5

The agency eliminated from detailed study an alternative that would have maintained existing inventoried roadless area boundaries and prohibitions on permanent road construction while still permitting temporary road construction and timber harvest. The stated reason was that such an alternative was not responsive to the purpose and need. That rationale is circular. The purpose and need was written to require deregulation, so any alternative that retains meaningful protections is defined out of existence before analysis begins. The agency's own document confirms this at the Alternatives Considered but Eliminated from Detailed Study section: "An alternative that considered maintaining existing inventoried roadless area boundaries and prohibitions on permanent road construction while allowing temporary road construction and timber harvest was considered but eliminated from detailed study as not being responsive to the purpose and need." The agency must explain, in non-circular terms, why an alternative structured around temporary-road-based hazardous fuel treatment and selective harvest cannot meet the stated fire and forest-health objectives, and must consider whether such an alternative belongs in the final EIS.

The agency's own recreation analysis makes the stakes concrete for people like me. The document states at Table 41 that "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." These are the conditions that make wildlife watching and photography meaningful, and that draw my family and friends to these forests year after year. The Social and Economic section documents substantial visitor expenditures tied to those settings, yet the purpose and need statement treats reduced regulatory burden as the governing value without weighing it against the risk of degrading the recreation character that sustains both visits and local economies. I want to know how many primitive and semi-primitive acres are projected to shift to roaded or more developed settings under the alternatives being analyzed, and what economic loss to recreation-dependent communities that shift would represent. The agency should provide that analysis in the final EIS.

Clean water, responsible land stewardship, and wild country my children can experience are not abstractions to me. They are what I am asking the agency to protect. I ask that the agency address both of these points in its response to public comment.

The DEIS must disclose the number and location of jurisdictional waters in the Suntop IRA, quantify fill discharges at each potential crossing, and document the Section 404 permitting pathway for each. Deferring CWA impacts to site-specific analysis is not adequate when the programmatic decision itself changes watershed protection status.

2. DEIS Materially Alters the 2020 Alaska FEIS Fish Habitat Finding

At page 318 (Appendix 4), the DEIS states: "The 2020 FEIS evaluated effects to fish habitat and found that there would be overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy (page 3-138)."

The page cite is right, but the text is altered. The 2020 FEIS reads: "Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including the riparian management strategy, and the lack of old-growth harvest or associated road construction allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas."

Three material alterations:

It deletes the third ground entirely: no old-growth harvest or road construction in T77 watersheds and Conservation Priority Areas, the only constraint on roads in high-value salmon watersheds.
It deletes "LUDs." LUDs allocate management prescriptions; standards condition activity. They are distinct protections.
It substitutes "whether the Roadless Rule is in place or not" for "under all alternatives." The 2020 FEIS noted protective differences among alternatives for these waters.

At page 243, the DEIS repeats this conclusion without attribution, presenting it as its own finding. Yet the same page states: "Roads pose the greatest risk to fish resources on the Tongass, partly because they pose the largest risk of management-caused sediment input to streams."

The DEIS can't name road sediment the greatest risk while resting a minimal-effects conclusion on protections stripped of the road ban in high-value watersheds. Appendix 4 discloses that the Tongass Plan Revision will consider alternatives without IRA designations, so the DEIS relies on a finding predicated on protections this rulemaking removes.

Requested Actions

Under 7 CFR 1b.7(f)(2)(v) and 1b.7(f)(3), I request that the Forest Service:

Correct the restatements at pages 318 and 243 to reproduce the full 2020 FEIS basis, including Forest Plan LUDs and the T77/Conservation Priority Area prohibition, and restore "under all alternatives."
Supply attribution and a page citation at page 243.
Supplement the Tongass aquatic analysis under 7 CFR 1b.7(f)(2)(iii) to state whether "minimal effects" holds without the T77/Conservation Priority Area restrictions, with a road-mileage and stream-crossing basis.

These are programmatic questions that can't be deferred. A conclusion without record support fails NEPA's hard-look requirement. (See Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002).)

The 2001 Roadless Rule has withstood a quarter-century of litigation, review, and administration changes. That durability warrants leaving it in place. Please abandon this proposed rescission.

Sincerely,

Toby

- Big Frog Addition (369 acres), Cherokee NF, Tennessee
- Bee Cove (3,025 acres), Sumter NF, South Carolina

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 money doesn't add up

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))

"By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, even with complete elimination of the Roadless Rule on the Tongass, the rule will not result in any new timber industry jobs on the Tongass over the next 100 years and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." (Complaint para. 54, Organized Village of Kake v. Vilsack, No. 1:20-cv-00011 (D. Alaska, filed Dec. 23, 2020), p. 23 of 50 (plaintiffs characterizing the agency's own 2020 FEIS at 3-55))

"Large trees accounted for 2.0 to 3.7% of all stems (DBH ≥ 1" or 2.54 cm) among five tree species; but held 33 to 46% of the total AGC stored by each species. Pooled across the five dominant species, large trees accounted for 3% of the 636,520 trees occurring on the inventory plots but stored 42% of the total AGC." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract (AGC is aboveground carbon; the study covers the six eastside national forests))

I ask that the agency reconcile the proposal with its own economic 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 on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.

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,
Andrew Scales
Chattanooga, TN

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)
Issue 3: Watershed Protection: The proposal does not address the impact of rescinding the Roadless Rule on watershed management and the impact on habitat.
•The Gifford Pinchot National Forest contains and estimated 213,000 acres of old-growth and recovering forest which would be opened to road building if this rule is rescinded. This area is already one of the most heavily roaded national forests in the system and is the watershed for the Lewis River, Wind River, Cispu River and Cowlitz River systems.
Issue 4: Carbon Capture capacity: The proposal does not address the impact of rescinding the Roadless Rule on the capacity of mature and old growth forest stands to capture carbon and mitigate climate change.
•Western Washington’s old-growth forests guard over 100 tons per hectare of what scientists call “irrecoverable carbon.” If lost to the atmosphere, this carbon cannot be recovered in time to avoid the worst impacts of climate change. Old-growth forests also do double duty as refuges for heat-sensitive species. (Originally published in the "Perspectives" section of Park Science magazine, Volume 37, Number 2, Winter 2023 (December 29, 2023).
Issue 5: Permitting and administrative burden: The proposal justifies rescission in part on permitting and administrative burden grounds.
•The rule as written, and the agency’s own analysis of it, state: "Development activities in inventoried roadless areas often cost more to plan and implement than on other National Forest System lands. Some planned timber sales in inventoried roadless areas are likely to cost more to prepare and sell than they realize in revenues received. Because of the level of public controversy and analytical complexity, projects in roadless areas often require development of costly environmental impact statements for most resource development activities, including timber harvesting, in inventoried roadless areas. In some cases, road construction costs are higher due to rugged terrain or sensitive ecological factors. Many development projects in inventoried roadless areas are appealed or litigated." (66 FR 3244, "Fiscal Considerations", printed p. 3246)

I ask that the agency identify in the DEIS which specific burdens are not already addressed by the rule’s existing exceptions. 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,
Nancy Adamson,
Battle Ground, Washington

NEPA requires that cumulative impacts be assessed across connected resources, not within arbitrary administrative boundaries. Grouse Lakes and East Yuba in Tahoe National Forest — 21.0 miles apart, sharing 5 climate-threatened species and 23,648 acres of 2 ecosystem types — constitute a single climate refugia network that must be evaluated as such.

The connected roadless landscape between Grouse Lakes and East Yuba in Tahoe National Forest currently provides exactly the climate refugia function that the agency's own NOI identifies as at risk. 5 climate-threatened species occupy 2 undisturbed ecosystem types spanning ~23,648 acres. This is not theoretical refugia — it is functioning refugia that roadless protection maintains.

Without network-level analysis of the Grouse Lakes–East Yuba refugia corridor in Tahoe National Forest, the DEIS cannot accurately assess what rescission costs. The 5 shared climate-threatened species, the 2 shared ecosystem types, and the ~23,648 acres of connected refugia represent a climate adaptation resource that area-by-area review will systematically fail to account for.

"Seed dispersal over sufficiently large distances can maintain ecological resilience in fragmented landscapes and buffer changes in local-scale functional diversity. Otherwise, functional diversity is maintained by local processes, meaning that ecological resilience of isolated forest fragments depends strongly on land use type and intensity. Habitat fragmentation and local disturbances jointly operate on ecological resilience at different scales. Forest fragments acting as intermediate stepping stones in the transfer of seeds maintained functional diversity across the landscape."
— Diversity and Distributions (Wiley), 2016

Failure to Substantively Respond to Content of Majority-Opposition Comments

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.

What the Roadless Rule has preserved over the past two-plus decades can't be rebuilt once it's gone. Please don't rescind it.

Yours sincerely,

CommentID: RLC-20260907-DCQ5KU

"Inventoried roadless areas provide large, relatively undisturbed blocks of habitat for a variety of terrestrial and aquatic wildlife and plants, including hundreds of threatened, endangered, or sensitive species. Many inventoried roadless areas function as biological strongholds and refuges for a number of species, and they play a key role in maintaining native plant and animal communities and biological diversity."
— USDA Forest Service

“Modeled erosion estimates at forestry stream crossings ranged from less than 0.1 to 381.4 Mg ha-1 y-1. USDA NRCS cites a road construction site erosion rate of 897 Mg ha-1 y-1. Soil erosion rates at forestry stream crossings can be significantly reduced through the implementation of BMPs. Maximum erosion values for haul roads were 191.9 Mg ha-1 y-1, similar to maximum erosion rates observed in legacy road studies. — Journal of Soil and Water Conservation, 2022 (https://doi.org/10.2489/jswc.2022.00110)”

“Decreased habitat connectivity has numerous well-documented effects on freshwater fish populations and communities and is recognized as a leading cause of declining freshwater diversity. The cumulative effects of small barriers such as culverts may collectively far exceed those of dams. Januchowski-Hartley and others (2013) and Diebel and others (2015) documented a ratio of 38 times and 24 times more culverts than dams in two separate North American watersheds. — U.S. Geological Survey Scientific Investigations Report, 2024 (https://doi.org/10.3133/sir20235132)”

“Warming trends were prevalent during summer and early fall months in recent 20- and 40-year periods (0.18–0.35°C per decade during 1996–2015 and 0.14–0.27°C per decade during 1976–2015). Future warming of 1–3°C would reduce thermally suitable riverine trout habitats by 8–31% while causing their upstream shift. — USDA Forest Service, Rocky Mountain Research Station, 2018 (https://doi.org/10.1002/tafs.10059)”

“Executive Order 11988 requires agencies to avoid, to the extent possible, the long- and short-term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative. Each agency shall provide leadership and shall take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and welfare, and to restore and preserve the natural and beneficial values served by floodplains in carrying out its responsibilities for (1) acquiring, managing, and disposing of Federal lands, and facilities; (2) providing federally undertaken, financed, or assisted construction and improvements; and (3) conducting Federal activities and programs affecting land use. Before taking an action, each agency shall determine whether the proposed action will occur in a floodplain — for major Federal actions significantly affecting the quality of the human environment, the evaluation required below will be included in any statement prepared under Section 102(2)(C) of the National Environmental Policy Act. — Federal Interagency Floodplain Management Task Force / Water Resources Council (https://asfpm-library.s3-us-west-2.amazonaws.com/General/Implementing_Guidelines_for_EO11988_13690_08_Oct15_508.pdf)”

The Rule should be retained; no adequate basis for rescission appears in this record.

With gratitude,

Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer.

As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires.

“Early quantitative analysis showing roadless areas substantially complement biodiversity conservation, with many roadless areas overlapping areas important for imperiled species. — DeVelice & Martin, 2001 (https://doi.org/10.1890/1051-0761(2001)011[1008:ATETWR]2.0.CO;2)”

Quantified Caribou Sensitivity in the Biological Assessment (1% Roads → 42% Decline) Never Carried Into the DEIS Effects Analysis

The Draft Biological Assessment for USFWS species states at page 66: "The research predicts that for every 1% increase in roads in the matrix habitat, there will be a 42% decline in southern mountain caribou abundance (Lochhead et al. 2022)." This is the agency's own screening document quantifying an extraordinary sensitivity of a listed species to precisely the activity the rescission would newly allow — yet the DEIS's effects analysis nowhere presents, applies, or even acknowledges this ratio in evaluating alternatives. NEPA requires that an EIS contain "a reasonably thorough discussion of the significant aspects of the probable environmental consequences," and general statements do not substitute for the quantified analysis the agency itself possesses. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1213 (9th Cir. 1998); Klamath-Siskiyou Wildlands Ctr. v. Bureau of Land Mgmt., 387 F.3d 989 (9th Cir. 2004). I request that the DEIS incorporate the Biological Assessment's quantified road-density findings for southern mountain caribou into its species effects analysis and disclose the projected consequences of foreseeable road construction in affected matrix habitat.

The Department's consideration of this comment and its underlying position — that the Rule should be retained — is appreciated.

Best regards,

CommentID: RLC-20260909-RGD2QJ

Regarding the Potato Island in the Chippewa National Forest, Minnesota:

ESA Section 7 mandates conference with USFWS whenever a federal action may affect a Proposed Threatened species. Monarch (Danaus plexippus, G4, PT) is documented in the Potato Island IRA, Chippewa National Forest — rescission is the federal action, and the consultation obligation is statutory, not discretionary.

The Roadless Rule currently functions as the barrier preventing activities that may affect Monarch (Danaus plexippus, PT) in the Potato Island IRA. Roads are not built because the rule prohibits them. Timber is not harvested because road access is unavailable. Rescission removes that barrier and enables the full suite of habitat-altering activities.

The DEIS must include the results of conference with USFWS for Monarch (Danaus plexippus, PT) in the Potato Island IRA, including any biological opinion and incidental take statement. Absent this documentation, the record does not demonstrate compliance with ESA Section 7.

"Increased road density and access into remote areas can lead to increased hunting, trapping, fishing, poaching, disturbance to wildlife, trampling and other direct human impacts on biodiversity in forest and aquatic ecosystems. Impacts of roads and linear clearings on tropical forests include elevated tree mortality, altered species composition, invasion of disturbance-adapted species, and reduced understory bird abundance extending hundreds of meters from road edges."
— Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Laurance et al. 2009, 2009

“Protected areas of natural vegetation effectively cool the land surface temperature, particularly the daily maximum temperature in the tropics, and reduce diurnal and seasonal temperature ranges in boreal and temperate regions. Daily maximum land surface temperature of protected tropical forests is 4.71°C ± 0.06°C lower than that of croplands. The warming rate in protected boreal forests is up to 20% lower than in their surroundings. Nonprotected areas with the same type of vegetation as protected areas show reduced warming buffer capacity, highlighting the importance of conservation to stabilize the local climate and safeguard biodiversity. — Science Advances, 2022 (https://doi.org/10.1126/sciadv.abo0119)”

“Changes in human footprint drive changes in species extinction risk. One stark forecast is that 25 million km of new roads will be built globally by 2050, threatening many intact areas. It is clear that many intact forests are under severe and rising pressure, and there is an urgent need for greater conservation efforts. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Di Marco et al. 2018, 2018 (https://doi.org/10.1038/s41467-018-07049-5)”

The proposed rescission should not be finalized; the Roadless Area Conservation Rule should remain effective.

With resolve,

CommentID: RLC-20260824-QZAYC4

The 2001 Roadless Rule protects some of the last large, unfragmented habitat blocks in the National Forest System, supporting clean drinking water, fish and wildlife habitat, and refuge for threatened and endangered species that depend on connected, low-disturbance landscapes. Roads fragment habitat, introduce invasive species, increase stream sedimentation, and degrade interior forest habitat well beyond their footprint. Delegating these decisions to individual forest-level plans risks a patchwork of outcomes where cumulative habitat loss is never evaluated at a landscape or national scale.

Tribal Impact

The Department's own record shows the majority of Tribal governments consulted oppose this rescission, citing threats to inherent rights, sovereignty, cultural survival, and the ecological health of ancestral homelands. Tribes report that removing national protections shifts the burden of project review onto Tribal governments with limited resources and exposes sacred sites, gathering areas, and subsistence resources to industrial activity without adequate government-to-government consultation. The Department should honor its trust responsibility, seriously consider Tribal proposals for co-management and Traditional Ecological Knowledge, and complete a full ANILCA Section 810 subsistence review for Alaska before any final action.

Recreation Impact

Roadless areas provide some of the last opportunities for quiet, remote, and self-reliant recreation — hiking, hunting, fishing, and backcountry travel — that depend on the absence of roads and development. The Department's own analysis acknowledges trade-offs with these recreation values, increased user conflicts, and an estimated $6.1 million in annual lost economic benefit to recreationists in operable areas alone. That value, once roads are built, is difficult to restore and should not be discounted against the modest, uncertain gains projected from expanded timber and road access.

Wildfire Impact

I do not agree that rescinding the rule is necessary or effective for wildfire management. New roads increase human access into remote areas, and human activity is the leading cause of wildfire ignitions nationwide — meaning more roads can increase risk in the very areas this rule protects. The existing rule already allows exceptions for genuine forest-health needs. The Department has not shown that the limited acreage newly opened to treatment would meaningfully reduce wildfire risk relative to the carbon, habitat, and Tribal costs of a nationwide rollback. Targeted fuels reduction near the wildland-urban interface can continue without eliminating roadless protections system-wide.

Conclusion

I urge the Department to withdraw this proposal and retain the existing nationwide roadless protections. The rule would trade well-documented, long-term carbon, habitat, Tribal, and recreational values for benefits the Department's own analysis describes as modest, uncertain, and localized. Please enter this comment into the public record for Docket No. FS-2025-0001.

The DEIS treats 2,332 inventoried roadless areas as interchangeable units for purposes of impact analysis, but the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest has distinct ecological conditions that produce site-specific impacts no programmatic document captures.

The DEIS must provide site-specific NEPA analysis for the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest, as required by 40 CFR 1502. A programmatic assessment of 2,332 roadless areas does not satisfy the requirement for analysis proportional to site-specific impacts.

"Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. Activities in waters of the United States regulated under this program include fill for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports) and mining projects. Section 404 requires a permit before dredged or fill material may be discharged into waters of the United States, unless the activity is exempt from Section 404 regulation (e.g., certain farming and forestry activities). The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment or (2) the nation's waters would be significantly degraded."
— U.S. Environmental Protection Agency

The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling.

As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires.

“Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Research - Wildlife Habitat”

“Tongass roadless areas contain very large biomass and soil carbon stocks, underscoring old-growth protection as a critical climate solution with global significance. — Research - Climate Solutions”

Rescission action is opposed; the Department is urged to allow the Rule to stand.

With respect,
Catherine

Headwater streams in the Middle Prong Addition IRA, Pisgah National Forest, support intact benthic macroinvertebrate communities, clean spawning gravel, and cold water temperatures that define high-quality aquatic habitat. These conditions are direct products of the roadless condition: no impervious road surfaces, no exposed cut slopes, no stream crossings delivering sediment to channels.

Road surfaces in the Middle Prong Addition IRA, Pisgah National Forest, would function as impervious collectors — compacted, unvegetated surfaces that shed rainfall as overland flow rather than allowing infiltration. Cut slopes expose bare mineral soil that erodes with every rain event. Fill slopes, composed of unconsolidated material pushed downhill during construction, slump and deliver sediment to drainages for decades after construction.

The DEIS must model the change in sediment yield between the current roadless condition and each action alternative for the Middle Prong Addition IRA, Pisgah National Forest. The baseline is zero road-generated sediment. The analysis must quantify, in tons per year, how much sediment each proposed road network adds to each affected stream reach.

"Modeled erosion estimates at forestry stream crossings ranged from less than 0.1 to 381.4 Mg ha-1 y-1. USDA NRCS cites a road construction site erosion rate of 897 Mg ha-1 y-1. Soil erosion rates at forestry stream crossings can be significantly reduced through the implementation of BMPs. Maximum erosion values for haul roads were 191.9 Mg ha-1 y-1, similar to maximum erosion rates observed in legacy road studies."
— Journal of Soil and Water Conservation, 2022

“Pisgah National Forest was established in 1915 as the oldest national forest in North Carolina [4]. Today the Middle Prong Addition, managed within the Pisgah Ranger District, is protected under the 2001 Roadless Area Conservation Rule.”

No Action Alternative Fails to Quantify Environmental Benefits of Retention

The No Action alternative's treatment fails to quantify the environmental benefits of retaining the 2001 Roadless Rule's protections. The Purpose and Need section (pp. 18-19) describes only that the Department clarified the proposed action and used literature "to inform analysis," without presenting any quantified baseline of unfragmented habitat acreage, watershed protection metrics, or wilderness/recreation values attributable to continued retention. This is a status-quo narrative, not the comparative analysis NEPA requires: 42 U.S.C. § 4332(2)(C)(iii) mandates "an analysis of any negative environmental impacts of not implementing the proposed agency action," which necessarily requires quantifying what would be lost, not merely describing the decision process. No figure here approaches the rigor of the acreage, harvest-volume, and operability projections built for the action alternatives. Given documented links between road construction, habitat fragmentation, and invasive species spread, the agency should quantify habitat connectivity, watershed protection, and recreation/wilderness values under No Action with comparable specificity before finalizing this EIS.

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

Best,

CommentID: RLC-20260909-O8AC4T

The Tongass carries real, documented reliance interests: its old-growth stands are a major carbon sink, it sustains bald eagle and wildlife habitat, and its salmon-bearing watersheds are central to Tribal and Alaska Native subsistence, food security, and culture. USDA's own consultation record shows most Tribal governments opposed this rescission, citing threats to sovereignty and inadequate government-to-government consultation. That opposition deserves real weight, and a full ANILCA Section 810 subsistence analysis is owed before any decision affecting the Tongass moves forward.

This also isn't the first attempt to unwind roadless protections — the 2001 Rule survived exactly this kind of rollback once already, in litigation culminating in the Ninth Circuit's 2009 decision in (California ex rel. Lockyer v. USDA 575 F.3d 999). A rushed, one-size-fits-all rescission is likely to end up back in court.

I'm asking USDA to:

- Exclude the Tongass from any final rescission, or adopt a Tongass-specific framework built on Tribal co-stewardship and Traditional Ecological Knowledge (e.g., the "Strengthened Roadless Rule Alternative").
- Complete a full ANILCA Section 810 subsistence analysis for the Tongass before finalizing any rule affecting it.
- Provide Tongass-specific data justifying the wildfire/forest-health rationale, or drop it.
- Give substantial weight to the Tribal governments' documented opposition.
- Conduct forest-specific analysis for other significantly affected forests, rather than one blanket nationwide justification.

Thank you for considering my comment.

Julie Stoner
Sagaponack, New York

The agency's own record undermines its wildfire rationale. The 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." Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. Those acres are quieter and safer from ignition precisely because roads do not cross them. The places I named, stretching from the Mt. Hood National Forest to the Umpqua, offer that protection now. I ask that the agency explain how this proposal departs from its own prior findings and 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 economic case for rescission is no stronger. 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 that minimal upside, the agency's 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 and a net present value ranging from -$92 million to +$199 million. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, and the forests I named drain into those same systems. The agency cannot establish a net benefit, yet proposes to expand a road system already carrying a $6.9 billion maintenance backlog. The agency must reconcile those numbers on the record before it proceeds.

The proposal argues that state-by-state approaches can replace the national rule. But the agency's own record shows what happened the last time that argument was made. A federal appellate court reversed and remanded the district court's decision that had blocked the 2001 rule, holding: "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 within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and found it did not create de facto wilderness. The agency has not explained how its current proposal avoids the deficiencies identified the last time it tried to replace the national rule with a patchwork of local decisions. The agency must address that question directly.

The agency also argues the 2001 rule exceeded its statutory authority, a position the courts have already examined and rejected. Beyond the appellate holding above, the agency's record reflects its own prior dissatisfaction with a nationwide approach, a dissatisfaction courts declined to translate into a legal defect. The agency has not identified what has changed in the underlying law. I ask that the agency state plainly, on the record, what legal authority it now believes limits the 2001 rule, and how that position accounts for binding appellate precedent upholding it.

These forests are not abstractions. The mental health of people who live near and visit the Gifford Pinchot, the Mt. Hood, the Umpqua, and the Siuslaw depends in part on the continued existence of places that roads have not yet reached. The agency must not rescind the 2001 rule.

Sincerely,
M.D.
Portland, OR

The eight State Attorneys General (DEIS Vol. III, p. 41): "Approximately 350 major watersheds found in inventoried roadless areas serve as a source of drinking water for millions of people across the United States." The City of Walla Walla (Vol. III, p. 257): "The Mill Creek Watershed is a 36 square mile area at the upper end of the headwaters of Mill Creek and is the primary source of drinking water for over 35,000 residents… A majority of the Mill Creek Watershed lies within the area mapped as Inventoried Roadless Areas designated by the 2001 Roadless Rule." The North Carolina General Assembly (Vol. III, p. 213): "Two million North Carolinians can trace their drinking water directly to a roadless area that would lose protection under the proposed repeal." Neither "Mill Creek" nor any other named source watershed appears anywhere in DEIS Vol. I.

Two defects follow. Each requires action in the FEIS.

1. The DEIS's only statement of effect on municipal water supply under the Proposed Action is an incomplete sentence. (p. 131): "If additional road construction or timber harvest result in a decrease in water quality, and or reduce the efficacy of water treatment." The sentence states no effect, and every sentence after it in that paragraph reports population exposure rather than effect. Alternative 1's entire municipal water discussion is one sentence (p. 130).

2. The DEIS rests its no-effect framing on Clean Water Act compliance without disclosing what that compliance requires. The DEIS never mentions CWA § 401, 33 U.S.C. § 1341, under which no federal permit or license for an activity that may result in a discharge issues without certification by the State or authorized Tribe in which the discharge originates; nor CWA § 303(c), 33 U.S.C. § 1313(c), under which those water quality standards are set. The DEIS's analysis of the Proposed Action cannot support its conclusions about reasonably foreseeable road construction and harvest in these watersheds until it accounts for § 401 certification as a constraint on that activity. 7 CFR 1b.7(f)(2)(iii); 42 U.S.C. § 4332(2)(C).

The DEIS's closing move on this resource — "Most forest plans acknowledge the need for protections for municipal watersheds" (p. 131) — answers none of the two. Forest plan components are the baseline this rescission alters; the DEIS cannot rely on the protective status it is removing. The decision before the agency is whether to remove a nationwide prohibition from watersheds that supply drinking water to millions of people, and that decision is made here.

I request that the FEIS: (a) correct the incomplete effect statements at pp. 130–131 and state the agency's finding on municipal water supply for each alternative; (b) identify by name the municipal source watersheds and public water systems within or downstream of potentially affected inventoried roadless areas,(c) analyze CWA § 401 certification and § 303(c) water quality standards as constraints on the road construction and timber harvest the DEIS finds reasonably foreseeable, and disclose the effect of that constraint on the Proposed Action's stated purpose and need.

Thank you for the opportunity to provide public comment.

After seeking and receiving over one and a half million comments to develop the roadless rule, why should this generatation/administration change it? I have two sons who are enthusiasts of wild places. One a photographer, the other a fly fisherman. These roadless areas need to remain roadless so their children, and possibly your own grandchildren, can inherit and experience them.

Clean water for over 7,000 cities comes from the watersheds the encompass roadless areas. I have family that lives in Bend and drinks water from the Deschutes watersheds. Bend is a growing city that is surrounding by recreational opportunties and clear flowing streams and rivers. "Muddying the water" is dangerous for the ecosystem, the people and the outdoor recreation economy it supports.

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.

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,
Katherine Fuller
Newport, Oregon

human-caused ignitions increase near roads. The Economic Analysis concedes more road access could increase wildfires. And 1.8 million acres of hazardous fuels reduction occurred inside roadless areas under the rule. I ask the Final EIS to reconcile these findings with the purpose and need, and to quantify any net fire-risk benefit of new roads rather than assert one.
2.National rankings hide effects in steep, wet, unstable Western Cascades terrain. Whatcom County's portion of this forest holds roughly 91,000 roadless acres, including North Fork Nooksack headwaters, and the Mt. Baker West roadless area includes part of Bellingham's municipal watershed. Harvest and road-building in the Canyon Creek drainage in the 1950s-70s contributed to debris floods that destroyed homes west of Glacier in the 1990s. The forest already has roughly 2,000 miles of road, and the DEIS reports road maintenance funding below 20 percent of need. Yet the DEIS describes road effects only as "more likely" or "less likely," with no projected road miles, sediment, or landslide risk by region, though it quantified roads for the Tongass. I ask the Final EIS to provide regional projections of road construction and their effects on sediment, slope stability, drinking water, and salmon habitat, including rain-on-snow and unstable-slope terrain in the North Cascades.
3.The analysis should account for the health value of unroaded settings. Primitive and semi-primitive recreation settings are among the rule's nine roadless characteristics. Clinically, their therapeutic value depends on sustained quiet, absence of engine noise, and an intact landscape, conditions that help clients, especially young people, settle out of a stress response. Research agrees: a study of nearly 20,000 people found about two hours a week in nature was associated with better health and wellbeing (White et al., 2019, Scientific Reports), and weekly awe walks increased positive emotion and reduced daily distress in older adults (Sturm et al., 2020, Emotion). Roads and logging remove exactly these qualities; a roaded forest is not a substitute. I ask the Final EIS to analyze effects on primitive settings specifically and address their public health benefits in the Cost Benefit Analysis.
4.Forest plans are not a substitute for a binding rule. The DEIS relies on plans as the remaining protection, yet states plans "do not compel action or authorize projects" and future decisions depend on local interpretation. Its plan-restriction figures also merge binding standards with non-binding guidelines. I ask the Final EIS to separate the two and disclose, by forest, including the Mt. Baker-Snoqualmie, how many roadless acres would retain binding prohibitions on roads and timber harvest.
By the DEIS's own count, about 99 percent of comments on the Notice of Intent opposed rescission. I urge the Forest Service to adopt Alternative 1 and keep the 2001 Roadless Rule.
Matthew Fogarty, Bellingham, WA

The Department's obligation to the interests reflected above remains, in my view, best discharged by leaving the Rule intact.

Regarding the Drift Creek in the Siuslaw National Forest, Oregon:

Rescission of the Roadless Rule strips the regulatory protection that currently maintains Pacific Northwest Moist Douglas-fir Forest (83.8%, ~5,304 acres) in the Drift Creek IRA, Siuslaw National Forest, as climate refugia for Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2, PE). This species faces 11 - Climate change & severe weather at Pervasive (71-100%) scope — rescission removes the policy mechanism that preserves the refugia mitigating that documented threat.

The Drift Creek IRA's intact condition sustains the refugia function that buffers Suckley's Cuckoo Bumble Bee (Bombus suckleyi) against climate stress. Roadless areas maintain cooler microclimates, more stable hydrology, and greater habitat connectivity than roaded landscapes — these are not incidental benefits but the specific mechanisms by which Pacific Northwest Moist Douglas-fir Forest shelters this species from 11 - Climate change & severe weather.

The agency's NOI acknowledges climate-driven stresses on Inventoried Roadless Areas. The DEIS must follow that acknowledgment to its logical conclusion and analyze how road construction in the Drift Creek IRA, Siuslaw National Forest, degrades the climate refugia that Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2, PE) depends on — the agency cannot acknowledge the stresses and then ignore how rescission compounds them.

"Higher elevations, taller canopies, and greater canopy cover promoted cooler maximum temperatures in stands used for roosting by California spotted owls. Roosts at low elevations consistently exceeded physiological thresholds when temperatures were warm, potentially explaining vacancies in low elevation territories with more open forest. For spotted owls to persist in warming environments, conserving tall, closed-canopy forests that promote cooler microclimates for roosting is critical."
— ScienceDirect / Biological Conservation, 2023

Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole.

“Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Research - Fire Safety”

My comments are respectfully submitted in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule.

Regards,

CommentID: RLC-20260823-FH1M8Z

The agency must use the best available scientific data — including NatureServe conservation status ranks and IUCN-CMP threat classifications — when analyzing impacts of rescission on Bog Turtle (Glyptemys muhlenbergii) in the Tusquitee Bald IRA.

"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

The Rule has served as a stable policy framework for more than two decades; the Department should not disturb it.

Most respectfully,
Maretta Mott

CommentID: RLC-20260826-ZLMUYK

Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Carolina Northern Flying Squirrel (Glaucomys sabrinus coloratus) in the Bearwallow Inventoried Roadless Area, including the documented threat of 8.1 - Invasive non-native/alien species/diseases.

"On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches)."
— Iranian Journal of Environmental Health Science & Engineering (PMC), 2013

“We document over a one-quarter decline in bird abundance and almost complete avoidance by some species between noise-on and noise-off periods along the phantom road and no such effects at control sites—suggesting that traffic noise is a major driver of effects of roads on populations of animals. We replicated the sound of a roadway at intervals during the autumn migratory period using a 0.5 km array of speakers within an established stopover site in southern Idaho. — Proceedings of the Royal Society B: Biological Sciences (PMC), 2013 (https://doi.org/10.1098/rspb.2013.2290)”

“From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar. — Ecology and Evolution (PMC), 2014 (https://doi.org/10.1002/ece3.1049)”

“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 (https://doi.org/10.1016/j.biocon.2010.02.009)”

The Department is asked to close this rulemaking without rescinding the 2001 Roadless Area Conservation Rule.

With hope,

CommentID: RLC-20260902-WI0SYY

exponentially increase them. Wildfires have become such a catastrophic disaster in the United States that we cannot risk any further chances. This is not just an environmental issue, it is a public health and safety issue. This summer we experienced days and weeks of unhealthy air quality that was entirely caused by wildfire smoke, as reported by NASA. Rescinding this rule to help provide more wildfire mitigation and management is incoherent. To elaborate, the 2023 report from the Wildland Fire Mitigation and Management Commission never mentioned or alluded to the Roadless Area Conservation Rule. Moreover, there is no clear evidence that this rule has interfered with wildfire management as there is an exception to the timber harvesting restriction to which it serves as an active management to improve the ecosystem. Projects that have taken place since 2001 include: “biomass removal, broadcast burning, herbicide applications, chipping, crushing, prescribed fire, grazing, jackpot burning, lop and scatter, machine piling, machine pile burning, mastication and mowing, and thinning…” (Eisen, 2025). These are practices that have all proven to be effective when it comes down to reducing wildfire intensity, a common concern in wilderness areas. Fiscally speaking, implementing more roads is not only an environmental concern, it's an economic concern. The Forest Service is currently $6.9 million behind on road maintenance and adding more road systems will only further exacerbate this problem. Many of these roadless areas contain very harsh terrain in which it would be very costly to construct a roadway. Extractionary projects will likely follow after the repeal of this rule and those processes will not bring a net positive sum of money. The Forest Service has even noted that the revenue from timber would not be sufficient to cover the cost of maintaining and constructing all new roads. Furthermore, the time to prepare any extractionary process is often endless when it involves widespread road construction. Obtaining multiple Environmental Impact Statements adds to this timeline. In our society, time is money and to reduce the burden on the average taxpayer we should not expose them to engagements that the United States is not financially prepared for. Due to the reasons stated above, fully or partially rescinding the Roadless Area Conservation Rule under Alternatives 2 and 3 of the draft Environmental Impact Statement would be a detrimental mistake. To conclude, I oppose the proposal to rescind or alter the Roadless Area Conservation Rule and I am in full support of Alternative 1, the No Action alternative.

losing comrades (American Psychiatric Association [APA], 2013). “PTSD is one of the most prevalent psychiatric disorders affecting veterans in the United States (U.S.), with nearly one in three veterans developing PTSD” (U.S. Department of Veterans Affairs, 2021).
The National Environment Education Foundation (NEEF) supported by the USDA Forest Service funds initiatives and programs “that recognize the benefits of therapeutic adventures for healing and as a symptom reducer of PTSD and depression among service-connected disabled veterans, active duty and first responders”, stating “how time in nature - paired with peer support and intentional programing - can restore wellbeing, build community, and create lasting pathways for engagement with public lands”.
Remote areas within the Cleaveland National Forest including Sill Hill (3717ft) and Eagle Peak (3226ft), both of which are bordered by Boulder Creek, Cedar Creek and Kelly Creek, are unique wilderness areas that we use for these therapeutic adventures and education. The indigenous lands of the Cuyamaca Mountain Range offer a unique experience of healing not only to our brave service people but a chance to recognize the importance of safeguarding such an important watershed, supplying water to El Capitan Reservoir and San Diego’s population. Preserving these areas from logging and population is crucial for keeping our clean water supply. According to the Journal of Soil and Water Conservation, “Logging roads have been linked to great increases in erosion rates and sediment delivery to streams – up to 850% over rates in undisturbed habitat” (Della Sala, D.A., Karr, J.R., Olson, DM.,2011 • Journal of Soil and Water Conservation).
Tribal lands will be affected by rescinding the Roadless Rule. The Inaja and Cosmit is territory of the Inaja Band of Diegueno Mission Indians, a sovereign Tribal nation of Kumeyaay indigenous people. The DEIS concedes that the legally required Tribal consultation process has garnered widespread Tribal opposition to the repeal, stating that “the majority sentiment among Tribal governments consulted is opposition to the proposed recission of the 2001 Roadless Rule, viewing it as a threat to inherent rights, Tribal sovereignty and the ecological health of ancestral lands” (site page 53828-32). According to roadlessrule-tribal-hub.org, the Kumeyaay Tribes express opposition to the repeal of the Roadless Rule, emphasizing its importance for protecting the environment and maintaining safe, clean drinking water for San Diego’s population. The DEIS also acknowledges that “road construction and logging could potentially have long-term negative impacts” on historic and archaeological sites nationwide.

In essence, the connection between our very souls and undisturbed wilderness cannot be overlooked. These areas offer more value and protection than meet the eye on a map. As someone who has been out on the land on foot, it is eye-opening to see the immense beauty and balance of nature in undisturbed areas. Areas of wilderness are a dwindling resource that must be protected for our world's well-being. These areas can never be regained once they are lost to population or commercial advancement, so we implore you to select Alternative 1., and keep the Roadless Area Conservation Rule in its entirety.
Thank you for considering this appeal.
Sincerely,
Eloise Connolly

If the Roadless Rule is causing a specific problem with fire management, community access, infrastructure, or something else, identify the problem and deal with it. That makes a lot more sense than throwing out the entire rule.

The pace of this process is another red flag. The Roadless Rule has been in place for twenty-five years. Something with that much history and that much effect on national forest management should not be undone through rushed public comment periods, especially while the Tongass is already in the middle of rewriting its Forest Plan.

I am not opposed to active management of the Tongass. I am opposed to removing an existing management rule before we even know what is going to replace it.

For the Tongass, finish the Forest Plan first. Let the people who live, work, fish, hunt, and raise families here have a real say in what that plan looks like. Then deal with the Roadless Rule based on that work.

Removing the rule first and figuring out the consequences afterward is backwards.

Patrick Baum
Juneau, Alaska

The wildfire rationale does not hold together either. The agency's own statement of what this rulemaking is for reads: "The purpose and need is to reduce regulatory burden and return decisionmaking to local officials." Fire is not the legal basis. And when the agency looked honestly at the overlap between roadless areas and wildland-urban interface as defined by HFRA, it found that "Overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and and the DEIS says the benefits of added fuel-management access 'would likely be modest and localized.'" The agency built a WUI-targeted alternative that would have answered the fire argument without erasing protections everywhere else, then rejected it. I want to know why. The agency should explain on the record why nationwide rescission was chosen over the targeted alternative it constructed and then discarded.

The exceptions argument is circular and the agency knows it. The 2001 rule was designed so that exceptions would be rare. They were rare. The agency now treats their rarity as a sign that the rule failed, in the same document that concedes "the rule's intent for infrequent use." A rule working exactly as designed is not a defect. It is evidence of success. The agency should publish the counts of exception requests, approvals, denials, and processing times so the public can evaluate whether the exceptions process was actually broken or simply used as intended.

Clean water is part of the public good. It is not incidental. The agency's own numbers are stark: "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 low impairment rate is not an argument for removing protections. It is the result of having protections. The agency's own data also shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Opening these watersheds to road construction puts that impairment rate at risk. The DEIS gestures at forest plans as a substitute safeguard without pointing to a single enforceable provision. The agency must identify, forest by forest, which plan provisions are the functional equivalent of 36 CFR 294.12 and 294.13 for municipal watersheds. Asserting that plans are adequate is not the same as showing it.

Roadless areas are part of what makes public land public in any meaningful sense. They are spaces the public can enter without the land having already been committed to extraction. Rescinding this rule does not return anything to the public. It removes a protection the public has had for more than two decades. The agency should not finalize this rescission.

Sincerely,
Tara Brown
Bodega Bay, CA

References Cited

Blackstock, Michael. “Water: A First Nations’ Spiritual and Ecological Perspective..” Journal of Ecosystems and Management, vol. 1, no. 1, 4 Dec. 2001, pp. 9–11, https://jem-online.org/index.php/jem/article/view/216/135, 10.22230/jem.2001v1n1a216. Accessed 29 Sept. 2026.
Kiklis, Beau, and Nik Moy. “6 Reasons to Keep the ‘Roadless Rule’ in Place.” National Parks Conservation Association, 4 Sept. 2025, https://www.npca.org/articles/10475-6-reasons-to-keep-the-roadless-rule-in-place. Accessed 26 Sept. 2026.

TCS. “Taxpayer Analysis of Proposed 2001 Roadless Rule Rescission - Taxpayers for Common Sense.” Taxpayers for Common Sense, 10 Sept. 2026, https://www.taxpayer.net/energy-natural-resources/taxpayer-analysis-of-proposed-2001-roadless-rule-rescission/. Accessed 29 Sept. 2026.

Rescinding the 2001 Rule opens the door to the potential for and anti-environmentalist and/or denier administration to appoint individuals with the power to cause irrevocable harm to pristine roadless areas without adequate guardrails or checks and balances.

Another important duty of our government is to increase public land ownership in wilderness and multifunction areas to protect or allow public use and access. Once developed, most of this land is forever lost to the public.

My input is just one of a preponderance of comments advocating that RIN 0596-AD66 be killed in favor of protecting the 2001 Rule.

regretted by the American people, and the leaders and politicians who supported it will have this disgraceful act taint the rest of their career.

I am also concerned about the proposed changes to practice-expense methodology and their disproportionate effect on ophthalmology. Retina is particularly dependent on sophisticated diagnostic technology and procedure-intensive care. A methodology that produces an additional substantial reduction in ophthalmology reimbursement risks affecting access to precisely the services that allow us to prevent irreversible vision loss.

CMS should also reconsider the site-of-service practice-expense reductions affecting surgery performed in hospitals and ambulatory surgery centers. The physician work and responsibility required to perform retinal surgery do not decrease simply because the procedure occurs in a facility rather than an office. Payment methodology should not inadvertently undervalue physicians who care for patients requiring facility-based surgical treatment.

I strongly oppose the proposal to reduce payment by 50% for the lower-valued service when a separately identifiable E/M service, reported with modifier -25, is provided on the same day as a procedure. In retina practice, this distinction is particularly important. A patient may present for evaluation of a new visual complaint or meaningful change in retinal disease and, based on that evaluation, require a procedure that same day. The examination and medical decision-making are real, clinically necessary services; they do not become half as valuable simply because appropriate treatment is subsequently performed. Penalizing same-day evaluation and treatment could create incentives to separate care into multiple visits, increasing inconvenience and potentially delaying treatment for Medicare beneficiaries.

I also encourage CMS to restore appropriate valuation of postoperative care included within global surgical packages. Physicians should be compensated consistently for equivalent E/M work, including medically necessary postoperative care bundled into surgical services.

Finally, I urge CMS to preserve reasonable flexibility within MIPS and the Quality Payment Program and to avoid transitions that create additional administrative burden without demonstrable improvements in patient outcomes.

As a retina specialist, I see directly what is at stake when access to ophthalmic care is delayed. For diseases such as neovascular age-related macular degeneration, diabetic retinopathy, retinal vascular disease, and retinal detachment, delays can translate into irreversible loss of vision. Medicare payment policy should support—not unintentionally undermine—the infrastructure required to diagnose and treat these patients promptly.

I respectfully ask CMS to reconsider these provisions and adopt a 2027 Physician Fee Schedule that maintains sustainable physician reimbursement, appropriately values physician work and practice expense, and protects Medicare beneficiaries’ access to ophthalmic care.

Thank you for considering my comments.

Sincerely,
Aya Barzelay-Wollman, MD, PhD
Assistant Professor of Ophthalmology
Retina Division, Jules Stein Eye Institute
UCLA

Employment does not always end through a single, uniform event. An employee may receive advance notice of termination, stop performing productive work while remaining on payroll, enter a paid notice period, use accrued leave, remain on benefits, or receive salary continuation or severance. The date duties end, the date payroll ends, the employer-designated termination date, and the date immigration-related notice is provided may differ.

If DHS intends immediate failure to maintain status to occur after “cessation,” the triggering event should be defined with sufficient precision that workers, employers, adjudicators, and reviewing courts can identify the same date prospectively.

Second, has DHS evaluated the increase in adjudicative error costs created by eliminating the grace period?

Under the present framework, a disagreement of several days concerning the termination date frequently does not alter the outcome because the subsequent filing remains within the 60-day period.

Under the proposed framework, even a one-day error could become outcome-determinative.

The underlying evidentiary problem therefore remains, while the legal consequence of error becomes substantially greater.

If DHS believes the proposal will reduce administrative burden, it should explain why converting an uncertain date into an immediate status cutoff will not instead increase disputes over termination dates, requests for evidence, and the need for precise factual reconstruction.

Third, DHS should distinguish between eliminating a grace-period calculation and eliminating the underlying timing problem.

Even after repeal, USCIS may still need to determine precisely when employment ended whenever maintenance of status is relevant to a later petition or application. The agency would no longer ask whether a filing occurred within 60 days, but it may need to answer a harder question: exactly when did lawful maintenance of status cease?

That is not necessarily administrative simplification.

It may instead be a transfer from a forgiving timing inquiry to a high-consequence day-zero inquiry.

This issue also bears on DHS’s broader rationale that employment-based nonimmigrant status should remain closely connected to qualifying employment. Even assuming DHS may reasonably adopt that policy objective, it does not follow that a zero-day transition is operationally necessary.

There is a meaningful distinction between saying that employment is the basis of a classification and saying that any factual cessation of employment must produce immediate failure to maintain status without a transitional interval.

If immediate cessation is a policy choice rather than a statutory requirement, DHS should evaluate the administrative consequences of that choice directly rather than treating them as inherent in the structure of the statute.

For these reasons, I respectfully request that DHS not finalize categorical elimination of the grace period on the present record.

At minimum, DHS should first:

1. define an administrable event that constitutes “cessation of employment”;
2. evaluate how often that event can be identified reliably from existing records;
3. assess the error costs created when uncertainty regarding that event immediately determines maintenance of status; and
4. demonstrate that eliminating the grace period actually reduces net adjudicative burden rather than merely making the same factual determination more consequential.