2001 Roadless Rule Revision

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

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

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

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

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

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

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 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

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

The Draft Biological Assessment discloses its method — IRA shapefiles run through IPaC for the FWS list, NMFS species compiled from consultation records, both lists vetted by Forest Service staff and sent to the Services in September–October 2025, occurrence data from GBIF and NRM (BA p. 25) — but reports counts only by taxonomic group (e.g., 30 candidate bird species, 4 removed, 26 remaining, BA p. 161) and states no total. The BA also warns its databases do not differentiate between DPSs, "causing potential inflation" (p. 25). The "more than 300" figure cannot be traced to this method, and it is unclear whether it double-counts distinct population segments.

Request 1: Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count, the date it reflects, whether DPSs are counted separately, and cross-reference the BA's Species Lists section wherever the figure appears — citing the correction per 7 CFR 1b.7(f)(3).

Second, the figure does no analytical work. It appears only as background and is never tied to an effects conclusion — even though the same page states fragmentation reduces biodiversity 13–75% (Haddad et al. 2015), with effects "greatest in the smallest and most isolated fragments."

The record already supplies the missing link: Dietz et al., "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species" (2021), is in the Draft EIS's own reference list, cited in Vol. III (p. 37 n.201), and discussed at length in both the eight-state AG letter (Vol. III pp. 38–39) and the joint Tribal letter (Vol. III p. 498). Its finding: of 537 vulnerable terrestrial vertebrate species, 308 (57%) have suitable habitat in roadless areas — despite roadless areas covering only 2% of the contiguous U.S. — every roadless area holds habitat for at least two such species, and 81% of roadless acreage is suitable for at least five.

Because this study is already in the agency's record, 7 CFR 1b.7(f)(2)(iv)'s bar on literature "not previously considered" doesn't apply — the agency need only analyze science it has already adopted. The chain is undisputed: rescission lifts road and timber-cutting prohibitions across the roadless network; the Draft EIS's own fragmentation finding predicts biodiversity loss, worst in small, isolated fragments; and Dietz et al. show this network is the disproportionate habitat base for the nation's vulnerable vertebrates — so shrinking it degrades species representation in the protected-area system.

Request 2: Under 7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission's effect on representation of species of conservation concern, using the corrected figure and engaging the Dietz finding — or explain in the response to comments why record science on this point doesn't apply.

Both requests are substantive under 7 CFR 1b.11(a)(53): an unreconcilable affected-environment figure and an effects analysis that ignores a record finding are a failure to consider an important aspect of the problem, 5 U.S.C. § 706(2)(A). Both also affect the Section 7 consultation record, which rests on the same unstated baseline (BA p. 25).”

Keep roadless areas roadless.

Respectfully,

CommentID: RLC-20260916-BIKIKN

The mountains of North Carolina and the broader Southern Appalachian region are treasured not only for their beauty, but for the environmental services they provide and the recreation economy they support. Keeping these areas roadless helps preserve the character of the landscape for future generations while reducing costly and unnecessary disturbance.

I urge you to uphold the Roadless Rule and reject efforts to weaken protections for these public lands. Once roadless character is lost, it is exceedingly difficult — and often impossible — to restore. Please protect these forests, streams, and wild places for the benefit of current and future generations.

Thank you for considering my comment.

Sincerely,
Brandon Inabinet

Purpose and Need Asserts a Balancing of Competing Values Without Performing It Against the Record's Own Conservation Evidence

I request three things.

1. That the FEIS supplement the rationale for the proposed rule to state the conservation values of inventoried roadless areas as the Department's own record documents them, including the Dietz et al. (2021) findings published at Volume III page 39, and to explain why the changed conditions recited at pages 18 through 20 outweigh them. 7 CFR 1b.7(f)(2)(iii).

2. That the FEIS correct the statement at page 20 that changed conditions "diminish the basis for a national prohibition," or supply the analysis that supports it. 7 CFR 1b.7(f)(2)(v).

3. That the FEIS disclose the population served by drinking-water source watersheds within the 44.7 million acres of inventoried roadless areas, or state on the record that the Department cannot determine it.

Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire.
The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography.
I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation.

If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire.

Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom.
Do the right thing. DO NOT RECIND THE ROADLESS RULE.

All the best,

Christian Kasperkovitz

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.

Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire.
The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography.
I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation.

If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire.

Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom.
Do the right thing. DO NOT RECIND THE ROADLESS RULE.

All the best,

Christian Kasperkovitz

Basin). The DEIS mentions herbicides only for invasive-plant control, conceding they can have "unintended adverse effects" on terrestrial and aquatic species (p. 142), and never analyzes post-harvest herbicide use or its effects on source water. Fuel reduction near communities is already permitted under the 2001 Rule (36 CFR 294.13(b); DEIS Table 1, p. 14); commercial timber harvest and new road construction in source watersheds are not necessary to achieve it. At minimum, protections should be retained in municipal source watersheds.
2.Wildfire. The DEIS's own data undercut its fire rationale. Ignition density on other NFS lands is about four times that of affected IRAs (41.8 vs. 12.0 fires per million acres per year, Table 18, p. 87), and human-caused ignitions are over seven times higher (22.4 vs. 3.0, Table 21, p. 90). The DEIS concedes that "human caused ignitions increase in abundance with proximity to roads" (p. 90) and that IRAs burned a smaller share of their area (8.7% vs. 13.8%, Table 18). It also admits "a lack of roads has not prevented fire prevention or protection measures" (p. 105). Its answer to added ignitions, restricting public access to new roads (p. 105), depends on gates, closures and enforcement the agency cannot fund (see 3).
3.Fiscal responsibility. The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges, counting passenger-car roads only, and a drop in annual road appropriations from $234 million (2004) to $73 million (2024); supplemental GAOA funding expired in 2025 and IIJA funding was set to expire September 30, 2026 (p. 43). It assumes timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project" (p. 45). No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has. The agency should address the existing backlog and disclose the life-cycle cost of new roads, and how it would be paid, before removing protections.
4.Old growth and intact habitat. Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors. The DEIS finds the proposal "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats (pp. 25, 161), and that 11-16% of the operable area where plans allow harvest is old growth and 54-63% is mature forest (p. 78). It projects 253,000-557,000 ccf of added harvest per year (p. 77), yet defers site-specific analysis because future activities are "uncertain" (p. 32). The agency cannot model where the timber is while declining to analyze the harm in those same places.
I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule (Alternative 1). If any change proceeds, it should occur through state-specific rulemaking with full analysis of water supply, wildfire, fiscal and habitat impacts.
Other sources: EBMUD 2023 Annual Water Quality Report (ebmud.com); CSERC, Stanislaus NF roadless areas (cserc.org); South Tahoe Now, Caldor Fire Reforestation Project (May 4, 2026); KUNR, Tahoe herbicide concerns (May 27, 2026); Mother Jones/Reveal investigation on Forest Service glyphosate use in California (Apr. 2026).
Jeff
East Bay, CA

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 agency's own record makes clear that the economic rationale for this proposal cannot bear weight. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." We have enough roads in this country, and not enough protected lands that will help safeguard the future of this planet. That is not a sentiment disconnected from economics. The Forest Service already carries a road maintenance backlog of $6.9 billion against an annual road budget of roughly $73 million. I ask that the agency reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million, and that it explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog.

The agency argues the 2001 rule exceeded its statutory authority, but that question was litigated and decided. A federal court of appeals held, exercising jurisdiction, and I quote the ruling precisely: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. I ask that the agency explain the legal basis on which it departs from that holding.

I paddle and kayak all summer in my city and participate in regular community science water quality monitoring efforts. This is the water we drink and the places we enjoy. Rescinding protections for roadless watersheds is not an abstraction in that context. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and more than 7,000 municipal water intakes sit in watersheds fed by these areas. The proposed rule certifies no significant impact on small entities while the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. Outfitters, guides, and tour operators are named as affected in the DEIS. The certification reaches its conclusion by spreading losses across every small firm in the sector nationally rather than the businesses actually permitted in affected areas. I ask that the agency withdraw that certification and assess impact on the small entities actually operating in these roadless areas.

Puerto Rico holds 2 inventoried roadless areas totaling 23,734 acres. The El Toro Area, 12,584 acres in El Yunque National Forest, is land I have been visiting since 1999. It is also historically important Taino land, and rescinding its protection would mean losing cultural heritage that cannot be rebuilt once it is gone. The Mameyes Area, 11,150 acres in the same forest, is a place I grew up going to, one that cleans the island's limited water resources and provides protection during frequent hurricanes. These forests are not peripheral to my life or to the lives of people in Puerto Rico. They are central to both.

The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" but its Cost Benefit Analysis weighs none. Under the principles established in Encino Motorcars and Regents, an agency reversing course must account for the reliance its prior policy created. Twenty-four years of decisions about where to live, how to spend time, where to volunteer, and what places to love are made in the shadow of rules like this one. Northern Massanutten helped me connect to a new home and inspired me to volunteer in natural spaces in my community. That relationship was built in part because the protection existed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one.

Sincerely,
Andrea Contreras
San Juan, PR/ Washington, DC

The Forest Service plans to hold ANILCA Section 810 subsistence hearings on this proposal. I ask that those hearings happen before any final decision and that what families like mine say in them carry real weight. For us this is not an abstract land-use question. It is a question of where our food comes from and what will be left for our sons.

Please withdraw the proposal and leave the rule as it stands.

Sincerely,
Jenn Lawlor
Sitka, Alaska

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.

2. The wildfire rationale does not apply to the Tongass. The "Rationale" section justifies rescission with drought, wildfire, and fuel-loaded forests, "especially in the Western United States." The Tongass is a temperate rainforest where large fires are rare. Conditions in other forests should not be used to remove protections from one where they don't exist. Recommended change: Exclude the Tongass from any rescission.

3. Forest plans do not give equivalent protection. The proposal claims that land management plans address "similar conservation objectives" as the 2001 Rule. Yet it also admits that later plan amendments "could increase the area where timber harvest and road construction would be allowed." A protection that can be amended away is not equivalent to a rule. The Tongass has been exempted and restored repeatedly since 2003, which shows how fragile protection is without a durable rule.

4. Stewardship should be led by Tribes, not shifted onto them. The proposal says local decisions would be "informed by Tribes." USDA's own summary, however, reports three things. Most consulted Tribal governments oppose rescission. Tribes warn that it shifts the burden of project-level review onto their limited resources. And Tribes asked for co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent. Tribal guardian programs in Southeast Alaska [name specific programs if you can] are the right stewards for any thinning, restoration, or forest management in Tongass roadless areas. That work should not be opened to commercial timber sales and road building. Recommended change: Keep Subpart B and develop a co-stewardship framework with Tribes on the Tongass, consistent with the federal trust responsibility under E.O. 13175.

5. Subsistence review must come first. The proposal says ANILCA Section 810 subsistence hearings will be announced later. USDA should not finalize any rule until those hearings are held in Southeast Alaska communities and a full 810 analysis is complete. That analysis should include effects on salmon watersheds. The proposal's conclusion that commercial fishing would not be significantly affected has not been examined for the Tongass specifically.

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

2. The wildfire rationale does not apply to the Tongass. The "Rationale" section justifies rescission with drought, wildfire, and fuel-loaded forests, "especially in the Western United States." The Tongass is a temperate rainforest where large fires are rare. Conditions in other forests should not be used to remove protections from one where they don't exist. Recommended change: Exclude the Tongass from any rescission.

3. Forest plans do not give equivalent protection. The proposal claims that land management plans address "similar conservation objectives" as the 2001 Rule. Yet it also admits that later plan amendments "could increase the area where timber harvest and road construction would be allowed." A protection that can be amended away is not equivalent to a rule. The Tongass has been exempted and restored repeatedly since 2003, which shows how fragile protection is without a durable rule.

4. Stewardship should be led by Tribes, not shifted onto them. The proposal says local decisions would be "informed by Tribes." USDA's own summary, however, reports three things. Most consulted Tribal governments oppose rescission. Tribes warn that it shifts the burden of project-level review onto their limited resources. And Tribes asked for co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent. Tribal guardian programs in Southeast Alaska [name specific programs if you can] are the right stewards for any thinning, restoration, or forest management in Tongass roadless areas. That work should not be opened to commercial timber sales and road building. Recommended change: Keep Subpart B and develop a co-stewardship framework with Tribes on the Tongass, consistent with the federal trust responsibility under E.O. 13175.

5. Subsistence review must come first. The proposal says ANILCA Section 810 subsistence hearings will be announced later. USDA should not finalize any rule until those hearings are held in Southeast Alaska communities and a full 810 analysis is complete. That analysis should include effects on salmon watersheds. The proposal's conclusion that commercial fishing would not be significantly affected has not been examined for the Tongass specifically.

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

2. The wildfire rationale does not apply to the Tongass. The "Rationale" section justifies rescission with drought, wildfire, and fuel-loaded forests, "especially in the Western United States." The Tongass is a temperate rainforest where large fires are rare. Conditions in other forests should not be used to remove protections from one where they don't exist. Recommended change: Exclude the Tongass from any rescission.

3. Forest plans do not give equivalent protection. The proposal claims that land management plans address "similar conservation objectives" as the 2001 Rule. Yet it also admits that later plan amendments "could increase the area where timber harvest and road construction would be allowed." A protection that can be amended away is not equivalent to a rule. The Tongass has been exempted and restored repeatedly since 2003, which shows how fragile protection is without a durable rule.

4. Stewardship should be led by Tribes, not shifted onto them. The proposal says local decisions would be "informed by Tribes." USDA's own summary, however, reports three things. Most consulted Tribal governments oppose rescission. Tribes warn that it shifts the burden of project-level review onto their limited resources. And Tribes asked for co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent. Tribal guardian programs in Southeast Alaska [name specific programs if you can] are the right stewards for any thinning, restoration, or forest management in Tongass roadless areas. That work should not be opened to commercial timber sales and road building. Recommended change: Keep Subpart B and develop a co-stewardship framework with Tribes on the Tongass, consistent with the federal trust responsibility under E.O. 13175.

5. Subsistence review must come first. The proposal says ANILCA Section 810 subsistence hearings will be announced later. USDA should not finalize any rule until those hearings are held in Southeast Alaska communities and a full 810 analysis is complete. That analysis should include effects on salmon watersheds. The proposal's conclusion that commercial fishing would not be significantly affected has not been examined for the Tongass specifically.

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

The Tongass NF holds 9,339,575 acres across 110 inventoried roadless areas, with over 12,930 miles of salmon-producing streams, and is the largest intact temperate rainforest left on Earth. Under EO 14153 and the FR rescission notice, the Tongass would keep no roadless protection under either alternative. Nine municipal watersheds named in the DEIS, Ketchikan, Petersburg, Sitka, Juneau, Wrangell, Kake, Klawock, Craig, and Hydaburg, depend on that landscape. WA holds 2,014,832 acres across 139 inventoried roadless areas, with 1,522 municipal water intakes in watersheds containing affected roadless areas. I spent decades trying to repair what road-building and logging had already done to fish habitat in these two places. The USFS is now proposing to open that door again at landscape scale, and I ask that it explain what has changed in the science of sediment and fish mortality that makes that choice defensible now.

The USFS own analysis is clear on what roads do to water. The DEIS and supporting literature confirm that roads and logging contribute up to 90 percent of the sediment from a timber sale, and that sedimentation causes egg and juvenile mortality in trout and reduces suitable spawning habitat. Nationwide, more than 7,000 municipal water intakes sit in watersheds fed by these roadless areas and USFS data shows 24 million Americans rely on this drinking water. Less than 12 percent of those watersheds have impaired streams today. Rescission puts that figure at risk. The USFS must address how it weighs sediment loading that new roads will produce against present water quality its own data documents.

The wildfire justification the USFS offers is contradictory to its own data. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding sits in the same record as the rescission proposal. USFS must explain why it departs from those prior findings, and must reconcile the rescission with the ignition data in DEIS Table 21, which reports human-caused ignition density of 22.4 fires per million acres per year on roaded NFS land against the affected roadless areas across the period 2014 -2024. The DEIS further states that "human-caused ignitions increase in abundance with proximity to roads." The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against whatever reduction in wildfire hazard it claims to achieve.

The agency's maintenance deficit makes road-building irrational. The USFS is already $6.9 billion behind on maintaining the roads it has, operating on a road budget of about $73 million a year. Building new roads into country that currently has none, when existing infrastructure is failing at that scale, is not a resource management strategy. It is a liability the public will carry indefinitely.

The regulatory flexibility certification is also contradicted by the analysis beside it. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency reaches its no-impact conclusion by averaging loss rather than assessing guides and outfitters actually holding permits in the affected areas. That methodology does not satisfy the purpose of a regulatory flexibility analysis. The agency should withdraw the certification and conduct an honest assessment of the businesses that operate in roadless areas.

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. The communities, businesses, fishermen, and Indigenous peoples who have organized their lives and livelihoods around the current protections deserve to have those interests identified and weighed before the rule is erased. The agency must do that work.

Sincerely,
Dayle Wallien
Washington

plans to hold ANILCA Section 810 subsistence hearings about this proposal. I think those hearings should happen before any final decision is made, and the people who live here should actually be listened to.
This isn't just about a rule or a piece of land. It affects where our food comes from and what the Tongass will be like for people who live here in the future.
Please withdraw the proposal and keep the 2001 Roadless Rule in place.
Sincerely,
Anonymous
Sitka, Alaska

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

2. The wildfire rationale does not apply to the Tongass. The "Rationale" section justifies rescission with drought, wildfire, and fuel-loaded forests, "especially in the Western United States." The Tongass is a temperate rainforest where large fires are rare. Conditions in other forests should not be used to remove protections from one where they don't exist. Recommended change: Exclude the Tongass from any rescission.

3. Forest plans do not give equivalent protection. The proposal claims that land management plans address "similar conservation objectives" as the 2001 Rule. Yet it also admits that later plan amendments "could increase the area where timber harvest and road construction would be allowed." A protection that can be amended away is not equivalent to a rule. The Tongass has been exempted and restored repeatedly since 2003, which shows how fragile protection is without a durable rule.

4. Stewardship should be led by Tribes, not shifted onto them. The proposal says local decisions would be "informed by Tribes." USDA's own summary, however, reports three things. Most consulted Tribal governments oppose rescission. Tribes warn that it shifts the burden of project-level review onto their limited resources. And Tribes asked for co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent. Tribal guardian programs in Southeast Alaska, such ans Kake, Yakutat annd others, are the right stewards for any thinning, restoration, or forest management in Tongass roadless areas. That work should not be opened to commercial timber sales and road building. Recommended change: Keep Subpart B and develop a co-stewardship framework with Tribes on the Tongass, consistent with the federal trust responsibility under E.O. 13175.

5. Subsistence review must come first. The proposal says ANILCA Section 810 subsistence hearings will be announced later. USDA should not finalize any rule until those hearings are held in Southeast Alaska communities and a full 810 analysis is complete. That analysis should include effects on salmon watersheds. The proposal's conclusion that commercial fishing would not be significantly affected has not been examined for the Tongass specifically.

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

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

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

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

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

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

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

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

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

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.

needed fire work.
The analysis concedes roads increase ignition risk but does not weigh it. The Summary of Potential Impacts acknowledges greater access can increase human-caused ignitions. A national study of 1992-2024 data found ignition density highest near roads and among the lowest in inventoried roadless areas (Aplet et al., Fire Ecology 22:8, 2026). The Final EIS should quantify expected new ignitions on the 18.2 million acres where permanent roads could be built and weigh them against claimed suppression benefits.
Costs outweigh benefits. The agency estimates $5.2-11.4 million per year in timber revenue to the Treasury and Forest Service. Against that sit a $6.9 billion deferred maintenance backlog for roads and bridges and an estimated $6.1 million per year in lost recreation benefits. The Final EIS should identify how new roads will be maintained and funded, and the water-quality effects of roads that are not.
Foreseeable plan changes are excluded. The notice concedes later plan amendments could expand logging and roads beyond what was analyzed, yet treats them as out of scope. Given the timber and energy orders cited as this action's purpose, such amendments are reasonably foreseeable effects and must be analyzed.
The analysis relies on narrowed ESA protections. The notice states local decisions remain subject to the ESA. But FWS and NMFS have since rescinded the regulatory definition of "harm," so habitat modification alone generally no longer constitutes take under Section 9. Section 7 consultation still applies to designated critical habitat, but listed species' habitat outside those designations has lost that protection. The Final EIS must analyze how this change affects its reliance on the ESA.
Disposal risk. In 2025, a Senate committee's draft budget bill would have mandated the sale of millions of acres of Forest Service and BLM land and did not exclude inventoried roadless areas. Removing national protection and fragmenting these areas with roads would make them easier to justify for sale. The final rule should state that rescission is not intended to facilitate disposal. Any future disposal should require full public process, including disclosure of the buyer.
Process. The 2001 Rule followed more than 600 public meetings and 1.6 million public comments. This rescission has offered a 21-day scoping period and a 45-day comment period, with public hearings only in Alaska. That is inadequate for 45 million acres of public land.

These are public lands, owned by the United States on behalf of all its people. Please retain the 2001 Roadless Rule.

Respectfully submitted.

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.

The agency's economic justification does not survive contact with the agency's own numbers. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those figures describe a marginal economic contribution, not a national imperative. Yet the agency presses forward while its own Cost Benefit Analysis projects timber revenue to the Forest Service of only $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. That range cannot establish a net benefit, and the road system the proposal would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile this proposal with those figures and explain, with specificity, how an action whose own analysis cannot demonstrate a positive return justifies enlarging a deferred-maintenance burden of that magnitude.

The administrative burden rationale fares no better, because the rule already accommodates the agency's stated concerns through its written exceptions. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Existing mineral leases and community wildfire protection are among the circumstances the rule already addresses. Before rescinding protections that make the quiet, roadless country worth reaching, the agency should be required to identify, by category and with quantified evidence, which specific burdens the existing exceptions do not address. That identification and that quantification belong in this record.

The regulatory flexibility analysis fails the small businesses whose operations the rule shapes most directly. 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. Spreading that loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected roadless areas, produces a number that conceals the real distribution of harm. The agency should withdraw the certification and replace it with an assessment grounded in the firms that actually operate in these places, not a national average that obscures the impact on those most exposed.

Finally, the agency invited comment on reliance interests and then built a Cost Benefit Analysis that weighs none of them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My own plans, and those of the friends I hike and backpack with, are built around the continued existence of protected roadless areas. When a rule has stood long enough to shape how people orient their lives toward the land, the agency changing course is obligated to take those interests seriously. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken.

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

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

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

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

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

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

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

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

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

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

The agency frames this rescission partly as a permitting and administrative burden argument. But the rule already accommodates the activities most often cited. 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)." The agency should identify, by specific category, which burdens are not already addressed by these existing exceptions, including those covering existing mineral leases and community wildfire protection, and it should quantify those burdens with evidence rather than assertion.

I hunt and fish because I believe in the value of the animals and in leaving something intact. The agency's own document acknowledges what roads do to that. The DEIS states 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." That finding appears in the agency's record and then stops there. No population-level projection follows. No estimate of what opening roadless areas means for elk numbers or hunter opportunity appears anywhere in the document. The agency must project those effects before it acts.

The DEIS acknowledges that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then set aside. It is never applied to the 40.1 million acres of potentially affected environment that this rescission puts in play. A number that wide, across an area that large, is not a footnote. It is the central question. The agency must apply that cited fragmentation range to the full 40.1 million acres and show what the consequences actually look like before this rule is eliminated.

Uncontrolled damage is irreversible. The agency has not shown that the benefits of rescission outweigh that fact. I ask that it answer each of these points in the record and reconsider this action.

Sincerely,
A concerned citizen

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.

Basin). The DEIS mentions herbicides only for invasive-plant control, conceding they can have "unintended adverse effects" on terrestrial and aquatic species (p. 142), and never analyzes post-harvest herbicide use or its effects on source water. Fuel reduction near communities is already permitted under the 2001 Rule (36 CFR 294.13(b); DEIS Table 1, p. 14); commercial timber harvest and new road construction in source watersheds are not necessary to achieve it. At minimum, protections should be retained in municipal source watersheds.
2.Wildfire. The DEIS's own data undercut its fire rationale. Ignition density on other NFS lands is about four times that of affected IRAs (41.8 vs. 12.0 fires per million acres per year, Table 18, p. 87), and human-caused ignitions are over seven times higher (22.4 vs. 3.0, Table 21, p. 90). The DEIS concedes that "human caused ignitions increase in abundance with proximity to roads" (p. 90) and that IRAs burned a smaller share of their area (8.7% vs. 13.8%, Table 18). It also admits "a lack of roads has not prevented fire prevention or protection measures" (p. 105). Its answer to added ignitions, restricting public access to new roads (p. 105), depends on gates, closures and enforcement the agency cannot fund (see 3).
3.Fiscal responsibility. The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges, counting passenger-car roads only, and a drop in annual road appropriations from $234 million (2004) to $73 million (2024); supplemental GAOA funding expired in 2025 and IIJA funding was set to expire September 30, 2026 (p. 43). It assumes timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project" (p. 45). No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has. The agency should address the existing backlog and disclose the life-cycle cost of new roads, and how it would be paid, before removing protections.
4.Old growth and intact habitat. Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors. The DEIS finds the proposal "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats (pp. 25, 161), and that 11-16% of the operable area where plans allow harvest is old growth and 54-63% is mature forest (p. 78). It projects 253,000-557,000 ccf of added harvest per year (p. 77), yet defers site-specific analysis because future activities are "uncertain" (p. 32). The agency cannot model where the timber is while declining to analyze the harm in those same places.
I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule (Alternative 1). If any change proceeds, it should occur through state-specific rulemaking with full analysis of water supply, wildfire, fiscal and habitat impacts.
Other sources: EBMUD 2023 Annual Water Quality Report (ebmud.com); CSERC, Stanislaus NF roadless areas (cserc.org); South Tahoe Now, Caldor Fire Reforestation Project (May 4, 2026); KUNR, Tahoe herbicide concerns (May 27, 2026); Mother Jones/Reveal investigation on Forest Service glyphosate use in California (Apr. 2026).
Jeff
East Bay, CA

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 agency's economic justification does not survive contact with the agency's own numbers. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those figures describe a marginal economic contribution, not a national imperative. Yet the agency presses forward while its own Cost Benefit Analysis projects timber revenue to the Forest Service of only $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. That range cannot establish a net benefit, and the road system the proposal would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile this proposal with those figures and explain, with specificity, how an action whose own analysis cannot demonstrate a positive return justifies enlarging a deferred-maintenance burden of that magnitude.

The administrative burden rationale fares no better, because the rule already accommodates the agency's stated concerns through its written exceptions. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Existing mineral leases and community wildfire protection are among the circumstances the rule already addresses. Before rescinding protections that make the quiet, roadless country worth reaching, the agency should be required to identify, by category and with quantified evidence, which specific burdens the existing exceptions do not address. That identification and that quantification belong in this record.

The regulatory flexibility analysis fails the small businesses whose operations the rule shapes most directly. 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. Spreading that loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected roadless areas, produces a number that conceals the real distribution of harm. The agency should withdraw the certification and replace it with an assessment grounded in the firms that actually operate in these places, not a national average that obscures the impact on those most exposed.

Finally, the agency invited comment on reliance interests and then built a Cost Benefit Analysis that weighs none of them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My own plans, and those of the friends I hike and backpack with, are built around the continued existence of protected roadless areas. When a rule has stood long enough to shape how people orient their lives toward the land, the agency changing course is obligated to take those interests seriously. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken.

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

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

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

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

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

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

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

In 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

The Draft Biological Assessment discloses its method — IRA shapefiles run through IPaC for the FWS list, NMFS species compiled from consultation records, both lists vetted by Forest Service staff and sent to the Services in September–October 2025, occurrence data from GBIF and NRM (BA p. 25) — but reports counts only by taxonomic group (e.g., 30 candidate bird species, 4 removed, 26 remaining, BA p. 161) and states no total. The BA also warns its databases do not differentiate between DPSs, "causing potential inflation" (p. 25). The "more than 300" figure cannot be traced to this method, and it is unclear whether it double-counts distinct population segments.

Request 1: Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count, the date it reflects, whether DPSs are counted separately, and cross-reference the BA's Species Lists section wherever the figure appears — citing the correction per 7 CFR 1b.7(f)(3).

Second, the figure does no analytical work. It appears only as background and is never tied to an effects conclusion — even though the same page states fragmentation reduces biodiversity 13–75% (Haddad et al. 2015), with effects "greatest in the smallest and most isolated fragments."

The record already supplies the missing link: Dietz et al., "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species" (2021), is in the Draft EIS's own reference list, cited in Vol. III (p. 37 n.201), and discussed at length in both the eight-state AG letter (Vol. III pp. 38–39) and the joint Tribal letter (Vol. III p. 498). Its finding: of 537 vulnerable terrestrial vertebrate species, 308 (57%) have suitable habitat in roadless areas — despite roadless areas covering only 2% of the contiguous U.S. — every roadless area holds habitat for at least two such species, and 81% of roadless acreage is suitable for at least five.

Because this study is already in the agency's record, 7 CFR 1b.7(f)(2)(iv)'s bar on literature "not previously considered" doesn't apply — the agency need only analyze science it has already adopted. The chain is undisputed: rescission lifts road and timber-cutting prohibitions across the roadless network; the Draft EIS's own fragmentation finding predicts biodiversity loss, worst in small, isolated fragments; and Dietz et al. show this network is the disproportionate habitat base for the nation's vulnerable vertebrates — so shrinking it degrades species representation in the protected-area system.

Request 2: Under 7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission's effect on representation of species of conservation concern, using the corrected figure and engaging the Dietz finding — or explain in the response to comments why record science on this point doesn't apply.

Both requests are substantive under 7 CFR 1b.11(a)(53): an unreconcilable affected-environment figure and an effects analysis that ignores a record finding are a failure to consider an important aspect of the problem, 5 U.S.C. § 706(2)(A). Both also affect the Section 7 consultation record, which rests on the same unstated baseline (BA p. 25).”

Keep roadless areas roadless.

Respectfully,

CommentID: RLC-20260916-BIKIKN

Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire.
The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography.
I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation.

If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire.

Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom.
Do the right thing. DO NOT RECIND THE ROADLESS RULE.

All the best,

Christian Kasperkovitz

Basin). The DEIS mentions herbicides only for invasive-plant control, conceding they can have "unintended adverse effects" on terrestrial and aquatic species (p. 142), and never analyzes post-harvest herbicide use or its effects on source water. Fuel reduction near communities is already permitted under the 2001 Rule (36 CFR 294.13(b); DEIS Table 1, p. 14); commercial timber harvest and new road construction in source watersheds are not necessary to achieve it. At minimum, protections should be retained in municipal source watersheds.
2.Wildfire. The DEIS's own data undercut its fire rationale. Ignition density on other NFS lands is about four times that of affected IRAs (41.8 vs. 12.0 fires per million acres per year, Table 18, p. 87), and human-caused ignitions are over seven times higher (22.4 vs. 3.0, Table 21, p. 90). The DEIS concedes that "human caused ignitions increase in abundance with proximity to roads" (p. 90) and that IRAs burned a smaller share of their area (8.7% vs. 13.8%, Table 18). It also admits "a lack of roads has not prevented fire prevention or protection measures" (p. 105). Its answer to added ignitions, restricting public access to new roads (p. 105), depends on gates, closures and enforcement the agency cannot fund (see 3).
3.Fiscal responsibility. The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges, counting passenger-car roads only, and a drop in annual road appropriations from $234 million (2004) to $73 million (2024); supplemental GAOA funding expired in 2025 and IIJA funding was set to expire September 30, 2026 (p. 43). It assumes timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project" (p. 45). No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has. The agency should address the existing backlog and disclose the life-cycle cost of new roads, and how it would be paid, before removing protections.
4.Old growth and intact habitat. Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors. The DEIS finds the proposal "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats (pp. 25, 161), and that 11-16% of the operable area where plans allow harvest is old growth and 54-63% is mature forest (p. 78). It projects 253,000-557,000 ccf of added harvest per year (p. 77), yet defers site-specific analysis because future activities are "uncertain" (p. 32). The agency cannot model where the timber is while declining to analyze the harm in those same places.
I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule (Alternative 1). If any change proceeds, it should occur through state-specific rulemaking with full analysis of water supply, wildfire, fiscal and habitat impacts.
Other sources: EBMUD 2023 Annual Water Quality Report (ebmud.com); CSERC, Stanislaus NF roadless areas (cserc.org); South Tahoe Now, Caldor Fire Reforestation Project (May 4, 2026); KUNR, Tahoe herbicide concerns (May 27, 2026); Mother Jones/Reveal investigation on Forest Service glyphosate use in California (Apr. 2026).
Jeff
East Bay, CA

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

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.

None of those metrics appears anywhere else in the Draft EIS. "Largest patch index" occurs at pp. 320 and 324; "clumpiness" at p. 324; "nearest neighbor" at p. 321. Every occurrence falls inside Appendix 5. The metrics are absent from the biodiversity affected-environment discussion at pp. 141–142, from the road-construction effects discussion at pp. 149, 159, and 162, and from the conclusion at pp. 165–166. No projected or post-rescission value is given for any of them, under any alternative.

I am not claiming the Draft EIS ignores fragmentation. It discusses fragmentation qualitatively at pp. 141–142 and ties it to species sensitivity, and it discusses fragmentation and edge effects from road construction at pp. 149, 159, and 162 with reference to named species including the cerulean warbler, elk, and the marbled murrelet. My concern is narrower, and I do not believe those sections answer it: the Draft EIS's conclusion is comparative, and it is unsupported by the only measurements the Draft EIS made.

At pp. 165–166 the Draft EIS concludes that road construction, road reconstruction, and timber harvest "could potentially have long-term adverse effects on biodiversity by increasing habitat fragmentation, loss of connectivity, negative edge effects, and human disturbance"; that "[t]hese impacts would likely be more frequent and broader in scale under alternative 2"; that impacts under alternative 3 "would likely have a lesser effect on biodiversity than alternative 2"; and that impacts "would likely be the least under alternative 1." That is a ranking of the three alternatives by severity of fragmentation effect. It is stated entirely in words of degree — "more frequent," "broader in scale," "lesser," "least" — with no quantity attached to any of them, while the agency's own fragmentation measurements sit unused thirty pages later.

The mechanism connecting the rescission to those measurements is the one the Draft EIS itself describes. Rescinding the 2001 Rule removes the prohibition on road construction and reconstruction in inventoried roadless areas under Alternative 2, and in a reduced subset of them under Alternative 3. New roads subdivide forest patches. Subdividing patches lowers mean patch area and largest patch index, raises edge density, and increases mean distance to nearest neighbor — these follow from the metrics' own definitions, and Appendix 5's table note says as much: "Largest patch index reflects habitat continuity and approaches 0 for highly fragmented landscapes." The link from that metric change to the biodiversity outcome the Draft EIS is ranking is supplied by Haddad et al. 2015, which the Draft EIS cites at pp. 141 and 149 for the findings that habitat fragmentation reduces biodiversity by 13 to 75 percent and that effects are greatest in the smallest and most isolated fragments and increase over time. The Draft EIS therefore holds, in its own record, both the baseline values and the published relationship between a change in those values and the effect it is comparing — and applies neither to the comparison.

The scale objection does not reach this request. Appendix 5's metrics were computed by the agency at the scale of the affected environment as a whole, by region and forest type group, minus the area within 100 feet of existing roads. That is a rule-scale analysis, chosen by the agency, and a baseline computed at rule scale admits of a projection at rule scale. Nothing I am asking for requires knowing where individual future roads would be sited; it requires applying a bounded range of road-density or road-mileage assumptions to a baseline the agency has already built.

Under 7 CFR 1b.7(f)(2)(iii) I request that the Forest Service supplement the biodiversity effects analysis to apply the Appendix 5 metrics to a projected post-rescission condition for each alternative — at minimum.

The habitat baseline omits the one published finding in this record that is specific to inventoried roadless areas and to species of conservation concern. The baseline reports that the potentially affected environment "provides habitat for more than 300 threatened, endangered, and proposed species" and gives the two critical-habitat counts. It reports nothing about how concentrated at-risk wildlife habitat is inside inventoried roadless areas, although the record contains a published measure of exactly that. Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021), "The importance of U.S. national forest roadless areas for vulnerable wildlife species," Global Ecology and Conservation vol. 32, doi:10.1016/j.gecco.2021.e01943, examined 537 terrestrial vertebrate wildlife species of conservation concern in the contiguous United States and found that "308 species, or 57%, have at least some suitable habitat in inventoried roadless areas, even though inventoried roadless areas only cover 2% of the area of the contiguous United States." This is not "science or literature not previously considered" within the meaning of 7 CFR 1b.7(f)(2)(iv). The agency has held this study since scoping: it is cited in the DEIS's own Volume III by the Attorneys General of Washington, California, Arizona, Massachusetts, Minnesota, New Mexico, Oregon, and Vermont at pages 37 through 39, by a Member of the House Committee on Natural Resources at page 415, and by other commenters at pages 498 and 506. It nonetheless does not appear in the DEIS's References Cited. The cause-and-effect link to this analysis is direct. The DEIS measures the affected environment by counts of listed entities - species, critical habitats - and that metric is blind to how concentrated vulnerable-species habitat is within the specific land base whose protections the proposed rescission would remove. It is the concentration, not the count, that determines the magnitude of the effect: 57 percent of the national pool of vulnerable terrestrial vertebrates has suitable habitat on 2 percent of the land area of the contiguous United States, and that 2 percent is the land base at issue in this rulemaking. A baseline that omits this understates what the rescission places at risk, and every effects conclusion tiered to that baseline inherits the understatement. I request supplementation of the analysis under 7 CFR 1b.7(f)(2)(iii): incorporate the Dietz et al. 2021 finding into the habitat discussion of the affected environment, add the study to the DEIS References Cited, and carry a roadless-specific measure of species-of-conservation-concern habitat through the effects analysis for each alternative, including the no-action alternative.

Under 7 CFR 1b.7(f)(3), I request that the response to each of the two items above cite where in the FEIS or the supporting proposal record the action taken is accounted for.

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

First, the two analyses the Draft EIS documents measure land designation, not road distance. Table 18 (p. 95) and Table 21 (p. 98) both compare other NFS lands, potentially affected IRAs, and wilderness, using Interagency Fire Occurrence Reporting Module (InFORM) Fire Occurrence Data Record ignitions with a point of origin on NFS lands for 2014-2024. A contrast among land designations cannot isolate a road-proximity effect, and the Draft EIS concedes the confounding on the same page. It states that "Other NFS lands typically have more land management activities, infrastructure (such as powerlines), and public recreation that can lead to human caused ignitions," and it reports that other NFS lands have "about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates" (p. 98). Natural ignitions are not caused by road access. The agency's own explanation for the natural-ignition differential - biophysical difference and detection rate - applies with equal force to the human-ignition differential in Table 21, and the Draft EIS neither tests nor excludes it before attributing that differential to roads.

Second, the only analysis in the Draft EIS that measures ignitions against road distance is Figure 15, "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs" (p. 98). Unlike the captions of Tables 18 and 21, the Figure 15 caption identifies no data source and no period, and the figure carries none of the documentation supplied for those tables in footnotes 38 through 40 at page 94. The narrative does not reference Figure 15 or report any value from it - no distance classes, no ignition counts by cause, no exposed area, no densities. The one within-IRA road-distance analysis in the document is presented with none of the information a reader would need to evaluate it, while the two designation-level analyses that cannot answer the road-distance question are fully documented.

I request that the Forest Service supplement the wildfire occurrence analysis (7 CFR 1b.7(f)(2)(iii)) to report the data underlying Figure 15 - the distance classes, ignition counts by cause, exposed area, and resulting ignition densities - and to state whether the road-distance relationship within the potentially affected IRAs survives the confounders the Draft EIS itself identifies at page 98. If it does not, the finding at page 98 and the Fire and Fuels row of the Comparison of Alternatives require factual correction under 7 CFR 1b.7(f)(2)(v). Absent one or the other, the Final EIS would assert a reasonably foreseeable effect for which it has disclosed no supporting analysis: not a cause-effect relationship established within the meaning of 7 CFR 1b.11(a)(23), and not a reasoned explanation under 5 U.S.C. Sec. 706(2)(A). See Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002).

Forum. This concern is directed to both the Draft EIS and the proposed rule. The road-proximity ignition finding supplies a factual predicate for the wildfire rationale stated in the Purpose and Need, and the Purpose and Need is the standard against which alternatives were measured for elimination from detailed study. An answer given only in the Final EIS response-to-comments appendix would leave the concern unanswered as a comment on the rule.

Protect what's left. Keep the Rule.

Yet, on page 14 of the draft EIS, Table 1., 2001 Roadless Rule exceptions (alternative 1) (36 CFR 294.12(b) and 294.13(b) (2001)), states: “Road construction, reconstruction, including temporary road construction, is prohibited in inventoried roadless areas, except when:
1) A road is needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property”

Fuel reduction projects on FS lands in California have been actively taking place since the Roadless Rule went into effect. I know this because I have worked on these projects. I also know this because there is published research documenting these activities: “The findings in our analysis are consistent with other studies, including research supported by the Forest Service’s Rocky Mountain Research Station, which evaluated nearly twenty years of monitoring data, concluding that “a lack of roads in IRAs [Inventoried Roadless Areas] has neither prevented fuel treatment nor led to substantially more fire” (Trout Unlimited 2026).

On page 24 of the draft EIS, Table 3., which shows comparison of effects under alternatives 1-3 divided by resource/topic, under Fire and Fuels Management, it states “Currently, the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands. Under alternatives 2 and 3, 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.”

This statement, along with statistics from other published, peer-reviewed, and agency-accepted studies regarding the topic (see below), refute the argument that adding additional roads would reduce fire risk by any meaningful amount.

“Analysis of information about ignition source and location from the Forest Service fire occurrence dataset (USA.FireOccurrence) shows the occurrence of human-caused wildfire ignitions is strongly correlated with roads. Seventy-eight percent of human-caused fires on NFS lands nationwide start within ½ mile of a road” (Trout Unlimited 2026).

References:
Trout Unlimited, 2026. Roadless: Active Management and Fire A GIS data analysis and research review. September 2, 2026. Accessed October 5, 2026, online at https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa.

Yet, on page 14 of the draft EIS, Table 1., 2001 Roadless Rule exceptions (alternative 1) (36 CFR 294.12(b) and 294.13(b) (2001)), states: “Road construction, reconstruction, including temporary road construction, is prohibited in inventoried roadless areas, except when:
1) A road is needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property”

Fuel reduction projects on FS lands in California have been actively taking place since the Roadless Rule went into effect. I know this because I have worked on these projects. I also know this because there is published research documenting these activities: “The findings in our analysis are consistent with other studies, including research supported by the Forest Service’s Rocky Mountain Research Station, which evaluated nearly twenty years of monitoring data, concluding that “a lack of roads in IRAs [Inventoried Roadless Areas] has neither prevented fuel treatment nor led to substantially more fire” (Trout Unlimited 2026).

On page 24 of the draft EIS, Table 3., which shows comparison of effects under alternatives 1-3 divided by resource/topic, under Fire and Fuels Management, it states “Currently, the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands. Under alternatives 2 and 3, 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.”

This statement, along with statistics from other published, peer-reviewed, and agency-accepted studies regarding the topic (see below), refute the argument that adding additional roads would reduce fire risk by any meaningful amount.

“Analysis of information about ignition source and location from the Forest Service fire occurrence dataset (USA.FireOccurrence) shows the occurrence of human-caused wildfire ignitions is strongly correlated with roads. Seventy-eight percent of human-caused fires on NFS lands nationwide start within ½ mile of a road” (Trout Unlimited 2026).

References:
Trout Unlimited, 2026. Roadless: Active Management and Fire A GIS data analysis and research review. September 2, 2026. Accessed October 5, 2026, online at https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa.

1. Landslide risk to public safety is increasing, and the DEIS should account for it.
A 2025 study in the journal Landslides (Darrow & Jacobs) found that Southeast Alaska has had the greatest per-capita increase in landslides in the state, and that Alaska's last four fatal landslides all occurred here: Sitka (2015), Haines (2020), Wrangell (2023), and Ketchikan (2024). The authors tie the increase to warmer temperatures and heavier rain, including atmospheric rivers, and expect it to continue. Logging and road building on steep slopes add to that risk; in the Maybeso Valley on Prince of Wales Island, aerial photos showed 13 landslides in the 100 years before logging and 116 in the nine years after (Bishop & Stevens 1964, reported in Harris 1974). The DEIS projects that rescission would make 168,000 more acres of Tongass old growth suitable for timber production. I ask the Forest Service to map where those acres overlap with high landslide-hazard slopes, community drinking water sources, roads and homes below them, and salmon streams. I also ask it to analyze landslide risk under current and projected climate conditions rather than historical averages, which no longer represent the region's landslide regime.

2. Local uses depend on roadless watersheds.
My family relies on about 17 salmon from the Taku River each summer. The DEIS asks for data on how rescission would affect commercial fisheries, recreation, and tourism. In Southeast Alaska these industries depend on intact salmon streams, and erosion from road building and logging-related landslides harms and can eliminate fish runs. Tourism is a major part of my community's economy, as it is across Southeast Alaska. Visitors come to travel through remote, roadless country, and many local businesses (bear viewing, guided hikes, fishing charters and lodges) depend on abundant wildlife, which needs mature forest habitat and healthy salmon streams. New roads and clearcuts above spawning habitat add sediment and debris to streams, disrupt wildlife habitat, and degrade the scenery visitors come for. Please include these effects, and their impacts on local economies, in the final EIS.

3. A subsistence evaluation under ANILCA Section 810 is needed.
The DEIS acknowledges that rescission could affect subsistence harvest opportunities, yet states that no Section 810 evaluation is required because this is a rulemaking. Removing protections from 9.3 million acres of Tongass inventoried roadless areas directly affects the subsistence resources rural Alaskans rely on. I ask USDA to complete a Section 810 evaluation, with hearings in affected communities, before issuing a final rule. Those hearings should gather current testimony rather than relying on hearings held in 2019. Conditions have changed since then: three of the four fatal landslides listed above happened after those hearings, and a new generation of residents who depend on these lands has not been heard.

Requested change.

Select the No Action alternative. At a minimum, if any change is made, keep roadless protections on the Tongass for areas with moderate or high landslide hazard, municipal and community watersheds, subsistence use areas, and watersheds with salmon streams listed in the Alaska Department of Fish and Game's Anadromous Waters Catalog, and complete an ANILCA Section 810 evaluation.

Thank you for considering these comments.

Megan Behnke
Douglas, Alaska

References

Darrow, M.M., & Jacobs, A. (2026). Read all about it! A review of more than a century of Alaskan landslides as recorded in periodicals. Landslides, 23(3), 807-821 (online Nov. 2025). https://doi.org/10.1007/s10346-025-02663-z

Bishop, D.M., & Stevens, M.E. (1964). Landslides on logged areas in southeast Alaska. USDA Forest Service Research Paper NOR-1.

Harris, A.S. (1974). Clearcutting, reforestation and stand development on Alaska's Tongass National Forest. Journal of Forestry, 72(6), 330. https://doi.org/10.1093/jof/72.6.330

thus greatly
increased avalanche threats to roads, people and property. (Miller et al., 2023). The United States
Geological Survey (USGS) recognizes this threat and has gone as far as publishing it on USGS.gov
(pubs.usgs.gov/publication/70249585).
There is a known and correlated increase in avalanche activity as a result of wildfire. It is recognized
that the number of wildland fire ignitions increase as humans gain road access, far outweighing the
benefit of increased firefighting response time. Wildfire impacts will increase in the western United
States as a direct result of rescinding the roadless rule, and thus the avalanche hazards shall also.
We recommend that the US Congress uphold the roadless rule on USFS lands and avoid
compounding the problems from wildland fire and avalanches.
-Ownership and Senior Avalanche Consultants of Avalanche Risk Solutions LLC
David Richards
Donald Sharaf
Kiira Antenucci
AVALANCHE RISK SOLUTIONS, LLC (801) 556-5615 INFO@AVALANCHERISKSOLUTIONS.COM
References:
Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national
forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(8)
Campbell, C., Gould, B., & Thumlert, S. (2019). Post Wildfire Analysis of Avalanche Hazard. The
Avalanche Journal, 121 (Summer 2019), 22–25. [1]
Miller, Z., Sykes, J., Guinn, M., VandenBos, B., Savage, S., and Peitzsch, E.H., 2023, Spatial extent of
forested avalanche terrain impacted by wildfire across the Sawtooth National Forest, in
Proceedings, International Snow Science Workshop 2023, Bend, OR, October 8-13, 2023, p. 272-
279.
AVALANCHE RISK SOLUTIONS, LLC (801) 556-5615 INFO@AVALANCHERISKSOLUTIONS.COM

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.

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

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

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

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

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

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

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

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

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 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

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 mountains of North Carolina and the broader Southern Appalachian region are treasured not only for their beauty, but for the environmental services they provide and the recreation economy they support. Keeping these areas roadless helps preserve the character of the landscape for future generations while reducing costly and unnecessary disturbance.

I urge you to uphold the Roadless Rule and reject efforts to weaken protections for these public lands. Once roadless character is lost, it is exceedingly difficult — and often impossible — to restore. Please protect these forests, streams, and wild places for the benefit of current and future generations.

Thank you for considering my comment.

Sincerely,
Brandon Inabinet

Purpose and Need Asserts a Balancing of Competing Values Without Performing It Against the Record's Own Conservation Evidence

I request three things.

1. That the FEIS supplement the rationale for the proposed rule to state the conservation values of inventoried roadless areas as the Department's own record documents them, including the Dietz et al. (2021) findings published at Volume III page 39, and to explain why the changed conditions recited at pages 18 through 20 outweigh them. 7 CFR 1b.7(f)(2)(iii).

2. That the FEIS correct the statement at page 20 that changed conditions "diminish the basis for a national prohibition," or supply the analysis that supports it. 7 CFR 1b.7(f)(2)(v).

3. That the FEIS disclose the population served by drinking-water source watersheds within the 44.7 million acres of inventoried roadless areas, or state on the record that the Department cannot determine it.

Basin). The DEIS mentions herbicides only for invasive-plant control, conceding they can have "unintended adverse effects" on terrestrial and aquatic species (p. 142), and never analyzes post-harvest herbicide use or its effects on source water. Fuel reduction near communities is already permitted under the 2001 Rule (36 CFR 294.13(b); DEIS Table 1, p. 14); commercial timber harvest and new road construction in source watersheds are not necessary to achieve it. At minimum, protections should be retained in municipal source watersheds.
2.Wildfire. The DEIS's own data undercut its fire rationale. Ignition density on other NFS lands is about four times that of affected IRAs (41.8 vs. 12.0 fires per million acres per year, Table 18, p. 87), and human-caused ignitions are over seven times higher (22.4 vs. 3.0, Table 21, p. 90). The DEIS concedes that "human caused ignitions increase in abundance with proximity to roads" (p. 90) and that IRAs burned a smaller share of their area (8.7% vs. 13.8%, Table 18). It also admits "a lack of roads has not prevented fire prevention or protection measures" (p. 105). Its answer to added ignitions, restricting public access to new roads (p. 105), depends on gates, closures and enforcement the agency cannot fund (see 3).
3.Fiscal responsibility. The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges, counting passenger-car roads only, and a drop in annual road appropriations from $234 million (2004) to $73 million (2024); supplemental GAOA funding expired in 2025 and IIJA funding was set to expire September 30, 2026 (p. 43). It assumes timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project" (p. 45). No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has. The agency should address the existing backlog and disclose the life-cycle cost of new roads, and how it would be paid, before removing protections.
4.Old growth and intact habitat. Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors. The DEIS finds the proposal "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats (pp. 25, 161), and that 11-16% of the operable area where plans allow harvest is old growth and 54-63% is mature forest (p. 78). It projects 253,000-557,000 ccf of added harvest per year (p. 77), yet defers site-specific analysis because future activities are "uncertain" (p. 32). The agency cannot model where the timber is while declining to analyze the harm in those same places.
I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule (Alternative 1). If any change proceeds, it should occur through state-specific rulemaking with full analysis of water supply, wildfire, fiscal and habitat impacts.
Other sources: EBMUD 2023 Annual Water Quality Report (ebmud.com); CSERC, Stanislaus NF roadless areas (cserc.org); South Tahoe Now, Caldor Fire Reforestation Project (May 4, 2026); KUNR, Tahoe herbicide concerns (May 27, 2026); Mother Jones/Reveal investigation on Forest Service glyphosate use in California (Apr. 2026).
Jeff
East Bay, CA

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's record addresses ignition. Its 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." I was six the first time I was evacuated for a wildfire. Roads and the humans who drive on them contribute to these blazes. The agency's proposal justifies rescission on wildfire and fuels management grounds, yet its own DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency reconcile those positions in writing and explain why the proposal departs from its own findings.

Erosion, sedimentation, and heat: bad for drinking water and the fishing tours that my town relies upon. Roads impair watersheds. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. The lower Deschutes holds one of only two national strongholds for federally threatened bull trout. Big Marsh supports the largest monitored population of federally threatened Oregon spotted frog. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analyses support decommissioning roads, not adding them. I ask the agency to explain what analysis it relied upon to conclude that watershed and species protections of this scale should be subordinated to a timber volume the agency describes as "less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The economic record deserves scrutiny: the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. A range that wide cannot establish a net benefit, and the agency must say so plainly.

As a Karuk citizen, I read the Tribal consultation record with attention. The agency states that "The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule." Deferring that statement until after the comment period denies the public and Tribal nations opportunity to respond. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule. None was analyzed. The agency must complete all 64 consultations and publish the Tribal Impact Summary Statement before any final rule is issued.

The proposal argues that the 2001 rule exceeded the agency's statutory authority. A federal court reviewed that question and concluded otherwise. In that case, the Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that holding and explain the legal basis for a contrary position.

This ill-conceived rule change will not benefit anyone except timber corporations, at great cost to the economies and communities nearby. I urge the agency to withdraw the proposal.

Sincerely,
Emily Woodworth
Sisters, OR

1. The wildfire rationale has to be tested against ignition data.
USDA points to about 28 million roadless acres at high or very high fire risk, and to roughly 80 million acres of National Forest land that need fuel or forest health treatment. Those problems are real. The question for this rulemaking is whether rescission addresses them. onX's analysis of National Interagency Fire Center records found that only 3% of mapped ignition points over 50 years fall inside inventoried roadless areas. Published research puts about 90% of wildfires within a half mile of a road, and 88% of wildfires are human caused. A four-decade satellite analysis found roadless areas have not burned at significantly higher rates or severity than roaded forest, and burned slightly less in the most recent decade. The Final EIS should state how many miles of new road the preferred alternative projects, what change in human-caused ignitions that mileage would produce using the agency's own fire records, and how much of the 28 million acres is already close enough to an existing road to be treated today.

2. The 2001 rule already allows the work the agency says it needs.
The rule permits fire suppression, tree cutting to reduce wildfire risk, fuel treatments, and road construction when a threat is imminent. I ask the agency to list every treatment proposal in an inventoried roadless area since 2001 that was denied or delayed because of the rule, with the reason for each. If the list is short, the DEIS has not shown a problem that rescission solves.

3. Multiple use is already met across the National Forest System.
FLPMA section 103(c) defines multiple use to include "the use of some land for less than all of the resources," and says management should not automatically pursue the mix that returns the most money. Section 102(a)(8) calls for preserving certain lands in their natural condition while still providing for recreation and human use. I recognize FLPMA's planning title is written mainly for BLM lands. Congress did give the Secretary of Agriculture rulemaking authority for National Forest System lands in section 310, and the 103(c) definition closely tracks the Multiple-Use Sustained-Yield Act the Forest Service already works under. onX's figures show roadless areas are 27.7% of the 193 million acres the agency manages, while 51.7% is managed for other values and a broader range of uses. The Final EIS should explain how that existing mix fails the multiple use standard.

4. The rule does not close existing access.
onX counted 7,201 miles of full-size motorized trails and primitive roads, 2,494 miles of ATV and side-by-side trails, 2,167 miles of motorized singletrack, and 1,295 miles of snowmobile trails inside these areas, along with over 17,700 miles of hiking and biking trails, nearly 1,500 miles of mapped ski routes, and close to 3,000 climbing areas. The rule bars construction and reconstruction of roads. It does not shut those routes. Where public access gets lost is at the boundary. FLPMA section 205 gives the Secretary of Agriculture authority to acquire access over non-federal lands to National Forest units, which is the tool for landlocked parcels. I ask the agency to quantify roadless acres that lack legal public access, and to compare the cost of new road construction in roadless areas with the cost of acquiring access easements.

5. Alternative 3 removes protection where ignition risk concentrates.
Alternative 3 strips designation from 31.7 million acres, including everything within a half mile of a road. That is the same band where the ignition research says most fires start. It also removes the 9.3 million acres of the Tongass. Please provide fire outcome data for the specific acres Alternative 3 would remove.

6. Tribal coordination and process.
FLPMA section 202(b) directs the Secretary of Agriculture to coordinate National Forest land use plans with tribal land management programs and to consider approved tribal land resource management programs. I ask the agency to document government-to-government consultation with each tribe that has treaty or ancestral ties to affected forests, and to show how their programs were weighed.

Thank you,
Amy Broman
Massachusetts

While my central concern in these comments is The Tongass, the rule-making is national in scope. The 2001 Roadless Rule protected roughly 58.5 million acres of inventoried roadless land across the National Forest System. Under this new proposal, essentially all of it, aside from the existing state-specific rules for Idaho and Colorado, would lose federal roadless status.

This proposed rescission reaches ecologically important land far outside Alaska: old-growth and roadless terrain in the Pacific Northwest, high-elevation backcountry throughout the Rocky Mountains, Sierra Nevada roadless areas in California, and roadless tracts in the Southern Appalachians. By USDA's own estimates, up to 18.2 million acres would become eligible for new permanent roads, 4.8 million acres of forest would open to expanded timber harvest, and 9.8 million acres of wilderness-urban interface would become newly eligible for fuel treatment. This would have impacts that extend well past the regions where the wildfire rationale might reasonably apply.

I raise this to show that a single, nationwide justification risks being applied to forests it was never built for—and The Tongass, as a temperate rainforest, rather than a fire-prone western forest, is the starkest example. The USDA should perform forest-specific analysis for every affected forest.

The Tongass is among the most significant such interests anywhere in the National Forest System: It holds an old-growth, temperate rainforest that serves as a major carbon sink and Tribal representatives have raised this directly in consultation, along with the need for an ANILCA Section 810 subsistence analysis before any decision.

It provides critical habitat for bald eagles and other species that depend on intact, un-fragmented old growth and undisturbed watersheds. Its salmon-bearing watersheds and subsistence resources are directly linked to the well-being, food security, and cultural practices of Tribal and Alaska Native communities. These are concrete, well-documented interests specific to this landscape, and USDA is obligated to weigh them accordingly. The Tribal consultation record already favors continued protection. USDA's own consultation summary reflects that most Tribal governments opposed the proposed rescission, viewing it as a threat to inherent rights, Tribal sovereignty, cultural continuity, and the ecological integrity of ancestral homelands, with inadequate government-to-government consultation cited as a central concern.

Substantial weight must be given to the documented opposition of the Tribal governments consulted on this rule-making. Conduct comparable forest-specific impact analysis for other significantly affected national forests, rather than relying on one blanket nationwide rationale for all 58.5 million acres covered by this rescission.

I have traveled in and around Alaska, and had the great fortune to have visited and hiked in The Tongass. I ask that The Tongass National Forest be removed from any final rescission of roadless protections or, at minimum, adopt a Tongass-specific management framework grounded in scientific ecological knowledge and Tribal co-stewardship.

Thank you for consideration of my deep concern for all forests of this nation that have historically been pillaged without careful forethought to the consequences -- all in the name of “maximizing potential” of our precious environmental treasures. The Tongass is absolutely one of those gems and deserves all the protections that The Roadless Rule has provided in the past. We must think of the future of this planet and what generations to come will have been left to discover and marvel at. I implore the USDA to, please, take care of our lands. Stop the exploitation. They need and deserve protection.

Wendy Stoner-Lincoln
Wiscasset, Maine

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.

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 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

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

The Draft Biological Assessment discloses its method — IRA shapefiles run through IPaC for the FWS list, NMFS species compiled from consultation records, both lists vetted by Forest Service staff and sent to the Services in September–October 2025, occurrence data from GBIF and NRM (BA p. 25) — but reports counts only by taxonomic group (e.g., 30 candidate bird species, 4 removed, 26 remaining, BA p. 161) and states no total. The BA also warns its databases do not differentiate between DPSs, "causing potential inflation" (p. 25). The "more than 300" figure cannot be traced to this method, and it is unclear whether it double-counts distinct population segments.

Request 1: Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count, the date it reflects, whether DPSs are counted separately, and cross-reference the BA's Species Lists section wherever the figure appears — citing the correction per 7 CFR 1b.7(f)(3).

Second, the figure does no analytical work. It appears only as background and is never tied to an effects conclusion — even though the same page states fragmentation reduces biodiversity 13–75% (Haddad et al. 2015), with effects "greatest in the smallest and most isolated fragments."

The record already supplies the missing link: Dietz et al., "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species" (2021), is in the Draft EIS's own reference list, cited in Vol. III (p. 37 n.201), and discussed at length in both the eight-state AG letter (Vol. III pp. 38–39) and the joint Tribal letter (Vol. III p. 498). Its finding: of 537 vulnerable terrestrial vertebrate species, 308 (57%) have suitable habitat in roadless areas — despite roadless areas covering only 2% of the contiguous U.S. — every roadless area holds habitat for at least two such species, and 81% of roadless acreage is suitable for at least five.

Because this study is already in the agency's record, 7 CFR 1b.7(f)(2)(iv)'s bar on literature "not previously considered" doesn't apply — the agency need only analyze science it has already adopted. The chain is undisputed: rescission lifts road and timber-cutting prohibitions across the roadless network; the Draft EIS's own fragmentation finding predicts biodiversity loss, worst in small, isolated fragments; and Dietz et al. show this network is the disproportionate habitat base for the nation's vulnerable vertebrates — so shrinking it degrades species representation in the protected-area system.

Request 2: Under 7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission's effect on representation of species of conservation concern, using the corrected figure and engaging the Dietz finding — or explain in the response to comments why record science on this point doesn't apply.

Both requests are substantive under 7 CFR 1b.11(a)(53): an unreconcilable affected-environment figure and an effects analysis that ignores a record finding are a failure to consider an important aspect of the problem, 5 U.S.C. § 706(2)(A). Both also affect the Section 7 consultation record, which rests on the same unstated baseline (BA p. 25).”

Keep roadless areas roadless.

Respectfully,

CommentID: RLC-20260916-BIKIKN

The mountains of North Carolina and the broader Southern Appalachian region are treasured not only for their beauty, but for the environmental services they provide and the recreation economy they support. Keeping these areas roadless helps preserve the character of the landscape for future generations while reducing costly and unnecessary disturbance.

I urge you to uphold the Roadless Rule and reject efforts to weaken protections for these public lands. Once roadless character is lost, it is exceedingly difficult — and often impossible — to restore. Please protect these forests, streams, and wild places for the benefit of current and future generations.

Thank you for considering my comment.

Sincerely,
Brandon Inabinet

Purpose and Need Asserts a Balancing of Competing Values Without Performing It Against the Record's Own Conservation Evidence

I request three things.

1. That the FEIS supplement the rationale for the proposed rule to state the conservation values of inventoried roadless areas as the Department's own record documents them, including the Dietz et al. (2021) findings published at Volume III page 39, and to explain why the changed conditions recited at pages 18 through 20 outweigh them. 7 CFR 1b.7(f)(2)(iii).

2. That the FEIS correct the statement at page 20 that changed conditions "diminish the basis for a national prohibition," or supply the analysis that supports it. 7 CFR 1b.7(f)(2)(v).

3. That the FEIS disclose the population served by drinking-water source watersheds within the 44.7 million acres of inventoried roadless areas, or state on the record that the Department cannot determine it.

Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire.
The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography.
I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation.

If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire.

Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom.
Do the right thing. DO NOT RECIND THE ROADLESS RULE.

All the best,

Christian Kasperkovitz

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.

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

Second, because 36 CFR 294.13(b)(1)(ii) (2001) already authorizes the fire-risk and forest-health treatment the purpose and need in the proposed rule identify, an alternative that retains the 2001 Roadless Rule while streamlining the review and approval process for exceptions under 36 CFR 294.12(b) and 294.13(b) (2001) - including the national tracking of requests, approvals, denials, and processing times whose absence the DEIS concedes at p. 14 - will meet the stated need without rescission. I request that this alternative be developed and evaluated under 7 CFR 1b.7(f)(2)(ii). If it is not carried forward, 7 CFR 1b.7(h)(3) requires the agency to state its reason; a reason that the alternative does not meet the purpose and need is unavailable while the purpose and need rests on the misstatement identified in item 1 and the unsupported causal claim identified in item 3. Because the Rationale for the Proposed Rule is also the agency's explanation for reversing a position it has maintained since 2001, I direct this concern to the final rule preamble as well as to the final environmental impact statement.

There are many examples in the proposed rule of unsupported justifications and assertions contradicted by the agency's own data, too many to list here in detail within the character limitations. Important data are missing.

Generally, rescission of the roadless rule will change the default from "don't build" to "build roads" on these priceless public lands in a time of significant and worsening climate change and immense habitat loss. Populations of nearly every species of wildlife are in decline. The government has not proved the need to increase roads in these areas.

Finally, the public response is overwhelmingly opposed to rescission of the roadless rule. And who is the ultimate owner of these lands? The public. These precious areas must be left as untouched as possible for future generations.

Thank you.

Notice-and-comment is not a referendum, and I do not ask the Department to treat it as one. But this record is evidence the APA requires the Department to engage: of the reliance interests it must weigh in reversing a settled policy, of the public values MUSYA and NFMA require it to consider, and of the 2001 factual findings it must confront before abandoning them.

The attached comment sets out 49 reasons. The principal ones:

Rescission is unnecessary. The preamble itself notes that any State or Tribe may petition for tailored roadless provisions under 5 U.S.C. 553(e) and 7 CFR 1.28. Idaho and Colorado did exactly that, and this proposal preserves both state rules. Local flexibility does not require eliminating the national baseline.

The legal questions are settled. The rule was challenged in the Ninth, Tenth, and D.C. Circuits and prevailed in each; the Supreme Court denied certiorari in 2012. No challenge to the 2001 Rule has ever succeeded on final judgment. The suits that did succeed struck down attempts to weaken it, including Organized Village of Kake v. USDA, 795 F.3d 956 (9th Cir. 2015) (en banc), which held the 2003 Tongass exemption arbitrary and capricious precisely because the Department reversed its own 2001 findings without explanation. That is the defect in this proposal, on a national scale. The preamble cites that litigation history as a reason to rescind; it shows the opposite.

The economics do not work. The Department projects $5.2-11.4 million per year to the Treasury from timber, against roughly $6.1 million in annual recreation losses and a conceded $6.9 billion deferred maintenance backlog for roads and bridges. It calls the rule economically significant under E.O. 12866 and says impacts "could exceed $100 million," yet certifies no significant impact on small entities under the Regulatory Flexibility Act. Those findings need reconciling.

The wildfire rationale is self-contradicting. The preamble concedes "greater public access can increase human-caused ignition potential." Only 24 percent of inventoried roadless acres overlap the wildland-urban interface, so a nationwide rescission is far broader than the stated community-protection purpose requires. The current rule already allows fire and fuels work.

The NEPA analysis is segmented. The Department concedes that subsequent plan amendments "could increase the area where timber harvest and road construction would be allowed," then declares those effects beyond scope while soliciting comment on them. It also declines to fully analyze the No Action, Strengthened Roadless Rule, and Traditional Homelands alternatives commenters requested.

Tribal consultation is unfinished. Of 64 requests, 34 were scheduled and 29 held. The final Tribal Impact Summary Statement is to issue with the final rule, after comment closes, so neither Tribes nor the public can comment on it. The ANILCA 810 subsistence analysis is likewise outside this period.

I ask the Department to withdraw the rule; failing that, to select No Action, fully analyze the requested alternatives and foreseeable plan amendments, publish the Tribal and subsistence analyses for comment before any final rule, reconcile its economic findings, confront its 2001 findings and the reliance built on them, and use the existing petition process for documented local needs.

I have hiked the entirety of the Pacific Crest Trail and the Tahoe Rim Trail and explored National Forests in more than twenty states. Much of that ground was inventoried roadless area. These places are drinking water, habitat, and the last unfragmented country we have, and there is no process that makes more of them.

disrepair. It is fiscally irresponsible to open up pristine lands to new infrastructure development when the agency cannot afford to maintain its current footprint.
Outdoor Recreation Economics: These roadless wildlands are major economic drivers, providing world-class backcountry recreation opportunities. These areas generate billions of dollars annually for local outdoor economies and support thousands of rural jobs.
Ignoring Public and Tribal Will: The Roadless Rule remains one of the most popular federal conservation policies in history, with recent polling showing over 75% public support. Past public comment periods yielded over 95% opposition to altering the rule. Furthermore, numerous Indigenous Tribes have voiced fierce opposition, noting that unroaded areas are essential to protecting cultural resources, fish, and native plants.
Fragmenting protections by pushing decisions to the local level weakens our national conservation framework. I ask that the USDA respect the will of the American public, uphold its duty as a land steward, and reject the proposed rollback.
Thank you for your time and consideration of these comments.

The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy.

National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk.

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.

Environmental Impacts
* The Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. 
* Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. 
* The science is clear: road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. 
Fire 
* Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. 
* 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. 
Clean Water 
* National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. 
* Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. 
Economic Considerations 
* The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. 
* The text of the Roadless Rule itself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. 
* On the local level, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. 
* Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. 
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 I strongly oppose rescinding the 2001 Roadless Rule. I ask that the agency not rescind the rule and before moving forward, the agency: 
* Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; 
* Guarantee that no watersheds will be negatively affected by rescission; 
* Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; 
* And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. 
Please protect America’s remaining roadless areas for current and future generations.

Allowing construction of roads will also result in further degradation of our country's biodiversity and ecology. These roadless areas are not incidental. They provide unfragmented habitat and connectivity corridors for sensitive and migratory species and safeguard the drinking water supply of downstream communities. In fact, we cannot even maintain the roads we already have. The Forest Service carries a multi-billion backlog in road maintenance and building more into the last of our wild places is both an ecological nightmare and a fiscal one. It would be a decision that serves narrow commercial interests at the permanent expense of the public lands and the public will. This proposal is another disgraceful disregard of the will of all Americans and future generations to come.

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

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

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.

The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range ("a 4 to 10 percent increase in total sawtimber harvest" (p. 30)) and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics.

This is not a limit of the analytical method, because the DEIS performs the quantified work for one forest. It states that "[t]he environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while the 2020 Alaska Roadless Rule FEIS "provides more specific, localized effects analysis for the Tongass National Forest affected environment, which supplement the broader nation-wide analysis" (p. 238). Carrying that analysis forward, the DEIS reports "an estimated 49 miles more of potential new road constriction [sic] within the Tongass compared to leaving the Roadless Rule in place" and an average road density of 0.23 miles per square mile (p. 239). By the DEIS's own accounting the Tongass is "nearly 1/4 of the potentially affected inventoried roadless area acreage" (p. 238). One quarter of the analysis area therefore receives a projected road-mile figure and the remaining 30.8 million acres receive none.

The omission cannot be deferred to project-level review, because the DEIS's own statement of need rests on quantified national targets. At p. 79 the DEIS relies on Executive Order 14225 and on the One Big Beautiful Bill Act section 50301, which "directs the Forest Service to sell at least 250 million board feet more each year for the next 10 years," and on the National Active Forest Management Strategy's goal of "an increase in timber production nationally by 25 percent." At p. 40 the DEIS says the amounts and locations are uncertain because "the rulemaking would not compel, require, or authorize any sitespecific activities." Both positions cannot hold. If the rescission is needed to meet a quantified national harvest target, then the harvest and the road construction required to reach that target are reasonably foreseeable effects of the rescission, and 42 U.S.C. 4332(2)(C) requires "a detailed statement... on... reasonably foreseeable environmental effects of the proposed agency action." If they are not reasonably foreseeable, the stated need for the rescission is unsupported, and every alternative eliminated for failing to meet that purpose was eliminated against a purpose the agency has not substantiated.

The Forest Service should supplement analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and resulting sedimentation and fragmentation across the potentially affected environment under each action alternative, at the level of specificity the DEIS applied to the Tongass National Forest at pp. 238-239, and cite in the final EIS where that supplemented analysis is accounted for, as 7 CFR 1b.7(f)(3) provides.

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.

- Oil and gas infrastructure (well pads, compressor stations, flares) is lit continuously and is among the most intense rural light sources in the country. The Allegheny NF sits atop the Marcellus and Utica shales and already hosts thousands of wells; its roadless areas are the only part of the forest free of this footprint.
- New roads bring nighttime traffic and lighted facilities, and open private inholdings to development no forest plan controls.
- Timber harvest and its roads remove the canopy that shields ground-level lighting from the sky.

Skyglow is not local. One industrial site degrades the sky tens of miles away; a developed landscape's glow is visible over a hundred miles. A dark sky is a regional resource that depends on every large undeveloped block within it staying undeveloped.

3. The rationale for local decisionmaking fails for a transboundary resource.

The Department argues local officials are "best positioned to make decisions about inventoried roadless areas." But the sky over Cherry Springs State Park depends on decisions in the Allegheny NF, and the sky over Spruce Knob on decisions in two states. No single forest supervisor can protect a resource degraded by the sum of independent local choices. That is why USDA found in 2001 that a national prohibition was "the best means to reduce conflict and potential for incremental impacts" - and incremental impact is how dark skies are lost.

The proposal also concedes later plan amendments "could increase the area where timber harvest and road construction would be allowed," so the "modest and localized" near-term effects are a floor, not a ceiling, and the Department has not analyzed what lies above.

4. The stated purpose does not apply to eastern roadless areas.

The Purpose and Need rests on wildfire, insects, disease, and wildland-urban interface protection, and concedes these are concentrated "especially in the Western United States." Pennsylvania and West Virginia's mesic hardwood forests lack those fuel conditions, and §§ 294.12(b) and 294.13(b) already allow fuel treatments where needed. A rescission driven by western conditions imposes an uncompensated loss on eastern forests where the stated problem does not exist.

5. The draft EIS and cost-benefit analysis omit an affected resource and industry.

The Summary of Potential Impacts notes tradeoffs with "quiet, remote and self-reliant recreation" and a $6.1 million annual recreation loss, but never identifies night-sky quality or astrotourism. Cherry Springs draws visitors from across the Northeast because the surrounding plateau is dark, and stargazing is a documented use at Spruce Knob and Dolly Sods. The National Park Service treats natural darkness as a protected resource, and the Forest Service planning framework protects "scenic character," which includes the night sky. NEPA requires a hard look at foreseeable effects on this resource. The final EIS should include a night-sky analysis for each region with roadless areas, especially eastern IRAs where dark sky is scarce, and the cost-benefit analysis should account for astrotourism.

Requested action: Retain Subpart B in full (No Action). If the Department proceeds, it should at minimum (a) retain the §§ 294.12 and 294.13 prohibitions in Forest Service Regions 8 and 9, where the wildfire rationale does not apply and dark skies are irreplaceable, and (b) supplement the draft EIS with a night-sky analysis before any final rule.

Thank you for considering these comments.

Respectfully, Resident of Massachusetts

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The agency frames this rescission partly as a permitting and administrative burden argument. But the rule already accommodates the activities most often cited. 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)." The agency should identify, by specific category, which burdens are not already addressed by these existing exceptions, including those covering existing mineral leases and community wildfire protection, and it should quantify those burdens with evidence rather than assertion.

I hunt and fish because I believe in the value of the animals and in leaving something intact. The agency's own document acknowledges what roads do to that. The DEIS states 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." That finding appears in the agency's record and then stops there. No population-level projection follows. No estimate of what opening roadless areas means for elk numbers or hunter opportunity appears anywhere in the document. The agency must project those effects before it acts.

The DEIS acknowledges that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then set aside. It is never applied to the 40.1 million acres of potentially affected environment that this rescission puts in play. A number that wide, across an area that large, is not a footnote. It is the central question. The agency must apply that cited fragmentation range to the full 40.1 million acres and show what the consequences actually look like before this rule is eliminated.

Uncontrolled damage is irreversible. The agency has not shown that the benefits of rescission outweigh that fact. I ask that it answer each of these points in the record and reconsider this action.

Sincerely,
A concerned citizen

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 Draft Biological Assessment discloses its method — IRA shapefiles run through IPaC for the FWS list, NMFS species compiled from consultation records, both lists vetted by Forest Service staff and sent to the Services in September–October 2025, occurrence data from GBIF and NRM (BA p. 25) — but reports counts only by taxonomic group (e.g., 30 candidate bird species, 4 removed, 26 remaining, BA p. 161) and states no total. The BA also warns its databases do not differentiate between DPSs, "causing potential inflation" (p. 25). The "more than 300" figure cannot be traced to this method, and it is unclear whether it double-counts distinct population segments.

Request 1: Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count, the date it reflects, whether DPSs are counted separately, and cross-reference the BA's Species Lists section wherever the figure appears — citing the correction per 7 CFR 1b.7(f)(3).

Second, the figure does no analytical work. It appears only as background and is never tied to an effects conclusion — even though the same page states fragmentation reduces biodiversity 13–75% (Haddad et al. 2015), with effects "greatest in the smallest and most isolated fragments."

The record already supplies the missing link: Dietz et al., "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species" (2021), is in the Draft EIS's own reference list, cited in Vol. III (p. 37 n.201), and discussed at length in both the eight-state AG letter (Vol. III pp. 38–39) and the joint Tribal letter (Vol. III p. 498). Its finding: of 537 vulnerable terrestrial vertebrate species, 308 (57%) have suitable habitat in roadless areas — despite roadless areas covering only 2% of the contiguous U.S. — every roadless area holds habitat for at least two such species, and 81% of roadless acreage is suitable for at least five.

Because this study is already in the agency's record, 7 CFR 1b.7(f)(2)(iv)'s bar on literature "not previously considered" doesn't apply — the agency need only analyze science it has already adopted. The chain is undisputed: rescission lifts road and timber-cutting prohibitions across the roadless network; the Draft EIS's own fragmentation finding predicts biodiversity loss, worst in small, isolated fragments; and Dietz et al. show this network is the disproportionate habitat base for the nation's vulnerable vertebrates — so shrinking it degrades species representation in the protected-area system.

Request 2: Under 7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission's effect on representation of species of conservation concern, using the corrected figure and engaging the Dietz finding — or explain in the response to comments why record science on this point doesn't apply.

Both requests are substantive under 7 CFR 1b.11(a)(53): an unreconcilable affected-environment figure and an effects analysis that ignores a record finding are a failure to consider an important aspect of the problem, 5 U.S.C. § 706(2)(A). Both also affect the Section 7 consultation record, which rests on the same unstated baseline (BA p. 25).”

Keep roadless areas roadless.

Respectfully,

CommentID: RLC-20260916-BIKIKN

The mountains of North Carolina and the broader Southern Appalachian region are treasured not only for their beauty, but for the environmental services they provide and the recreation economy they support. Keeping these areas roadless helps preserve the character of the landscape for future generations while reducing costly and unnecessary disturbance.

I urge you to uphold the Roadless Rule and reject efforts to weaken protections for these public lands. Once roadless character is lost, it is exceedingly difficult — and often impossible — to restore. Please protect these forests, streams, and wild places for the benefit of current and future generations.

Thank you for considering my comment.

Sincerely,
Brandon Inabinet

Purpose and Need Asserts a Balancing of Competing Values Without Performing It Against the Record's Own Conservation Evidence

I request three things.

1. That the FEIS supplement the rationale for the proposed rule to state the conservation values of inventoried roadless areas as the Department's own record documents them, including the Dietz et al. (2021) findings published at Volume III page 39, and to explain why the changed conditions recited at pages 18 through 20 outweigh them. 7 CFR 1b.7(f)(2)(iii).

2. That the FEIS correct the statement at page 20 that changed conditions "diminish the basis for a national prohibition," or supply the analysis that supports it. 7 CFR 1b.7(f)(2)(v).

3. That the FEIS disclose the population served by drinking-water source watersheds within the 44.7 million acres of inventoried roadless areas, or state on the record that the Department cannot determine it.

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

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

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

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

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

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

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

- 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

While my central concern in these comments is The Tongass, the rule-making is national in scope. The 2001 Roadless Rule protected roughly 58.5 million acres of inventoried roadless land across the National Forest System. Under this new proposal, essentially all of it, aside from the existing state-specific rules for Idaho and Colorado, would lose federal roadless status.

This proposed rescission reaches ecologically important land far outside Alaska: old-growth and roadless terrain in the Pacific Northwest, high-elevation backcountry throughout the Rocky Mountains, Sierra Nevada roadless areas in California, and roadless tracts in the Southern Appalachians. By USDA's own estimates, up to 18.2 million acres would become eligible for new permanent roads, 4.8 million acres of forest would open to expanded timber harvest, and 9.8 million acres of wilderness-urban interface would become newly eligible for fuel treatment. This would have impacts that extend well past the regions where the wildfire rationale might reasonably apply.

I raise this to show that a single, nationwide justification risks being applied to forests it was never built for—and The Tongass, as a temperate rainforest, rather than a fire-prone western forest, is the starkest example. The USDA should perform forest-specific analysis for every affected forest.

The Tongass is among the most significant such interests anywhere in the National Forest System: It holds an old-growth, temperate rainforest that serves as a major carbon sink and Tribal representatives have raised this directly in consultation, along with the need for an ANILCA Section 810 subsistence analysis before any decision.

It provides critical habitat for bald eagles and other species that depend on intact, un-fragmented old growth and undisturbed watersheds. Its salmon-bearing watersheds and subsistence resources are directly linked to the well-being, food security, and cultural practices of Tribal and Alaska Native communities. These are concrete, well-documented interests specific to this landscape, and USDA is obligated to weigh them accordingly. The Tribal consultation record already favors continued protection. USDA's own consultation summary reflects that most Tribal governments opposed the proposed rescission, viewing it as a threat to inherent rights, Tribal sovereignty, cultural continuity, and the ecological integrity of ancestral homelands, with inadequate government-to-government consultation cited as a central concern.

Substantial weight must be given to the documented opposition of the Tribal governments consulted on this rule-making. Conduct comparable forest-specific impact analysis for other significantly affected national forests, rather than relying on one blanket nationwide rationale for all 58.5 million acres covered by this rescission.

I have traveled in and around Alaska, and had the great fortune to have visited and hiked in The Tongass. I ask that The Tongass National Forest be removed from any final rescission of roadless protections or, at minimum, adopt a Tongass-specific management framework grounded in scientific ecological knowledge and Tribal co-stewardship.

Thank you for consideration of my deep concern for all forests of this nation that have historically been pillaged without careful forethought to the consequences -- all in the name of “maximizing potential” of our precious environmental treasures. The Tongass is absolutely one of those gems and deserves all the protections that The Roadless Rule has provided in the past. We must think of the future of this planet and what generations to come will have been left to discover and marvel at. I implore the USDA to, please, take care of our lands. Stop the exploitation. They need and deserve protection.

Wendy Stoner-Lincoln
Wiscasset, Maine

"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

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

I ask the agency to explicitly describe what steps it will take to maintain the wilderness, the pure watershed, and the bird habitat in the Superior National Forest.

"The visitor industry is the largest private sector contributor to regional employment after government. The visitor industry provides over 8,000 jobs, 18 percent of regional employment, and over $249 million in earnings, 11 percent of regional earnings, each year." (Complaint para. 51, same filing, pp. 22-23 of 50)

"Given the urgency of keeping additional carbon out of the atmosphere and continuing carbon accumulation from the atmosphere to protect the climate system, it would be prudent to continue protecting ecosystems with large trees for their carbon stores, and also for their co-benefits of habitat for biodiversity, resilience to drought and fire, and microclimate buffering under future climate extremes." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract)

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,
Michael Edward Christoph
Denver, Colorado

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 DEIS supplies the mechanism itself, one page earlier, and does not carry it forward. At p. 130 it states: "Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation." Rescinding the prohibition permits road construction and timber harvest in the very watersheds the DEIS has already identified as containing municipal intakes. Increased sediment and turbidity in a surface-water source raise treatment cost and can exceed treatment capacity during storm and post-disturbance runoff, forcing intake shutdowns and reliance on alternate supply. That is the sentence the DEIS began at p. 131 and did not finish, and it is the finding the FEIS must make.

The scale of what is undisclosed is the DEIS's own. At pp. 129-130 it reports that "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas" and that "Approximately 24 million people utilize water which originates within potentially affected inventoried roadless areas," with Table 35 breaking that out by region. For the Proposed Action the DEIS states that "The Intermountain Region is also affected in that over 1 million people receive water directly from watersheds containing inventoried roadless areas" (p. 131) - and then states no effect on them.

The record contains a named, quantified system inside that figure. The Salt Lake City Department of Public Utilities told the agency (DEIS Vol. III, pp. 246-247) that "Our community opposes any federal action that could put our regional water quality at risk for 400,000 users throughout the Salt Lake City metropolitan area," that "The Wasatch Mountains east of Salt Lake City provide 60% of our daily water supply," and that "Protecting our water quality and our public health is the foremost responsibility of our work at SLCDPU." Table 35 puts the entire Intermountain Region, which covers Utah, at 1,118,900 people served by intakes; the single system documented in the agency's own record is 400,000 of them, roughly a third of the region's whole intake-served population. "Salt Lake" appears once in Volume I of the DEIS, in a list of references cited under Recreation. "Wasatch" does not appear in Volume I at all.

The obligation to make this finding is stated by the agency, in this document. At p. 127 the DEIS says: "The Forest Service is required to manage National Forest watersheds that supply municipal water under multiple use prescriptions in land management plans (36 CFR part 219)." A rescission that removes the rule-level prohibition on road construction across watersheds holding more than 7,000 municipal intakes cannot be evaluated against that requirement on a record that states no effect for any alternative. See Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989); Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998).

The sentence that closes this section at p. 131 - "Most forest plans acknowledge the need for protections for municipal watersheds with plan components that have an overall management objective to maintain and improve watershed status" - does not supply the missing finding and cannot defer it. No plan component is identified, none is cited, and "most" concedes that some plans have none. The decision under review is made at the rule scale and made now: the prohibition either stands or is removed nationally, and the watersheds it currently covers either keep that protection or lose it on the effective date. Whatever a later project-level analysis may add, it cannot supply the effects disclosure NEPA requires for the decision actually before the agency.

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 paragraph's citations are attached to other propositions. White et al. 2016 is attached to the sentence immediately preceding the figure - "Some communities located around Federal recreation lands have a high dependence on economic inputs from recreation visitor spending and may experience negative economic conditions if visitation declines or visitor spending patterns change (White et al. 2016)" - which is a statement about community dependence, not about visitation counts. USDA Forest Service 2025a (National Forest and Grassland Economic Contributions, Forest Service Publication FS-1251) is attached two sentences after the figure, to "Visitor spending in FY2023 contributed approximately $16.2 billion to U.S. GDP and supported about 167,000 jobs, both full-time and part-time." Every other statistic in that paragraph is FY2023 and is drawn from that FY2023 source. The FY2024 visitation count is the only FY2024 datum in the paragraph, and a source cited for FY2023 spending and GDP cannot supply an FY2024 visit count. The same sentence appears at page 16 of the Economic Analysis, where the sentence order is different - the figure appears first and the White et al. 2016 citation two sentences after it - which confirms that no source is attached to the figure in either document.

The Draft EIS also cites the National Visitor Use Monitoring program at page 220 as "(USDA Forest Service 2026a)." The string "Forest Service 2026" appears exactly once in Volume I, at that in-text citation. The References Cited section at pages 249-285 contains no entry for USDA Forest Service 2026a; its only National Visitor Use Monitoring entry reads "U.S. Department of Agriculture, Forest Service. 2024. Forest Service National Visitor Use Monitoring Data Dashboards." The Draft EIS therefore relies on an unidentified source for the one program capable of producing a national visitation figure, and the public cannot review the data the agency used.

These are not questions of citation form. The FY2024 visitation figure is the quantitative foundation of the recreation-economics discussion at pages 220-222, which the Draft EIS uses to characterize the visitor spending and employment potentially affected by the rescission. A quantity asserted with no source in the record is not a fact found, and under 5 U.S.C. 706(2)(A) and Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983), the agency must articulate a rational connection between the facts found and the choice made. It cannot do so on a figure the record does not support. Because this concerns compliance with applicable law, the information is substantive under 7 CFR 1b.11(a)(53) and the issue cannot be certified as comparatively not of a substantive nature under 7 CFR 1b.7(j).

I request two factual corrections under 7 CFR 1b.7(f)(2)(v), each of which the agency should account for by citation under 7 CFR 1b.7(f)(3):

1. Supply the source and data year for the FY2024 visitation estimate at Draft EIS page 220 and Economic Analysis page 16, or remove the figure from both documents. If the source is the National Visitor Use Monitoring program, identify the specific NVUM release and its publication date.

2. Add a complete References Cited entry for "USDA Forest Service 2026a," or correct the in-text citation at page 220 to the source actually relied upon.

Because the same unsupported figure carries the recreation baseline in the Economic Analysis that supports the proposed rule, these corrections are owed both in the Final EIS and in the final rule's explanation of the economic effects on which it relies.

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.

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.

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

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

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.

organizations have financial relationships with the agency that continue to bring potential for conflicts of interest. These special interests or Friends Groups cannot be the solution for an underfunded / under-resourced federal agency.
This ill-conceived rescinding of the 2001 Roadless Conservation Rule will work in tandem with the proposed Travel Management Rule to further economic divides in this country. It will continue to provide opportunity for recreation to the elites while leaving most Americans excluded from the benefits of their national forests. It will also open the land to "exploitation without consequence" by corporations and special interests, while again bringing no benefit to the majority of Americans. Future generations will have fewer resources because of the greed exemplified by this rule.

The Forest Service is not equipped with the funding or personnel to assess its current conditions or the impacts of its actions. Societies and the world at large have changed drastically while the agency has not; in fact, the Forest Service is so locked into its behaviors and internal culture that it cannot evolve. With such limitations, there are a handful of "goods" that the agency could perform, but poorly conceived, short-term actions like eliminating the Roadless Rule are not a "good."
With adoption of this rule, the Forest Service will continue to fail the people it is charged to serve.
Thank you for taking my comment.

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.