Read the comments.

To Whom it May Concern: I live in Seattle, WA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, living in or near a National Forest community, and Trail runner. Natural places, untouched by roads and development, are critical for the health of our environment and for our own enjoyment and appreciation of the world. Lake Ann Trail is one place that has shaped my views on this proposal. It is within the Mount Baker North Inventoried Roadless Area in Mount Baker-Snoqualmie National Forest. We hiked to Lake Ann this past weekend, and were blown away by the natural scenery! The trail meanders through a basin surrounded by rocky peaks and golden meadows. The lake itself was a gorgeous jade, surrounded by golden larches just reaching their peak. These places need to be preserved for future generations! I am concerned about wildlife habitat and landscape connectivity. Large areas without road access provide more protection for the habits of diverse species of plants and wildlife. I am concerned about clean water and healthy watersheds. Roads disrupt natural vegetation and waterways that protect our water sources. They also create pollution, which risks the health of our watersheds and the plants and wildlife sustained by them. Roadless areas matter to me for recreation and the experiences they provide. Being able to visit these incredibly special places is a privilege, and one that we are uniquely honored to have in our country. I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. Roads are associated with increased fire risk through the increased opportunity for wildfire ignition. The data shows that a majority of human caused wildfires ignite near areas with road access. I am concerned about increased timber-development pressure in currently roadless areas. The importance of a healthy tree canopy cannot be overstated, particularly at a time when we are facing increasing stresses on the climate. I believe maintaining a national conservation baseline matters. The US is special BECAUSE of the vast areas of undeveloped nature. Unlike Europe and other more densely populated countries we have the opportunity to preserve these spaces and should not be short-sight about this. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

Dear USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule. I am a hiker, PNW resident and climate action-driven citizen and I am joining millions of Americans of all backgrounds in support of the Roadless Rule. As a hiker and animal/nature enthusiast, myself and so many citizens benefit hugely from Inventoried Roadless Area conservation, like the areas near Bellingham and in the Methow Valley. Inventoried Roadless Areas offer tremendous benefits to communities and ecosystems that would be threatened or destroyed by road building. Here are just a few examples of the benefits of retaining the Roadless Rule. Wildlife habitat: imperiled species like Northern Spotted Owls, Marbled Murrelets, and countless other birds rely on large, intact forests with undammed, unlogged streams and connected landscapes. Salmon, trout, elk, and other species are also threatened when habitat is fragmented Drinking water: 60 million Americans rely on national forests for drinking water; intact forests filter water naturally. Many inventoried roadless areas are important parts of watersheds that supply clean water. Wildfire risk: wildfires are 4x more likely to start near roads; roughly 90% of wildfires are human caused and start within half a mile of a road — these facts directly contradict one of the Trump administration’s main rationales for rescinding the rule. Old growth & carbon storage: mature and old-growth forests are a critical buffer against runaway climate change. We should be protecting more forests, not gutting their protections. Additionally, these forests are far more resilient to wildfires than commercially logged forests. I urge you to keep the Roadless Rule in place as it is. Thank you for your time.

I oppose the proposal to rescind the Roadless Rule. I co-own a small photography business that photographs proposals and elopements in the backcountry. Our clients don't book us to stand beside a logging road. They come for quiet, intact wild places, and that landscape is the foundation of our livelihood. For 25 years, the Roadless Rule has given businesses like mine something rare: predictability. We can plan seasons, invest in this work, and promise couples these places will still be here. Rescinding the rule trades that lasting value for short-term flexibility. The economics don't add up. Visitors to roadless areas spent $8.5 billion in nearby communities in 2024 (DEIS p. 212), while timber from these areas is projected to generate just $2.2 to $11.4 million a year (p. 220). The DEIS itself notes that outfitters and guides may face higher costs (p. 224). Small businesses like mine would pay for a harvest that earns far less than the recreation it displaces. The wildfire rationale is thin. Per the DEIS, human-caused fires are a much smaller share of fires in roadless areas than elsewhere on national forest land, and ignition density is about four times higher on other lands (pp. 86, 89). The document also acknowledges that timber projects are the primary motivation and funding source for new roads (p. 102). That makes this look more like a timber policy than a fire policy. We can't maintain the roads we have. The Forest Service reports a $7 billion maintenance backlog, and fewer than 30% of its roads are in good condition (pp. 40, 42). The DEIS concedes timber revenue wouldn't cover the cost of building and maintaining new roads (p. 45). Water and wildlife are at stake. About 7,000 municipal water intakes sit in watersheds containing roadless areas (p. 120), and landslides are 6 to 9 times more likely near forest roads (p. 111). These lands overlap the range of more than 300 threatened, endangered, and proposed species (p. 160). Tribal interests deserve more than a promise. The DEIS acknowledges possible reduced access to treaty-reserved resources and sacred sites (pp. 201-202). Please keep the rule in place, and give the public a comment period equal to a decision affecting tens of millions of acres. These untouched areas are also where I spend my own time: skiing, hiking, mountain biking, paddleboarding, river rafting, wildlife viewing, stargazing, and foraging. It's incredibly important to me and to anyone else who recreates in these areas that they remain wild wilderness.

I oppose any change to the 2001 Roadless Area Conservation Rule. Many agencies spent thousands of hours painstakingly collecting data before enacting the 2001 Rule, and there is no need to change it. It seems disingenuous to state that "the management direction for inventoried roadless areas would continue to be governed by the applicable land management plans for each unit of the National Forest System," when the Trump administration has fired 6000+ people from the Forest Service, and appointed a Timber Industry executive with no former forest service experience, to the position of Chief of the Forest Service, . The claim that building new roads and allowing new access into roadless areas is necessary for wildfire management, is contradicted by many wildland firefighting organizations, with a direct quote from FUSEE (Firefighters Unted for Safety, Ethics and Ecology); "Constructing new logging roads into roadless areas will increase human-caused wildfire ignitions by careless recreationists, criminal arsonists, or simple accidents," said Carson States, a 10-season veteran firefighter and Type 6 engine boss from Oregon. "More roads mean more fires, so the broadened access to a wildfire incident will be undermined by the increased number of wildfires that will need to be suppressed." With tens of thousands of scientists around the world agreeing that forest preservation is vital to the survival of all life on earth, the idea that more logging and more roads into pristine wilderness is somehow in anyone's best interest is ludicrous. I am in complete agreement with the Tribal assessment that " removing this layer of national protection shifts the unsustainable burden of project-level review onto their limited resources and exposes previously untouched areas to industrial activity, mining interests, and destructive recreational access, all of which threaten sacred sites, traditional gathering areas, water quality, and subsistence resources." Further the " Proposed alternatives that were frequently requested: "retaining the existing rule (“No Action”) or establishing new co-management structures, such as a “Strengthened Roadless Rule Alternative” or a “Traditional Homelands Conservation Rule” that integrates Traditional Ecological Knowledge, Tribal co-stewardship, and Tribal consent for major decisions, would be critical to any change. I absolutely object to rescinding any part of The 2001 Roadless Area Conservation Rule. Even though I live in a state with it's own Roadless Rule, I am a property owner in Nevada, and spend much time in the wilds of our country, and it is plain to see the impact of human overuse already in our wide open spaces. We have to preserve what we have for the future of all life on earth to survive. With deepest concern for our vital roadless wilderness, Laralee Leavitt Idaho Resident

•I oppose the Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule. •The Forest Service should strengthen the Roadless Rule, not eliminate it. The current rule provides essential protections but still permits damaging activities in Inventoried Roadless Areas. •Rescission would remove national protections from approximately 45 million acres of National Forest lands, exposing intact wildlife habitat and watersheds to additional logging, grazing-related roads, mining, and fragmentation. •Research examining 1,500 fires shows that protected (unroaded) forests burn at lower intensity and have lower rates of fire spread when controlled for weather conditions. Roads can increase human-caused fire ignitions and spread invasive plants. •The Forest Service should close loopholes that permit logging and the construction of so-called “temporary roads” in roadless areas. Temporary roads can cause lasting harm to wildlife habitat, soils, and watersheds. •The 2001 Roadless Rule does not address livestock-grazing impacts, and grazing has continued uninterrupted in Inventoried Roadless Areas. A mapping analysis estimates that between 10 million and 15 million acres of these lands are actively grazed by domestic livestock each year. Livestock can damage streams and springs, remove riparian vegetation, compact soils, spread invasive plants, and displace native wildlife. New road construction would enable harmful livestock grazing to expand. •The Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values. •The existing rule does not prohibit hardrock mining claims under the General Mining Law of 1872, and mineral leasing can continue. USDA should ask the Secretary of the Interior to withdraw Inventoried Roadless Areas from mineral entry under section 204 of the Federal Land Policy and Management Act, subject to valid existing rights. The Forest Service should also prohibit new mineral leasing within these lands.More than 9,000 miles of mapped motorized trails cross roadless areas.. Motorized use can compact soils, spread invasive species, disturb wildlife, fragment secure habitat, and increase human-caused wildfire risk. Inventoried Roadless Areas should be nonmotorized by default, with narrow exceptions for valid existing rights, necessary administrative access, and emergencies. •The Forest Service should withdraw the proposed rescission and adopt a stronger national rule that protects roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and harmful motorized use. Here are some helpful talking a points you can use. Keep the first and last and just focus one a few points from the middle. and TELL them about your self and why you care.

Hello! I am writing to urge the USDA to uphold strong protections for all roadless areas. Reversing the 25-year-old roadless rule opens up the most protected areas of our national forest land to logging, mining, and other drilling in what little undominated natural spaces we have left. I understand the benefits of utilizing natural resources but those short-term economic gains (to a few) are far outweighed the short- and long-term benefits (to everyone) of keeping that land protected. Wildfire is a significant issue in our country, particularly prevalent in the western states where the majority of roadless area are located. However, this is not generally where wildfires are starting. 84% of wildfires are caused directly by human activity. I am concerned that the analysis in this proposal does not accurately account for the increased risk. It also does not address the fact that logging and other land-use practices create an abundance of dry fuels that can lead to larger fires. Congruent, uninterrupted spaces are essential for wildlife. These roadless areas, while only 2% of land in the continental 48, provide habitat for more than 50% of vulnerable terrestrial species. Not only threatened and endangered animals but all sorts of wildlife make these roadless areas home. Fracturing of these spaces threatens animal and plant communities. Noise affects birds and their animals, vehicles on roads directly kill and injure countless creatures and impact migration, runoff from vehicles pollutes soil and waterways, and increased traffic brings invasive and non-native species. The benefits of these intact ecosystems are almost impossible to fully quantify. For example, about 24 million Americans get their clean drinking water from roadless areas. What is the cost of immediately and safely replacing that? Many recreational activities are dependent on the peaceful, road-free environments of these protected areas. I do not want to see that opened up for extraction of coal, oil, wood, and other natural materials. It is so much more valuable to all of us as a living, breathing, active ecosystem. Please do not rescind the Roadless Rule. Instead, I urge the USDA and US Forest Service to maintain full protection of roadless areas (alternative 1 - no action alternative). I encourage more listening to public comment, prioritizing Tribal perspectives, and following science. Thank you, ____

I am writing to oppose the proposal to rescind the Roadless Area Conservation Rule. I am a resident of Shasta County, CA, where approximately half of our land is federally managed, with a full 30.5% of land in the county owned by the Forest Service. As a resident here, I spend hundreds of hours and have travelled thousands of miles recreating on public lands through hiking and other forms of self-reliant wilderness travel. I also have spent the last ten years of my career as a field biologist working on projects related to timberland management, wildlife monitoring, environmental restoration, and outdoor recreation, and I have been able to travel to many areas of our public lands that are less frequently visited and see the impacts of policies on these remote areas of the forests. This issue is important to me because many of the areas in my region that are under the jurisdiction of the Roadless Rule act as de facto wilderness areas, while less than 6% of lands in our county are formally protected wilderness areas. Six percent of the land separated into disjunct chunks is not enough to provide vital ecological functions. Forest Service memos state that they consider their holdings “land of many uses,” and I disagree with maximizing the extraction of natural resources on these lands. I believe that this is in direct contradiction to the agency’s stated goals. Timber sales of Forest Service lands are frequent already, and private timber companies already maximize production on their owned and acquired lands. Unlike a timber company, the Forest Service is not a private company with a singular goal to increase profits and production. The Forest Service must manage these lands for many purposes, including things like recreation, enjoyment by the public, healthy ecosystems/wildlife/botanical communities, and as a source of clean water and air. Another major issue with the rescission on the Roadless Rule is that this new proposal claims to “reduce regulatory burden,” but it will do just the opposite by increasing the number of roads the agency is maintaining while failing to address current shortfalls. The Forest Service already has thousands of miles of “drivable” roads that are already constructed but have none to dangerously little maintenance. Even worse, in many cases the Forest Service does not currently have the staffing or resources to obtain up to date information or inventories on them or to safely decommission failing roads. These roads pose a hazard to fire and emergency crews trying to use them for access as well as to recreationalists who have become stranded along them. Many of these poorly maintained roads have significant issues with washouts, erosion, and culvert blowouts. The erosion from this crumbling infrastructure can cause siltation in creeks, rivers, and watersheds, affecting wildlife, especially aquatic wildlife like fish, with negative impacts that can work their way to every rung of the food chain. This unchecked erosion from thousands of poorly maintained roads diminishes the water quality for our communities as well. Green-lighting the building of more roads will only exacerbate these negative impacts. The Forest Service already has more miles of roads than they can hope to maintain, especially with recent budget reductions and cuts to the agency. The issue with fire risk is closely related to the lack of investment in the Forest Service. Allowing building of new roads is not going to reduce fire risk automatically and would increase the risk of human-caused fires in more remote areas. Also, forests that are logged heavily and frequently have a much higher risk of fires than old growth forests. These fire-resilient mature forests have larger trees that shade out the forest floor. This means no brushy, fireprone understory or a thicket of densely spaced young trees that are all getting enough light to survive. Rapid and maximized logging without thoughtful forest management leads to these thickets of dense young trees that are a severe fire risk. Many areas logged 50+ years ago exhibit this pattern. The Forest Service should instead invest more time, money, and personnel in performing controlled burns, targeted thinning projects, and science backed regeneration of logged areas. If these factors are ignored, the regrowth will cause even more fire risk, and it won’t even survive to see sustained future logging. I support acting more conservatively with respect to road building; the Forest Service should not open the door to building new roads but should instead focus on maintaining the roads and land it already has within the current regulations. This management must be “for many uses” and it must consider impacts to wild spaces and future generations. This is why I support keeping the Roadless Rule intact.

Dear USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule. I am n environmental researcher and birder and I am joining millions of Americans of all backgrounds in support of the Roadless Rule. Inventoried Roadless Areas offer tremendous benefits to communities and ecosystems that would be threatened or destroyed by road building. Here are just a few examples of the benefits of retaining the Roadless Rule. * Wildlife habitat: imperiled species like Northern Spotted Owls, Marbled Murrelets, and countless other birds rely on large, intact forests with undammed, unlogged streams and connected landscapes. Salmon, trout, elk, and other species are also threatened when habitat is fragmented * Drinking water: 60 million Americans rely on national forests for drinking water; intact forests filter water naturally. Many inventoried roadless areas are important parts of watersheds. * Wildfire risk: wildfires are 4x more likely to start near roads; roughly 90% of wildfires are human caused and start within half a mile of a road — these facts directly contradict one of your agency’s main stated rationales for rescinding the rule. * Old growth & carbon storage: mature and old-growth forests are a critical buffer against runaway climate change. We should be protecting more forests, not gutting their protections. Additionally, these forests are far more resilient to wildfires than commercially logged forests. * Outdoor Recreation: Roadless areas offer abundant outdoor recreation opportunities such as hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands, and roadless areas contribute millions of dollars to local economies through the recreation industry. * Fiscal Responsibility – Roads are costly. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely, if ever, used (the existing road network already carries an $8.5+ billion maintenance backlog). The road network throughout national forests is already massive and should be reduced instead of expanded. I urge you to keep the Roadless Rule in place as it is. Thank you for your time.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the USDA and U.S. Forest Service to retain its protections. Here in Montana, public lands are central to our communities, outdoor recreation, and local economy. Intact forests provide places to bike, hike, ski, and experience the outdoors, while protecting clean water, wildlife habitat, and the landscapes that make these experiences possible. Removing national restrictions on road construction and timber harvesting would put these values at greater risk. Roads and logging can fragment habitat, increase erosion, and permanently change the character of backcountry trails. Maintaining recreational access means protecting the landscapes people come to enjoy. I recognize the need to address wildfire risk and forest health. The agency should explain why existing management authorities and exceptions are insufficient, and consider targeted alternatives that preserve roadless protections rather than rescinding the entire rule. Please fully evaluate the long-term and cumulative effects on watersheds, wildlife, recreation, trail networks, and communities that depend on outdoor tourism. These public lands belong to all of us, including future generations. I urge you to retain the 2001 Roadless Rule and prioritize their lasting protection.

To the United States Forest Service: I am writing to strongly oppose the Department of Agriculture’s proposal to repeal the 2001 Roadless Area Conservation Rule. Intact inventoried roadless areas are critical for safeguarding clean drinking water for millions of Americans, preserving old-growth ecosystems, and supporting robust local outdoor recreation economies. The number of ecological services provided by contiguous wilderness are inumerable. Not to mention the importance for wildlife conservation, maintaining plant diversity, increase erosion risk, buffer against flooding and increase water filtration efficacy. In our region, intact forest ecosystems—like the mature woodlands of the New Jersey Highlands and the critical catchment areas around the Stony Brook, Lower Millstone, and Raritan River watersheds—directly shield our water quality. Undisturbed forest floors prevent heavy sediment erosion, buffer against severe flooding, and keep critical tributaries free from high turbidity and pollutant loads. Beyond the immediate region, contiguous forests in and around the great lakes are critical in maintaining the water qualtiy of the largest fresh water source in the world. As climate disruption and water scarcity accelerate globally, secure access to clean fresh water has transitioned from a local conservation issue to a primary metric of national infrastructure resilience. Allowing industrial development and new road infrastructure to compromise these headwaters weakens the defense-in-depth of our public water grid, introduces long-term economic vulnerability, and degrades a finite strategic asset that cannot be engineered back to health once polluted or disrupted. Decades of peer-reviewed ecological research further affirm that maintaining the Roadless Rule provides profound, quantifiable scientific benefits: • Water Filtration & Grid Resilience: A recent study published in PLOS Water confirms that inventoried roadless areas protect over 80,000 miles of domestic rivers, naturally filtering out contaminants through undisturbed plant roots and forest soils. This green infrastructure supplies clean drinking water to 25 million Americans and lowers chemical treatment costs for downstream municipal utility grids. • Wildfire Mitigation: Spatial data shows that nearly 90% to 95% of human-caused wildfire ignitions ignite within a half-mile of a road corridor. Introducing new road infrastructure into pristine backcountry exponentially increases fire risks, whereas unroaded areas act as natural, resilient buffers. • Biosecurity & Habitat Integrity: Forest Service data indicates that non-native, highly flammable invasive plants (such as cheatgrass) are twice as common within 150 meters of a road cut. Keeping lands roadless prevents the severe ecosystem fragmentation that drives habitat loss and allows biological invasions to degrade native wilderness. The Department of Agriculture’s own draft environmental impact statement confirms that rolling back these protections threatens undeveloped backcountry ecosystems, water resources, and local wildlife corridors. New road construction and logging infrastructure would fragment these fragile habitats, introducing invasive species and The justification that rescinding this rule will mitigate wildfire risks is contradicted by existing science and the Forest Service’s own data. Research shows that human-caused ignitions are significantly more common near roads, and building new infrastructure fragments fragile habitats and invasive species corridors. Furthermore, the Forest Service already manages a multi-billion-dollar road maintenance backlog; adding more unmaintained roads will worsen fiscal and environmental strains rather than alleviate them. I urge the agency to listen to the overwhelming public, tribal, and bipartisan opposition to this repeal and maintain full protections for our remaining backcountry national forest lands. Sincerely, Cara Love

Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) Dear Forest Service Officials, I am a resident of Driggs, ID and someone who frequently recreates on public land, mostly in the Jedediah Smith Wilderness and Caribou-Targhee National Forest. I am writing to strongly oppose the U.S. Department of Agriculture’s proposal to repeal the 2001 Roadless Area Conservation Rule. For a quarter of a century, this rule has successfully protected roughly 45 million acres of pristine national forest lands from commercial logging and new road construction. I am concerned about the impact that new roads will have on the ecosystems that so many species depends on. I think it is short-sighted and dangerous to rescind safeguards that threaten vital public resources: • Clean Water: Roadless national forests act as natural filtration systems, supplying clean drinking water to more than 60 million Americans across thousands of communities. • Wildlife Habitat: These untouched landscapes provide critical corridors and refuges for hundreds of at-risk and imperiled species. • Climate and Recreation Resilience: Intact forests sequester carbon effectively and support robust local outdoor recreation economies. Furthermore, the justification that removing protections improves wildfire management is flawed and contradicted by existing science and maintenance backlog realities. Instead of opening these wild public lands to extractive industries, the agency should focus its capacity on maintaining existing infrastructure and prioritizing community safety. Furthermore, the economic vitality of my small tourist community hinges on the protection of these pristine places. To jeapordize them for the interests of commercial logging could have negative impacts on the economy of my small town. I urge the Forest Service to withdraw this repeal and maintain full protections for our roadless national forests. Sincerely, Jennifer Piperno Driggs, ID 83422

I strongly oppose rolling back the Roadless Rule and any attempt to restrict public access to our backcountry. I strongly oppose opening our precious public lands to the extraction industries. The forest service does not have the money to maintain their existing roads, yet you push for more. Why? Wildfire mitigation is not a valid reason to rescind the Roadless Rule. Scientific consensus does not support large-scale road construction and commercial logging as effective wildfire mitigation tools. Roadless forests are actually more resilient to fire. Repealing the Roadless Rule would INCREASE wildfire risk throughout the forests because wildfires are 4 times more likely to start in areas with roads than in roadless forest tracts. More than 90 percent of all wildfires nationwide have occurred within half a mile of a road. Effort and money would be much better spent acknowledging that climate change is not a “hoax”, and investing in technologies to help reverse it, such as renewable energy, which this current administration seems hell bent on restricting, even if it takes large payouts of taxpayer money to cancel existing contracts. If rescinding the Roadless Rule would actually mitigate wildfires, that would be one thing. But since the Trump administration went to great lengths in his first term to exempt the Tongass National Forest in Alaska from Roadless Rule designation, I call BS on that excuse. I worked as a seasonal surveyor in the Tongass National Forest some years back, and it is a rainforest. You’d be hard-pressed to start any fire there. But there were lots and lots of trees. There isn't any more wilderness being created. If we let it go, it's gone forever. The Roadless Rule essentially banked wilderness areas to help preserve & protect what's left of our wilderness - old growth forests, clean water, and endangered species and other wildlife. We need wild forests, animals need wild forests, a livable climate requires wild forests. Please stop your attempts to destroy them. They belong to Americans, not politicians and their extraction industry supporters. STOP!

To Whom it May Concern. I fully oppose the plan to rescind the Roadless Area Conservation Rule, both partially and fully. I am a U.S. citizen and teacher living in Los Angeles, CA. According to the administration’s DEIS, eliminating the Roadless Rule would: 1. Cause a Loss in Recreation and Visitor Spending: The administration estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. 2. Imperil Wildlife: Eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In Oregon, this includes listed species such as Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet, Northern spotted owl, Oregon silverspot butterfly, Oregon spotted frog, Sierra Nevada red fox, and steelhead, among others. 3. Threaten Water Quality: According to the DEIS, “… inventoried roadless areas typically have good water quality due to limited disturbance,” and “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.” Communities like Bend, Eugene, La Grande, Ashland, and others in Oregon receive drinking water from watersheds fully or partially within IRAs. 4.Spread Invasive Species: The DEIS states that increased road construction and timber harvest are likely to “introduce and spread invasive plant species due to ground disturbance.” Invasive plants tend to be more flammable, leading to higher wildfire risk, and can outcompete native plant species. 5. Undermines Tribal Interests: During the legally required Tribal consultation process, the administration found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission.” Its analysis concedes that timber harvest and road construction in these areas “could have long-term negative effects on Tribal rights and interests.” 6. Could Increase Fire Risk: The administration admits “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. 7. Add to Infrastructure Backlog: According to the DEIS, the Forest Service could build new roads across 18.2 million acres (44.5% of current IRAs) in the short term. This would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion. Again, for these reasons I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. We are in a climate crisis. Time to act like it. Best, Amanda Ackerman

I am writing to express my opposition to rescinding the Roadless Area rule of 2001. I prefer alternative 1 in the DEIS. I live in close proximity to both the Mt Hood and Gifford Pinchot National Forests and visit both forests regularly to hike; my drinking water comes from The Dalles watershed on the Mt Hood NF. I also visit other national forests around the west to recreate and also to assist with rare plant monitoring - I am a retired botanist. Roadless areas provide intact habitats for hundreds of threatened and endangered species, both plant and animal. It is far better - and more cost effective - to keep habitats intact than to attempt to restore damaged habitats as part of recovery efforts to improve conditions for T&E species. I have been involved in restoration work and it is slow, expensive, and not always successful. T&E species are important parts of functional ecosystems, even if we don’t understand how they fit in, and by law (the ESA) and what is actually in our own best interests and morally right, they need to be protected and prevented from going extinct. Many other wildlife species are dependent on intact habitats that are not broken up by roads or visited by humans. Road construction is the largest source of water degradation and road failures on national forest lands are all too common. The FS already has twice the road mileage of our national highway system but is billions of dollars behind in road maintenance. This is incredibly obvious when driving around - roads that are the main arteries into the forest are seriously neglected with potholes, road slumps, and unbrushed shoulders blocking the view of oncoming vehicles or obstacles. Some have washouts or missing bridges. And these are the primary roads - taking the secondary roads is even worse, if they are even passable. Why would anyone want to add still more roads when they can’t begin to maintain what they have? Ever since the agency decided to contract out road maintenance rather than doing it themselves the roads have steadily deteriorated and become unsafe. When logs fall across roads it looks like users cut them out enough to get past instead of the FS clearing the road of the hazard. Drinking water for 1 million Oregonians, including me, comes from the Mt Hood NF and nationwide forest service land provides water for over 25 million Americans. Roads & logging within these watersheds are incompatible, leading to heavy sedimentation instead of clean filtered water. Large openings from logging and road corridors lead to quicker snowmelt and runoff, lessening the shade and sponge effect of an intact forest which helps retain water for a slow release through summer months. That cool shade which aids in moisture retention is also important for the resilience of forests to fires. About 85% of fires are human caused and they are about 4x more likely to start in close proximity to roads. Roads increase fire danger, roadless areas decrease the risk. Logged forests also increase fire risk & intensity as the ground warms up the vegetation becomes stressed & dries out. Roads are corridors for invasive species, particularly weeds which damage habitat. Recreation has become a primary use on national forests and is an important and fairly reliable source of income for surrounding communities, steadier than the boom & bust pattern of logging which employs fewer people since what logging and milling do occur is more automated. I’ve seen that an estimated $9 million would be lost annually from recreation spending in communities near roadless areas. Many roadless areas are popular for the lakes, waterfalls, scenic views and other features that they contain and that would be damaged with roading & resource extraction. I hike & visit many roadless areas and recognize that they remained roadless because of their topography and often poor quality trees (for harvest) due to inhospitable growing conditions. Some of our best old growth stands are in roadless areas, places that are critical for species dependent on the conditions only an old growth forest provides. National forests are managed for multiple uses and retaining roadless areas ensures many of those uses are protected. In closing I reiterate that I am opposed to rescinding the Roadless Rule which has been so effective for the last quarter century and which from the beginning has been overwhelmingly popular with Americans. These are our public lands and we don’t want them damaged by roads and development any more than they already have been. There is plenty of forest that has more roads than can be maintained on current inadequate budgets and areas that were previously logged that can be re-entered for a second harvest. Keep the Roadless Rule intact.

Docket ID: FS-2025-0001 (RIN 0596-AD66) Copy and paste this finalized text into the Regulations.gov Roadless Rule Comment Page: I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. As an avid outdoor recreationist who frequently visits and relies on public lands, I am deeply concerned about the devastating impacts this rollback will have. I regularly hike, hunt, and camp in national forests across Western Montana, Arizona, and Southern California, including the Lolo, Flathead, Bitterroot, Coconino, and Cleveland National Forests. These specific landscapes are irreplaceable to me for these backcountry activities. The agency’s rationale that removing roadless protections will mitigate wildfire risk is fundamentally flawed and contradicts established science. Roughly 85% to 90% of wildfires are human-caused, and the vast majority ignite near roads. Carving new roads into our last intact wildlands will inherently increase wildfire risks to nearby communities, not reduce them. This is especially dangerous in wildfire-prone landscapes like Southern California and the drought-stressed forests of Arizona and Montana. Furthermore, the Forest Service already faces a massive multi-billion-dollar road maintenance backlog. Expanding infrastructure into roadless areas is a fiscally irresponsible burden that the agency cannot afford. From the critical wildlife corridors and pristine waters of the Lolo, Flathead, and Bitterroot, to the fragile, life-sustaining ecosystems of the Coconino and Cleveland, roadless areas are vital. They preserve essential watersheds that provide clean drinking water, protect biodiversity, and offer the quiet, undeveloped spaces required for quality hiking, hunting, and camping that are vanishing elsewhere. I urge the Forest Service to reject this rescission entirely, maintain the 2001 Roadless Rule, and protect these specific forests for future generations.

My name is Elliott Moffett & I’m a member of the Nez Perce Tribe (NPT), I’ve lived on and near the Nez Perce Indian Reservation (NPIR) most of my life. I am also member and cofounder of the organization called the Heart of the Monster Society, which organized to give voice to marginalized communities like Indigenous Peoples. HoftheMS formed to represent Indigenous, Tribal & community members who want to live in sacred relationships with our communities & Mother Earth. We oppose rescinding the Roadless Rule, as we are in a sacred relationship with Mother Earth. The reasons we are against this federal action are because lack of consultation with tribal peoples, we do not need more roads in our forests. This action denies climate warming because it will open more timbered areas to more logging, more road construction & reconstruction, threatening old growth stands, which open forests to climate, less shade of lands & waters. It will open more species some ESA species to extermination. Local. Control means national policies like those considering Indigenous rights will be ignored, rejected, & at the very least marginalized. More extractive industries will have access to valuable species, like mining for minerals threatening fisheries and habitats. The lands of national forests are already harmed by past actions. Millions of dollars are spent trying to “undo” years of gold mining, which mining companies are less apt to restore. The NPT ancestral territories include multiple national forests, for which the tribe and its members must take care to use and includes managing. Prior to Euro Americans coming to this country, Nimiipuu-NPT people have taken care managed territories including forested areas for over 16,000 years, long before the development of the US, the State & FS. I associate these comments with environmental concerns as expressed by such organizations as Friends of the Clearwater(FOC). The Indigenous Peoples manage to serve the most for the greatest value, like our forests provide clean water for drinking & municipal uses. There is enough and I claim too much logging as is, as a commuter of Idaho roads in the forests & along the streams and rivers, I can attest to the number of logging trucks on the roads where we must compete with speeding logging trucks trying to cut down and move logs to market. Wildfires still occur even with all of the logging. More logging more roads will not reduce numbers and severity of wildfires, unless the goal is to cut all trees; under the no trees, no fires theory. The number of salvage timber sales has grown with more fires, interesting. I object to the reason to rescind the roadless rule is to return to more local decision making. Guess what they’ll do: more logging, more mining and with the country going crazy with data centers more mining to get rich quick, which is foundation of Idaho’s heritage. They’ve logged almost all private and State lands and so must rely on logging national forests. Local decision making has led to the forest service denying its trust responsibilities to tribes and their members. Treaty rights were the basis of suing the FS, as it failed to exercise its trust duties to help protect treaty rights. As stated the tribe and its members exercise inherent rights, and where the tribe is recognized as fisheries commanders, we must also be treated as co- land managers. These are ancestral territories which help in cultural survival which supports tribal sovereignty. We work with the tribe as an organization for the ecological health of inherent territories. We look for greater diversity in ecosystems, which are provided in multiple use management which is not served by the practice of timber plantations. Local decision making has ignored and opposed for generations tribal sovereignty and jurisdictional prerogatives. The roadless rule protects miles of rivers and streams. The ForestService has responsibility to exercise trust responsibilities to tribes and its members and has not convinced us that federal objectives would be better served by having more roads, we see more chances to extract “resources” from already depleted lands from past roaded areas. For these reasons, on behalf of Indigenous organization, Heart of the Monster Society, opposes rescission of the roadless rule.

This is regarding the Proposed Rescission of the 2001 Roadless Area Conservation Rule I oppose the rescission of the 2001 Roadless Rule and urge the Forest Service to keep these protections in place. I have dedicated my life to working on behalf of lands, waters, and wildlife wherever I have lived. I currently live in Marin, California and work alongside our national park partners at the Point Reyes National Seashore to care for these lands on behalf of ecosystem and human health. This work (and my work as an educator for many years) has taught me that roadless forests do things no other landscape can do. They shelter wildlife that needs unbroken habitat, they filter and store the water that communities downstream depend on, and they help keep ecosystems resilient. These benefits are essential to human health, not just amenities. If we want to preserve life on this planet, we need to listen to what wildlife, water, and forests are telling us. Rolling back protections for nearly 45 million acres puts short-term access ahead of the long-term health of the land and ignores the interests of future generations, who will inherit whatever we leave intact. I urge the agency to retain the Roadless Rule, or at minimum to analyze and adopt an alternative that keeps meaningful protections for these areas. Thank you for considering my comment. Heather Clapp, Bolinas, CA

To the Roadless Rule Rulemaking Team:Edit salutation I am writing as a naturalist and concerned citizen opposing the rescission of the Roadless Rule. The proposal would destroy the places and wildlife that I love. I am concerned about how it would affect the Chattahoochee National Forest, a place I go for peace, recreation, and wildlife appreciation. Boggs Creek in the Chattahoochee National Forest protects the headwaters of Dicks Creek and Cowrock Creek, which form the foundation of a cold-water stream network that supports species dependent on stable, unwarmed water. The hellbender (*Cryptobranchus alleganiensis*, near threatened, IUCN), a fully aquatic salamander that requires high dissolved oxygen and temperatures below 74°F, depends on the riparian shade and groundwater inputs that an intact, roadless headwater forest provides. The seepage salamander (*Desmognathus aeneus*, near threatened, IUCN) and Chattahoochee slimy salamander (*Plethodon chattahoochee*, imperiled, IUCN) occupy the saturated seepage zones and riparian margins of these headwater systems, where they are sensitive to both temperature fluctuation and hydrological disruption. Maintaining the roadless condition preserves the forest canopy and soil structure that regulate streamflow and temperature across the entire downstream drainage. Boggs Creek harbors multiple rare plant species adapted to the specific microclimates of Southern Appalachian cove forests and seepage zones: small whorled pogonia (*Isotria medeoloides*, federally threatened), mountain sweet pepperbush (*Clethra acuminata*, apparently secure, IUCN), mountain dwarf-dandelion (*Krigia montana*, vulnerable, IUCN), jewelled wakerobin (*Trillium simile*, vulnerable, IUCN), and mountain meadow-rue (*Thalictrum clavatum*, apparently secure, IUCN). These species occupy narrow ecological niches—seepage slopes, cove bottoms, and specific soil and moisture conditions—that are vulnerable to disturbance and slow to recover. The roadless condition protects the hydrological stability and undisturbed soil structure these plants require; once disrupted, the recovery of rare plant populations can take decades or longer, if restoration is possible at all.Edit personal connection We are already watching the decline of too many beloved species. The proposed rescission is a bad idea unsupported by science that would exacerbate and accelerate that loss. It will increase the introduction and spread of invasive species. It will increase erosion. It will negatively impact water quality. It will cause destruction in one of the things that most makes America great --- our wild and scenic spaces. I see no way that it benefits those of us who enjoy or live near the forests, only irreparable, irreversible loss.Edit what you lose Roadless areas buffer and connect existing protected lands. Roadless areas are directly adjacent to protected areas on 58 percent of their land, expanding the six largest core protected areas in the lower 48 by an average of 25 percent. They also reduce isolation between protected areas and add representation of underprotected ecosystem types — including temperate grasslands and cool temperate forests — that the existing protected-area system does not cover well (Talty et al. 2020). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Please accept my entire formal comment attached as FS-2025-0001-223869_RLC-20261007-I1RDZT.pdf I'm filing this comment because I think the rescission is wrong, and I want that on record. Please keep the Roadless Rule in place. Respectfully, Sarah E. Kelsey

I am writing as a concerned citizen and public lands user to oppose the proposed recission of the 2001 Roadless Area Conservation Rule (Roadless Rule). I urge the Forest Service to retain the current Roadless Rule by selecting Alternative 1. As a community member, I am concerned about the claim that the proposed recission emphasizes greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning process to maintain ecological, cultural, and public values of roadless areas to an adequate level across the National system. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protection measurements. 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. As a community member, I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk. 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). It is clear that more roads mean more fires. Findings published in Fire Ecology conclude from 32 years of data that wildfire ignitions are 4x more dense near roads than in roadless areas (Aplet, Hartger, & Dietz 2026). Balch et al. (2017) note that "human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, dominated an area seven times greater than that affected by lightning fires, and were responsible for nearly half of all area burned." Fires are becoming more extreme each year. Why fuel the fire risk by introducing more roads? Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters rather than broadly removing protections from remote landscapes. While I am dismayed by the myriad consequences of this recission, I am particularly concerned about sensitive/endangered/threatened species, wildlife habitat and connectivity, and clean water. For instance, multiple studies since the Roadless Rule was established have found that roadless areas serve as essential places of refuge for rare, threatened, and endangered species, providing ecosystem integrity and much needed habitat connectivity (Loucks et al. 2003; Dietz, Barnett, Belote & Aplet 2021; Talty, Mott Lacroix, Aplet & Belote 2020). According to one source, "of the 537 wildlife species of concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless area (IRA)" (Dietz, Barnett, Belote & Aplet 2021). With this, one third "of all IRAs are adjacent to a national park, and two-thirds are within 1 kilometer of one" (Dietz, Barnett, Belote & Aplet 2021). Loucks et al. (2003) concluded "that IRAs belonging to the U.S. Forest Service are one of the most important biotic areas in the nation, and that their status as roadless areas could have lasting and far-reaching effects for biodiversity conservation." These are critical habitats and areas of connectivity with some of our most well-known public lands. This will have consequences for the health of a number of our 433+ National Park units as well. Additionally, roadless areas serve as critical sources of clean water for millions of Americans, protecting water sources from sediment and pollution (DellaSala 2011). One study shows that "the cost savings to water treatment plants and highway departments from avoiding sedimentation caused by logging in IRA watersheds is estimated to be up to $18 billion annually," and this was in 2011, so it is clearly more of a savings by today's numbers (DellaSala 2011). Research has found that "logging roads have been linked to great increases in erosion rates and sediment delivery to streams-up to 850% over rates in undisturbed habitat (DellaSala 2011). As a concerned citizen and public lands user, this recission makes no sense. The numbers speak pretty plainly. Why would you want to spend (probably) billions of dollars on extractive industry and infrastructure (roads, water management and treatment facilities to address the erosion that comes from denuding the landscape), to make millions through logging and mining... when the Roadless Rule is already saving billions of dollars by providing clean water, critical habitat, and space for public recreation? If nothing else, please recognize that the Roadless Rule benefits American citizens through access to clean water and is a multi-billion-dollar cost savings.

I have had the privilege of living very near to several IRA's in the last 6 years. I fundamentally oppose the recission of the roadless rule, and I believe it is not based in logic, science, or the law. The roadless rule should not be repealed and should remain as it has been. I went to college in Southwest Virginia and spent as many weekends as I could hiking, camping, and stargazing at Brush Mountain IRA and Brush Mountain East IRA in the Jefferson National Forest. During deer hunting season I volunteered with the Virginia Department of Wildlife Resources to test deer harvested for chronic wasting disease. A few Saturdays during the season we tested deer from various parking lots throughout Montgomery county. Many of those hunters hunted in the National Forest, and many on Brush Mountain. Kids harvested their first does in this IRA and families bonded hiking to tree stands in the Forest they had been hunting for decades. Brush Mountain and Brush Mountain East is a sacred place to everyone who has spent any time in Craig, Roanoke, and Montgomery county. Whether just passing through on a hike, spending four years of weekends there while in college nearby, or living there for generations, the IRA designation of Brush Mountain protects it as a sacred place. In 2021 I had the opportunity to camp host at a camground at the base of Mount Timpanogos. Growing up in the dense green forests of Appalachia, the wide-open Utah landscape kept me in awe every day. I spent every spare moment exploring the area, spending extra time hiking in the Unita IRAs and Wasatch-Cache Utah IRA. I spent a lot of time off-roading in rock crawlers, hauling my camper around to dispersed camp sites, and mountain biking all over Utah, but the time I spent hiking in the IRA is by far the most memorable. The Forest Service is already incapable of maintaining the roads that it has already built. Opening up acreage to build more roads when the ones that exist are not well maintained is illogical. As a lover of motorized recreation, never once have I thought, I wish there were more roads in the national forest. As a hiker and lover of intact wilderness for their ecological and environmental benefits, I am grateful every day for IRAs and the value they provide to big and small game species, the ecosystem overall, and for the peace and tranquility they offer to everyone who visits. The science shows that intact wilderness, like IRAs, are better for the ecosystem, for more productive environmental services, like water filtration and carbon sequestration, and in more cases than not, more resistant to fire when properly managed under the already existing rules and regulations under the roadless rule. It goes against all valid science to say that repealing the roadless rule will have any scientific, environmental, or ecological benefit. Finally, but maybe most importantly, the proposed recission of the roadless rule is illegal. The draft EIS is deficient in every way, arbitrary and capricious, and lacks any valid alternatives analysis. I am finishing my final semester of law school and have spent the last two years reading nearly every past and present NEPA, NFMA, and APA case. I have been a part of a team that has filed two lawsuits to stop the USFS from continuing on with two logging projects in the White Mountain National Forest. In my time working on these suits I have read some well-done Environmental Assessments and Environmental Impact Statements. I know what a well-done, comprehensive, and legally sound NEPA process looks like, and this roadless rule recission process is the furthest thing from well-done, comprehensive, or legally sound.