Read the comments.

To the USDA Roadless Rule Team: As a Coloradan, and a wildlife enthusiast, I believe the 2001 rule is the single most important land management instrument and the threat of its removal is not only catastrophic but infuriating. Every year, I take a fall trip to explore these beautiful mountains and every year I am left with wonder. Seeing new wildlife, a new sunset, a new plant, a riverbed - it never ceases to amaze me. The protection of these ecosystems are imperative for us, but also for all. Being able to backpack through these undisturbed mountains and connect with other life is one of the few things that bring me joy and peace in such a hectic world. Roads end that possibility. Regarding the Mount Antero in the Pike & San Isabel NFs- Alpine and Subalpine Climate Refugia Connectivity — The area spans from 13,600 feet to 14,276 feet across multiple subalpine and alpine ecosystem types—Rocky Mountain subalpine spruce-fir forest, alpine tundra, and bristlecone pine woodland—creating an intact elevational gradient that allows species to shift their ranges as climate conditions change. This vertical connectivity is critical as warming temperatures push suitable habitat upslope; species dependent on cool conditions can only persist if they can move continuously to higher elevations without fragmentation. Road construction fragments this gradient by creating edge effects, altering microclimate through canopy removal, and introducing invasive species along disturbed corridors, which would trap populations in lower-elevation refugia that are becoming increasingly unsuitable. DEIS Narrative Exceeds the 150-Page Statutory Limit With No Extraordinary-Complexity Determination on the Record The Draft EIS exceeds the statutory page limit and contains no determination authorizing it to do so. Volume I of the Draft EIS is 333 pages. Its narrative text runs from the Introduction at page 9 through page 248. References Cited occupies pages 249 through 285, and the List of Appendices and Appendices 1 through 5 occupy pages 286 through 333. Excluding citations and appendices, as the statute directs, the environmental impact statement is therefore approximately 240 pages long. The applicable limit is 150 pages. 42 U.S.C. 4336a, enacted by the Fiscal Responsibility Act of 2023, limits an environmental impact statement to 150 pages excluding citations and appendices, and permits 300 pages only where the proposed agency action is of extraordinary complexity. USDA's NEPA procedures implement the same limits at 7 CFR 1b.7(a) and (i). The Draft EIS expressly adopts those procedures, stating at page 9 that the Forest Service "has prepared this draft environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA) and other relevant laws and regulations," and that "all references to 7 CFR 1b within this document refer to the interim rule." The document therefore exceeds the 150-page limit by approximately 90 pages. The only lawful basis for an environmental impact statement of this length is a determination that the proposed action is of extraordinary complexity. Volume I contains no such determination. The phrases "extraordinary complexity," "page limit," and "Fiscal Responsibility Act" do not appear anywhere in the document, and 42 U.S.C. 4336a is cited nowhere in it. The Draft EIS asserts compliance with "other relevant laws and regulations" while exceeding the one quantitative constraint those laws place on the document itself, and without invoking the exception that would authorize the excess. This is not a matter of formatting. The page limit operates together with 7 CFR 1b.7(i), which directs that issues not of a substantive nature receive the briefest possible discussion. A ceiling of 150 pages applied to a rescission affecting approximately 44.7 million acres of National Forest System lands compels the agency to compress its effects analysis, and the extent of that compression depends directly on which ceiling the responsible official was working to. A document written to 150 pages must omit substantially more analysis than one written to 300. The public reading this Draft EIS cannot tell which constraint shaped it, because the document never says - and the difference is roughly 90 pages of effects analysis across 44.7 million acres. I request that the responsible official make and document the extraordinary-complexity determination required by 42 U.S.C. 4336a and 7 CFR 1b.7(a) as the predicate for a Final EIS exceeding 150 pages, or, if no such determination is made, that the Final EIS text comply with the 150-page limit. Under 7 CFR 1b.7(f)(3), the response to this comment should cite where in the Final EIS or the supporting proposal record that determination is accounted for. A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this. CommentID: RLC-20261006-9WBQV3

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. My name is Dawson Autry and I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The humpback whales we watched around Baranof Island brought me to this fight. I want those waters protected, and I want to know exactly how logging the Port Alexander and North Baranof roadless areas, covering 120,681 acres and 314,089 acres respectively in the Tongass National Forest, will affect the humpback whales who frequent those waters. The Tongass is the largest intact temperate rainforest left on Earth, holding over 12,930 miles of salmon-producing streams. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. I oppose that outcome completely. I also paddle parts of the Teanaway River, which flows through the Teanaway roadless area in Wenatchee National Forest. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Washington State is currently in the fourth consecutive year of drought and in a drought emergency. Our rivers have remained free flowing. How will rescission affect the volume of water and sediment load in the Naches, Tieton, and Yakima rivers and all their tributaries on the east side of the Cascades? Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, in habitat the DEIS identifies as Essential Fish Habitat and critical habitat managed by NMFS. I want to know what the effect on local salmon runs will be, and I ask the agency to answer that question squarely in the final record. We have visited Hyder, Alaska the last two summers and enjoyed watching the bears fishing at the USFS Fish Creek Wildlife Observation Site. The DEIS quotes the federal grizzly recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. How will rescission affect the number of bears and salmon that come to that observation site? The agency must address this. The national forests of Washington state already show scars from previous National Forest roads that remain in place, many of those roads receiving no maintenance. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. What will happen to the service level on current National Forest roads if the roadless rule is repealed and additional roads are built? How much will that cost taxpayers? The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." 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 how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. The agency's own record also states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on wildfire and fuels management grounds. Those two positions cannot both be right. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence 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. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. Sincerely, Margaret Van Cleve Selah, WA

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rescission of the Roadless Area Conservation Rule is, as far as I can tell, purely about removing regulatory burden. It does not promise road development. It does not promise logging. It simply strips away protection from some of the last remaining old growth forestland in the world, for no reason the agency has made plain. This is old growth. It takes centuries to even approach that designation. Reforestation efforts across the world today pale in comparison to what true old growth forest represents. If roads go in and that land is destroyed, nothing like it may never be able to grace the earth again. The Forest Service held more than 600 public meetings and took 1.6 million public comments to put this rule in place. To undo something so substantial without a single comparable public process is, to me, a mistake. I ask that the agency explain what process it believes substitutes for that record of public participation, and why rescission of a rule built on 1.6 million comments requires none of its own. On water, the agency's own data shows that 24 million Americans drink water that originates in these roadless areas. Roads are known to cause contamination in the areas where they are built. The agency's own analysis confirms this directly, finding that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Rescinding this rule opens those watersheds to exactly that kind of harm, affecting the drinking water of millions of Americans with little to no real benefit. I ask the agency to explain on the record what specific, quantified benefit justifies that risk to public water supplies. On wildfire, the proposal invokes forest health and fuels management as justification for rescission. The agency's own record says the opposite: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal offers no reconciliation with that finding. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. On the state-by-state approach, the agency has already traveled this road and lost. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Courts rejected that state-by-state substitute before. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last tried to replace the national rule with state petitions. On statutory authority, the proposal argues the 2001 rule exceeded what Congress authorized. A federal appellate court already answered that question: "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 held 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. The agency must explain on the record the basis for any position to the contrary. Finally, on administrative burden, the rule as written already contains exceptions, including for "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 has not identified which specific burdens those exceptions fail to address. It must do so, with quantification, before rescission can stand as a proportionate response to any genuine operational difficulty. Future generations deserve to have this land, to experience the beauty the world has to offer, and we are discussing potentially opening the door to take that away.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet found in backcountry areas is not available anywhere near roads and human development. I have hiked and camped in many such places, and I know that feeling of time slowing down, that grounded, peaceful quality that simply does not exist where roads are found. Each backcountry location is incredibly unique in so many ways, and each one we have matters for that variety, for the ecosystems found there, and for ourselves and our children's children to be able to experience. The proposal before the agency would put all of that at risk, and the agency's own record makes a poor case for doing so. Start with fire. The agency's own findings state that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nevertheless justifies rescission partly on wildfire and fuels management grounds. The agency needs to explain, in plain terms, why this proposal departs from its own prior findings on fire occurrence, and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold up either. The record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those are small numbers to set against significant permanent losses. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. Meanwhile, the road system the agency would expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot demonstrate a net positive outcome justify enlarging that liability? The agency has also been down this road before. The record quotes the agency itself expressing dissatisfaction with the Roadless Rule and rejecting its "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That dissatisfaction led to a state-by-state replacement, and the Ninth Circuit struck it down. The proposal moves in the same direction again. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and it must explain how this proposal avoids the specific legal deficiencies identified the last time it tried to substitute state processes for one national rule. Finally, the existing rule already accommodates a range of management needs. 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 exceptions for public health and safety, existing mineral leases, and community wildfire protection are already in the text. The agency claims administrative burden justifies rescission, but it has not shown which specific burdens those exceptions fail to address. It should identify them, by category, and quantify them before going further. The places I am writing about are irreplaceable. That variety of ecosystems, that quiet, that slow-down feeling, once a road cuts through it, it does not come back. The agency has not made a factual, legal, or economic case sufficient to justify this rescission, and I urge it to withdraw it. Kristen Portland, Oregon

I strongly oppose the USDA’s proposal to eliminate, weaken, or alter the Roadless Rule. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. As stated in the Draft Environmental Impact Report (DEIS), the Rationale for the Proposed Rule is to reinstate “….important management tools for key areas where there are needs or opportunities to address overgrown and fuel-loaded national forests.” Essentially, repealing the 2001 Roadless Rule will allow the construction of roads to facilitate management of overgrown and fuel-loaded national forests. However, the Department’s own analysis indicates that it will have the opposite effect. Page 85 of the DEIS states that “Past research and new analyses presented here indicate that more fires, both in absolute numbers and density, originate on other NFS lands compared to IRAs and wilderness areas. The DEIS goes on to state that “The proportion of human-caused fires in IRAs and wilderness is less than half that on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads.” Furthermore, the DEIS states that “the new analysis presented in this DEIS indicates that other NFS lands also have about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates. The number of “actionable” and reportable wildfires may also be generally greater in areas outside of roadless or wilderness areas.” The DEIS fails to analyze the economic benefits and reduced negative impacts of focusing management actions on “other NFS lands” compared to IRAs and wilderness area. As stated on page 26 of the DEIS, “Alternatives analyzed in detail must be technically and economically feasible and meet the purpose and need (NEPA section 102 (2 (c)(iii)), 7 CFR 1b.7(h)). Analyzing increased management of “other NFS lands” is technically and economically feasible and meets the purpose and need of “reducing regulatory burden” and providing “management flexibility”. For these reasons, I believe the Department has failed to comply with NEPA, and the 2001 Roadless Rule should remain in place until an additional alternative (increased management of other NFS lands) is fully analyzed. Sincerely, Jeff Stephens OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing lakes, rivers, creeks, and streams without roads cutting through the surrounding land is one of the few remaining privileges available to people willing to make the trek. That is not a small thing. The ecosystems and habitats that support the life in those waters only hold together because human intrusion has been limited. To continuously push the development of infrastructure where it is not needed will lead to the devastation of it all entirely. I hike and camp for the same reason: to experience wildlife as it is, to disconnect, to encounter nature without extreme human intrusion. A large majority of this country has already been developed for commercial, agricultural, and residential use. What remains unroaded and intact should stay that way. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule in full and ask the agency to answer the specific questions raised below. The agency justifies this proposal in part on wildfire and fuels management grounds, but its own record contradicts that justification. The agency found that "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." Opening more roadless acres to road construction under that finding is not a fire management strategy. I ask the agency to explain how the proposal departs from those prior findings and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which the record shows reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is just as weak. The agency's own analysis shows that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal gains, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The agency cannot establish a net benefit from this action, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. The agency must explain, in plain terms, how that arithmetic supports rescission. The agency also argues that state-specific approaches can replace a single national rule. But the agency's own record acknowledges that it "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The last time the agency substituted local decision-making for the national rule, the Ninth Circuit found that approach legally deficient. The agency has not explained how this proposal avoids the same deficiencies, and it has not addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. A clear answer to both points is required. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. That question has already been litigated. A federal appellate court reviewed the challenge to the rule and held, exercising jurisdiction under 28 U.S.C. Section 1291, that it would "REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency needs to state plainly what basis it has for a contrary position, given that a federal court has already ruled on this question. This land was meant to remain untouched and preserved. Preserving the national forests for their ecosystems and wildlife is just as important as any commercial use. The agency should answer each of these points in the final record before any action on this proposal is taken. Sincerely, Mary Landaberde Groveland, Florida

Re: RIN 0596-AD66; Docket FS-2025-0001 — Roadless Area Conservation To the U.S. Dept. of Agriculture and U.S. Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and request that USDA select the No Action Alternative and retain the Rule. If changes are necessary to address wildfire, forest health, or unusual local conditions, USDA should adopt targeted amendments rather than eliminate the nationwide conservation framework. USDA argues that rescission would provide greater local flexibility. Local conditions certainly matter, but local decision-making and national minimum protections are not mutually exclusive. The Roadless Rule establishes a conservation baseline while already allowing exceptions. USDA should identify specific situations in which those exceptions are inadequate and address those problems directly. Road construction and fiscal responsibility-USDA's analysis states that approximately 18.2 million acres of affected inventoried roadless areas are covered by existing plans that could allow permanent road construction following rescission. At the same time, the Forest Service has a $6.9 billion deferred-maintenance backlog for existing roads and bridges. Before making millions of additional acres potentially available for roads, USDA should fully consider the long-term costs of constructing, maintaining, repairing, monitoring, and eventually decommissioning them. Forest Service research also documents hydrological, ecological, aquatic-habitat, wildlife, biodiversity, and other effects associated with forest roads. Wildfire-I recognize the need to reduce wildfire risk and protect communities. However, USDA has not demonstrated that complete rescission is necessary to accomplish these objectives. The proposal itself acknowledges that increased public access can increase human-caused wildfire ignition. Where a community, watershed, or infrastructure faces a demonstrated wildfire threat that cannot reasonably be addressed under the existing Rule, USDA should create a narrowly tailored exception. Roads genuinely necessary for community protection or ecological restoration should be distinguished from roads facilitating commercial timber harvest, mining, energy development, or other resource extraction. Forest plans are not an equivalent replacement-Individual forest plans do not provide the same consistent national protection as the Roadless Rule. USDA acknowledges that plans may later be amended, potentially allowing additional roads and timber harvest. Rescission therefore replaces a national conservation standard with protections that can vary by forest and change over time. It also shifts the burden to citizens, Tribes, communities, and other interested parties to repeatedly participate in forest-plan amendments and individual project decisions to protect areas currently covered by a national rule. Roadless lands have multiple values-Roadless areas should not be evaluated primarily according to resources that might be extracted from them. They provide watersheds, wildlife habitat, biodiversity, hunting and fishing, recreation, scenic landscapes, cultural resources, carbon storage, scientific value, and opportunities for quiet and remote recreation. Once roads fragment an intact landscape, restoring its previous roadless character can be difficult, expensive, or impossible. The potential permanent loss of these values deserves substantial weight. Tribal concerns-USDA reports that the majority sentiment among Tribal governments consulted was opposition to rescission. Concerns included sacred sites, gathering areas, water quality, subsistence resources, cultural survival, ancestral homelands, and the burden of repeatedly participating in project-level reviews. These concerns demonstrate a significant problem with replacing national protection with project-by-project decision-making. USDA should give substantial weight to Tribal consultation before making such a consequential change. A better alternative-I urge USDA to retain the 2001 Roadless Rule while addressing demonstrated management problems through targeted amendments. Any new exception should require a showing that road construction is necessary and that a less environmentally damaging alternative is not reasonably available. USDA should also fully account for lifecycle road costs and preserve national protections for watersheds, wildlife, biodiversity, cultural resources, Tribal interests, and remote recreation. A national conservation standard and responsible local forest management can coexist. Where the Rule creates a demonstrated obstacle to necessary management, USDA should address that specific problem rather than rescind nationwide protections covering millions of acres. For these reasons, I respectfully request that USDA withdraw the proposed rescission of 36 CFR Part 294, Subpart B and retain the 2001 Roadless Area Conservation Rule. Thank you for considering my comments.

I am a 57 year old Oregonian and CTO of a clearing broker-dealer. Like many of us, I care deeply about the public lands that comprise the American wilderness. I moved here from Texas over 15 years ago in large part due to the natural beauty and the wild outdoors, which are a direct result of our historic conservation and preservation of these spaces. National parks, national forests, state parks and forest, bureau of land management -- I spend as much time as possible in all of these places. They are the very heart and soul of America, and of The West, and we must protect them in every way. I just drove from Portland, OR to Eureka, CA down 101 with a brief stop in the wilderness along the Rogue River halfway between Powers and Agness on Forest Road 33. It is rough and slow going, as challenging and inconvenient as it is inspirational, breathtaking, life-affirming to see untouched wild spaces and vistas as stunning as crossing the Rogue River. Open any of this to development -- topple the first domino -- and complete destruction of our natural environs and wild spaces will proceed in what seems like a blink of an eye. Do this now, my yet-unborn grandchildren -- my kids are 21 -- will lose a birthright that has until now conveyed to all Americans, one of the most valuable and precious things we have. Please do not rescind the roadless rule. P.S. AI didn't write this, and I didn't ask for or receive any help from people or machines. Straight from my head and heart, filled with love and hope, with equal parts concern and conviction. Wilderness Acreage Figures at Page 195 Stated Without Any Citation The Draft Environmental Impact Statement states, at page 195 (Chapter 3, "Recreation Opportunities and Setting," Effects of Alternative 3 – Modified Rule, subsection "Wilderness"): "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation. The sentence is unsourced on its face. The next citation in the subsection, Landres et al. (2015), is attached to a different proposition — the five qualities of wilderness character interpreted from Section 2(a) of the Wilderness Act — and supports nothing about acreage. Nothing in the surrounding text identifies where either number came from, and a reader cannot trace either figure from the text to any entry in the literature cited. These are the two figures by which the Draft EIS characterizes the resource whose treatment under this rulemaking it then analyzes, and they are stated as fact inside the effects analysis for the Modified Rule alternative rather than in an introductory or background passage. National Wilderness Preservation System acreage is not a fixed quantity; it changes with each congressional designation, so a figure stated without a source and without a date cannot be checked by anyone. NEPA requires a "detailed statement" under 42 U.S.C. § 4332(2)(C). The Department's own procedures define substantive information to include information that meaningfully informs "compliance with applicable laws, executive orders, and regulations" (7 CFR 1b.11(a)(53)), and provide for "[m]aking factual corrections" as a response to a substantive comment (7 CFR 1b.7(f)(2)(v)). A headline resource figure that the public cannot trace to any source is not a verifiable element of a detailed statement. The agency cannot answer this concern by citing the passage in which the figures appear, because that passage is the one lacking the source. I request that the Final EIS do one of two things: (1) identify the source of both the 111.9-million-acre National Wilderness Preservation System total and the 36.7-million-acre National Forest System subset, state the date to which each is current, and add that source to the literature cited; or (2) if no source supports the figures as stated, correct them. Under 7 CFR 1b.7(f)(3), the response should cite where in the Final EIS or the supporting proposal record the action taken is accounted for.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I live in North Carolina, have family property near the Horse Heaven roadles area in Virginia and travel extensively each year in the western states, I spend many weeks each year moving through this country on foot, by canoe, and by paddle, buying gas, eating at local restaurants, sleeping in local lodging. These roadless areas are not abstractions to me. I am also an engineering geologist, and I have built roads into new terrain. I know what that work costs and what it leaves behind. I have seen many debris flows, some of which have killed people, that were initiated at a dirt road built in a mountainous area. I have paddled extensively in Idaho, Utah, Oregon, Virginia and North Carolina. Construction in these areas leads to substantial siltation of rivers. I see firsthand the damage done to rivers by debris flows that start at excavated and disturbed roadways. Virginia alone holds 64 inventoried roadless areas totaling 393,682 acres. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. I have also worked on water supply dams, and I see the struggles that water treatment plants face when treating sediment-laden water from construction and debris flow runoff. New roads can substantially increase the money spent on filtering and cleaning drinking water. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I ask that the agency explain in detail how it weighed this sediment loading against the drinking water supply function these watersheds perform, and how it accounts for the cost that burden shifts onto water utilities and ratepayers. The economic case for rescission does not hold together. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." As an engineering geologist who has been involved firsthand in building roads into new areas, I can say plainly: the initial cost is enormous and maintenance is an ongoing and costly outlay of funds. The agency is already carrying a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. 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 -$92 million to +$199 million, and that it explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system it cannot already maintain. The rule the agency proposes to rescind already permits what the agency claims it cannot do. 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)." The proposal justifies rescission partly on permitting and administrative burden grounds. The agency must identify which specific burdens are not already addressed by those existing exceptions and quantify them with precision. The agency's regulatory flexibility analysis is not credible. "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 local outfitters, guides and tour operators who hold permits in the affected areas are not protected by spreading an aggregate loss across every small firm in the sector nationally. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, this comment is itself a reliance interest the agency invited and then failed to weigh. "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." I, like most Americans, want to leave a legacy for my child and her cousins and all their descendants. There is not much land to save, and most of this is land that is particularly difficult to develop. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Let's leave it better than we found it for our kids. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Gary Rogers Greensboro, NC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The garden I keep is deliberately wild and messy, a patch set aside for pollinators and wild birds, because I watch the numbers decline every year and I understand what that loss means. No bees, no food. It is that simple, and it is that serious. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The bird communities that depend on unroaded forest are among the things this proposal would most directly harm. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Roads do not merely open ground for timber; they alter the acoustic and ecological conditions that make forest habitat functional for wildlife. A logged stand grows back. A road, once cut, does not. The agency must explain how it weighed these documented effects on bird communities against whatever benefit it claims to achieve, and that explanation must be specific enough to be tested. The proposal's treatment of drinking water is not adequate. The agency's own environmental review states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." That sentence quantifies the stakes and then leaves them unaddressed. The DEIS gestures toward forest plans as a substitute for the rule's protections without identifying a single enforceable provision in any of those plans that is equivalent to what would be rescinded. Water is life, and protecting watersheds from timber-related sediment is imperative. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. The sediment question goes deeper than that general failure. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number appears in the document and then nothing follows it. There is no projection of how much sediment would reach the more than 7,000 municipal intakes downstream once roadless protections are removed. The agency must quantify projected sediment delivery to those intakes before it acts. The maintenance problem makes the road-building logic harder still to follow. The agency's own analysis states: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." The same document proposes opening these areas to new road construction. I work hard to pay my taxes, and when I see those dollars directed toward actions that benefit the wealthy and connected while degrading resources that belong to every American, it matters to me. Adding road mileage to a system the agency itself says is undermaintained, and then citing that maintenance failure as a cause of water quality harm, is a contradiction the record does not resolve. The agency should reconcile the proposed increase in road mileage with the maintenance shortfall its own analysis identifies as a water quality cause. Finally, the alternatives analysis fails on its face. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose statement written entirely around deregulation forecloses the comparison that environmental review exists to produce. The agency held more than 600 public meetings and received more than a million and a half comments before writing the rule it now proposes to undo. It has held none to undo it. I want my son and his family and future children to inherit a world with wildlife, water, and clean air. The agency must restate the purpose and need in terms of actual forest conditions and analyse at least one fully protective alternative before this proceeding goes further. Sincerely, Jennifer Wei Belmont, NC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Living in Arizona, I value the ability to hike in remote areas without roads. The Oracle Roadless Area, the Butterfly Roadless Area, the Santa Rita area, and really any roadless corner of the Coronado National Forest matters to me. These lands are national treasures, not a holding area for money making. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The Coronado holds 23 inventoried roadless areas totaling 482,687 acres. Those areas, spanning the Santa Ritas, the Rincons, and the other sky island ranges, are the connective tissue between isolated mountain forests surrounded by hot desert. Jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, using the roadless corridors between those ranges as the only pathways that make that movement viable. The Upper Rincon Roadless Area, the Santa Rita area at 6,078 acres, the Happy Valley area at 7,972 acres: these are not abstract inventory entries. They are the ground where that connectivity either holds or breaks. Opening them to new roads does not protect them. It fragments them. I ask the agency to explain on the record why it believes the rescission is consistent with its own documentation of these corridors as irreplaceable biological pathways. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal cites wildfire management as a justification for rescission. That argument moves in the opposite direction from the agency's own findings. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to reconcile the rescission with those ignition figures and explain the departure from its prior findings. The proposal also rests on economic and employment grounds. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. It makes no sense at all to build new roads when the agency cannot even maintain the current roads. The existing maintenance backlog stands at $6.9 billion against a road budget of about $73 million a year. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already collapsing under that backlog. The agency's own record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The proposal argues that state-specific approaches can replace the national rule. That argument has been tested. The Ninth Circuit found that local decision-making can incrementally reduce nationally significant roadless values, and the state-by-state replacement was rejected. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres, and across the Southwestern region 739 municipal water intakes sit in watersheds containing affected roadless areas. What happens to those values under a patchwork approach is not a hypothetical. The agency must explain how this proposal avoids the deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state approach. Finally, the agency's record states: "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 proposal argues that the 2001 rule exceeded statutory authority. The Tenth Circuit held that 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. The agency owes a clear explanation of the legal basis for any position contrary to that holding, and it must provide one. Sincerely, Andrea C. Tucson, AZ

My wife and I enjoy hiking, rafting, and the simple joys of bird and wildlife watching in the Chattahoochee-Oconee National Forest. We also make frequent visits to California and Oregon to explore the Redwood and Sequoia Forests. We oppose the rescinding of the Roadless Rule permitting road construction that would result in severe damage to these pristine ecological areas and threaten fish and wildlife species. Allowing roads to be built for logging or mining equipment will have numerous devastating impacts: 1- Roads are the primary cause of the introduction of invasive, non-native species that can overwhelm native wildlife. 2- Roads increase sedimentation that seriously pollutes water quality, affecting not only fish, amphibian, and reptile life in the streams but ultimately groundwater that can impact the natural aquifers from which humans draw their drinking water. 3- Road stream crossings create a barrier to fish movement in national forests and restrict spawning and propagation of trout and other aquatic life. 4- Road construction introduces potential landslides and erosion that destroy established forest roots and slope stability resulting in potential floods and stream sedimentation. 5- The introduction of livestock can cause overgrazing which adversely affects species dependent on grasses for feeding or ground nesting, increasing runoff and soil compaction. 6- Roads can interrupt fires necessary for fire-dependent ecosystems while increasing the possibility of uncontrolled wildfires due to campsites or cigarettes thrown from vehicles. Road construction in roadless areas is the primary cause of ecosystem destruction and endangering wildlife. For these reasons, in addition to the aesthetic loss of our national treasures, we vehemently oppose rescinding the Roadless Rule. Facilitating energy, mineral, and timber production “to the maximum possible extent” on public lands will cost our nation far more in ecological desecration than will be compensated by short-term revenues they generate. We urge you to support H.R. 3930, the Roadless Area Conservation Act, to provide lasting protection for inventoried roadless areas within our treasured National Forest System. The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). 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. I request that the Forest Service supplement the analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and of the 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.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests and parks of this country are worth defending. I hike and camp in U.S. parks and forests specifically to take time with the beauty these areas have to offer. The wildlife filling them is irreplaceable. This letter opposes the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The agency's own record undermines the wildfire rationale it offers for rescission. 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." Opening roadless areas to road construction does not reduce fire risk by the agency's own prior findings. It increases the likelihood of human-caused ignitions. The DEIS Table 21 data, by the agency's own account, shows far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain in this proceeding why the proposal departs from these findings and how it reconciles the rescission with that ignition data. The agency also says the rule imposes permitting and administrative burdens that justify eliminating it. But the rule already accommodates a range of management needs. As the agency's own materials describe, 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)." Existing exceptions also address mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside these provisions. It has not quantified those burdens anywhere in the record. The agency must identify, precisely and with supporting data, which claimed burdens the rule's current exceptions do not already resolve. The regulatory flexibility analysis accompanying this proposal reaches a conclusion that the record cannot support. The proposed rule certifies no significant impact on small entities, yet, as the agency's own materials state, "the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification rests on spreading a $9 million annual expenditure loss across every small firm in the relevant sector nationally, rather than examining the outfitters, guides and tour operators who actually hold permits in the affected areas. The analysis concedes some of those firms may lose those receipts entirely. Averaging across a national population of firms that have no stake in these specific areas produces a number that obscures real harm to real permit holders. The agency should withdraw the certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas, not a national average that dilutes and hides their exposure. Finally, the agency solicits comment on reliance interests. The proposed rule asks for "any reliance interests in the current rule that could be affected by this proposal" at 91 FR 53830-31, and the Cost Benefit Analysis weighs none. I hike and camp in these forests in part because the Roadless Rule has provided a stable protection for the lands and wildlife I go there to find. The wildlife in these areas is irreplaceable, as I stated. That is a reliance interest. The rule has been in place long enough that people like me have organized our expectations around it. An agency that changes course is required to identify and weigh the reliance interests its prior policy created, not simply solicit them and then ignore them in the analysis. This comment constitutes such an interest. The agency must identify and genuinely weigh the reliance interests expressed in the comments it receives, including this one, before any final action is taken. Sincerely, Kristen N Allegheny County, PA

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in Wenatchee, Washington, below the Okanogan-Wenatchee National Forest. I hold a Ph.D. in geoscience from the University of Wisconsin–Madison, I make documentary films about earth science, and I’m an avid outdoorsman on this beautiful country’s public land. The wildfire rationale conflicts with the Department's own analysis. The Department gives rising wildfire risk as the main reason for rescission. Yet the draft EIS for this proposal states that "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." A study published in Fire Ecology on January 29 of this year looked at federal wildfire records from 1992 through 2024. It found that areas within 50 meters of a forest road were as much as four times more likely than roadless areas to see ignitions, and the result held in every Forest Service region. Allowing new roads into the areas that now have the fewest roads would add ignition sources to them. The final EIS should explain how rescission reduces wildfire risk given what the draft already concedes about roads and ignitions. The 2001 rule already allows fuel reduction. Under 36 CFR 294.13(b)(1)(ii), generally small-diameter timber may be cut in inventoried roadless areas to reduce the risk of uncharacteristic wildfire effects. The Department has not shown why that exception is inadequate, or why removing the rule entirely is necessary to get the fuel work it describes. The agency cannot maintain the roads it already has. By the Forest Service's own reporting, its system of roughly 380,000 miles of roads carries a deferred maintenance backlog measured in billions of dollars. Adding road mileage to a system the agency already cannot afford to maintain is not sound stewardship. The final rule should explain how new roads would be funded and maintained. Roads are a major source of human-caused sediment in mountain watersheds. The Forest Service's own research on forest roads has documented this for decades. Road cuts, fills and stream crossings deliver fine sediment to channels, and that sediment fills the spawning gravels and cold-water refugia fish depend on. In the Wenatchee and upper Columbia basins those fish include ESA-listed spring Chinook, steelhead and bull trout. Public money is already being spent to recover those populations, and roadless headwaters are among the last places their habitat still works as it should. Opening those headwaters to road building would undercut that investment. The fish downstream are already federally protected. The roadless headwaters of the upper Columbia drain into rivers that hold Upper Columbia spring Chinook, listed as endangered in 1999; Upper Columbia steelhead, listed under the Endangered Species Act; and upper Columbia bull trout, listed as threatened in 1998. Before finalizing any rescission, the Department should analyze, watershed by watershed, how new road construction in these basins would affect listed fish and the recovery efforts already underway. The public process does not match the scale of the action. The 2001 rule followed more than 600 public meetings and drew about 1.6 million public comments, more than any other rule in the nation's history at the time. This proposal would remove those protections from 44.7 million acres. A 30-day comment period with a 15-day extension is not enough for the public to review a draft EIS and cost-benefit analysis of that size. I urge the Department to withdraw the proposed rule and keep the 2001 Roadless Area Conservation Rule in place. Ethan C. Parrish, Ph.D.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas around Mt. Rose have been part of my life for 35 years. I have hiked with others and camped in or near Rose - Galena, Rose - Whites Canyon, Rose - Summit, and the Mt. Rose roadless area in the Lake Tahoe Basin Management Unit. I have paddled Lake Tahoe, a world-renowned treasure, and I have been privileged to spot the quite unique band-tailed pigeon in these mountains, along with grouse and other upland species. These places, the Galena drainage, White's Creek drainage, and the Mt. Rose summit country, make northwest Nevada unique. They draw millions of outdoor lovers now, an economic force that was a trickle when I moved here and is a major driver today. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. We have already seen wildfire in the Toiyabe up close, human caused as the population grows. The agency's own data on fire should stop this proposal The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal offers wildfire management as a justification for rescission, while the agency's own draft environmental impact statement records the opposite. The Humboldt-Toiyabe is the largest national forest in the lower 48, scattered across mountain ranges rising from the Great Basin desert, each roadless range a sky island with its own ecology, its own water, its own wildlife. Roads into that terrain, according to the agency's own finding, multiply the chance of ignition. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and to reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside these roadless areas. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. A federal appellate court already answered that question. Exercising its jurisdiction, the Tenth Circuit stated: "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 held the rule was within the authority Congress granted and did not create de facto wilderness. The agency has not explained what has changed in the law since that ruling. I ask the agency to address the Tenth Circuit's holding and explain the legal basis for any contrary position it now takes. The rule already permits what the agency says it cannot do. The agency's own description states: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The proposal cites permitting and administrative burden as reasons to rescind the rule entirely, but the rule as written already carves out exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific burdens fall outside those exceptions. Nevada holds 316 inventoried roadless areas totaling 3,186,206 acres, and the Humboldt-Toiyabe alone holds 354 inventoried roadless areas totaling 3,383,849 acres. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Runoff into the Truckee from logging in the basin would be a disaster, and clean water from these drainages is not a burden, it is the point. The agency must identify, with specificity and on the record, which burdens are not already addressed by the rule's existing exceptions. Finally, the agency certified no significant impact on small entities while its own Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year and its own DEIS names outfitters, guides, and tour operators as affected parties. . That is not a regulatory flexibility analysis; it is an averaging exercise designed to obscure the real harm. Much of the U.S. is still scarred by logging for the benefit of a few, while the many who depend on intact forests for their livelihoods and their lives are left with the damage. The agency should withdraw the certification and assess the actual impact on the small businesses operating within the potentially affected roadless areas. Sincerely, Susan Juetten Carson City, Nevada

October 6, 2026 I am writing to express my continued opposition to repeal of the U.S. Forest Service’s Roadless Area rule (36 C.F.R. pt. 294). As a law professor specializing in natural resources and public land law, my views on this matter are based on more than 40 years researching, writing, and teaching about America’s public lands, including national forest history, policy, and law. The roadless rule has served the nation well since its adoption in 2001. It has not seriously hindered timber production on the national forests; rather the decline in timber production is due to numerous other factors, including mill closures, overriding ecological concerns, and less costly alternative timber sources. By all accounts, there is little commercially viable timber that is readily accessible on the roadless lands, which are generally in remote, higher elevation, and often steep terrain. In fact, significant amounts of commercially viable national forest timber remain available on the existing, lower elevation national forest lands that are managed for multiple-use purposes. Opening the roadless national forest lands will do little to address the growing wildfire risk. In fact, research shows that the presence of roads is a frequent factor in human-caused fire ignitions in forests. Most roadless acreage is remote and not proximate to the Wildland Urban Interface (WUI) zone, so there is little need to undertake hazardous fuel reduction projects on existing roadless lands. Given current budget cuts and personnel reductions, the Forest Service simply does not have the capacity to meaningfully extend its fuel reduction work onto roadless lands. Besides, the Roadless Area rule contains exceptions that would allow necessary hazardous fuel reduction projects to proceed near WUI zones. The roadless areas were initially set aside to address watershed protection and wildlife conservation, and to provide diverse recreational opportunities. By any measure, this has proven a success, meeting these important Forest Service multiple use statutory objectives. Rescinding the Roadless Area rule will adversely impact these important resource uses with little gain, as recognized in the explanatory material accompanying the Federal Register notice, i.e., the acknowledgment that few roads, timber sales, or energy projects are likely to be constructed on the roadless lands. Further, existing and accessible Forest Service roads provide those interested in motorized and off road vehicle recreation adequate opportunities to pursue these recreational activities. There is simply no compelling legal, policy, or practical reason to rescind the rule and to put watershed, wildlife, and recreation uses and values at risk. There is little doubt that the construction of roads, timber sales, and energy projects will divert Forest Service resources from other multiple use purposes at a time when the agency is facing severe budget cuts and workforce reductions. Given the number of public comments on the rule recission proposal, it is clear that the public does not support this change in agency policy. Because state, local, and tribal governments enjoy a special privileged status regarding participation in forest management decisions, including proposals for exceptions to the roadless rule, the local decision-making rationale for revising the rule is neither necessary or compelling. Moreover, the clear direction of Forest Service policy during the past 30 years has been toward conservation rather than the production of commodities that often negatively impacts ecological integrity. And should the agency rescind the rule, that decision will undoubtedly be challenged in court, as will most road building, timber harvesting, and other development decisions affecting roadless lands, putting a costly and unnecessary burden on the agency. All of which can and should be avoided by not rescinding the roadless rule in this time of budgetary pressures, workforce reductions, and political divisiveness. In short, the proffered rationale for rescinding the roadless rule is far outweighed by the myriad benefits derived from the existing rule and the costs that will attach to its recission, which would not significantly benefit the national forests or the nation. Thank you for considering my professional and personal views on this matter, which do not necessarily reflect the views of my employer. Robert B. Keiter Wallace Stegner Professor of Law University Distinguished Professor University of Utah S.J. Quinney College of Law Salt Lake City, UT 84112

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and the removal of protections under 36 CFR part 294, subpart B. As a San Diego resident who values hiking, wildlife, and public lands, I want our national forests protected for future generations. The Trump administration’s push to eliminate these safeguards puts irreplaceable public resources at risk. Describing conservation protections as a “regulatory burden” fails to recognize their public value. USDA should fully evaluate the potential consequences of expanded road construction and timber harvesting, including habitat fragmentation, erosion, water quality degradation, loss of carbon storage, and damage to outdoor recreation. The analysis should also account for the long-term taxpayer costs of maintaining additional roads and restoring disturbed landscapes. I support effective wildfire prevention and responsible forest management. However, USDA should demonstrate why existing management tools and exceptions are insufficient before eliminating nationwide protections. Claims of greater flexibility should be supported by evidence showing that rescission would improve public safety without sacrificing conservation. National forests belong to the American people. Their future should reflect long-term stewardship, meaningful Tribal consultation, and public participation. I urge USDA to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule. Once intact forests are fragmented, the damage can last far beyond any administration.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Pemigewasset Wilderness has been part of my family across three generations. I have gone since I was born, and it is meaningful to me, my parents, and my grandparents. Losing its purity would be a loss to family memory and to land I hope to share in an untouched form with my future kids. That is why I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and ask the agency to address each of the following points in its final record. The White Mountain National Forest holds 16 inventoried roadless areas totaling 240,669 acres, including the Pemigewasset Wilderness, whose headwaters feed rivers running to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region alone, 286 municipal water intakes sit in watersheds containing affected roadless areas. The New England mountains were clearcut once before, and the damage was so severe that Congress passed the Weeks Act of 1911 specifically to authorize federal purchase and recovery of those lands. These places, home to moose, black bear, brook trout, and Canada lynx, recovered under protection. The economic case for rescission does not hold together. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a spread so wide it cannot establish a net benefit. Meanwhile the agency already carries a $6.9 billion maintenance backlog on roads it cannot afford to keep, against a road budget of roughly $73 million a year. I think it makes no sense to increase roads that we need to use taxpayer dollars to maintain. This is a terrible and poorly analyzed plan, and reducing long-term spending means doing it pragmatically, not expanding infrastructure the agency cannot sustain. I ask that the agency reconcile the proposal with these figures and explain how an action whose own analysis cannot demonstrate a net benefit justifies adding to a road system already buckling under deferred maintenance. The proposal argues that state-by-state approaches can replace a national rule. The agency's record itself states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed exactly that state-by-state alternative and found it deficient. I ask that the agency address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time a national rule was replaced with a state-by-state approach. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The court that examined that question reached a different conclusion. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the record a direct explanation of any contrary legal position it intends to rely on. Finally, the proposal cites permitting and administrative burden as justifications for rescission. The rule as written already provides that 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)." Additional exceptions address existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside those existing provisions. It should do so, with quantification, before any further action on this proposal. Public land should be managed for long-term value to the country and its people. The Pemigewasset Wilderness represents exactly that kind of value, accumulated across generations and irreplaceable once a road goes in. I ask the agency to answer each of these points in the record before it proceeds. Sincerely, Calvin Kinghorn San Francisco, CA