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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

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

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: 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 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

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests where I hike are not abstract. I go to Ocala National Forest to see pristine wild landscapes, and when I visit family in California we hike in Sequoia National Forest to breathe clean air. These are not amenities. We live in an ecosystem, and the lands inside it should be preserved for the long-term survival of our children and our nation. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly that, and I oppose it. The Ocala sits directly on top of the Floridan Aquifer. Alexander Springs, a first-magnitude spring in the heart of the forest, pumps 80 million gallons of crystal-clear water per day through karst limestone that makes any road construction a direct contamination pathway to the drinking water supply of central Florida. The forest holds 4,855 acres across 2 inventoried roadless areas. Red-cockaded woodpeckers recovered here from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads, and Florida scrub-jays, found nowhere else on the planet, depend on the surrounding scrub. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The scale of what this rescission puts at risk is not speculative; the agency's own inventory makes it legible. On wildfire, the proposal justifies rescission in part on fuels management grounds, yet the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why this proposal departs from that prior finding, 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. This response is even more timely, given the increased fire frequency driven by climate change induced drought. On economics, the proposal also relies on timber and employment benefits, but 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 same record 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, while the existing road system already carries a $6.9 billion maintenance backlog. How does an action whose own cost-benefit analysis cannot establish a net benefit justify expanding that backlog? On the state-by-state approach, the proposal argues that local decision-making can substitute for a national rule, yet the record shows the agency itself once stated: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency must 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 the last time the agency replaced the national rule with a state-by-state approach. Finally, on statutory authority, the proposal questions whether the 2001 rule exceeded the agency's legal power. The reviewing court 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 that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain, with specificity, the legal basis for any contrary position before proceeding further. Cyrene Schweitzer Plantation, FL

Re: Special Area; Roadless Area Conservation Docket No. FS-2025-0001 RIN 0596-AD66 I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule because its claimed wildfire management benefits do not justify the environmental, recreational, and fiscal costs. I am a native New Hampshirite and hike or backpack in the White Mountain National Forest (WMNF) once or twice a month. Some of its wildest areas - like Lincoln Woods, the Sandwich Range and Mount Chocorua, and areas surrounding the Pemigewasset Wilderness - lie within the 235,000 acres of Inventoried Roadless Areas (IRA) in the WMNF [1]. These landscapes help draw roughly six million people annually [2]. The rescission of the Rule places them at risk from commercial timber harvesting. I argue three points against this proposed rescission: 1. Wildfire Management Benefits are not Proportional to Environmental Risks The Rule already allows substantial wildfire risk management, so the Forest Service’s rationale that a full repeal is needed for wildfire mitigation is flawed. Under 36 C.F.R. § 294.13(b)(1), small-diameter timber may be cut or removed to maintain or restore ecosystems, including to “reduce the risk of uncharacteristic wildfire effects.” The Forest Service also stated that “hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule, so long as road construction or reconstruction is not necessary.” 66 Fed. Reg. 3244, 3258 (Jan. 12, 2001). The Rule separately permits road construction when necessary to protect public health and safety from an imminent threat of fire or another catastrophic event. 36 C.F.R. § 294.12(b)(1). I concede that rescission would provide managers more flexibility, but that does not justify eliminating nationwide protections. New roads fragment habitat, increase erosion and sedimentation, and increase human access; the proposed rule itself acknowledges that “greater public access can increase human-caused ignition potential.” 91 Fed. Reg. 53829 (2026). If additional access is needed in particular high-risk forest, “especially in the Western United States,” the Forest Service should adopt targeted exceptions instead of repealing the Rule nationwide. 2. Harm to Scenic Value and Recreation Beyond environmental significance, the WMNF is the crown jewel among NH’s natural assets that support major tourism and outdoor recreation activity. This activity supports 30,000 jobs and contributes $4 billion to the state’s economy annually [2]. The Forest Service acknowledges that rescission could cause “noise, visible infrastructure, and temporary closures” and reduce opportunities for “quiet, remote and self-reliant recreation.” What’s more, the estimated $6.1 million in annual lost recreation is likely an underestimate because the analysis relies heavily on assumptions and admits substantial uncertainty about what and where development would actually occur. In a heavily visited forest like the WMNF, those losses deserve substantial weight. Commercial access that degrades remote landscapes should not be expanded absent a demonstrated public benefit. 3. New Roads are Difficult to Justify Amid a $6.9 Billion Maintenance Backlog The Forest Service already faces a multi-billion dollar backlog of deferred maintenance for its existing roads. 91 Fed. Reg. 53829. It acknowledges that timber harvest and vegetation management would likely create the greatest demand for new roads, and that expected timber-efficiency gains would be “incremental” and constrained by road costs, maintenance funding gaps, and the $6.9 billion backlog. It is fiscally irresponsible to open areas to taxpayer-funded road expansion for the benefit of private timber harvesters when the agency can’t afford to maintain existing infrastructure. Limited Forest Service resources would be better directed toward maintaining existing infrastructure than opening currently roadless lands to additional development. In sum, I request that USDA withdraw the proposed rescission and retain the 2001 Roadless Rule. If the agency concludes that additional management flexibility is necessary for wildfire risk reduction in particular regions or circumstances, it should pursue narrowly tailored amendments that preserve the Rule's nationwide baseline protection while addressing demonstrated management needs. Stripping all protections is an unnecessary excuse to open these delicate ecosystems to extractive industrial activities. [1] https://newhampshirebulletin.com/2026/09/14/repub/unique-stretch-of-new-england-forest-under-threat-after-proposed-rollback-of-roadless-rule/ [2] https://www.unh.edu/news/whos-visiting-new-hampshires-white-mountains

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The backcountry trails of the Lake Tahoe Basin are where I go to find native wildflowers, and that landscape, its water, its clarity, its living detail, is what this comment is about. Rescinding the Roadless Area Conservation Rule puts every element of that place at risk, and I am asking the agency to answer, concretely and on the record, for each contradiction its own documents expose. The agency has framed rescission partly as a wildfire management tool. Its own analysis says the opposite. The agency's record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The Tahoe forest sits in exactly the high-risk category this language describes. Opening roadless areas to road construction there would, by the agency's own reasoning, increase ignition risk rather than reduce it. I ask that the agency explain why this proposal departs from those prior findings, 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. The agency also cites permitting burden as justification. Yet the rule as written already accommodates the work the agency claims is being blocked. It states that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the existing exceptions for public health, safety and reserved rights are insufficient, the agency has not demonstrated where or why. I ask that it identify, with specificity, which burdens are not already addressed by those exceptions, and that it quantify them rather than assert them. Water is not an abstraction in Lake Tahoe. The lake itself is the region's foremost attraction, and the quality of tap water in the surrounding communities is something residents and visitors alike depend on and take pride in. Destruction to that watershed would not only affect drinking water for everyone living and traveling here; it would damage the very thing that makes this place what it is, the lake, its famous clarity, the reason tourism exists at all. The agency's own analysis acknowledges that roads and their associated facilities can produce up to ninety percent of the sediment from a timber sale operation. In a basin where water quality defines the economy and the ecology both, that figure cannot be treated as acceptable collateral. I ask that the agency address, directly and with specific reference to the Tahoe watershed, what sediment and runoff consequences it foresees and how those consequences were weighed. The regulatory flexibility certification accompanying this proposal is also internally inconsistent. The agency's own language exposes it: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The method used to reach that certification distributes an aggregate expenditure loss across every small firm in the sector nationwide, which obscures what happens to the outfitters and guides who actually hold permits in areas like the Tahoe forest. The native wildflower photography I do in these backcountry corridors depends on the same access infrastructure that those permit holders provide and protect. The certification should be withdrawn and replaced with an assessment of the small entities that are actually operating in the affected roadless areas. Finally, the agency has placed foreseeable consequences beyond the scope of its analysis while simultaneously asking the public to comment on them. Its own language makes this plain: "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That is not a coherent process. A decision of this scope requires that the agency analyze the foreseeable plan-amendment scenario, including expanded timber harvest, as part of this action, not as something future administrators will address without today's public input. I oppose rescission of the Roadless Area Conservation Rule and ask the agency to respond substantively to each of the points above before any final action is taken. Sincerely, Emilie Comer Tahoma, CA

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tongass has shaped my life in Sitka in ways I am still learning to name. In two years here it has molded how I move through the landscape, what I am grateful for, how I eat, what I notice. The sheer grandeur of an intact temperate rainforest does that. It is hard not to be enamored, and even harder not to feel grateful for what the Tongass is: a main pillar of subsistence, culture, recreation, and ecosystem in Southeast Alaska. The Tongass makes life whole here. As someone who lives inside that wholeness, I submit these comments opposing the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The forest I am writing from is the largest intact temperate rainforest left on Earth. It holds 110 inventoried roadless areas totaling 9,339,575 acres, more than 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by United States national forests. 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. That means the salmon streams, the Sitka black-tailed deer, the brown bear, the wolves, the bald eagle, and the five species of Pacific salmon that anchor subsistence life here are all subject to what follows from that zero. The nine municipal watersheds named in DEIS Table 2, including Sitka, are also subject to it. I ask the agency to explain in specific terms what protection, if any, replaces the rule for those watersheds and that wildlife. The agency's own Tribal consultation record makes the procedural posture of this rescission indefensible. "The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule." Tribal governments proposed alternatives, among them a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analyzed. I find it deplorable that the summary of that consultation arrives only after the comment period closes. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule is issued. The economic case for rescission is not established by the agency's own numbers. The agency acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal contribution, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and the road system this rescission would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with that record and explain how an action whose own analysis cannot establish a net benefit is justified. The legal foundation here is also troubled. The agency's record 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 proposal argues that state-specific approaches can substitute for a national rule. The Ninth Circuit already reviewed that argument the last time the agency replaced the national rule with a state-by-state approach and found it wanting. 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 those same deficiencies. Finally, the DEIS itself quantifies a consequence it does not then apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record. No projection across the 40.1 million acres of potentially affected environment follows from it. The agency should apply its own cited finding at the scale of the action it is proposing. I implore policymakers to visit Southeast Alaska, bring your kids, show them what an intact temperate rainforest looks like, gaze upon it with gratitude for all the life it supports, be humbled. A logged stand grows back. The agency should say plainly what does not. Sincerely, Zia NoiseCat Sitka, AK

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 To whom it may concern: I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them. Issue 1: Rescission of the Roadless Area Conservation Rule (hereafter “Roadless Rule rescission”) will result in increased habitat fragmentation, loss of habitat connectivity, and increased road-related mortality in a number of federally-listed species, including the Southern Sierra Nevada distinct population segment of fisher (Pekania pennanti), Bi-State distinct population segment of greater sage-grouse (Centrocercus urophasianus), and Sierra Nevada bighorn sheep (Ovis canadensis sierrae). Conservation assessments and strategies for these species have identified roads as significant sources of mortality and habitat fragmentation in these species. These significant impacts should be analyzed and addressed in the EIS, including in specific areas of concern – such as the Boundary Peak roadless area (Bi-state sage-grouse); Kings River, Dinkey Lakes, Black Mountain, and Greenhorn Creek roadless areas (Southern Sierra fisher); and San Joaquin and Hoover roadless areas (Sierra Nevada bighorn sheep). Additionally, I ask the agency evaluate impacts of the Roadless Rule rescission to big game populations, such as elk, mule deer, pronghorn, and moose. These impacts should be assessed to evaluate effects to habitat connectivity and population-level impacts in these species and how it may affect hunting and wildlife viewing activities by the public. Additionally, I ask that the agency evaluate impacts of the Roadless Rule rescission to federally-listed plant species, such as whitebark pine (Pinus albicaulis). Lastly, I ask the agency to evaluate the impacts of the Roadless Rule rescission on species of conservation concern identified in revised Land Management Plans on national forests. Issue 2: I ask that the Roadless Rule rescission EIS evaluate cumulative effects of the proposed action with other recent agency-wide policy changes proposed by the U.S. Forest Service. In particular, these cumulative effects should include the proposed amendment to the existing Travel Management Rule (36 CFR 212) announced on August 21, 2026 on the agency’s website. It should also include cumulative effects of any other recent policy changes that broadly affect National Forest System roads, such as Land Management Plan revisions and amendments. Issue 3: The U.S. Forest Service’s own fire data shows that wildfire ignitions are closely associated with roads and road access. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System lands against 3.0 fires per million acres inside the affected roadless areas (DEIS Table 21, 2014-2024). The DEIS states that human-caused ignitions have increased in abundance with proximity to roads. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. I also ask the agency to conduct a thorough evaluation of the effects of roads on wildfire ignitions on national forests and other federal lands using he best available science information. Issue 4: I ask that the agency please address effects of the Roadless Rule rescission on the potential spread of invasive species, such as cheatgrass, on National Forest System lands. Numerous scientific publications have linked roads and road construction to increased cover and spread of invasive plants and their potential to increase the frequency and rate of spread of wildfires in wildlands. I request that the agency respond in the record to each of the issues raised in my comment and that it analyze in the DEIS an alternative that retains the 2001 Roadless Rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Susan Roberts Mammoth Lakes, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The mountain wilderness of Vermont is what I photograph. Leaving these areas as true wilderness is the only way to preserve them for future generations, including my children, and the proposal to rescind the 2001 Roadless Area Conservation Rule would move directly against that purpose. Vermont holds 25,096 acres across 6 inventoried roadless areas, and 286 municipal water intakes in the Eastern region sit in watersheds containing affected roadless areas. I am filing this comment in opposition to Docket FS-2025-0001. Water is becoming an ever more important resource. Untouched wilderness has a vital role in our water cycle, helping to replenish and clean our water supplies. The agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Creation of roads can generate sediment pollution that affects water sources throughout the country, and those 286 municipal intakes in my region represent real drinking water for real communities. I ask the agency to explain, specifically and on the record, how opening roadless watersheds to road construction is compatible with its own sediment data, and to address what mitigation measures, if any, would protect those intakes once the national rule no longer applies. The proposal invokes wildfire and fuels management as justification for rescission, but the agency's own prior findings cut the other way. 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." The DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must reconcile that finding with the wildfire rationale offered here, and must explain why its own ignition data does not counsel against the rescission rather than for it. The proposal also argues that state-specific approaches can replace a single national rule. The agency has attempted this before, and the record of that attempt is not favorable. The agency previously acknowledged 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 found deficiencies in that state-by-state substitution the last time it was tried. Fewer and fewer truly wild places remain on Earth, and a patchwork of state petitions is not an equivalent substitute for a standing national protection. I ask the agency to explain how this proposal avoids the legal deficiencies identified in that prior litigation and to address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values. The rule as written already accommodates the situations the proposal cites as burdens. 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)." Before rescinding the entire national rule, the agency should identify which specific administrative or permitting burdens fall outside those existing exceptions, including those covering existing mineral leases and community wildfire protection, and it should quantify those burdens in concrete terms. A general claim of administrative friction is not a sufficient basis for eliminating protections that the Forest Service reached only after holding more than 600 public meetings and receiving 1.6 million comments, while this rescission has proceeded without a single equivalent public process. Finally, the regulatory flexibility certification claiming no significant impact on small entities does not hold together. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and the DEIS identifies outfitters, guides and tour operators as affected parties. Spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides actually holding permits in the affected areas, does not constitute a meaningful analysis. The agency should withdraw that certification and assess the actual impact on the small entities operating in these specific roadless areas. That assessment is owed to those businesses and to the public before any final action is taken. Sincerely, Daniel Rosenberger Jersey City, New Jersey