Read the comments.

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.

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 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

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

See Attached File: As a South Dakota resident who enjoys using roadless areas, I oppose rescinding the 2001 Roadless Rule. My interest and passion come from experiencing these places. Their value to me includes solitude, viewing natural surroundings, and the opportunity to enjoy public land away from roads and vehicle traffic. Beyond my own personal enjoyment, it is also important to know that we are retaining large, intact landscapes and clean rivers and lakes. These roadless areas deserve consideration and respect. My comment concerns the proposed removal of the protections in 36 CFR Part 294, Subpart B, which restrict road construction, road reconstruction, and timber harvest in inventoried roadless areas, subject to exceptions. USDA proposes relying on individual forest planning and management decisions in place of these national protections. My personal concern is what that change would mean for wildlife, water quality, and landscapes that sustain the activities I enjoy and contribute to my community's economy. (USDA, proposed rule, 91 FR 53827, August 20, 2026.). When I choose a roadless area for fishing or hiking, the undeveloped setting is part of the reason I go. The Sand Creek Roadless Area in Wyoming is a wonderful example of a Roadless Area that my husband and I have explored multiple times. We are drawn to the roadless area for the amazing water quality that sustains an incredible fishery. My husband and I explored the Sand Creek area and found it to be a wonderfully peaceful and beautiful location that my husband and I enjoyed for hours, catching Brown Trout and then releasing them back to the water for others to enjoy. My background and career were in a science-based field, and with that background I am fully aware that a good fishery depends on healthy watersheds. Forest Service research identifies effects of roads on hydrology and aquatic habitat and emphasizes that those effects must be evaluated in their local environmental context. This supports examining individual watersheds rather than assuming that national estimates adequately describe the risks to places people fish. (Gucinski and others, Forest Roads: A Synthesis of Scientific Information, 2001, PNW-GTR-509.) I feel strongly that the NOI and DEIS fail to provide science-based rationale for rescinding a Rule that has been in place for nearly 25 years. A Rule, for example, that protected large intact landscapes for recovery of the Grizzly Bear in the Lower 48. For this reason and so many other reasons, the 2001 Roadless Rule must be retained! I recognize and encourage that where the USDA identifies a specific management problem, it should first evaluate whether existing exceptions or a narrowly tailored approach can address it while preserving roadless characteristics. Over my career in the USDA Forest Service (USDA), I gained a practical working knowledge of Forest Plans (programmatic) and NEPA (site-specific). I acknowledge that Forest Plans vary in age and thus protection for Roadless Areas if “The Rule” is rescinded. More importantly, the limitations referred to in the NOI and DEIS do not tell me whether the places I value would retain equivalent protection over time. The agency should explain what protections would remain; how it accounts for the loss of quiet recreation, how it impacts wildlife that are dependent on large intact landscapes, and how it may impact water quality and quantity. My fishing and hiking experiences have taught me that the character of a place matters as much as the ability to reach it. Once roads and development change that character, the experience may be difficult to recover. I urge USDA to retain the Roadless Rule, address demonstrated management needs through targeted approaches, and clearly disclose the local recreation and watershed consequences of any proposed change. Future generations should have the opportunity to enjoy these public lands as roadless places. le(s)

To Whom It May Concern, I am writing to express my strong opposition to the proposed removal of the 2001 Roadless Area Conservation Rule. I urge the U.S. Forest Service to select Alternative 1 (No Action) and retain the critical protections currently afforded to inventoried roadless areas (IRAs). As a retired professional with a career background in ecology, zoology, and environmental consulting, I review land-management actions through a lens of empirical data, cumulative impact analysis, and landscape-scale conservation. While I am submitting this comment from Florida, the ecological principles governing wildlife displacement, edge effects, and habitat degradation remain constant across all public lands. The agency’s proposal fails to adequately account for these systemic biological disruptions. I request that the Forest Service address the following substantive points in its final decision-making process: 1. Disruption of Security Cover and the Public-to-Private Land Displacement Crisis: Decades of wildlife biology, dating back to foundational Montana field studies in the 1970s and 1980s, demonstrate that elk (Cervus canadensis) and other large ungulates require contiguous blocks of unfragmented mature timber for security cover. The introduction of logging roads and motorized corridors into pristine areas causes immediate habitat fragmentation. It increases the flight distance of big game, effectively rendering adjacent habitat unusable even if the timber itself is not completely cleared. The agency must evaluate the broader, state-level cumulative impacts of this displacement. Data from state wildlife agencies confirms that when public backcountry is roaded, elk permanently flee these historic public ranges for lower-elevation private agricultural lands. This has triggered an ongoing distribution crisis where deep wilderness populations collapse due to a lack of secure forage, while private lands face unsustainable overpopulation. Removing the Roadless Rule will severely exacerbate this damaging trend. 2. Flawed Wildfire Mitigation Logic and Edge-Effect Ignitions: The justification that rescinding the Roadless Rule is necessary for wildfire mitigation and mechanical thinning contradicts established spatial ecology and fire science. Linear corridors such as logging roads introduce edge effects, altering microclimates by increasing wind penetration and drying out understory fuels. Peer-reviewed forestry data demonstrates that the density of wildfire ignitions is lowest in unroaded backcountry, while the highest frequency of human-caused ignitions occurs within close proximity to road networks. Furthermore, a full repeal is legally unnecessary to achieve public safety goals. The 2001 Roadless Rule already contains narrow, well-defined exceptions under 36 CFR Section 294.13(b)(1) that explicitly allow the Forest Service to harvest timber and conduct hazardous fuels reduction to protect communities, provided it is done without constructing permanent, ecosystem-disrupting road networks. 3. Fiscal Irresponsibility and Lack of NEPA Viability: From a project management standpoint, proposing new infrastructure development while failing to maintain existing assets violates basic logistical prudence. The Forest Service currently faces an approximate 8 billion dollar deferred road maintenance backlog across its existing 380,000-mile network. Allocating taxpayer funds to expand road networks into 6.4 million acres of pristine backcountry—when the agency cannot ecologically or financially mitigate its current infrastructure footprint—is a failure of sustainable land stewardship. Conclusion: The 2001 Roadless Rule is one of the most effective, science-based policies the Forest Service has to protect biodiversity and contiguous wildlife corridors. The ecological and economic costs of its repeal far outweigh the temporary gains of commercial timber extraction. I strongly advocate for the preservation of all existing Inventoried Roadless Areas under Alternative 1. Thank you for considering these science-based comments. Sincerely, A Retired Environmental Consultant & Ecologist State of Residence: Florida

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because the record the agency assembled does not support this action. I live in Oregon. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and 1,522 municipal water intakes across the Pacific Northwest region sit in watersheds containing affected roadless areas. Opening roadless land to extraction when the agency's own data say the costs outweigh the gains is not wise. The deer I watch from my window depend on roadless land more than many people realize. The agency's own DEIS cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed. The Tribal Summary Impact Statement in the agency's own record credits the rule's protection with the recovery of deer populations in Alaska by preserving old-growth winter shelter. Rescinding the rule puts exactly that kind of roadless security at risk for deer across the country. I ask the agency to explain in this proceeding how it weighs documented harms to deer against any claimed benefit of the rescission. The birds I enjoy watching and listening are also at stake. 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 have to carry vehicles to harm birds; their noise alone does measurable damage. I want the agency to explain how it reconciles those findings with a proposal to expand the road system into areas currently protected. On wildfire, 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 roadless lands." The proposal nevertheless cites wildfire and fuels management as justification for rescission. Those two positions cannot both be right. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the protected roadless areas. The economic case for this rescission is weak. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total U.S. 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." Numbers support me in saying the public wants wild habitats preserved, and those numbers show the extraction gains are trivial. The agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million, and the Forest Service already carries a $6.9 billion road maintenance backlog. The agency must reconcile the proposal with an economic analysis that cannot establish a net benefit. Explain how adding to a road system already in deficit serves the public interest. The agency also argues that state-by-state approaches can replace a single national rule. Its own prior 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 Ninth Circuit has already reviewed what happened when the agency substituted local decision-making for the national rule and found it deficient. The agency needs to explain in this proceeding how this proposal avoids repeating those same deficiencies. Finally, the agency claims the 2001 rule exceeded its statutory authority. The Tenth Circuit already examined that question and 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 rule was within the authority Congress granted and did not create de facto wilderness. The agency must address that holding directly and state on what basis it now takes a contrary position. Public land should be managed for citizens, not for benefit of cattle ranchers, data center managers, or oil and gas drillers. Our lives are greatly enriched sharing this planet with our wild friends, and the record before this agency does not justify trading that away for gains its own analysis cannot confirm. Sincerely, Jean M. Winslow Newport, OR

I submitted comments to the proposed rule in Sept 2025. Attached below. Consider these integral to my current comments. I strongly oppose recission of the 2001 Roadless Rule. I served on the roadless rule Content Analysis Team (CAET) in 2000, we read and synthesized all comments. Sentiment strongly favored protecting roadless areas and benefits they provide: clean water, biological diversity, wildlife habitat, forest health, and recreation. Climate change and population growth have increased support for roadless areas. I worked on the WMPZ Forest Plan Revision Team for forests in Western Montana; Flathead, Lolo, and Bitterroot. Despite efforts and substantial expense by American taxpayers, these were shelved due to a national lawsuit. Courts ruled the 2005 planning rule was inconsistent with the National Forest Management Act. The Flathead National Forest completed its forest plan revision in 2018 under the 2012 planning rule. My September 2025 comments must be considered in conjunction with my current comment for 53828 Federal Register/Vol. 91, No. 160/Thursday, August 20, 2026/Proposed Rules, which states, “As resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service’s multiple-use mission.” NOTE: While the 2001 roadless rule constrains officials from exercising their absolute place-based discretion, it does not follow such discretion is needed to meet the Forest Service’s multiple-use mission. On the contrary, NFMA was driven by management skewed to commodity production over multiple use values: watershed, wildlife, wildlands, recreation. Conditions on the Bitterroot amd the Monongahela national forest were evidence a more balanced approach was needed, resulting in NFMA. “In addition, evolving national priorities and changed conditions have required more active management approaches. The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns.” NOTE: See pg 8 from my 2025 comments for a research being done. There are volumes that dispel lack of active management as a driver of forest health concerns. On the contrary, there is evidence forest management itself fosters such concerns. “This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 ……The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency’s land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit’s expected distinct roles and contributions to the local area, region, and Nation. “ NOTE: Interdisciplinary planning and consideration of landscape-level conditions was done on the Flathead NF and ongoing revision on the Lolo NF. Refer to my Sept 2025 comment using Flathead as an example. Of 500,000 roadless acres, fewer than 200,000 remained. The rest were assigned management areas based on conditions and public input. Decision-makers balanced conflicting uses and devised management area prescription for roadless areas. “At the same time, this planning approach allows for place- based, collaborative decisionmaking that is responsive to specific on-the- ground resource conditions, rather than a ‘‘one-size-fits-all’’ national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities.” Note: Yes, this is being done for revisions under the 2012 planning rule. Ironically, the Roadless Rule Recission is itself a blanket one-size-fits-all mandate that the rule dispesl. I requested the DEIS disclose forests that have done plan revisions, those in the process, and those not started. Only those that have not started could be subject to the recission. Those completed or undergoing revisions have engaged in place-based, collaborative decision-making responsive to on-the-ground conditions. The DEIS fails to respond to my request.

The natural beauty of this country should not only be celebrated. It should be honored, and it should be protected. These places are a gift, and they are our responsibility. On that understanding, I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The procedural record behind that rule is itself a statement about how seriously the public takes these lands. The agency held more than 600 public meetings and received 1.6 million comments to write it. It has held none to undo it. That asymmetry alone deserves acknowledgment, and the substantive problems in the proposal compound it. 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). This asks the public to comment on something the agency has already declined to analyze. Plan amendments are a foreseeable and stated consequence of rescission. They are not hypothetical. Treating them as outside the scope of this action while simultaneously soliciting comment on them is not a coherent procedure. I ask that the agency analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action, and explain in the record why it was originally excluded. The carbon question receives the same incomplete treatment. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. That figure is presented and then set aside. The DEIS concludes that these lands will continue to sequester and store carbon, but it offers no analysis of what happens to storage and sequestration under the alternatives that permit harvest and road construction. Stating a number and drawing a conclusion without connecting them is not analysis. I ask that the agency quantify the projected change in carbon storage and sequestration under each alternative before finalizing this action. On the core legal question, The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule. An agency is entitled to change its position. It is not entitled to reverse a factual finding without explaining what changed and why the prior evidence no longer holds. Nothing in the proposal identifies the evidence supporting the reversal or engages with the agency's own prior finding. The agency must do that, and must do it in the record. Finally, the economic treatment of recreation and small business is internally contradictory. 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 certification reaches its conclusion by distributing loss across every small firm in the sector nationally, not by examining the outfitters and guides actually holding permits in the areas at issue. Some of those firms may lose the receipts that sustain them entirely. Spreading a concentrated loss across a national average firm obscures rather than analyzes the impact. The certification should be withdrawn and replaced with an assessment of the small entities actually operating in the potentially affected roadless areas. These places are a gift and they are our responsibility. The children who will inherit them deserve a decision built on complete analysis, honest accounting of what is being given up, and a procedural record proportionate to what is at stake. This proposal does not yet meet that standard.

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Photography pulled me to Yosemite and to public lands wherever they exist. I go looking for what is still there, and I want it passed from generation to generation. To hell with "profits." That conviction is why I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The strongest reason to reject this proposal is the one the agency's own record makes for me. 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 proposal nonetheless invokes wildfire and fuels management as partial justification for rescission. Those two positions cannot coexist without explanation. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, 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 fire rationale carries a second problem. The stated legal basis for the rescission is not wildfire protection at all. The agency declared that "the purpose and need is to reduce regulatory burden and return decisionmaking to local officials. Overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS says the benefits of added fuel-management access 'would likely be modest and localized.'" The agency itself built a wildland-urban interface targeted alternative that would address the fire rationale without dismantling protections across the full affected area, and then rejected it. I ask that the agency explain why nationwide rescission was chosen over that targeted alternative it constructed and then set aside. The agency also argues permitting and administrative burden, but the rule as written already accommodates the activities the agency says it cannot conduct. 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)." Exceptions for public health and safety, existing mineral rights, and community wildfire protection are already in the rule. The agency has not shown what specific operational need falls outside those provisions. It should identify which burdens are not already addressed by the existing exceptions and quantify those burdens on the record before asking the public to accept rescission as the remedy. The process that produced this proposal was also structurally flawed. A purpose framed as deregulation closes off the comparison that environmental review requires. The record shows that "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.'" No protective alternative was analysed in full. The agency should restate the purpose and need in terms of actual forest conditions and analyse at least one protective alternative on the merits. Water is life. When the streams are poisoned and the last fish hunted, you cannot eat money. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The places I photograph, the public lands I believe should be held in trust across generations, depend on watersheds that the rule currently protects. Rescission trades that protection for a deregulatory objective the agency cannot quantify and a fire benefit its own record describes as modest and localized. This proposal should be withdrawn. Sincerely, Christian Velasquez

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking is when I feel most at peace and in awe of the world. These roadless areas are what make that possible, and the agency's proposal to rescind the 2001 Roadless Area Conservation Rule threatens them in ways the agency's own record does not support. The agency argues that opening roadless areas to road construction would help manage wildfire. Its own findings say 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 agency must explain what changed. Its own DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain, clearly and in the rulemaking record, why this proposal departs from those prior findings and how it reconciles the rescission with the ignition data its own analysis produced. The agency also cannot make the economics work. Its own record acknowledges: "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 timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. The agency's road maintenance backlog already stands at $6.9 billion. How does the agency justify expanding a road system it cannot afford to maintain, for commodity yields that by its own numbers are a fraction of national production, when its own analysis cannot confirm the action pays? The agency argues that state-by-state approaches can replace a single national rule. But the agency's own record reflects its prior position: "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 the last time the agency substituted state petitions for the national rule and found it deficient. The agency has already found that local decision-making can incrementally erode nationally significant roadless values. This proposal must address what is different now, and explain how it avoids the specific deficiencies identified in that prior litigation. The agency also suggests the 2001 rule exceeded its statutory authority. The courts that examined this question did not agree. The record includes the following holding: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." 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 state in the rulemaking record the legal basis for any position that contradicts that holding. Clean water connects all of this. Without clean water we cannot survive and thrive. These roadless watersheds are part of what keeps water clean, and the agency's own analysis shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must explain what specific protection will replace the 2001 rule for the municipal water intakes and drinkers who depend on these watersheds, and it must do so with analysis, not assertion. I oppose rescission of the 2001 Roadless Area Conservation Rule and ask that each of these points receive a substantive response before any final action is taken. Sincerely, Lyla Rothschild Tucson AZ 85719

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forest areas where I walk my dog and camp in primitive sites are the kind of country this rule was written to protect. I am opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. The agency's own record contains a finding I want addressed directly. "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, yet this language comes from the agency itself. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which the record indicates reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold together either. 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." 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 Forest Service is already $6.9 billion behind on maintaining the roads it has, against a road budget of roughly $73 million a year. My view is simple: take care of the existing roads. Building new roads into country that has none, when the agency cannot maintain what it already manages, adds cost without a demonstrated return. I ask that the agency explain, with specificity, how an action whose own cost-benefit analysis cannot establish a net benefit justifies further expanding a road system already carrying that backlog. The proposal argues that state-specific approaches can replace the national rule, but this ground has already been tested. The agency's own record acknowledges "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 that prior attempt to substitute state-by-state management for the national rule and found it wanting. The agency has not explained how this proposal avoids those same deficiencies or addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. That question deserves a direct answer in this record. On the question of statutory authority, the Tenth Circuit already reviewed whether the 2001 rule exceeded the agency's power and held otherwise, reversing a permanent injunction and remanding to vacate it. The court's ruling was clear: "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 specifically found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not find that it created de facto wilderness. The agency's current proposal rests in part on a contrary statutory reading. The agency must explain in this record what basis it has for that position in light of that holding. My children enjoy the outdoors and nature. I want my grandchildren to have as much opportunity as I did. 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. That asymmetry is itself a reason this record is inadequate. The agency should answer each of the specific points raised above before any final action is taken. Sincerely, Christine Cavender Clermont, FL

Despite a short comment period, over 625,000 people submitted letters of signed petitions, with the vast majority opposed to rescission of the Roadless Rule. The draft EIS reports public-participation figures derived from a comment-screening process that used a definition of “substantive” that is no longer in effect. Under the definition now in effect, a compliance comment is substantive on its face, with no showing of impacts required. This must be corrected. Because the draft EIS states that comments received “were used to inform the range of alternatives and environmental impact analyses,” a screen that undercounted compliance comments carried forward into the range of alternatives analyzed in this draft EIS. The Forest Service needs to: 1. Correct Appendix 3, footnote 72, and the statement at p. 9 and footnote 1 to state the definition of “substantive” at 7 CFR 1b.11(a)(53), as amended effective April 3, 2026, including the compliance limb, and identify which version governed the screening of each comment record; 2. Re-screen the NOI comment record and the comments on this draft EIS against the operative definition, and disclose in the final EIS the number of comments that are substantive under it but were not substantive under the interim-rule definition, together with any resulting changes to the themes, concerns, and recommendations reported in Appendix 3 and to the range of alternatives those comments informed; and 3. Disclose, with the reported figures, the counting rules that produced them — how a “comment letter” was distinguished from a “submission,” how petition signatures were attributed, and the criteria by which a letter was classified as “generally opposed” or “generally in support” — so that the 99 percent / 1 percent characterization rests on a stated and reviewable basis. Because the reported comment figures and the screening standard behind them bear on the agency’s explanation of its change in position, this concern is addressed to the final rule preamble as well as to the final EIS appendix. Roads kill wildlife. They degrade water quality and habitat. Over 80 percent of wildfires nationwide are human-caused. Repeal of the Roadless Rule is a terrible idea.

RE: Docket FS-2025-0001, RIN 0596-AD66, proposed rescission of 36 CFR part 294, subpart B Introduction My family has held a Forest Service recreation residence permit since the 1930s. Our cabin is on one national forest, but I see the Roadless Rule as larger than any single place. I am commenting on the agency's stated goal of prioritizing local decision-making over a uniform national rule. Background USDA has said the rescission would "prioritize local agency decision-making over regulatory rules that are the same across the country." My comment addresses whether that rationale holds up, given how the 2001 rule actually works. Analysis The 2001 rule is not a rigid ban. It allows roads to protect public health and safety in cases of imminent threat of flood, fire, or other catastrophic event (36 CFR 294.12(b)(1)). It allows cutting of generally small-diameter timber to improve habitat or reduce wildfire risk (36 CFR 294.13(b)(1)). It respects existing rights. Local forest managers have used these provisions for twenty-five years. The rule sets a baseline and leaves real room for local judgment. Without a national baseline, each roadless area will be defended one project or forest plan at a time. That shifts a heavy burden onto the public, who must track and comment on many separate local decisions, often with little notice. Some areas will be lost simply because no one had the time or resources to respond to a particular proposal. A national rule exists so the public does not have to fight the same question in every forest. The values at stake are national. The 2001 rule found that roadless areas include 354 municipal watersheds contributing drinking water to millions of people (66 Fed. Reg. 3244, Jan. 12, 2001). They store large amounts of carbon in mature and old forests. They include places such as Alaska's Tongass, among the most intact temperate rainforests on Earth. People in every state rely on these lands for water, wildlife, and recreation, whether or not they live near them. I also ask the agency to explain which specific local management needs the current rule has prevented, with examples. If the existing exceptions have been enough, then the local decision-making rationale does not justify rescission. Recommendations 1. Retain 36 CFR part 294, subpart B as the national baseline and select the no-action alternative. 2. If particular forests face specific needs, address them through targeted, site-specific changes with full public notice, rather than removing protection nationwide. 3. Publish examples of local management actions the rule has actually blocked since 2001. Conclusion The current rule already balances national protection with local flexibility. Please withdraw this proposal and keep the 2001 Roadless Rule.

RE: Docket FS-2025-0001, RIN 0596-AD66, Special Areas; Roadless Area Conservation Introduction I am in my forties, which means I am among the people who will live longest with the outcome of this rulemaking. My family has held a recreation residence permit on a national forest since the 1930s. The cabin and the forest around it have been passed through the generations before me, and I hope to pass the experience of that forest on to the generations after me. I am commenting on how the proposed rescission of 36 CFR part 294, subpart B shifts costs onto future generations. What I am commenting on My comment addresses the cost and benefit analysis, especially the long-term costs that would fall on future taxpayers and forest users. Analysis My generation is inheriting many bills: aging infrastructure, more severe fire seasons, and growing pressure on water supplies. This proposal would add to them. In 2001 the Forest Service reported a backlog of about $8.4 billion in deferred maintenance and reconstruction on more than 386,000 miles of existing roads (66 Fed. Reg. 3244, Jan. 12, 2001). Every new road becomes a maintenance obligation for decades, long after any timber revenue has been spent. Those future costs should be counted in today's analysis, not left for later budgets. At the same time, roadless areas are among the best long-term assets the public owns. They supply clean water without treatment plants, store carbon at no cost to taxpayers, shelter fish and wildlife, and give people somewhere to get away from the noise of everyday life. These benefits continue year after year. A road, by contrast, is a one-way door. Once an area is roaded and logged, it does not return to its earlier condition in my lifetime or my children's. The existing rule already allows the agency to fight fires, reduce fuels, and build roads where public safety requires it (36 CFR 294.12(b)(1) and 294.13(b)(1)). Rescinding it does not give the agency a tool it lacks. It only removes the safeguard. I ask the agency to use a long time horizon in its analysis. A short horizon makes timber revenue look large and long-term losses look small. A fifty-year view would show the true balance. Recommendations 1. Select the no-action alternative and retain 36 CFR part 294, subpart B. 2. Evaluate costs and benefits over at least fifty years, including road maintenance, water treatment, fire suppression, and lost recreation value. 3. Disclose who will pay the long-term maintenance costs for any new roads and how those costs will be funded. Conclusion I want the people who come after me to have the same chance I had: to walk into a forest that is still whole. Please keep the 2001 Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands must be managed with a sharp eye toward preservation and protection for generations to come, not exploited as assets on a balance sheet. That is not a sentiment. It is the standard against which this rescission fails, and I am writing to oppose it. I live adjacent to State Forest lands on five wooded acres. Despite my disability, birdwatching is accessible to me precisely because the landscape around me still functions. Over the last decade, as building increased habitat loss, I have watched the diversity of my local bird population decline. Tufted titmice, white-breasted nuthatches, American goldfinches, Eastern bluebirds, black-capped chickadees, mourning doves, hummingbirds, turkeys, northern flickers, and hawks still use the property, as do foxes, deer, and chipmunks, year after year treating it as a nursery. That word, nursery, is the right one. What I watch on five wooded acres depends on what is protected at scale. 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. The wild turkeys that cross my land, and the complex forest structure they depend on for mast, are named in the DEIS among the species that lose the most when that structure is broken. The deer that use my property as a nursery face disrupted migration routes and lost unroaded security if this rescission proceeds: the agency's own record, citing Wyoming research, documents that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed. I ask the agency to explain in this proceeding how those documented effects on birds and deer are consistent with a decision to open roadless areas to road construction. The wildfire rationale offered for this rescission cannot be reconciled with the agency's own record. 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." If the agency is using fire management to justify rescission, it must explain why its proposal departs from that finding and reconcile the proposed action with the ignition data in DEIS Table 21, which the record shows reports far higher fire density on roaded land than inside the affected roadless areas. On the economics, 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." Selling timber from these areas has always been a losing proposition. Water once fouled never returns to purity regardless of remediation, and the record projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year and a net present value whose own range spans from negative to positive. The agency must explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when its own Cost Benefit Analysis cannot establish a net benefit. The state-by-state approach advanced here has a history. The agency's 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." That approach was tried and the Ninth Circuit found it wanting. The agency needs to confront its own prior finding that local decision-making can incrementally erode nationally significant roadless values and explain how this proposal avoids the same deficiencies. On statutory authority, the Tenth Circuit was direct: "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 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must explain the basis for any contrary position and address that holding squarely. The Roadless Rule was implemented to stop and prevent degradation of our watersheds and our forests. Rescinding it, on economic justifications the agency's own numbers undercut and on wildfire logic the agency's own data contradict, is not management. It is the balance-sheet thinking that public lands were never meant to serve. Sincerely, Beth Conry Milford, Pennsylvania 18337

To Whom It May Concern: My name is Clara Hildman, and I live in Loveland, Colorado. I am writing as an individual to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I’m writing to specifically address the section of the proposal regarding Purpose and Need for Action where there is a paragraph that speaks about resource use in certain areas. “Specifically, this deregulatory action advances the policy objectives of Executive Order 14192, Unleashing Prosperity Through Deregulation, to alleviate unnecessary regulatory burdens. In Executive Order 14225, Immediate Expansion of American Timber Production, the President declared that “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” In Executive Order 14154, Unleashing American Energy, the President likewise declared that “it is in the national interest to unleash America's affordable and reliable energy and natural resources.” In Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, the President declared that “it is the policy of the United States to fully avail itself of Alaska's vast lands and resources” and “maximize the development and production of the natural resources located on both Federal and State lands within Alaska.” Consistent with this policy, Executive Order 14153 directed the Secretary of Agriculture to reinstate the 2020 Alaska Roadless Rule that exempted the Tongass National Forest in Alaska from the 2001 Roadless Rule. This proposed rescission does not mandate timber cutting or road construction but would relieve regulatory burden relative to management of National Forest System lands.” I would like to highlight this last sentence in contrast to the previous language of what came before it. It seems to slightly contradict the previous phrasing of things like “...maximize the development…” and “...fully avail itself of Alaska's vast lands and resources”. I believe this proposed action requires adjustment because the current rule that is in place has been shown to improve the wilderness character, opportunities for solitude, a noticeable lessen in pollution, and protects our forests. For example, in my community, I have seen how the presence of trucks close to the wilderness area can affect the environment near said road. To improve this rule and better serve the public, I recommend that the agency: Find a alternative to rescinding the rule completely If the rule does get rescinded, to find restrictions and a type of strict management with the absence of this rule Thank you for the opportunity to share my perspective on this important matter and for your time in reviewing substantive public feedback. Sincerely, Clara Hildman

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Clean air, clean water, the smell of the earth and trees, the sound of silence, the sounds of nature, the great expanse untamed: these are medicine to the mind, body, and soul. These untrammeled and unpaved lands must exist for our generation and for future generations, because wilderness is what makes us, as humans, a part of this planet, whole. That conviction is why I oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, without reservation. The agency's own record destroys the wildfire rationale at the center of this proposal. The DEIS states plainly: "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 these areas to new roads does not reduce ignition risk. It multiplies it. The agency must explain, in specific terms, why this proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and it must reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is no stronger. The agency's own analysis 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." These are the agency's numbers, not mine. The 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. The road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot establish a net benefit justify adding to that backlog? The agency must reconcile this proposal with those figures and answer that question on the record. I photograph the trees, running waters, the skies and the expanse, the critters and wildlife I encounter. Every photo is a precious memory and a gift of gratitude that such places exist. My wish is for every creature to have a place called home where it can sustain a life without human conflict. Outfitters, guides, and tour operators who bring people into these places share something of that purpose, and the DEIS names them directly as affected parties. Yet the regulatory flexibility analysis certifies no significant impact on small entities by spreading a $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 areas at issue. The same analysis concedes some of those firms may lose those receipts entirely. The agency must withdraw that certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not a national average firm that has never set foot in them. Finally, the agency frames rescission as a solution to administrative burden, but the rule as written already accommodates the situations cited. It generally banned road building "subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Existing exceptions cover public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific burdens fall outside those provisions. It must do so, with numbers attached, before claiming the rule itself is the obstacle. These untrammeled places are what make us whole. The record assembled by the agency does not support taking them apart. I urge the agency to withdraw this proposal. Sincerely,

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to ask the Department to select Alternative 1 (no action) in the final decision. I have spent time in the Monongahela National Forest, including Dolly Sods and the Cranberry Wilderness, as well as the George Washington National Forest. What makes those places worth the drive from Sharpsburg is precisely what this proposal would strip away: no road noise, intact headwater streams you can drink from with a filter, and backcountry where ruffed grouse, brook trout, and black bear still have room. Those areas are within two to three hours of the Baltimore-Washington corridor, which means they are some of the only large unroaded landscapes accessible to roughly ten million people. Opening them to road construction trades a permanent public asset for a short-term private one. I live in Sharpsburg, Maryland, in the Potomac watershed. The nearest inventoried roadless areas to my community sit in those same forests, whose headwaters feed the Potomac River that supplies drinking water to millions of people downstream, including in Washington County. Roadless backcountry protects water quality at the source by preventing the sediment, culvert failures, and runoff that come with new road construction on steep forest ground. Maryland does not have a national forest, but it lives downstream of several, and that is why this rule matters here. The DEIS does not justify a full rescission. The 2001 rule already contains exceptions for road construction needed for wildfire response, public health and safety, and other circumstances (36 CFR 294.12), so the claim that the rule blocks fire management does not hold up against the rule's own text or the agency's own history of approving treatments in roadless areas. If the Department believes specific areas need site-specific flexibility, the lawful path is a targeted amendment or state-specific rulemaking with full analysis, as Idaho and Colorado did, not a nationwide repeal that removes protection from roughly 45 million acres at once. Rescission would also commit the Forest Service to building and maintaining new roads it cannot afford. The agency already carries a road maintenance backlog measured in the billions of dollars. Adding mileage in remote terrain shifts cost to taxpayers while delivering most of the benefit to private extraction interests. The process itself has been inadequate. The original 2001 rule followed more than 120 days of public comment and hundreds of public meetings. This rescission was given roughly 30 days plus a 15-day extension, with no public meetings in the affected forests, for a decision affecting a quarter of the national forest system. The record from the 2025 scoping period, in which the overwhelming majority of more than 600,000 commenters supported keeping the rule, should be given real weight rather than treated as a formality. Please retain the 2001 Roadless Rule in full and adopt Alternative 1.

Re: RIN 0596-AD66 — Special Areas; Roadless Area Conservation I respectfully oppose rescission of the 2001 Roadless Area Conservation Rule and urge USDA and the U.S. Forest Service to retain the protections in 36 CFR Part 294, Subpart B. The proposal would remove national limits on road construction, road reconstruction, and timber harvesting in inventoried roadless areas, relying primarily on individual forest plans. This would weaken consistent protection for nationally significant wildlife habitat, watersheds, recreation, scenery, and ecological connectivity. Retain the national standard Inventoried roadless areas are among the remaining large, relatively undeveloped blocks of National Forest System land. They provide connected habitat, clean water, dispersed recreation, carbon storage, scenic values, and refugia for wildlife. Their benefits extend across forest and state boundaries; wildlife, watersheds, migration corridors, fire regimes, and recreational landscapes do not follow administrative boundaries. Returning decisions entirely to individual forest plans could produce inconsistent protections for comparable landscapes and eliminate an important national conservation baseline. Forest plans should address site-specific conditions, but they should not replace national minimum protections. Road construction is not inherently necessary for wildfire management I recognize the serious threat wildfire poses to communities, forests, wildlife, and watersheds. However, wildfire risk alone does not justify permanent road construction throughout inventoried roadless areas. Roads can increase human-caused ignition risk, fragment habitat, facilitate access and disturbance, spread invasive species, and create long-term maintenance obligations. Wildfire management should rely on strategically targeted, science-based treatments. Where a specific project is necessary for public safety or ecological restoration, it should be evaluated through existing statutory, regulatory, and environmental-review processes rather than by eliminating protections across millions of acres. Consider the road-maintenance backlog The proposal acknowledges the Forest Service’s substantial deferred road and bridge maintenance obligations, including an estimated $6.9 billion backlog. Adding roads would create further obligations for inspection, maintenance, drainage, erosion control, repair, and eventual decommissioning. Before removing restrictions on new roads, the Forest Service should demonstrate that it has the funding and capacity to maintain additional infrastructure. Expanding the road network while struggling to maintain existing roads would be fiscally and environmentally counterproductive. Protect wildlife, connectivity, and water resources Large, undisturbed landscapes provide habitat and connectivity for species sensitive to roads, human activity, and fragmentation. Road construction can divide habitat, disrupt movement, increase disturbance, and facilitate additional development and recreational pressure. Maintaining roadless landscapes also supports ecological connectivity as species respond to climate change and shifting habitat. Road construction can also cause erosion, sedimentation, altered drainage, stream crossings, and other impacts to aquatic ecosystems. Because National Forest lands provide important drinking-water sources, intact watersheds should remain a national management priority. Site-specific NEPA review of future projects cannot fully replace the broad, preventative protections provided by the Roadless Rule. The proposal does not demonstrate that benefits outweigh costs The proposal emphasizes increased management flexibility, but flexibility alone is not an environmental benefit. USDA should demonstrate that rescission would produce measurable benefits sufficient to justify foreseeable costs, including habitat fragmentation, increased disturbance, impacts to water resources and recreation, and additional infrastructure obligations. The proposal acknowledges that projected increases in timber management are limited by operability, road costs, and existing maintenance obligations. If anticipated economic and forest-management benefits are limited, eliminating a national conservation standard protecting millions of acres is not justified. Inventoried roadless areas are finite and irreplaceable. Once roads fragment these landscapes and previously remote areas become accessible to intensive use, their roadless character cannot easily be restored. The Forest Service should maintain a national baseline protecting large, connected, undeveloped landscapes while using targeted exceptions and site-specific environmental review where truly necessary. I respectfully request that USDA reject the proposed rescission of 36 CFR Part 294, Subpart B.