Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I live in North Carolina, have family property near the Horse Heaven roadles area in Virginia and travel extensively each year in the western states, I spend many weeks each year moving through this country on foot, by canoe, and by paddle, buying gas, eating at local restaurants, sleeping in local lodging. These roadless areas are not abstractions to me. I am also an engineering geologist, and I have built roads into new terrain. I know what that work costs and what it leaves behind. I have seen many debris flows, some of which have killed people, that were initiated at a dirt road built in a mountainous area. I have paddled extensively in Idaho, Utah, Oregon, Virginia and North Carolina. Construction in these areas leads to substantial siltation of rivers. I see firsthand the damage done to rivers by debris flows that start at excavated and disturbed roadways. Virginia alone holds 64 inventoried roadless areas totaling 393,682 acres. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. I have also worked on water supply dams, and I see the struggles that water treatment plants face when treating sediment-laden water from construction and debris flow runoff. New roads can substantially increase the money spent on filtering and cleaning drinking water. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I ask that the agency explain in detail how it weighed this sediment loading against the drinking water supply function these watersheds perform, and how it accounts for the cost that burden shifts onto water utilities and ratepayers. The economic case for rescission does not hold together. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." As an engineering geologist who has been involved firsthand in building roads into new areas, I can say plainly: the initial cost is enormous and maintenance is an ongoing and costly outlay of funds. The agency is already carrying a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. I ask that the agency reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system it cannot already maintain. The rule the agency proposes to rescind already permits what the agency claims it cannot do. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The proposal justifies rescission partly on permitting and administrative burden grounds. The agency must identify which specific burdens are not already addressed by those existing exceptions and quantify them with precision. The agency's regulatory flexibility analysis is not credible. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The local outfitters, guides and tour operators who hold permits in the affected areas are not protected by spreading an aggregate loss across every small firm in the sector nationally. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, this comment is itself a reliance interest the agency invited and then failed to weigh. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." I, like most Americans, want to leave a legacy for my child and her cousins and all their descendants. There is not much land to save, and most of this is land that is particularly difficult to develop. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Let's leave it better than we found it for our kids. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Gary Rogers Greensboro, NC

Dear Chief: I am a wildlife artist making work about local ecology that I share in educational settings. I rely on research, conversations with biologists and my daily visits to the national forest. Having observed wildlife across a representative cross-section of the inventoried roadless areas in the affected region, I write as a sustained observer to oppose the proposed rescission, the rationale for which the field evidence does not support. My opposition rests on several issues, chief among them fire. I will note ahead of that arguement below, that rescinding the Roadless Rule will fragment habitats and increase road mortality of wildlife. Your analysis, its failure to consistently and adequately address core habitat, as well as improperly aligned data regarding management plans for listed species, fails to address the effects on health, population and distribution of the Southern California population Puma Con Color. I request that it do so. Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire. The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation. If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire. Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom. Do the right thing. DO NOT RECIND THE ROADLESS RULE. All the best, Christian Kasperkovitz

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 This past summer my three sons and I hiked to Three Fingered Jack, Canyon Creek Meadows, and Wasco Lake in the Deschutes National Forest was a gift. A park ranger greeted us at the trailhead, and what followed was four hours of beauty and peace, away from development, cars, and commerce. That kind of conversation and connection with family would not have happened surrounded by traffic, busy roads, and noise. I oppose the proposed rescission of the Roadless Rule, and I support the No Action Alternative. The Deschutes holds 11 inventoried roadless areas totaling 136,446 acres. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The existing rule already contains the flexibility the agency says it lacks. 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 gestures at permitting and administrative burdens as justification for rescission, but it does not identify which specific burdens fall outside those existing exceptions. I ask that the agency identify, on the record, which burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those burdens with specificity. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My family has planned around the existence of this rule. The hike to Three Fingered Jack was possible because those 136,446 acres in the Deschutes have remained intact. Finally, the agency's own fire data cuts against the proposal. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The Deschutes, where my sons and I walked through four hours of undisturbed forest, sits within a region where fire risk is not a hypothetical. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access and weigh it against any claimed reduction in wildfire hazard before this rescission can proceed.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands belong to all Americans, and they should be managed for the enduring health and integrity of those lands and for their many non-destructive benefits to the public, not for the profits of the timber industry. The proposed rescission of the 2001 Roadless Area Conservation Rule fails that standard, and I oppose it without reservation. The agency's own findings on wildfire make the rescission indefensible on its stated justification. The 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 nonetheless invokes wildfire and fuels management as reasons to open roadless areas to road construction. I ask that the agency explain, in this proceeding, why the proposal departs from these prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which the record shows documents far higher fire density on roaded land than inside the affected areas. The economic case for rescission is no stronger. The agency's own analysis 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 modest upside, 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 range spanning -$92 million to +$199 million, a range so wide it cannot establish a net benefit at all. The agency is already $6.9 billion behind on maintaining the roads it has, with a road budget of about $73 million a year. My question is direct: are you proposing to continue neglecting existing roads in roaded areas in order to accommodate the timber industry and its shareholders, while the agency's own numbers cannot demonstrate that expanding the road system pays? The agency must reconcile this proposal with its own economic record and explain how an action of uncertain net value justifies deepening a maintenance deficit of that magnitude. The rule the agency proposes to rescind already contains the flexibility it claims to need. The record acknowledges 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)." The proposal rests in part on permitting and administrative burden, yet it does not identify which specific burdens fall outside those existing exceptions, including those covering public health and safety, existing mineral leases, and community wildfire protection. The agency must name those burdens specifically and quantify them. The Larch Roadless Area in Mt. Hood National Forest, Oregon covers 12,961 acres and is vital to the City of Portland's Bull Run Watershed, which provides Portland's drinking water. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, according to DEIS Table 35. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres. Road construction in areas like Larch introduces sediment, increases runoff, and elevates the risk of contamination to the water supply of a major American city. I ask plainly: is the agency proposing to foul the drinking water of Portland and communities like it throughout the Pacific Northwest, and if not, what enforceable protection replaces the rule for the 1,522 intakes that DEIS Table 35 identifies? Finally, the alternatives analysis is fatally compromised by the way the agency wrote its own purpose. The record reflects 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.'" A purpose defined as deregulation forecloses exactly the comparison NEPA requires. The agency must restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative before this proceeding closes. Sincerely, Stephenie J. Frederick Portland, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Roadless Area Conservation Rule has protected places that matter to real people doing real work, and rescinding it would be a mistake this country will spend decades undoing. I worked for the Forest Service at Carson National Forest and saw firsthand how valuable roadless areas are to both the people and the businesses around them. The roadless areas near Sipapu Ski Resort meant available clean water, less fire risk, and they did not prevent the continued expansion of the resort. Visitors, residents, and snow-making operations all depended on that water. Having lived in northern New Mexico, I know that water is scarce and hard-won. Entire towns understand that without the water quality protection roadless areas provide, the town itself is at risk. New Mexico holds 120 inventoried roadless areas totaling 1,505,508 acres, and across the Southwestern region 739 municipal water intakes sit in watersheds containing affected roadless areas. The stakes for communities here are not abstract. On wildfire, I have watched what roads actually do. I've had to leave many areas due to roadside fires started. I was also living in Taos when the Calf Canyon Fire started, and I returned to work on Carson National Forest right after it. While that fire started from a different cause, what I witnessed was a difficult recovery paired with hard discussions about past Forest Service mismanagement that increased fire risk. One thing became clear in those conversations about past local fires: roads increase fire risk because they increase human activity. 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 current rule already allows roads for firefighting. Repealing it and permitting additional traffic and logging will increase ignition risk to the communities nearby. 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 DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The financial case for rescission does not hold together either. There is already a shortage of funds to manage existing roads. Creating new ones is a mismanagement of funds, and it makes zero sense financially, safety-wise, or as a long-term investment in the economy and health of these forests. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile this proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and it must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also has not explained what specific permitting or administrative burdens the rule actually creates that cannot already be addressed under its own exceptions. The rule as written "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency should identify which specific burdens are not already addressed by existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and it should quantify those burdens on the record rather than assert them. Finally, this comment is itself a reliance interest. My work on Carson National Forest, my understanding of what these areas protect, and the communities I have seen depend on clean water and reduced fire risk all rest on the continued operation of the rule. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. The agency must identify and genuinely weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Keep the rule in place and keep protecting the people nearby. Sincerely, A concerned citizen

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Deschutes National Forest is steps outside of my neighborhood. I walk in it every day. I have been evacuated twice for wildfires. That history shapes how I read this proposal, and what I need the agency to address. I work as a grant writer for a forest nonprofit, so I am familiar with the road maintenance backlog. The $6.9 billion deficit is astounding. Rescinding the 2001 Roadless Area Conservation Rule would exacerbate that problem. Our road system carries a large number of undersized culverts with no budget allocated toward upsizing them. Adding new roads into the North and South Paulina roadless areas, which cover 28,744 acres inside the Deschutes, would deepen a liability the agency has demonstrated it cannot fund. The agency should explain on the record how expanding a road network carrying a deficit this large constitutes responsible stewardship, and address why the proposal does not require the existing system to be brought into defensible condition. The agency's record addresses ignition. Its DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I was six the first time I was evacuated for a wildfire. Roads and the humans who drive on them contribute to these blazes. The agency's proposal justifies rescission on wildfire and fuels management grounds, yet its own DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency reconcile those positions in writing and explain why the proposal departs from its own findings. Erosion, sedimentation, and heat: bad for drinking water and the fishing tours that my town relies upon. Roads impair watersheds. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. The lower Deschutes holds one of only two national strongholds for federally threatened bull trout. Big Marsh supports the largest monitored population of federally threatened Oregon spotted frog. Across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analyses support decommissioning roads, not adding them. I ask the agency to explain what analysis it relied upon to conclude that watershed and species protections of this scale should be subordinated to a timber volume the agency describes as "less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The economic record deserves scrutiny: the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. A range that wide cannot establish a net benefit, and the agency must say so plainly. As a Karuk citizen, I read the Tribal consultation record with attention. The agency states that "The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule." Deferring that statement until after the comment period denies the public and Tribal nations opportunity to respond. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule. None was analyzed. The agency must complete all 64 consultations and publish the Tribal Impact Summary Statement before any final rule is issued. The proposal argues that the 2001 rule exceeded the agency's statutory authority. A federal court reviewed that question and concluded otherwise. In that case, the Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that holding and explain the legal basis for a contrary position. This ill-conceived rule change will not benefit anyone except timber corporations, at great cost to the economies and communities nearby. I urge the agency to withdraw the proposal. Sincerely, Emily Woodworth Sisters, OR

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge USDA to withdraw it and adopt the No Action alternative. The preamble's own findings do not support the stated purpose and need, and the record fails to analyze costs the agency itself acknowledges. I live in Arizona and Vermont, and have seen firsthand the ecological and economic benefits of the rule. In addition to using public lands for recreation, these lands protect our nation's heritage, and natural resources we will rely on into the future. As Arizona is currently in a water crisis due to decreased Colorado River flows, intact national forests that ensure clean water supply and aquifer recharge are essential--and any change to this rule can be read as disrespect for the citizens of that state. Near Tucson, where I live, the The Upper Rincon and Santa Rita IRAs on the Coronado National Forest protect sky island headwaters above the Tucson basin, and the Arizona National Scenic Trail crosses both. USDA should analyze the rescission's effects on these watersheds and on recreation along the trail. The agency's findings undercut its rationale. USDA justifies rescission by citing wildfire, insects, and forest health (91 FR 53828), yet concedes management opportunities would be "modest and localized" (53829). Projected timber gains assume harvest across all 4.8 million operable acres, which USDA calls "unlikely" (53829). Speculative benefits cannot rationally justify removing protections from tens of millions of acres. Under Motor Vehicle Mfrs. Ass'n v. State Farm (1983), the agency must show a rational connection between the facts found and the choice made. It has not. Drinking water impacts are unanalyzed. The preamble acknowledges roadless areas at high risk of intense fire that threatens "drinking water sources" (53829) and records Tribal concern for water quality (53832), but quantifies no effect of new roads, harvest, or leasable mineral development on sediment, turbidity, or treatment costs for downstream utilities. USDA should identify affected public water systems by watershed and quantify these effects before any final action. USDA admits the rule will raise human-caused ignition risk. The preamble states greater public access "can increase human-caused ignition potential" (53829). The fire benefit it cites, fuel treatment in the wildland-urban interface, involves 9.8 million acres, about 24 percent of affected areas (53829), and the 2001 Rule already permits cutting small-diameter timber to reduce uncharacteristic wildfire effects (36 CFR 294.13(b)(1)). A narrower alternative exists: clarify that exception for WUI fuels work while keeping protections elsewhere. USDA must explain why it rejected that option. Economic costs are understated and fall on small entities. USDA estimates $6.1 million per year in lost recreation benefits, plus closures, noise, user conflicts, and trade-offs for tourism (53829-30), and says impacts could exceed $100 million (53830). Outfitters, guides, and tourism operators are largely small businesses, yet USDA certifies no significant impact on small entities (53831). That certification conflicts with its own findings. New roads would also add to a $6.9 billion deferred maintenance backlog (53829) that the analysis does not cost out. Wildlife and subsistence analysis is incomplete. The preamble lists threatened and endangered species and plant and animal diversity among the values at stake (53828), notes possible long-term effects on commercial fisheries (53830), and defers ANILCA Section 810 subsistence hearings to a later notice (53830). Finalizing before that analysis is complete would be premature. Tribal consultation is incomplete. USDA concedes the rescission has substantial direct effects on Tribes, that most Tribes consulted oppose it, and that only 29 of 64 requested consultations have been held (53831-32). The final Tribal impact statement will appear only with the final rule. Proceeding first is inconsistent with E.O. 13175 and the federal trust responsibility. Reliance interests must be weighed. USDA invites comment on reliance interests (53830). Under DHS v. Regents (2020), an agency changing course must consider them. Water utilities, recreation businesses, Tribes, and communities have relied on these protections for 25 years. I request you withdraw the proposed rule and adopt No Action. The USDA justifications for changing this rule are contradicted within its own documents. This increases new fire risk, decreases water quality, and disproportionately affects the economies of smaller towns and rural America. This cannot be justified and cannot go through.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests of El Yunque shaped how I understand what wild land means. I grew up hiking there with family and friends, and since moving to the DC area I have continued that life in the forests around me, including the Northern Massanutten in the George Washington National Forest in Virginia. These are the places where I gather with the people I love and connect to where I live. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens that directly, and I oppose it. The agency's own record makes clear that the economic rationale for this proposal cannot bear weight. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." We have enough roads in this country, and not enough protected lands that will help safeguard the future of this planet. That is not a sentiment disconnected from economics. The Forest Service already carries a road maintenance backlog of $6.9 billion against an annual road budget of roughly $73 million. I ask that the agency reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million, and that it explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. The agency argues the 2001 rule exceeded its statutory authority, but that question was litigated and decided. A federal court of appeals held, exercising jurisdiction, and I quote the ruling precisely: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. I ask that the agency explain the legal basis on which it departs from that holding. I paddle and kayak all summer in my city and participate in regular community science water quality monitoring efforts. This is the water we drink and the places we enjoy. Rescinding protections for roadless watersheds is not an abstraction in that context. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and more than 7,000 municipal water intakes sit in watersheds fed by these areas. The proposed rule certifies no significant impact on small entities while the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. Outfitters, guides, and tour operators are named as affected in the DEIS. The certification reaches its conclusion by spreading losses across every small firm in the sector nationally rather than the businesses actually permitted in affected areas. I ask that the agency withdraw that certification and assess impact on the small entities actually operating in these roadless areas. Puerto Rico holds 2 inventoried roadless areas totaling 23,734 acres. The El Toro Area, 12,584 acres in El Yunque National Forest, is land I have been visiting since 1999. It is also historically important Taino land, and rescinding its protection would mean losing cultural heritage that cannot be rebuilt once it is gone. The Mameyes Area, 11,150 acres in the same forest, is a place I grew up going to, one that cleans the island's limited water resources and provides protection during frequent hurricanes. These forests are not peripheral to my life or to the lives of people in Puerto Rico. They are central to both. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" but its Cost Benefit Analysis weighs none. Under the principles established in Encino Motorcars and Regents, an agency reversing course must account for the reliance its prior policy created. Twenty-four years of decisions about where to live, how to spend time, where to volunteer, and what places to love are made in the shadow of rules like this one. Northern Massanutten helped me connect to a new home and inspired me to volunteer in natural spaces in my community. That relationship was built in part because the protection existed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Andrea Contreras San Juan, PR/ Washington, DC

I oppose the proposed rescission of the Roadless Area Conservation Rule and support Alternative 1 (No Action). I live in Piedmont, California, and have a deep background in finance, including evaluating the costs, risks and returns of major investments. Measured that way, this proposal fails on its own record. Page citations are to the Draft EIS (DEIS). 1.Drinking water. About 90 percent of my tap water comes from EBMUD's Mokelumne River watershed, which EBMUD describes as "largely protected from human activity" and consisting "mostly of national forests and undeveloped lands" (EBMUD 2023 Annual Water Quality Report). That watershed includes inventoried roadless land on the Stanislaus National Forest along the North Fork Mokelumne River canyon. The DEIS finds that nearly 5 million people in the Pacific Southwest Region draw water from intakes in watersheds containing affected IRAs, more than any other region, and calls the region "particularly vulnerable" (Table 35, pp. 121-123). It acknowledges that these areas "typically have good water quality due to limited disturbance," that road construction is "the largest source of sediment related to timber harvest operations," and that Alternative 1 "provides the greatest protection of water quality" (p. 122). Post-fire and post-harvest reforestation in California increasingly relies on herbicides, including glyphosate; the Caldor Fire Reforestation Project, for example, lists glyphosate among five herbicides it may use (Lake Tahoe Basin). The DEIS mentions herbicides only for invasive-plant control, conceding they can have "unintended adverse effects" on terrestrial and aquatic species (p. 142), and never analyzes post-harvest herbicide use or its effects on source water. Fuel reduction near communities is already permitted under the 2001 Rule (36 CFR 294.13(b); DEIS Table 1, p. 14); commercial timber harvest and new road construction in source watersheds are not necessary to achieve it. At minimum, protections should be retained in municipal source watersheds. 2.Wildfire. The DEIS's own data undercut its fire rationale. Ignition density on other NFS lands is about four times that of affected IRAs (41.8 vs. 12.0 fires per million acres per year, Table 18, p. 87), and human-caused ignitions are over seven times higher (22.4 vs. 3.0, Table 21, p. 90). The DEIS concedes that "human caused ignitions increase in abundance with proximity to roads" (p. 90) and that IRAs burned a smaller share of their area (8.7% vs. 13.8%, Table 18). It also admits "a lack of roads has not prevented fire prevention or protection measures" (p. 105). Its answer to added ignitions, restricting public access to new roads (p. 105), depends on gates, closures and enforcement the agency cannot fund (see 3). 3.Fiscal responsibility. The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges, counting passenger-car roads only, and a drop in annual road appropriations from $234 million (2004) to $73 million (2024); supplemental GAOA funding expired in 2025 and IIJA funding was set to expire September 30, 2026 (p. 43). It assumes timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project" (p. 45). No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has. The agency should address the existing backlog and disclose the life-cycle cost of new roads, and how it would be paid, before removing protections. 4.Old growth and intact habitat. Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors. The DEIS finds the proposal "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats (pp. 25, 161), and that 11-16% of the operable area where plans allow harvest is old growth and 54-63% is mature forest (p. 78). It projects 253,000-557,000 ccf of added harvest per year (p. 77), yet defers site-specific analysis because future activities are "uncertain" (p. 32). The agency cannot model where the timber is while declining to analyze the harm in those same places. I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule (Alternative 1). If any change proceeds, it should occur through state-specific rulemaking with full analysis of water supply, wildfire, fiscal and habitat impacts. Other sources: EBMUD 2023 Annual Water Quality Report (ebmud.com); CSERC, Stanislaus NF roadless areas (cserc.org); South Tahoe Now, Caldor Fire Reforestation Project (May 4, 2026); KUNR, Tahoe herbicide concerns (May 27, 2026); Mother Jones/Reveal investigation on Forest Service glyphosate use in California (Apr. 2026). Jeff East Bay, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I oppose rescinding or altering the 2001 Roadless Rule and support Alternative 1, the No Action alternative. The roadless areas near Red Feather Lakes are where I go to maintain my mental, physical, and spiritual health. Watching owls, hawks, squirrels, foxes, pikas, and bighorn sheep is an essential part of my life as a Coloradoan, and the quiet of those unroaded landscapes is what makes that possible. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The agency's own record undercuts the wildfire rationale it offers for this rescission. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding sits in the same document that proposes to open 40.1 million acres to road construction. The agency offers no explanation for how a policy that multiplies road access serves fire risk reduction. 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 DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The administrative burden argument fares no better when measured against what the rule actually says. The DEIS acknowledges 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 already permit road construction for public health and safety, for existing mineral leases, and for community wildfire protection, the agency has not shown what burdens remain that rescission alone could address. I ask that the agency identify, specifically and on the record, which burdens are not already resolved by those exceptions, and that it quantify them. The diverse animal life in these landscapes depend on unroaded habitat, and the DEIS contains evidence directly relevant to their survival that the agency declines to apply. The document cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." The agency produced that citation and then projected no population-level effects on big game anywhere in the document. The same record that tells us what roads do to ungulate survival stops short of asking what opening 40.1 million acres would do to ungulate populations or to hunting opportunity. I ask that the agency project those effects on big game populations and hunter opportunity before any final decision is made. The fragmentation data receive the same partial treatment. The DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is wide, the stakes are measurable, and the affected area is known. Strikingly, no projection of that range across the 40.1 million acres of potentially affected environment appears anywhere in the analysis. The agency built Alternative 3 specifically because commenters asked it to protect big game habitat, fisheries, and wildlife connectivity, and then selected the alternative that protects none of it. The cited fragmentation finding demands application at the scale of this decision. The agency must apply the cited fragmentation range to the 40.1 million potentially affected acres before this proceeding closes. I believe public lands must be managed with communities, especially those most affected, including tribal councils and indigenous individuals. The record before me does not reflect that standard. The agency identified the harms, noted the alternatives, and chose the path its own data argue against. I ask that it answer, specifically, each of the questions raised above. Sincerely, Zoë Roberts, Fort Collins, CO

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Bighorn and Snowy ranges are where I go to escape, to camp in the front country, backcountry, or simply boondock somewhere remote. I return to these forests for unparalleled solitude, natural beauty, and an abundance of wildlife, including moose, elk, mustelids, and birds of prey. I photograph charismatic mammals large and small and watch raptors and woodpeckers in the forest. At Libby Flats in the Medicine Bow-Routt National Forest, I have fond memories with family taking in the views and the wildlife, from elk to marmots. I want to see this place protected for others in the future. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. Our public land should be managed for the benefit of the American public and their children, not for private for-profit interests. Access to solitude, wildness, clean water, quiet, and outdoor recreation is part of our heritage as Americans. Rescission of the rule puts all of that at risk across the roadless areas I named in this comment, including Sibley Lake and Devils Canyon in the Bighorn National Forest, Bridger Peak and Libby Flats in the Medicine Bow-Routt National Forest, and Beaver Park in the Black Hills National Forest in South Dakota. The agency's own record contradicts the wildfire justification for this rescission. 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 that finding is in the agency's own draft environmental impact statement, the proposal to open these areas to road building requires the agency to explain why it departs from those findings. On the question of permitting burden, the agency's own description of the existing rule notes that it already carries exceptions: "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 a rule that protects roadless areas across millions of acres, the agency must identify which specific burdens are not already addressed by those existing exceptions, including the ones for public health and safety, existing mineral leases, and community wildfire protection, and it must quantify those burdens with actual data. I rely on the watershed shaped and safeguarded by Black Hills National Forest. South Dakota holds 8 inventoried roadless areas totaling 79,597 acres, with 325 municipal water intakes across the Rocky Mountain region sitting in watersheds containing affected roadless areas. We need fresh, clean water in the west, not more roads. The agency has documented that roads and their facilities can produce a substantial share of the sediment from a timber sale; opening roadless areas to new construction is unreasonable. The elk I look for in these forests are directly addressed by the agency's own citations, and the record falls short. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. That finding appears and then stops. No projection of population-level effects on elk or other big game across the affected environment follows anywhere in the document. The agency must project those effects and their consequences for big game populations and hunter opportunity before finalizing any rescission. The same gap appears on habitat fragmentation. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The moose, elk, and birds of prey that draw me to these forests depend on intact, connected habitat. Citing that range without applying it to the 40.1 million acres of potentially affected environment is not analysis; it is notation. The agency must apply the cited fragmentation range to the full affected acreage and show what the record actually predicts for the wildlife those acres support. The agency built Alternative 3 in direct response to commenters who asked it to protect big game habitat, fisheries, and wildlife connectivity, and then selected the alternative that protects none of it. That choice requires a reasoned explanation. What does the record show drove the agency away from the alternative its own process generated in response to public concern about wildlife? That question deserves a direct answer before this proceeding closes. Sincerely, Elizabeth L Custer, South Dakota

Dear Decision-Makers, I am writing to express my strong support for maintaining and protecting the Roadless Rule. As a professor at Furman University and someone who regularly spends time kayaking and exploring the outdoors of Upstate South Carolina and the mountains of North Carolina, I have seen firsthand how valuable intact, undeveloped public lands are to both people and ecosystems. Roadless areas provide some of the most important remaining opportunities for solitude, recreation, and connection to the natural world in our region. For those of us who paddle local waterways, hike mountain trails, and seek out quiet backcountry spaces, these lands are not abstract policy concerns — they are living landscapes that shape our quality of life and our sense of place. Protecting roadless areas is also essential for clean water, wildlife habitat, and long-term forest resilience. Roads and associated development can fragment habitat, increase erosion and sedimentation, and damage the headwaters and streams that support downstream communities, recreation, and biodiversity. In the southern Appalachians, where the ecological richness is extraordinary, these protections are especially important. The mountains of North Carolina and the broader Southern Appalachian region are treasured not only for their beauty, but for the environmental services they provide and the recreation economy they support. Keeping these areas roadless helps preserve the character of the landscape for future generations while reducing costly and unnecessary disturbance. I urge you to uphold the Roadless Rule and reject efforts to weaken protections for these public lands. Once roadless character is lost, it is exceedingly difficult — and often impossible — to restore. Please protect these forests, streams, and wild places for the benefit of current and future generations. Thank you for considering my comment. Sincerely, Brandon Inabinet Purpose and Need Asserts a Balancing of Competing Values Without Performing It Against the Record's Own Conservation Evidence I request three things. 1. That the FEIS supplement the rationale for the proposed rule to state the conservation values of inventoried roadless areas as the Department's own record documents them, including the Dietz et al. (2021) findings published at Volume III page 39, and to explain why the changed conditions recited at pages 18 through 20 outweigh them. 7 CFR 1b.7(f)(2)(iii). 2. That the FEIS correct the statement at page 20 that changed conditions "diminish the basis for a national prohibition," or supply the analysis that supports it. 7 CFR 1b.7(f)(2)(v). 3. That the FEIS disclose the population served by drinking-water source watersheds within the 44.7 million acres of inventoried roadless areas, or state on the record that the Department cannot determine it.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests of New England are special in my life. My lifelong best friend and I have hiked together every year since 1995, often in or near national forests. My husband and I paddled remote rivers in Maine for our honeymoon, using the water to travel through pristine wilderness where there were no roads. My son learned rock climbing on many weekend trips to the White Mountain National Forest in New Hampshire when he was in college. It's a magical place that our family has returned to year after year. Its 16 inventoried roadless areas, totaling 240,669 acres, are what I am writing to protect. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask the agency to answer the specific questions this comment raises. The White Mountains were clearcut once. The Weeks Act of 1911 was passed precisely because of what happened to New England's mountains when that occurred, and the federal purchase authority it created is the reason these forests exist as public land today. Those 240,669 roadless acres are now the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. I have photographed those rivers and ponds, the ferns at their margins and the animals near them. Moose, black bear, Canada lynx, American marten, brook trout, Bicknell's thrush, the northern long-eared bat: all verified in the White Mountain roadless areas. I once spent a whole day photographing decaying trees, marveling at the new lives they support. The forest is not a single thing to be managed toward a single use; it is an interlocked system, and roads are not neutral to it. The agency cites permitting and administrative burden to justify rescission, but the rule as written already accommodates the situations that burden claims to address. 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 does not explain which specific burdens fall outside those existing carve-outs for public health and safety, existing mineral leases, or community wildfire protection. I ask that the agency identify each such burden by category and quantify it with specificity, so the record reflects what the existing rule genuinely cannot handle. The fire data assembled by the agency's own analysts cuts directly against the direction the proposal takes. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. Maine's 5,988 roadless acres sit within an Eastern region where 286 municipal water intakes depend on watersheds containing affected roadless areas. If roads bring ignition rates closer to the roaded average, the downstream consequences for those intakes and for the communities they serve are not theoretical. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against any claimed reduction in wildfire hazard before this proceeding closes. Our public lands are sacred spaces and should be protected from development so these amazing places will be open for our children's children and beyond. That is not a sentiment; it is a reliance interest, and the agency invited exactly this. 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. Every trip my friend and I have planned, every river my husband and I paddled, every camping trip I took my son on, every photograph I made of a living or a decaying thing in those forests: all of it was undertaken with the understanding that the roadless rule meant those places would remain. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, and explain on the record how it has accounted for them. Sincerely, Jill Drew Sharon, CT

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Everywhere and everyone deserves to have safe access in their backyard. That belief is why I oppose the rescission of the 2001 Roadless Area Conservation Rule. The land is a teaching tool. That is how I think about it: using it well, understanding the value of the animals it holds, and making sure it lives long into the future. My family has fished for generations. There are ups and downs sometimes, but uncontrolled damage is irreversible, and that distinction matters. I walk and hike in places near my house, and even after living here for years there is still so much I have not seen. What is at stake here is not abstract. It is the kind of country that rewards patience and teaches people to care. The agency has not squared its proposal with its own numbers. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those figures do not describe a resource emergency. The agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, and a net present value range spanning -$92 million to +$199 million. The existing road system already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile this proposal with those figures and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road network the agency cannot afford to maintain. The agency frames this rescission partly as a permitting and administrative burden argument. But the rule already accommodates the activities most often cited. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency should identify, by specific category, which burdens are not already addressed by these existing exceptions, including those covering existing mineral leases and community wildfire protection, and it should quantify those burdens with evidence rather than assertion. I hunt and fish because I believe in the value of the animals and in leaving something intact. The agency's own document acknowledges what roads do to that. The DEIS states that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." That finding appears in the agency's record and then stops there. No population-level projection follows. No estimate of what opening roadless areas means for elk numbers or hunter opportunity appears anywhere in the document. The agency must project those effects before it acts. The DEIS acknowledges that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is cited and then set aside. It is never applied to the 40.1 million acres of potentially affected environment that this rescission puts in play. A number that wide, across an area that large, is not a footnote. It is the central question. The agency must apply that cited fragmentation range to the full 40.1 million acres and show what the consequences actually look like before this rule is eliminated. Uncontrolled damage is irreversible. The agency has not shown that the benefits of rescission outweigh that fact. I ask that it answer each of these points in the record and reconsider this action. Sincerely, A concerned citizen

I spent college up in the western NC mountains and their beauty match no other, destroying these lands for development and logging would be detrimental to tourism and the environment. I am an archaeologist who loves to hike in nature and protect lands. Land is already being destroyed and developed on in many other places in the state, including where I live now. To see my refuge be affected by greedy corporations who want land and money hurts my heart greatly. Protect these lands, the diversity they hold and the emotional significance to millions of people. I recently went hiking in the Linville Gorge and visited the falls, it was amazingly beautiful and refreshing. After many trails were affected by Hurricane Helene and have only recently been reopened the revenue lost for those years will only grow if land is taken. I first hiked in the Appalachian mountains and I wish to take my kids there for their first hikes. I need them to experience the beauty of one of the oldest mountain ranges in the world in its natural state not in capitalistic infrastructure the exudes greed. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Mineral extraction, oil and gas development, and associated infrastructure permanently industrialize otherwise undeveloped landscapes. Roadless areas store carbon, buffer temperature extremes, and provide intact refugia where species can shift in response to a warming climate. DEIS Regional Carbon Accounting Omits a Forest Service Region and Drops the Source's Own Attribution of the National Forest System Sink The Draft EIS's National Forest System carbon baseline misstates the source it cites, in two respects that appear within a single sentence and that the source itself resolves. At Volume I, page 74 (Alternative 3 – Modified Roadless Rule/IRA Boundaries, Potentially Affected Environment, Forest Vegetation), the Draft EIS states: "In 2021, forested lands within the national forest system sequestered 43.5 million metric tons (MMT) CO2, which follows national trends of increasing forest biomass in recent decades, however forests in the drier and more fire prone Intermountain, Rocky Mountain, Northern, and Southwestern Forest Service regions had net carbon loss (31.5 MMT CO2) while the remaining regions had a net carbon increase, sequestering 63.5 MMT CO2 (Domke et al. 2023)." First, the sentence's components do not produce its own total. A net loss of 31.5 MMT set against a net gain of 63.5 MMT yields a net sink of 32.0 MMT, not the 43.5 MMT the same sentence reports. The source shows where the discrepancy comes from. Domke et al. 2023, table 3 ("Carbon stock changes (net flux) from forest land remaining forest land within the National Forest System (NFS) by NFS region and year (MMT CO2 Eq.)"), gives 2021 net flux for all nine National Forest System regions. The four regions the Draft EIS names as net-loss regions are the four with positive values — Intermountain 11.5, Rocky Mountain 12.2, Southwestern 6.9, and Northern 0.9 — which sum to 31.5, the figure the Draft EIS reports correctly. The remaining five regions are Alaska (4.0), Eastern (11.5), Pacific Northwest (28.3), Pacific Southwest (5.7), and Southern (25.5), which sum to 75.0 MMT of net uptake, not 63.5. The Draft EIS's 63.5 is 75.0 less the Eastern Region's 11.5: the Eastern Region has been dropped from the uptake side while the total continues to include it. Restoring it reconciles the sentence, because 75.0 less 31.5 is 43.5, which is table 3's own net line for 2021. Both are factual corrections within the meaning of 7 CFR 1b.7(f)(2)(v), and under 7 CFR 1b.7(f)(3) the agency should cite where in the Final EIS each correction is accounted for. The issue is substantive under 7 CFR 1b.11(a)(53) because it bears on compliance with applicable laws: an agency may not rest an environmental analysis on a characterization that the record it chose to rely on contradicts. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A). Domke et al. 2023 is a Forest Service publication cited in the Draft EIS's own literature cited section, so these corrections require nothing of the agency beyond agreement with its own source.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking and camping is one of the most important and meaningful ways my family and I connect to each other, decompress from the stresses of life, and find joy in living. Places like Seneca Creek and the Dolly Sods Roaring Plain in the Monongahela National Forest are within driving distance of our home in Maryland. It is a place my family has been and a forest I look forward to further exploring with my family. It disturbs me to my core to think this forest could be stripped of its wilderness, chopped down, habitats of living creatures paved over, polluted with runoff from roads, and the dark starry night skies blotted out with light pollution. This land belongs to the people of the United States, and I say this is NOT what I want done to my land. These places give my life meaning. They give my family connection. To spend time in the presence of roadless wilderness is one of the most awe-inspiring human experiences. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I ask that it be entered and addressed in full on the record. The Monongahela's 20 inventoried roadless areas total 174,885 acres and protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C. Seneca Creek alone covers 22,287 acres. The Dolly Sods Roaring Plain covers 13,392 acres. These are not abstract statistics. They are the places where my family breathes. The ecosystems at Dolly Sods are spruce-bog remnants more reminiscent of northern Canada than West Virginia, relics of the last ice age clinging to the highest ridges. The Monongahela shelters the West Virginia northern flying squirrel, the Cheat Mountain salamander, the snowshoe hare, the northern long-eared bat, and the red spruce. Road access will not leave any of this intact. It will open these irreplaceable places to being gutted by logging industries and other industrial uses. Why should my generation and the next be robbed of the very few remaining intact forests left in this country? The agency says the rule's permitting burden justifies rescission. But the rule already provides for what the agency claims it cannot do. It generally banned road building subject to limited exceptions including: the preservation of "reserved or outstanding rights" or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The agency has not shown which specific burdens those existing exceptions fail to address. I ask that the agency identify which specific burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those burdens with specificity. Across the Eastern region, which includes West Virginia, 286 municipal water intakes sit in watersheds containing affected roadless areas. West Virginia alone holds 25 inventoried roadless areas totaling 195,455 acres. My family, driving from Maryland to reach these forests, is among the users whose reasonable expectations were shaped by two decades of the rule's protections. 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. That is not a procedural footnote. It is a legal deficiency. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Finally, the agency's own fire data undermines a core justification for rescission. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The agency claims new road access will reduce wildfire hazard. Its own numbers say the opposite. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire risk before this proposal advances another step. Keep the Roadless Rule. Protect Seneca Creek, the Dolly Sods Roaring Plain, and the Monongahela National Forest. Let all 58.3 million acres of wild National Forests remain intact, wild, beautiful, and the absolute American priceless treasure that they are to all living creatures. Sincerely, Rachel Smith Baltimore, Maryland

Re: Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket # FS-2025-0001 / RIN 0596-AD66) Dear Mr. Schultz, I'm a professional photography guide who has spent fifteen years taking paying clients into backcountry protected by the 2001 Roadless Area Conservation Rule. I respectfully ask the Department to reconsider the proposed rescission. My work spans national forests nationwide, but Washington State shows what's at stake. I've watched the sunrise from Suntop in the Mt. Baker-Snoqualmie National Forest countless times, photographed the stars from its ridges, and shared that peace with clients. Once a road goes in, that character is lost for generations. My opposition rests on conditions in places like Suntop and on deficiencies in the Draft Environmental Impact Statement (DEIS). 1. Clean Water Act Section 404 Deficiencies The Suntop Inventoried Roadless Area (IRA) contains jurisdictional waters of the United States, including stream channels and wetlands subject to Section 404 permitting. Every road stream crossing places fill material (culverts, bridge footings, approach fills) into these waters, a Section 404 discharge. The DEIS must disclose the number and location of jurisdictional waters in the Suntop IRA, quantify fill discharges at each potential crossing, and document the Section 404 permitting pathway for each. Deferring CWA impacts to site-specific analysis is not adequate when the programmatic decision itself changes watershed protection status. 2. DEIS Materially Alters the 2020 Alaska FEIS Fish Habitat Finding At page 318 (Appendix 4), the DEIS states: "The 2020 FEIS evaluated effects to fish habitat and found that there would be overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy (page 3-138)." The page cite is right, but the text is altered. The 2020 FEIS reads: "Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including the riparian management strategy, and the lack of old-growth harvest or associated road construction allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas." Three material alterations: It deletes the third ground entirely: no old-growth harvest or road construction in T77 watersheds and Conservation Priority Areas, the only constraint on roads in high-value salmon watersheds. It deletes "LUDs." LUDs allocate management prescriptions; standards condition activity. They are distinct protections. It substitutes "whether the Roadless Rule is in place or not" for "under all alternatives." The 2020 FEIS noted protective differences among alternatives for these waters. At page 243, the DEIS repeats this conclusion without attribution, presenting it as its own finding. Yet the same page states: "Roads pose the greatest risk to fish resources on the Tongass, partly because they pose the largest risk of management-caused sediment input to streams." The DEIS can't name road sediment the greatest risk while resting a minimal-effects conclusion on protections stripped of the road ban in high-value watersheds. Appendix 4 discloses that the Tongass Plan Revision will consider alternatives without IRA designations, so the DEIS relies on a finding predicated on protections this rulemaking removes. Requested Actions Under 7 CFR 1b.7(f)(2)(v) and 1b.7(f)(3), I request that the Forest Service: Correct the restatements at pages 318 and 243 to reproduce the full 2020 FEIS basis, including Forest Plan LUDs and the T77/Conservation Priority Area prohibition, and restore "under all alternatives." Supply attribution and a page citation at page 243. Supplement the Tongass aquatic analysis under 7 CFR 1b.7(f)(2)(iii) to state whether "minimal effects" holds without the T77/Conservation Priority Area restrictions, with a road-mileage and stream-crossing basis. These are programmatic questions that can't be deferred. A conclusion without record support fails NEPA's hard-look requirement. (See Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002).) The 2001 Roadless Rule has withstood a quarter-century of litigation, review, and administration changes. That durability warrants leaving it in place. Please abandon this proposed rescission. Sincerely, Toby

Dear Tom Schultz, I have traveled to Idaho to explore and appreciate the Smoky and Pioneer mountains every summer. I honestly don't know if I've encountered another high desert mountain terrain with as much beauty as these regions. The immense amount of species diversity and varying ecological landscapes are astounding and stunning and rely on protections such as the Roadless act to remain intact. Multiple nights spent dispersed camping with no sound but trickling creeks or rustling leaves, hikes spent IDing bird species I've not once encountered anywhere close to a road or civilization, hillsides full of high elevation blooms just thriving and making the air honey-scented. Stunning trout lazily swimming near the edges of glacial lakes that looked like jewels. All of these moments rely on these mountains remaining wild and protected. The Draft EIS's treatment of roadless-area wildlife habitat has real consequences for places like these “Species Count Not Reconciled to the Biological Assessment; Record Study on Species Representation Not Engaged The Draft EIS states (pp. 141, 168) that inventoried roadless areas provide habitat for "more than 300" threatened, endangered, and proposed species, per the "most recent USFWS and NMFS data." It gives no exact count, date, or cross-reference. The Draft Biological Assessment discloses its method — IRA shapefiles run through IPaC for the FWS list, NMFS species compiled from consultation records, both lists vetted by Forest Service staff and sent to the Services in September–October 2025, occurrence data from GBIF and NRM (BA p. 25) — but reports counts only by taxonomic group (e.g., 30 candidate bird species, 4 removed, 26 remaining, BA p. 161) and states no total. The BA also warns its databases do not differentiate between DPSs, "causing potential inflation" (p. 25). The "more than 300" figure cannot be traced to this method, and it is unclear whether it double-counts distinct population segments. Request 1: Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count, the date it reflects, whether DPSs are counted separately, and cross-reference the BA's Species Lists section wherever the figure appears — citing the correction per 7 CFR 1b.7(f)(3). Second, the figure does no analytical work. It appears only as background and is never tied to an effects conclusion — even though the same page states fragmentation reduces biodiversity 13–75% (Haddad et al. 2015), with effects "greatest in the smallest and most isolated fragments." The record already supplies the missing link: Dietz et al., "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species" (2021), is in the Draft EIS's own reference list, cited in Vol. III (p. 37 n.201), and discussed at length in both the eight-state AG letter (Vol. III pp. 38–39) and the joint Tribal letter (Vol. III p. 498). Its finding: of 537 vulnerable terrestrial vertebrate species, 308 (57%) have suitable habitat in roadless areas — despite roadless areas covering only 2% of the contiguous U.S. — every roadless area holds habitat for at least two such species, and 81% of roadless acreage is suitable for at least five. Because this study is already in the agency's record, 7 CFR 1b.7(f)(2)(iv)'s bar on literature "not previously considered" doesn't apply — the agency need only analyze science it has already adopted. The chain is undisputed: rescission lifts road and timber-cutting prohibitions across the roadless network; the Draft EIS's own fragmentation finding predicts biodiversity loss, worst in small, isolated fragments; and Dietz et al. show this network is the disproportionate habitat base for the nation's vulnerable vertebrates — so shrinking it degrades species representation in the protected-area system. Request 2: Under 7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission's effect on representation of species of conservation concern, using the corrected figure and engaging the Dietz finding — or explain in the response to comments why record science on this point doesn't apply. Both requests are substantive under 7 CFR 1b.11(a)(53): an unreconcilable affected-environment figure and an effects analysis that ignores a record finding are a failure to consider an important aspect of the problem, 5 U.S.C. § 706(2)(A). Both also affect the Section 7 consultation record, which rests on the same unstated baseline (BA p. 25).” Keep roadless areas roadless. Respectfully, CommentID: RLC-20260916-BIKIKN

Dear Ms. Rollins: As an outdoor enthusiast, I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to note that the Department's statutory obligations under the Multiple Use — Sustained Yield Act and the National Forest Management Act require a genuine accounting of the non-commodity values the Rule protects — an accounting that the proposed rescission's record has not provided. I've been lucky to call the PNW home for the last 26 years and the Larch and Gifford Pinchot areas around the Gorge and Mt. Hood mean more to me than can adequately be expressed. I urge to resist the fascistic impulse to acquiesce towards corporations with nothing to offer beyond the carving up of our shared outdoor resources. We live in an area that is still dealing with the impacts of the Celilo Falls destruction. I urge you again to reconsider allowing additional development in an effort to boost the bottom lines of short term corporate interests. Like the falls, once these resources are destroyed we cannot get them back. Regarding the Larch in the Mt. Hood National Forest, Oregon: The threat mechanism classified as 4.1 - Roads & railroads (IUCN-CMP 4.1) is actively degrading habitat for Cascade Torrent Salamander (Rhyacotriton cascadae, G3) in the Larch Inventoried Roadless Area, Mt. Hood National Forest, at Serious - slight severity across Restricted (11-30%) scope. The persistence of Cascade Torrent Salamander in Larch under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 4.1 - Roads & railroads to one that accelerates it. NEPA requires the agency to take a hard look at the effects of rescission on Cascade Torrent Salamander (Rhyacotriton cascadae) in the Larch IRA. The DEIS fails this standard without site-specific analysis of 4.1 - Roads & railroads at the severity and scope documented by NatureServe. "The expansion of road networks degrades the slope stability and further increases the susceptibility to landslides. Deforestation, infrastructure construction, and mining triggered about 16% of fatal landslides from 2004 to 2016. High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians, which means that forests protecting both biodiversity and landslide risks to human society are important conservation targets." — Proceedings of the National Academy of Sciences, 2022 The "No Direct Effect" Framing Is Contradicted by the Assessments' Own "Reasonably Certain" Findings and by the Record The USFWS Biological Assessment frames the action at page 377: "The Forest Service has determined that rescinding the Roadless Rule will have no direct effect on ESA-listed resources because it does not authorize, fund, or carry out future forest management activities." The same document undoes that framing. Page 376: "it is reasonably certain that active forest management and road construction will increase in these areas." Page 24: "it is reasonably certain to occur that there would be an increase in new proposals for uses involving road construction or reconstruction." And the agency's own Tribal Summary Impact Statement records the decisive rejoinder (p. 2): "The Hopi Tribe noted that removing prohibitions, in itself, has an impact." An agency may not deconstruct a programmatic action into harmless paperwork while its own documents find the consequences reasonably certain; reasonably foreseeable effects of removing a prohibition are effects of the action. 42 U.S.C. § 4332(2)(C); Kern v. U.S. Bureau of Land Mgmt., 284 F.3d 1062 (9th Cir. 2002) (programmatic NEPA analysis may not defer all effects); Ocean Advocates v. U.S. Army Corps of Eng'rs, 402 F.3d 846 (9th Cir. 2005). I request the FEIS analyze the reasonably certain increase its own assessments find, rather than resting on the no-direct-effect formulation. The Rule has protected these forests across multiple administrations. I'm asking this one to do the same. Respectfully, CommentID: RLC-20260909-YP9YL1

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Twenty-six years of owning a cabin at Lake Quinault have given me a clear picture of what is at stake in the South Quinault Ridge roadless area and across the Olympic National Forest. The old growth stands of Douglas Fir, Spruce, and Cedar that surround the lake in this temperate rainforest are not abstract policy objects. They are what I return to. Building roads for access into this mountainous terrain will likely increase erosion and degrade water quality and the salmon habitat. I oppose rescission of the 2001 Roadless Area Conservation Rule and file these comments for Docket FS-2025-0001. Public lands should be managed for conservation of old growth stands and water resources, public recreation, and resource use, with balance among these purposes. The Roadless Rule provides that balance. So much of the national forests are already open to development and logging, and what remains of our roadless forests should remain a high priority so future generations can experience them and have the opportunity for quality water sources. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and the South Quinault, and Moonlight Dome areas within the Olympic National Forest represent exactly the irreplaceable country this rule was written to protect. The proposal justifies rescission partly on permitting and administrative burden, but the rule as written already contains flexibility. It generally banned road building subject to limited exceptions, including "the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." I ask the agency to identify which specific burdens fall outside these existing exceptions and quantify them, on the record, before using regulatory burden as a reason for nationwide rescission. The agency is also selling this action as wildfire protection, but its own effects analysis contradicts that framing. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." That is more than seven times the ignition rate on roaded land. The agency must quantify the expected increase in human-caused ignitions resulting from new road access and weigh it explicitly against the claimed reduction in wildfire hazard before that rationale can bear any weight. Its own accounting makes the contradiction worse. The agency's Cost Benefit Analysis Table 4 (p. 30) lists among the qualitative unquantified costs of this proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; agency road maintenance burden." In the benefits column, "reduced wildfire risk" sits among the benefits the agency says it cannot quantify. The promise of fire reduction is unquantifiable; the cost of increased ignition risk is acknowledged but also left unquantified, beside data showing roaded land burns at a far higher human-caused rate. The agency must quantify the net wildfire effect of this action in either direction before wildfire can serve as any justification for it. There are so many existing back-country roads already in disrepair and needing brush clearing, drainage work, and surface repair to make them passable. Our tax dollars would be better spent repairing and maintaining the roads that already exist than building more into country that has none. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Roads and their facilities can produce the overwhelming majority of sediment from a timber sale, and removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities, and growth of coho salmon in what the agency's own materials describe as Essential Fish Habitat and critical habitats managed by NMFS. The South Quinault Ridge stands above a watershed where these consequences are not theoretical. Finally, the agency's stated purpose is to reduce regulatory burden and return decision-making to local officials, not fire management. The overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS itself says the benefits of added fuel-management access "would likely be modest and localized." The agency constructed and then rejected a WUI-targeted alternative that would have addressed the fire rationale without eliminating protection for the remaining 76 percent of affected roadless acres. The agency must explain, in plain terms, why that narrower alternative was set aside in favor of nationwide rescission. Sincerely, Barbara Bailey Tacoma, WA