Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Camping, rafting, and backpacking throughout the West has been part of my entire life. I rely on these places for solitude and the chance to connect with nature, and the proposed rescission of the 2001 Roadless Area Conservation Rule threatens both. I oppose it. The agency's own record undermines the wildfire rationale at the center of this proposal. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding sits in the same document being used to justify opening these areas. The agency must explain how it can cite wildfire management as a reason for rescission while its own analysis documents that road access drives ignition rates upward. I ask that the agency explain why this proposal departs from those prior findings and how it reconciles the rescission with its own conclusions about ignition risk. The ignition data makes the contradiction more precise, not less. The DEIS reports that "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." A ratio that wide is not a rounding error. The places I have spent my life traveling through, camping and backpacking in the backcountry of the West, are precisely the kind of low-ignition environments this data describes. The agency has not explained how new road access into these areas would produce a net improvement in fire conditions. It must quantify the expected increase in human-caused ignitions from new road access and weigh that number honestly against any claimed reduction in wildfire hazard. Access to clean water should be a basic human right. Adding roadways to America's already over-taxed watersheds will do irreparable harm, and the agency's own analysis does not contradict that concern. The DEIS acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The watersheds fed by these roadless areas supply drinking water to millions of people. Opening them to road construction is not a reversible experiment. The agency should explain what safeguards, if any, it has analyzed that would prevent the kind of sediment loading its own documents describe, and it should respond to the water quality implications of this rescission. The regulatory flexibility certification in this rulemaking does not hold up. "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 no-impact conclusion is reached by spreading projected losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. Some of those firms may lose these receipts entirely. Spreading the damage thinly across a national average does not make it disappear for the businesses actually exposed. The agency should withdraw the certification and assess the impact on the specific small entities operating inside the potentially affected roadless areas. Finally, the agency has not fulfilled its own invitation. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. I have organized my outdoor life around the existence of these protected areas. Under established administrative law, an agency reversing a longstanding policy must assess the reliance interests its prior rule created, not merely ask for them and then set them aside. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Kate Lips Salt Lake City, UT

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking and hiking through places like Pyramid in the Lake Tahoe Basin and the Paiute roadless area in Inyo National Forest to commune with nature, watch birds, and observe wildlife, I have come to understand what these landscapes hold. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own analysis does not support the step it is proposing to take. I am an avid backpacker and day hiker who lives in Northern California. I have travelled all over the United States to hike and backpack. The impact of roads and off road vehicles on wildlife, the land and the experience being in the “wilderness” is obvious and depressing. Bird watching is not incidental to why I go into roadless areas. It is a central reason. The agency's own record, drawing on research the DEIS cites, documents 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. California already holds 381 inventoried roadless areas totaling 4,389,760 acres, and the birds I go to find depend on the quiet and the unbroken canopy those areas provide. Opening that landscape to road-building does not simply alter the scenery. It restructures the acoustic and ecological conditions that determine whether those species stay or go. I ask the agency to explain, with specificity, how the benefits it claims from rescission can be weighed against documented declines in bird abundance and species presence that its own cited science predicts. The wildfire rationale the agency offers for this rescission conflicts directly with what its own record says. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The DEIS further reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency must explain why its proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions from new road access weighed against any claimed reduction in wildfire hazard. The regulatory flexibility certification also cannot stand as written. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading expenditure loss across every small firm in the sector nationally rather than examining the guides and outfitters holding permits in the specific affected areas. The agency concedes some firms may lose those receipts. It should withdraw the certification and assess impact on the small entities actually operating in and permitted for the potentially affected roadless areas. The Chugach National Forest in Alaska is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta within it hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration, including western sandpiper in the millions. Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape at a scale that exists nowhere else in the national forest system. The 2001 rule is the structural protection that has kept those conditions intact. A state-petition process substituted for a national rule creates no guarantee that protection continues, and the agency's own record does not model what happens to that ecosystem if the rule falls. Finally, the proposal itself 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 years of hiking, birding, and backpacking in California's roadless areas, and my expectation that federal policy would continue to protect them, are exactly the kind of reliance interests the agency invited and then declined to assess. The agency must identify and weigh those interests as part of this proceeding, including what this comment represents. Sincerely, Kristen Sorensen Petaluma, CA

I oppose the proposal to fully and partially rescind the Roadless Area Conservation Rule. As someone who lives in the Tongass National Forest rescinding the Roadless Rule will greatly negatively impact thousands and that’s just here in Alaska! Rescinding the Roadless Rule will not meaningfully reduce wildfire risk. In fact, it's likely to increase it. - "The proportion of human-caused fires in Roadless areas is less than half. on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads." (pg 86; see Aplet et al. 2026) USFS doesn't have the budget to maintain their existing road infrastructure, much less new ones. - Costs for maintaining roads = $5,000-$50,000 / mile. Costs for building new roads = $80,000 - $2 million / mile, depending on if the road is dirt, gravel, or asphault. (pg 42) - The Forest Service has a $7 billion deferred maintenance backlog, and an estimated $1.6 billion is needed annually to maintain existing roadways. In 2023, the USFS received <20% of this amount for road maintenance. (pg 42) - Less than 30% of NFS roads are in 'good condition' (pg 40) - The DEIS states "...revenue generated by timber sales or other resource extraction activities would be used for some road-related system management but not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." (pg 45) These are just a couple examples of the many why rescinding the Roadless Rule is shortsighted and reckless. The decisions of what happens to our public lands are most often made by those who will never be impacted by their actions and the communities who rely on our public lands. Destroying our forests and public lands for short term gains will be irreversible. Please stop this madness. Concerned Juneau and Tongass National Forest resident.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 We are already seeing what happens when we use too many resources. Let's back off taking from the earth for awhile. Water from national forest country in the Pacific Southwest Region reaches as many as 2,264,400 people downstream, by the agency's own data. My tap may be one of them. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The substance of round one is never answered I commented in the first round, and I have read what the agency says it did with everything we sent. Its own account describes counting, not answering: By the agency's own count, over 220,000 comment letters were received, representing over 625,000 submissions, and approximately 99 percent were generally opposed to the rescission. The DEIS says the comments helped inform the alternatives and identifies no issue that changed anything. Counting comments is not responding to them. I ask that the agency state which substantive issues from the first comment period altered the proposal, and which were rejected and why. Issue 2: Tribal consultation is incomplete and its summary is withheld from comment I commented in the first round and waited to be heard. By the agency's own record, others owed a far more formal hearing are still waiting too: The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analysed; the final impact statement arrives only when comment is closed. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule. Issue 3: Every conservation alternative was eliminated by how the purpose was written I took the time to comment before, and I expected the alternatives to reflect what the public asked for. The agency's own document shows how it wrote every protective option out of consideration: 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 written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full. Issue 4: Reliance interests are invited and never assessed How this reaches me is stated above in my own words, and that is a reliance interest. The agency asked for exactly this and then weighed none of it: 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. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Brenna Geehan San Francisco, CA

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule (the Roadless Rule). I am a resident of Western North Carolina (WNC) where we are privileged to have many rare and wonderful species of plants and animals and pristine natural areas. The rescission of the Roadless Rule would negatively impact humans, plants, and animals in WNC. The Pisgah and Nantahala National Forests are home to many unique and sensitive species of plants and animals. The EPA reports that a preliminary biological assessment found the rescission of the Roadless Rule is likely to adversely affect 327 ESA-listed species and 71 designated critical habitats. One item this administration is championing as a positive reason to rescind the Roadless Rule is mitigation of wildfires. However, findings contradict the need for more roads to mitigate a perceived wildfire threat. The Purpose and Need argues that the 2001 Roadless Rule limited vegetation management and contributed to forest-health problems, but the agency's own Fire and Fuels Management chapter cites research finding that the Roadless Rule did not meaningfully constrain hazardous fuel treatment activities when measured as a share of forested land treated. The document's own cited evidence contradicts the central justification offered for rescinding the rule. The agency’s findings showed, “the 2001 Roadless Rule did not meaningfully constrain hazardous fuel treatment activities when considering the number and area of treatments” (Hazardous Fuel Reduction). In closing, for the reasons I have discussed, fully or partially rescinding the Roadless Area Conservation Rule would not benefit humans by reducing wildfires and would negatively affect plants and animals important to Western North Carolina. Thank you for your time. A Citizen of Watauga County, North Carolina

Clean water matters to me, my kids deserve these vast beautiful lands, and I want to know how my tax money is being spent before it goes to something like this. The agency's fire safety argument does not hold up under its own numbers. The document states, at the Fire Control section, that "With increased road access, initial attack success rates would be expected to increase." But no analysis isolates roads as the cause of any difference in outcomes. The document itself acknowledges that less-than-full suppression is used more often in roadless areas, which makes any direct comparison of initial attack success rates unreliable without controlling for suppression strategy. It also concedes that most new roads expected under rescission would be temporary timber spurs, not strategic fire roads. The agency needs to separate the effect of roads from suppression strategy in its initial attack comparison, and estimate how many fire-useful roads are actually expected given real funding limits. I want a clear answer to that specific question before this rule moves forward. The agency also cannot have it both ways on irreversible harm. The Scope of the Analysis section declares that "An irreversible or irretrievable commitment of resources will not be made by the rulemaking because none of the rulemaking alternatives propose specific actions," yet the same document discloses that rescission is likely to adversely affect 327 ESA-listed species and 71 critical habitats, and that permanent road construction and old-growth removal are reasonably foreseeable. Those are exactly the kinds of irreversible commitments the disclaimer purports to rule out. The Forest Service must reconcile that contradiction directly. This is a horrible priority when we need healthcare, affordable housing, food, and so many other essential services. Do you want kids to grow up without these vast beautiful lands? I don't. The agency should explain, on the record, why rescinding nationwide protections serves the public better than keeping them.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas of western Montana are the foundation of the outdoor life I value. Hiking, rafting, camping, hunting, fishing, and skiing in these places matters to me, and so does the wildlife that depends on them, including the birds that rely on intact, unroaded habitat to survive. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask this agency to answer, in writing, the questions its own analysis leaves open. Start with fire. The agency justifies this rescission partly on wildfire and fuels management grounds, yet its own draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That sentence is in the agency's own record. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to explain, in plain terms, why this proposal departs from its own prior findings, and to reconcile the rescission with the ignition data in that table. Montana holds 235 inventoried roadless areas totaling 6,395,392 acres. These are not abstract figures. These acres produce habitat for the birds and wildlife I described, and they sit inside watersheds that serve 1,287 municipal water intakes across the Northern region. The birds I look for in these places depend on the continuity of that habitat. The agency's own DEIS cites the finding 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 DEIS also cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then disappears. No projection applies it to the 40.1 million acres of potentially affected environment. I ask that the agency close that gap: apply the cited fragmentation range to the full affected acreage and show what it means for bird communities and other wildlife in Montana and beyond. The same omission appears when it comes to hunting. 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." Trails near Wilderness and Wilderness Study Areas in western Montana are places where these dynamics are real, not theoretical. Yet nowhere in the document does the agency project what road-building and increased access would do to elk populations or hunter opportunity at any scale. The agency should provide that projection. Carbon storage is raised and then set aside. 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." The document then concludes that these lands will continue to sequester and store carbon, with no analysis of what harvest and roading under any alternative would actually change. Roughly 0.9 billion metric tons is not a number that can be mentioned and ignored. The agency must quantify the projected change in carbon storage and sequestration under each alternative before this rulemaking moves forward. Protection of these places is critical. The intact ecosystems of western Montana, the trails adjacent to Wilderness and Wilderness Study Areas, the birds and wildlife that use them, all of this is at stake. The agency's own data on fire ignition, fragmentation, elk behavior and carbon storage each point in the same direction, and none of it is reconciled with the decision to rescind the rule. I ask that the agency treat these gaps as the serious analytical failures they are and address each of them fully in any final record of decision. Sincerely, Carla Belski Whitefish, MT

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Roadless areas are very important to me. I could speak to generally how they help create more diverse and wild landscapes everywhere not just in their vicinity. The United States actually still has wild places unlike many other countries. But I will speak to my specific experience within Deep Creek Roadless Area. I hike there for the last 10 years every year. I love how I can not hear vehicles. I would be heartbroken if this place did not exist or if it was destroyed. To even build a single road in this area I am sure would destroy a lot. The waters in the creek are so clean and the hot springs so delicately placed near the creek. All that would be polluted with run off if roads were built. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about Deep Creek (23,869 acres), San Bernardino National Forest, California. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I photograph trees, and my work is part of the recreation economy this document weighs. The agency certifies no impact while the analysis beside it says otherwise: 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 supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Foreseeable plan amendments are placed beyond scope I photograph landscapes, and every frame depends on what the management plans allow next. The agency concedes where this leads and then declares it out of scope: 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). The agency is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. Issue 3: Reliance interests are invited and never assessed I photograph wildlife, and years of that work are built on these protections holding. That is a reliance interest, and the agency invited me to name it: 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. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 4: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. 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 effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Katherine Bauer Corona Del Mar, California

I oppose rescinding the roadless rule on the grounds that it would increasing the risk of wildfire in this country. In a study published in the journal Fire Ecology in January of 2026, scientists analyzed 32 years of data from across all U.S. forest regions and found that areas within 50 meters of roads were four times more likely to catch fire than areas that were roadless. It stands to reason, then, that building more roads into forests will increase wildfires. Wildfires not only harm the biodiversity living in our national forests, they put more carbon dioxide into the air, speeding up climate change. They also fill the air of cities and towns with smoke, endangering the health of U.S. citizens, and especially vulnerable people, such as myself. At a time when fire crews are tasked to their limits and barely able to contain the fires that have already been on the increase each fire season, rescinding this rule poses a grave threat to our country. I am citing the following study as evidence: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 I would also like to submit the following additional evidence: Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates 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.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mountain biking and camping with my family in the Mt. Hood National Forest is not an abstract interest. I ride the Forest Road 44 trails. My kids come with me. That is the ground this comment stands on, and it is the ground this proposal puts at risk. The agency's own data on road infrastructure should stop this proposal before it starts. The Forest Service is already billions of dollars behind on maintaining the roads it has. Building new roads into country that currently has none compounds a maintenance burden the agency has not come close to meeting. The sensible course is to focus resources on improving current infrastructure, not extending it into areas that are still intact. I ask that the agency explain on the record why adding new road miles is justified when the backlog on existing roads remains unaddressed. Roadless watersheds feed the water supply for an enormous number of Americans, and the Forest Service's own analysis acknowledges that roads and their associated facilities can produce the large majority of sediment from a timber operation. Clean water is the best legacy we can leave the next generation. I want my kids to inherit that, and I want the agency to answer directly whether the sediment risk from new road construction in these watersheds has been weighed against whatever timber or resource benefit is claimed. The regulatory flexibility certification in this proposal does not hold up against what the supporting documents actually say. "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 the projected expenditure loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not an assessment; it is an average used to obscure a real impact. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The proposal also invites public comment on reliance interests and then does nothing with them. "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." Families who have organized their recreation around roadless protections, outfitters who have built permit-dependent businesses under the existing rule, and communities whose water comes from these watersheds have all relied on the 2001 rule across more than two decades. Soliciting those interests and then leaving them unweighed in the economic analysis is not a lawful change of course. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. On fire, the agency's own numbers argue 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 effects analysis itself concedes that road access could increase the number and frequency of wildfires. Opening these areas to road construction would move the ignition density inside them toward the much higher rate observed on roaded land. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this proposal can proceed. Finally, the proposal treats the most consequential downstream effects as outside its scope while simultaneously asking the public to comment on them. "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)." Rescinding the rule without analyzing what plan amendments will follow is analyzing only half the action. The foreseeable plan-amendment scenario, including expanded timber harvest area, belongs inside this analysis, not deferred to a later process the public cannot yet reach. The Forest Road 44 trails, the watershed those forests feed, and the country I want my children to know the way I know it are what is actually at stake. The 2001 rule should stand. Sincerely, Emily Martin Hood River, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Green Mountains of Vermont and the White Mountains of New Hampshire are where I find exercise, tranquility, and connection to nature and the hiking community. I go there often, and what I find in those places, the wildness, the quiet, the beauty that belongs to all people, is exactly what this proposal would put at risk. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the docket record. Vermont holds 6 inventoried roadless areas totaling 25,096 acres. Those acres represent something that cannot be rebuilt once it is paved over. Public land should be managed for all people and protected so that the wild and beautiful spaces it contains remain available for everyone to enjoy. Rescinding the rule moves in the opposite direction, converting a national protection into a state-by-state patchwork where those spaces are only as safe as the next administrative decision. I ask that the agency address directly, in its final analysis, how rescission serves the public interest in retaining these spaces in their current condition. The agency's own fire data undercuts the case for opening these areas to road construction. The DEIS states that "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." These numbers do not support the suggestion that new roads reduce fire risk. They suggest the opposite. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that figure honestly against whatever wildfire hazard reduction the proposal claims. The fiscal argument for this rescission is equally hard to square with reality. We already struggle to maintain the roads and infrastructure we have, and money should go into improving those rather than paving over nature. The agency is $6.9 billion behind on maintaining the roads it already operates, on a road budget of about $73 million a year. Building new roads into country that currently has none, under those conditions, is not a maintenance solution. It creates a new liability. The agency should explain, plainly and specifically, how it intends to fund the long-term upkeep of any roads built in areas currently protected by this rule. The regulatory flexibility analysis does not survive scrutiny. "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." That conclusion is reached by spreading losses across every small firm in the sector nationally, rather than looking at the guides and outfitters who actually hold permits in the affected areas. The Eastern region, which includes Vermont, has 286 municipal water intakes sitting in watersheds that contain affected roadless areas, and the communities and businesses that depend on those watersheds deserve an honest local accounting, not a national average. The agency should withdraw the no-impact certification and assess the actual small entities operating in these specific areas. The alternatives analysis is compromised at its foundation. "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose statement written to mandate deregulation cannot produce a genuine comparison of alternatives. NEPA requires that comparison, and framing the purpose around executive orders rather than forest conditions forecloses it before the analysis begins. The agency should restate the purpose and need in terms grounded in actual resource conditions and carry at least one genuinely protective alternative through a full effects analysis. Finally, the proposal invites reliance interests and then ignores them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is exactly such an interest. The 2001 rule has shaped how hikers, outfitters, water utilities, and communities have planned and invested for years. An agency changing course must assess those interests, not merely invite them. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas buffering the Kalmiopsis and Rogue River Wilderness areas are not abstractions to me. I hike and recreate each year in the North and South Kalmiopsis wilderness areas, the Red Buttes Wilderness, the Siskiyou Wilderness, Siskiyou National Monument, and the Rogue River Wilderness. These are unique ecosystems that support threatened salmonid species, the threatened northern spotted owl, and endemic plant fauna not found anywhere else. I believe these areas are worth protecting, and I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I bird for northern spotted owls in the Rogue Siskiyou National Forest. The agency's own draft environmental impact statement is not silent on what roads do to birds. The DEIS cites the 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.). The agency has never explained, in this rulemaking, how it expects bird communities to absorb what its own cited science says they cannot. I ask the agency to reconcile its rescission proposal with those cited findings about road noise and bird abundance before this record closes. Late successional forest reserves provide clean drinking water to my rural community, and locally we use our surface waters for crop irrigation, swimming, fishing, and fresh drinking water. These beneficial uses are more valuable than gold. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. When these resources are lost, the cost and effort needed to restore them grows significantly. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. That number sits in the record. What the record does not contain is any honest accounting of what that sediment loading means for the 1,522 intakes downstream in this region alone. I want that accounting provided. The wildfire rationale offered for this rescission is the point where the agency's case collapses against its own findings. 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." I raised wildfire resiliency and clean water in my previous comment on this proposal, and I have received no response. The agency must explain on the record why this proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and 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. This proposal also ignores a legal history the agency knows well. The record shows that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency has been here before. A state-by-state approach was tried. The Ninth Circuit addressed what came of it. The agency must explain how this proposal avoids those same deficiencies and must address its own prior finding that local and incremental decision-making can erode nationally significant roadless values over time. Surrendering public lands to resource extraction means losing the small remaining untouched wild areas left in the West. 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. Opening these lands for private resource extraction is stealing our common resources. I want my kids and future generations to be able to enjoy these areas, to test their resolve through recreation, and to benefit from clean water and air. Has the Forest Service considered the substantial science behind wildfire resiliency and water protection that supports keeping these wild areas intact? That question belongs in this record, and this letter demands an answer. Sincerely, Bryan Duggan Coos Bay, Oregon

I am writing to oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I work for the National Park Service and have worked in, recreated in, and enjoyed the benefits of roadless wilderness areas my entire life. With that said, wild places are valuable for many reasons beyond the personal benefits they've provided to my life. They're the watersheds for our rivers and the water we drink, the lungs of our planet, and the homes of species that have inherent value simply by sharing this country with us. The value of wild places is that they are for everyone, and that they belong to no one. In his book "Desert Solitaire", Edward Abbey wrote, "We can't have wilderness without freedom." I would argue that the opposite is also true: we can't have freedom without wilderness. Rescinding the 2001 Roadless Rule will have an irreversible and massive impact on our country. The argument proposed for rescinding or altering the Roadless Rule is ostensibly for wildfire prevention. To be frank and use contemporary slang, this reason is very much "concern trolling." The predominant cause of wildfires is human activity. A recently published study by Aplet et al. (2026) found that wildfire-ignition density is lowest in wilderness areas, while the highest ignition density occurred in lands within 50 meters of roads. This study found that areas within 164 ft (50 meters) of a forest road are as much as four times more likely than roadless areas to see fire ignitions. Another study has found that 90% of wildfires are ignited within a quarter of a mile of a road (Morrison, 2007). The Roadless Rule already includes explicit provisions for fire suppression actions and road construction in cases of imminent threat. Another argument proposed for ending or modifying the Roadless Rule is timber extraction. The US Forest Service is already the largest road management jurisdiction agency on earth, with some 370,000 miles of existing roads to maintain. Less than 30% of these roads are in good condition according to the Forest Service's own Draft Environmental Impact Statement (p.40), and the USFS is already burdened with $7 billion in deferred maintenance. Creating new roads would cost the USFS more money than timber extraction would be able to recoup. Timber extraction is a $300 million industry, which includes plantations that are far easier and less costly to harvest. Meanwhile, the outdoor recreation industry is worth a gargantuan $13.5 billion per year, according to the latest assessments, which brings immense benefits to local communities. Maintaining healthy roadless wildernesses for Americans who engage in this industry is worth far more to the American economy than timber extraction. Establishing roads in roadless public lands--some of the most high quality habitat in the U.S.--would also have cascading impacts on the ecosystem services that wilderness areas provide. Sediment from the construction of roads in these areas would pollute and overwhelm the watersheds that these areas support. Tire wear particles from vehicles would pollute streams near roads, and carry toxins which bioaccumulate in fishes like salmon and trout (which sustain and are consumed by both people and other species). Roadless areas supply clean water to millions of Americans; construction can irreversibly damage this service. If roadless protections are reversed or diminished, species that require these areas will see myriad impacts. Road ecology research has shown that animals from antelope to salmon are losing their ability to migrate due to road traffic, noise, and fencing; invasive plants hitch rides in tire treads and spread to previously uncolonized areas; road salt contaminates lakes and rivers; and vehicle noise sends songbirds and mammals fleeing even from significant distances due to their sensitivity to the sounds of human activities (Goldfarb, 2023). For the above reasons, I am truly baffled by the decision to rescind the Roadless Rule, and I strongly urge the Department of Agriculture to examine the decades of road ecology, fire ecology, water ecology, and sound ecology research that supports the existence of roadless areas. I am an ardent fan of wilderness areas and a public servant that has worked to protect them for the benefit of all Americans. Rescinding this rule is short-sighted and actively harms both Americans and the habitats that sustain us. References Aplet, G.H., Hartger, P. & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8. https://doi.org/10.1186/s42408-026-00450-2 Goldfarb, B. (2023). Crossings: How Road Ecology Is Shaping the Future of Our Planet. W.W. Norton & Co. Morrison, P.H. (2007). Roads and Wildfires. Pacific Biodiversity Institute, Winthrop, Washington. 40 p. 2001 Roadless Rule Rescission_Proposed Rule_Draft EIS Volume I. https://www.regulations.gov/document/FS-2025-0001-224064

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The public lands belong to all of us, and I want this pristine nature to remain as is. The proposed rescission of the 2001 Roadless Area Conservation Rule moves in exactly the opposite direction, and the environmental review supporting it is legally and analytically deficient in ways the agency must address before proceeding. The most fundamental problem is that the entire analysis was structured to eliminate protective outcomes before they could be considered. Alternatives with more protection were dismissed as not responsive to 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." NEPA does not permit an agency to write its purpose as deregulation and then discard alternatives because they protect too much. The comparison NEPA requires cannot happen when the thumb is on the scale from the first sentence. I ask that the agency restate the purpose and need in terms of actual forest conditions and analyze at least one fully protective alternative on its merits. The wildfire rationale the agency has used in public discussion does not hold up against the agency's own numbers, and it is not even the stated legal basis for the action. 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 constructed a WUI-targeted alternative that would have addressed fire concerns without eliminating protections across the entire inventoried roadless system, and then rejected it. Nationwide rescission is a far broader instrument than the fire problem, even as the agency describes it, could justify. Why was the WUI-targeted alternative the agency built discarded in favor of eliminating the rule entirely? The agency's treatment of the rule's exception provisions compounds these problems. The 2001 rule's exceptions were expected to be infrequent by design; their infrequent use is now offered as evidence of failure, in a document that concedes "the rule's intent for infrequent use." A safety valve that operates as designed is not broken. Citing its own intended operation as a reason to dismantle the underlying rule is circular, and the agency cannot use that reasoning to meet its burden of reasoned decision-making. The agency should publish the counts of exception requests, approvals, denials and processing times so the public and reviewing courts can evaluate whether any genuine operational problem exists. Taken together, these defects describe a process that began with a conclusion and worked backward. The deregulatory purpose foreclosed protective alternatives. The fire rationale is simultaneously overstated and not the legal basis for the action. The exception record that might support a finding of failure has not been disclosed. None of this satisfies the agency's obligations under NEPA or the Administrative Procedure Act, and none of it gives the public a fair opportunity to comment on a record that actually supports the decision being made. I want this pristine nature to remain as is. The 2001 Roadless Area Conservation Rule has provided the framework for doing exactly that. Rescinding it without a lawful, complete environmental review is not a legitimate path forward. Sincerely, Mike Kennett, PA

I oppose the rescission of the Roadless Area Conservation Rule and request that it be abandoned forthwith as a waste of taxpayer dollars, a dangerous flouting of established wildfire and water science, and a top-down, anti-democratic, anti-local forcing through of something that was overwhelmingly opposed at the NOI stage. I also protest the inadequate process surrounding the proposed rescission; if the rescission is not abandoned, the process must be corrected. Regarding process, the 2001 Roadless Area Conservation Rule received extraordinary public input, largely positive, through 2 60-day comment periods and over 600 public meetings drawing over 23,000 participants. This rescission proposal initially allowed only a 21-day comment period on the NOI and a 30-day comment period on the DEIS, inadequate to a broad rule that affects nearly 45 million acres all across the nation. Even with the DEIS comment extension, the total comment period is little half that of the original rule. If the rescission is not abandoned, the comment period should be extended another 45 days and it should include at least one meeting per forest—half of what was provided for the original rule. Communities surrounding the forests should have every opportunity to state their opinions and share the likely impact on their livelihoods and lifestyles. Also, although the USDA correctly determined that Tribal consultation is warranted by the proposal, it has held fewer than half of the requested consultations, per the TSIS has held no consultations since the DEIS has been released, and it misconstrued what consultation means. Sending line officers without decision-making power to record opinions before alternatives have been publicized is not the same as decision-makers meeting with Tribes regarding the actual impacts of proposed alternatives. The TSIS nonetheless shows that the majority of Tribes oppose the rescission, and yet this rescission is being forced through. Furthermore, alternatives proposed by Tribes were not analyzed in detail. If this rescission is not abandoned, government-to-government consultation should be correctly held with the requesting Tribes, a Tribally-proposed alternative should be analyzed in a supplemental DEIS, and an updated Tribal Summary Impact Statement should be issued for comment before the final rule. As for the impacts of the rule itself, as a tax-payer I am infuriated that the enormous backlog of deferred maintenance on current Forest Service roads is being passed over in favor of building new roads in areas that, if they were easy to build roads in, would already have them. I have recently traveled Forest Service roads in Mendocino National Forest, where my companions and I had to navigate a landslide and a washout. While fire trucks might have been able to navigate the landslide, after a delay for digging it out, the washout was barely navigable in a passenger vehicle. In the best case trying to get engines through there would have delayed fire response by forcing the engines to be rerouted; in the worst case it could have caused injuries or even deaths to our firefighters. Rather than attempt to build new roads, the backlog should be better funded and roads should be prioritized for repair according to their impact on public safety. Adding insult to potential injury, timber sales from areas newly opened to logging are unlikely to pay for themselves or the roads; essentially, they are a corporate giveaway. The rescission will not, as claimed, make it easier to manage fire in forests. I have seen fuels management in Caples Creek, one of my favorite inventoried roadless area, that successfully protected the area from the massive, severe Caldor Fire 2 years later, and the DEIS acknowledges that the 2001 Roadless Rule does not "meaningfully constrain hazardous fuel treatment activities". It also acknowledges that IRAs have far fewer ignitions than roaded lands. In other words, rescinding the rule—according to the DEIS—can be expected to increase ignitions without improving fuels management. Firefighters themselves state that in rugged areas air support is preferable to trying to get engines in, and point to delays caused by poorly maintained roads. More roads will not make this better. Adding more roads also decreases water quality at a time when fresh, clean water is of utmost importance and in short supply. Roads increase erosion and sediment, while maintaining forests captures sediment. Turbidity is a major, costly problem for downstream water users, who have to bear the indirect costs of the new roads. The DEIS barely addresses this impact other than to say that it likely exists. There are far more reasons to oppose rescinding a rule that preserves our forests and clean water for the generations to come. The rescission should be abandoned and our taxpayer dollars used for something useful like restoring the many fire fighter support personnel who have left the Forest Service.

These parks have to be protected. That is the simplest way I can put it. I bartend for a living, and I exist in a climate where the people and the world around me are struggling. People I know get away to these places and come back healed from the grind. That matters. And my tax money should not be going toward dismantling the protections that make it possible. The agency's own data undermine the case for rescission before the argument even gets started. The document states that existing land management plans already "Further restrict (do not allow or generally do not allow) timber harvest on 26.7 million acres (66.5 percent of the potentially affected IRAs)" in the Potentially Affected Environment section. If two thirds of this acreage is already off limits under plan direction that survives rescission regardless of what happens to the national rule, the Forest Service has not shown that eliminating the 2001 Roadless Rule actually delivers the forest-health and timber benefits it is claiming. The agency should quantify what rescission adds beyond those existing plan restrictions before relying on those benefits as justification, and I want a clear response to that gap in the analysis. The historical harvest numbers make the promised benefits even harder to credit. The agency's own activity data, described in the Vegetation and Forest Management section, show that "timber harvest within the potentially affected IRAs was completed on approximately 500 acres per year, on average, with volume harvest levels inconsequential to overall nationwide" supply, across the full 44.7 million acres the rule covers. If the land has produced inconsequential harvest volume for over two decades, the claim that roadless prohibitions are driving a national timber-supply or forest-health crisis does not hold together. The Forest Service should explain with actual data how opening land with that track record will now produce the meaningful benefits the agency describes. The fire control argument deserves the same scrutiny. The Fire Control section of the document asserts that "With increased road access, initial attack success rates would be expected to increase." But the document's own comparison between roadless and other forest land ignores that less-than-full suppression strategy is used more often in roadless areas, and the document acknowledges that most new roads built under rescission are expected to be temporary timber spurs rather than strategic fire roads. No analysis in the document isolates the effect of roads from the effect of suppression strategy. I want the agency to separate those two variables in its initial attack comparison and estimate how many fire-useful roads are actually expected to result, given real funding constraints. My money and everyone else's water and the places people I know rely on to recover from the grind are all tied up in this decision. The least the agency owes the public is analysis that actually supports its conclusions.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The birds I chase through binoculars at Pictured Rocks National Lakeshore, the frogs and salamanders I crouch down to identify at the water's edge, the flowers and mushrooms I photograph whenever something catches my eye: these are not abstractions. They are what I go outside for, and they depend on the places this rule has protected. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be weighed in Docket FS-2025-0001. Public land should be managed for the general public, not the one percent that will benefit from opening these areas to roads and extraction. This country was built by the people, for the people, and that principle is exactly what the Roadless Rule has been honoring for more than two decades. Rescinding it now, without a single public meeting and without the kind of deliberate rulemaking that produced more than 600 public meetings and 1.6 million comments, hands irreplaceable terrain to interests that have not earned it. Trees that have been growing for hundreds of years in some of these forests do not just come back when we realize we made a mistake. Our kids should have more than we have, not less, and they should not inherit the consequences of a decision made for a quick buck. The birdwatching I do matters here in a way the agency has documented and then ignored. The DEIS cites the finding 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. If roads enter these areas, the birds I go looking for will retreat or disappear from them. The agency has quantified that harm and built no serious response to it into this proposal. I ask that the agency explain, specifically, how it reconciles its own cited findings on bird abundance and species avoidance with a rule that invites new road construction into the last unroaded third of the national forests. The water question is just as direct. I love doing anything in the water, from paddle boarding and kayaking to swimming, and knowing that roads and the logging they enable will take such a massive toll on water quality makes me profoundly sad. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and fewer than 12 percent of the watersheds fed by these roadless areas have impaired streams today. That is a condition worth protecting, not gambling away. The agency must explain on the record what it expects to happen to those watersheds and the people downstream when that sediment load arrives. The road maintenance math does not help the agency's case either. There is already a reported backlog of maintenance on existing roads, and a road budget that cannot close that gap. These roads are not being proposed for accessibility. They should not be added when existing infrastructure cannot be kept up, and the people actually operating businesses in these areas will bear real costs. 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. That contradiction cannot stand. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The fire record cuts the same direction. 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 owes the public a quantified projection of what new road access will do to that ignition rate, weighed honestly against any claimed reduction in wildfire hazard. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have organized my recreation, my birdwatching, my photography, and my expectations around places that have been protected for more than two decades. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet no projection across the 40.1 million acres of potentially affected environment follows from that number. Citing a range and declining to apply it is not analysis. The agency should apply the cited fragmentation range to the 40.1 million acres and show its work. Sincerely, A concerned citizen, Ann Arbor, Michigan

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless areas have been a critical part of my life. I have hiked, camped, and backpacked in them across the Midwest, Southwest, Rockies, and West Coast. I paddle as far away as I can get from crowds, industrial noise, logging scars, and other effects of roads. That experience is not incidental to who I am, and I want my child to have that option. Rescinding the 2001 Roadless Area Conservation Rule would foreclose it. I oppose this proposal and ask that the agency address the following points in the record. The agency's own fire data does not support the direction it is moving. "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 contrast is striking. The DEIS concedes that road access could increase the number and frequency of wildfires, yet no estimate of the expected increase in ignitions from new road construction is placed alongside the claimed reduction in wildfire hazard. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it plainly against the claimed wildfire benefit. The fragmentation problem is named but never applied. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then disappears. No projection across the 40.1 million acres of potentially affected environment follows from it. A number cited and then set aside is not analysis. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment before this proposal advances further. I also cannot accept the agency's certification that this rule would have no significant impact on small businesses. "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 supporting analysis reaches its no-impact conclusion by averaging losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the areas that would be opened to roads. The analysis itself concedes some firms may lose these receipts. That is not a finding of no significant impact; it is a finding that impact is hidden by averaging. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. My reliance on these areas is the kind of interest the agency invited and has not weighed. "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 have built my outdoor life around these places in the expectation that they would remain protected. My child's opportunity to do the same rests on the same assumption. The agency asked for these interests and then did not account for them. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Finally, I would not want my tax dollars wasted on new roads in these areas under any circumstances, but the fiscal case against this proposal is especially clear. The agency is already billions of dollars behind on maintaining the roads it has. Building new roads into country that currently has none compounds a deficit the agency has no realistic plan to close. The rule the agency proposes to rescind was developed through more than 600 public meetings and 1.6 million public comments. No comparable public process has been held to undo it. These are the last unroaded third of the national forests. A logged stand can grow back. A road does not. The agency has not explained why the public should accept that loss without the same opportunity to be heard that produced the original rule. Sincerely, David Clark Berkeley, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I raised my boys in the Pisgah National Forest. I taught them to love and cherish our beautiful planet there, and we returned numerous times each year for rest, recreation, and to appreciate what North Carolina holds. Many days and nights spent camping in that area have been incredibly special to my family. I sincerely hope these places will be preserved for future families. That hope is why I am filing this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. The Pisgah holds 18 inventoried roadless areas totaling 99,369 acres, including places like Linville Gorge, where the last wild headwaters of rivers flowing to both the Atlantic and the Gulf begin, and where more than 30 endemic salamander species, black bear, hellbender, brook trout, cerulean warbler, and the northern long-eared bat live. These are among the most biodiverse temperate forests in North America. Anytime my family is outside, any wildlife sighting reminds us all that we share this planet with magnificent creatures. The loss of these roadless areas would not be an abstraction for my family. It would be personal. The agency's regulatory flexibility analysis certifies no significant impact on small businesses while the record says otherwise. "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 averaging impacts across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. That method does not answer the question. I ask that the agency withdraw the certification and assess impacts on the specific small entities operating in the potentially affected roadless areas, not a national average. I am also writing as someone with a direct reliance interest in the rule. I raised a family around the Pisgah's roadless character, and that character shaped choices I made about where and how to do it. The agency itself invites 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." An agency reversing a twenty-year-old rule has a legal obligation to account for the reliance its prior policy created. This comment is one such interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. On fire, the agency's own data cuts against the proposal. I believe the risk of fire should be managed carefully, and I expected the agency's analysis to show that road access would help. It does not. "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 should quantify the expected increase in human-caused ignitions that new road access would bring and place that number honestly against whatever wildfire hazard reduction it claims. Roads enable development and contribute to contamination of the watershed. North Carolina holds 378 municipal water intakes in watersheds containing affected roadless areas, and these places are the headwaters of safe and clean drinking water for many residents. We cannot compromise our water supply in any way. I do not want a penny of my tax dollars used to despoil the Linville Gorge area. Seriously. The agency is already $6.9 billion behind on maintaining the roads it has, with a road budget of about $73 million a year. Building new roads into country that has none, under those conditions, makes no fiscal sense and creates permanent damage that a logged stand cannot match. A stand grows back. A road does not. On biodiversity, the agency's own science makes a finding it then declines to apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears and then nothing follows from it. No projection is applied to the 40.1 million acres of potentially affected environment. The agency should apply that cited range to the full affected acreage and explain what it means before finalizing any action. Prior generations had the foresight to set aside these public lands for health, recreation, and quality of life, including the more than 600 public meetings and 1.6 million comments that produced this rule. No equivalent process has been held to undo it. My boys should not inherit fewer of these places than I was given. Neither should theirs. Sincerely, Leigh Coulter Indian Trail North Carolina

I was born and raised in the Pacific Northwest, and the national forests of this region have shaped my entire life — as places of work, recreation, and deep personal connection. Because of that lifelong relationship with these landscapes, I follow Forest Service planning efforts closely and care deeply about decisions that affect the long‑term health and accessibility of our public lands. I appreciate the opportunity to comment on the proposed revision to the 2001 Roadless Rule, a policy that has played a critical role in protecting the ecological integrity of some of the most valuable remaining undeveloped forest areas in the country. The proposed repeal of the Roadless Rule is legally and analytically deficient, particularly in its treatment of wildfire risk. The DEIS does not adequately analyze the Forest Service’s own fire‑history datasets — including ignition sources, burn severity, suppression access, and comparative fire behavior in Inventoried Roadless Areas versus roaded landscapes. These datasets are well‑established, widely used in other Forest Service analyses, and essential for understanding whether roadless areas actually present elevated suppression challenges or increased fire danger. By omitting this evidence, the DEIS relies on assumptions rather than data, understates the ecological and fiscal costs of expanded road networks, and fails to meet NEPA’s requirement for a reasoned, evidence‑based evaluation. For these reasons, I urge the Forest Service to ensure that any revision to the Roadless Rule is guided by transparent scientific analysis rather than political ideology. Sound policy must be grounded in accurate data, ecological integrity, and long‑term stewardship — not in predetermined outcomes.