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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

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

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

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.

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 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

Dear Secretary Rollins, I am writing to oppose the proposed full or partial rescission of the Roadless Area Conservation Rule. My name is Woody Jackson, President, Friends of the Breitenbush Cascades (FBC). FBC was established in 1988. FBC advocates before the United States Forest Service on behalf of our constituents and operates at the intersection of conservation and recreation. Today, FBC submits public comment objecting to any alteration of the Roadless Rule. I reside in the North Santiam Canyon downstream of our organization’s primary area of interest in the Breitenbush Basin. I, along with over 200,000 Oregonians downstream, rely on the delivery and production of cold, clean water within the North Santiam Basin and Breitenbush Sub-Basin. We are concerned that any modification to the roadless rule would adversely affect the Oregon Department of Fish and Wildlife’s State Wildlife Plan. Our focus area is the Breitenbush Basin within the Detroit Ranger District of the Willamette National Forest. Alterations to the rule would compromise the plan’s objective of maintaining wildlife connectivity among the Mount Jefferson, Opal Creek, and Bull of the Woods Wildernesses. The Breitenbush Basin encompasses approximately 77,000 acres; currently, only 19,000 roadless acres are contiguous with these wilderness areas, leaving roughly 57,000 acres designated as Matrix Lands and Late Successional and Riparian Reserves. Following the 2020 Oregon wildfires, a substantial portion of the remaining wildlife connectivity and refugia were significantly impacted. Preserving the roadless areas within the Breitenbush Basin remains essential to ecological recovery. Nationally, eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In the Breitenbush basin, rescission would be counterproductive to improving habitat for Spring Coho Salmon. The Breitenbush watershed contains an extensive network of headwaters, seeps, and both thermal and cold springs; additional road construction would jeopardize recovery efforts for spring chinook salmon and accelerate amphibian population declines. The DEIS states, “…inventoried roadless areas typically have good water quality due to limited disturbance,” and “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” There is significant concern that the Detroit Ranger District of the Willamette National Forest lacks the capacity to maintain its current road system and must continue decommissioning roads that frequently contribute to sedimentation and culvert failure. Given the anticipated absence of near- or long-term increases in agency funding and staffing, any revision of the roadless rule would be both risky and ill-advised. What does Friends of the Breitenbush Cascades recommend instead of any alterations in the Roadless Conservation Plan? 1)Continue the conservation efforts to restore anadromous fish runs, such as the upcoming North Breitenbush River Stage 0 Floodplain Restoration, and increase conservation planning for the Beaver Emphasis Area in the Breitenbush Basin as a necessity of climate resilience. 2) Additional decommissioning of roads that have proven to exacerbate sedimentation and culvert failure. 3) Improve federal tribal consultations and leverage Traditional Ecological Knowledge, including cultural burning, replacing today’s proscribed fires. Friends of the Breitenbush Cascades supports Alternative 1, the No Action alternative. Thank you, Woody Jackson President, Friends of the Breitenbush Cascades

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Smith River and Umpqua drainages have already taken more than their share of roads and clearcuts. I used to live there. I know what that looks like on the ground, and I am not persuaded that the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule represents anything other than more of the same treatment applied to what remains. The agency's own record undermines the fire-management rationale offered for this rescission. The rule's supporting analysis 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 proceeds as though this finding does not exist. The agency must explain why it is departing from its own prior conclusions about fire occurrence and fuel treatment in roadless areas, and it must reconcile the rescission with the ignition data in its own draft environmental impact statement. Those data make the contradiction sharper. The DEIS records 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." The agency has not explained how opening these areas to road construction reduces wildfire hazard when its own decade of ignition data points in the opposite direction. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that number against whatever hazard reduction it claims to anticipate. Roads are not the answer. The Umpqua drainage taught me that roads and clearcuts are the problem. The agency faces a deferred maintenance backlog and a road budget that cannot keep pace with the infrastructure it already holds. Building new roads into country that currently has none does not resolve that problem; it compounds it. I ask that the agency explain to commenters how adding road miles to the national forest system is consistent with responsible stewardship given the state of existing forest road maintenance. The regulatory flexibility analysis accompanying this proposal certifies no significant impact on small entities. That certification cannot be squared with what appears elsewhere in the supporting documents. The same rulemaking states: "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." A certification reached by distributing a projected loss across every small firm in the sector nationally, rather than by examining the outfitters and guides actually holding permits in the areas affected, is not a meaningful analysis. The agency should withdraw the certification and conduct an assessment focused on the businesses that actually operate in the potentially affected roadless areas. This letter is itself a reliance interest. The 2001 rule was developed through more than 600 public meetings and drew 1.6 million comments. People organized their lives, businesses and expectations around the protections it established. The proposal acknowledges as much: it 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 that changes course is obligated to identify and weigh the reliance interests its prior policy created. The agency must do that here, taking seriously the interests described in the comments it receives. Show some compassion for youth. Leave them a habitable planet. The roadless areas of the Umpqua and the forests like it are part of what a habitable planet looks like. A logged stand grows back slowly. A road network, once built, is not undone. The rule was written to protect the last unroaded third of the national forests, and it was written carefully. This rescission was not. The agency has held no public meetings and has offered no adequate accounting for what is being given up. I expect a substantive response to each of the points raised here. Sincerely, G. Goodwin Swafford Eugene, Oregon

I have been visiting the Indian Peaks and the Indian Peaks Adjacent Area since I moved to Boulder, CO, in 2005. The fishing and hiking are excellent, and some of my most blessed moments have come while watching the evening light over Blue Lake. The baby moose I discovered in 2013 changed my relationship with my partner. I will be hiking and camping in the Indian Peaks adjacent area for the rest of my life. I ask that the agency explicitly describe its plan for how to preserve the pristine cleanliness of the watershed in Colorado. Superior National Forest is one of the most magical places in the upper Midwest of the United States. So much of the land in neighboring North Dakota has already been privatized and developed. It will be a tragedy to put roads in such proximity to the watershed of the Boundary Waters. I have canoed and backpacked in the forest with my best friend, where I observed loons and a bald eagle. When we hiked in 2008, we encountered a great deal of blown-down timber from a past tornado in the area. This resulted in carpets of fresh raspberries that fed birds and rodents in the wilderness. I will be returning in the summer of 2028 for a canoe trip with my friend and my goddaughter. Please keep protections in place for all parts of wilderness preserved by the Roadless Rule. Losing the wild nature of this area will condemn us to consumerist doom. I ask the agency to explicitly describe what steps it will take to maintain the wilderness, the pure watershed, and the bird habitat in the Superior National Forest. "The visitor industry is the largest private sector contributor to regional employment after government. The visitor industry provides over 8,000 jobs, 18 percent of regional employment, and over $249 million in earnings, 11 percent of regional earnings, each year." (Complaint para. 51, same filing, pp. 22-23 of 50) "Given the urgency of keeping additional carbon out of the atmosphere and continuing carbon accumulation from the atmosphere to protect the climate system, it would be prudent to continue protecting ecosystems with large trees for their carbon stores, and also for their co-benefits of habitat for biodiversity, resilience to drought and fire, and microclimate buffering under future climate extremes." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract) I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain 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. 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, Michael Edward Christoph Denver, Colorado

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Every year hiking with my dad in wilderness areas has shown me something that no policy brief can teach: what makes roadless country irreplaceable is precisely the absence of exploitation and intervention. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. These places can be reached by hunters, by anglers, by conservation enthusiasts, by campers, but only through effort, and that effort is part of what they are. Once a road goes in, the prior state cannot be recovered. Keep it Wild. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own record undercuts that argument. The DEIS states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." The agency's own data show far higher fire density on roaded land than inside affected roadless areas. 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. The economic case does not hold together either. 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." Against that, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. I object to the creation of an expanded opportunity economy for the wealthy at the expense of people who lead simpler, more meager lives and just want a few patches of nature to enjoy. Decisions of this kind are not making fiscal sense, particularly when the agency is already carrying a $6.9 billion road maintenance backlog on a budget of roughly $73 million a year. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system the agency already cannot maintain. The proposal also claims the rule imposes administrative burdens, but the agency's own analysis of the existing rule states: "It makes little fiscal or environmental sense to build additional roads in inventoried roadless areas that have irretrievable values at risk when the agency is struggling to maintain its existing extensive road system (FEIS Vol. 1, 1-5 and 3-22)." The rule as written already contains exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific operational needs fall outside those existing exceptions. I ask that it do so, and that it quantify those burdens on the record rather than assert them. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The communities drawing from those watersheds include people who are not wealthy, who rely on intact headwaters, and who are not positioned to absorb costs from sedimentation or degraded source water that road construction accelerates. The small-business certification that accompanies this proposal reaches its no-impact conclusion by spreading estimated losses across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency concedes that some of those firms may lose those receipts. Spreading a real local loss across a national average does not make the loss disappear; it makes the analysis misleading. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas. The rule the agency proposes to rescind was built on more than 600 public meetings and 1.6 million comments. No comparable process has been offered for its undoing. There are things worth preserving so that future generations can connect with the historical experiences of Americans who long preceded them. The proponents of this rescission can find their wealth opportunities elsewhere. I ask that the agency address each of these points in the final record. Sincerely, A.M.C. Washington, DC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The national forests I hike and camp in, Inyo, Eldorado, and Humboldt-Toiyabe, are some of the most treasured places in this state. They deserve protection from roads built for resource extraction and corporate profit. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask this agency to respond to the following. The Humboldt-Toiyabe is the largest national forest in the lower 48. It holds 354 inventoried roadless areas totaling 3,383,849 acres, scattered across mountain ranges that rise from the Great Basin like islands from a sea of sagebrush. Each range is its own sky island with its own water, its own ecology, its own wildlife. Birds are part of what those roadless areas protect, and the agency's own record makes clear how badly roads harm them. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Adding roads to places like the Humboldt-Toiyabe, where birds still exist in habitat that is more pristine, would set that damage in motion. I ask the agency to explain in this docket how the rescission is consistent with its own documented findings on roads and bird abundance. The proposal points to wildfire and fuels management as a justification for rescission. 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." That finding is in the agency's own draft environmental impact statement. The proposal departs from it without reconciling it. I ask that the agency explain, in its final record, why the rescission moves forward against its own prior findings on ignition risk, and that it reconcile this action with the fire density data reported in DEIS Table 21. The economic case for rescission is weaker than the proposal lets on. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit. The agency is also proposing to expand a road system already carrying a $6.9 billion maintenance backlog. How does it justify that cost to the public for a share of national production that its own numbers describe as negligible? The agency must address this contradiction directly before it finalizes any action. The proposal argues that state-specific approaches can replace a single national rule. But the agency's own record shows it has been down this road before. It states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already reviewed what happened when the agency replaced the national rule with a state-by-state approach and found it wanting. The agency must address the deficiencies identified in that prior litigation and explain how this proposal avoids repeating them. Finally, 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides who actually hold permits in the affected areas. That is not a genuine assessment. The agency should withdraw the certification and evaluate the actual small businesses operating in the roadless areas at stake, not a national average that dilutes the real harm. Roadless areas in this country allow wildlife and birds to exist in habitat that remains more pristine. Fuel corporate greed by opening those places to roads and extraction, and that is gone. I urge the agency to withdraw this proposal. Sincerely, A concerned citizen Boulder Creek, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The places I am describing are real to me. I hike, backpack, and ride my gravel bike in the Sierra National Forest, and I have covered ground across California and west through Colorado, Arizona, New Mexico, Oregon, Washington, Idaho, Montana, Utah, Wyoming, and Nevada. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The wildfire argument the agency makes for rescission collapses against its own findings. Oat Mountain needs protection from fire, and I believe people are a hazard to that area. The agency's record states this plainly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ride gravel bikes and I am familiar with the damage that motorized vehicles cause. They race around on roads and are not respectful of nature. The Woodchuck area is now burnt up, and I believe it should be protected from vehicles, not opened further to them. The Shuteye area draws the same concern. I ask that the agency explain why this proposal departs from its own prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission does not hold together either. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. The Forest Service is already carrying a $6.9 billion maintenance backlog on its road system. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. I have hiked and ridden my bike along the Kings River, where the water is collected in reservoirs and released as needed and the river serves both recreation and farming. Opening these watersheds to roads for economic returns the agency's own numbers cannot confirm is not a trade I accept. The agency must reconcile this proposal with a Cost Benefit Analysis that cannot establish a net benefit, and explain how expanding a road system already billions of dollars in arrears serves the public interest. I have backpacked in Dinkey Lakes. It is stunningly beautiful. We need to protect it for future generations. I watch for eagles, mountain sheep, mountain goats, bighorn sheep, birds, fish, frogs, whatever we can see. The record shows that Alternative 3 exists precisely because commenters asked the agency to protect big game habitat, fisheries, and wildlife connectivity. The agency built that alternative and then chose the one that protects none of it. On birds, the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency must say plainly why it rejected the alternative its own record built for the protection of these species, and what it proposes to substitute. The agency tried replacing the national rule with state-by-state approaches before. The record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected that approach. The agency has not explained how this proposal avoids the same deficiencies that caused it to lose in court the last time it tried this, and that explanation is owed. Finally, the agency has certified no significant impact on small entities while its own DEIS identifies outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books a minimum recreation benefit loss of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than examining the specific outfitters and guides holding permits in these areas. The agency should withdraw that certification and assess the small entities actually operating in the affected roadless areas. Sincerely, Laura Fresno, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I ask the Forest Service to honor the long-standing public consensus and keep strong protections in place by maintaining the 2001 Roadless Area Conservation Rule. The America of my dreams is wild, untamed, genuinely free, and the Mt. Hood National Forest is one of the places where that dream lives. Being able to walk among century-old trees with my son, hear the calls of the hermit thrush and the song of the water ouzel next to rapidly flowing waters, is the greatest blessing of my life. My children have learned personal responsibility, self-reliance, and the genuine spirit of the American Dream in the wilderness. Protecting these areas is nothing less than safeguarding the very soul of this country. Three wildfires burned in Mt. Hood National Forest this year. Two of them were caused by human activity, and that activity was enabled by butts in seats travelling on pre-existing roads. That fact is not incidental to this rescission proposal; it is the center of it, because the agency's own record says the same thing. The agency has found that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency also concedes in its own effects analysis 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." The proposal nevertheless advances rescission partly on wildfire and fuels management grounds. The agency must explain, with specificity, why it is departing from its own prior findings on fire occurrence, and it must reconcile the rescission with the ignition data in DEIS Table 21, which reports fire density on roaded land at a level that dwarfs what occurs inside the roadless areas. Beyond that, I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that increase honestly against the claimed reduction in wildfire hazard before this proceeding advances any further. The economic analysis supporting this proposal is internally inconsistent in a way the agency has not addressed. The proposal certifies no significant impact on small entities, yet the DEIS names outfitters, guides, and tour operators as affected, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading an annual expenditure loss of $9 million across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency concedes that some of those firms may lose those receipts entirely. Certifying no significant impact under those conditions is not analysis; it is arithmetic designed to produce a predetermined answer. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. There is a further procedural problem the agency has created for itself. 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 organized our relationship to the national forests around the protections the 2001 rule provides. Hiking and backpacking into wilderness areas free from the noise of machinery is a year-long activity for us, grounded in the expectation that those areas remain unroaded. The rule was developed through more than 600 public meetings and 1.6 million comments. No comparable process has been offered to undo it. Under the legal standards governing agency reversals, an agency changing course must genuinely assess the reliance interests its prior policy created. Soliciting those interests in the Federal Register and then declining to weigh them in the cost-benefit record does not satisfy that obligation. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I urge the US Forest Service to select Alternative 1 (the No Action Alternative) in the Draft Environmental Impact Statement (DEIS). Sincerely, Preston Boyd Gresham, Oregon

Re: Docket FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Chief Schultz: I am writing to urge the Forest Service not to rescind the 2001 Roadless Area Conservation Rule. I have lived in the Colorado mountains for 38 years and spend a great deal of time hiking, biking, and recreating on our public lands. I have also watched wildfire risk become an increasingly serious concern for mountain communities. For that reason, I am particularly troubled by the suggestion that rescinding roadless protections and allowing additional road construction would reduce wildfire risk. The Forest Service's own analysis does not convincingly support that conclusion. The Draft Environmental Impact Statement acknowledges that human-caused wildfire ignitions increase with proximity to roads. At page 98, the DEIS states that human-caused ignitions increase near roads because roads facilitate human access. At page 109, it further acknowledges that increasing road density is associated with increases in the probability, number, and frequency of wildfire ignitions. The DEIS's own data make this issue especially important. Table 21 reports a human-caused ignition density of 22.4 fires per million acres per year on other National Forest System lands, compared with only 3.0 in potentially affected inventoried roadless areas. That is approximately a 7.5-fold difference. Natural ignition rates are much closer: 16.8 compared with 8.5. In other words, much of the difference in wildfire occurrence between roaded and roadless lands is associated with human-caused ignition. This is not simply a theoretical concern. Forest Service research has found that the advantages roads may provide for positioning firefighting resources can be offset by increased human-caused ignitions near roads. More recent Forest Service research reports that human-caused ignitions account for more than 60 percent of recorded wildfires across the western United States. Despite this evidence, the DEIS concludes at page 113 that the net effect of new roads on fire occurrence is likely to be "small or insignificant," based in part on potentially improved response times and initial attack. That conclusion deserves much stronger support. The DEIS suggests that some new roads might be closed to public access, thereby limiting additional ignitions. But the proposed rescission does not appear to require a particular proportion of new roads to be closed, nor does the analysis quantify the expected increase in ignitions under different levels of road construction and public access. It therefore relies on a possible mitigating measure without demonstrating that the measure will occur or that it will offset the documented relationship between roads and human-caused wildfire. I support responsible forest management. I support targeted fuels reduction, prescribed fire, and other measures where science demonstrates that they can help protect communities and improve forest health. But those objectives do not require wholesale removal of roadless protections. The Forest Service should distinguish between targeted management needed to address a specific wildfire threat and opening currently roadless landscapes to substantially greater road construction and human access. Those are not the same policy. Before relying on wildfire reduction as a justification for rescission, the Forest Service should use the data already contained in the DEIS to quantify the likely change in human-caused ignition risk associated with additional roads. It should also identify what percentage of new roads it assumes would be closed to public access and analyze what happens if those closures do not occur. If the agency cannot demonstrate that increased suppression access outweighs increased ignition risk, it should not characterize rescission as a wildfire-risk-reduction measure. Roadless areas also protect watersheds, wildlife habitat, recreation opportunities, and large relatively intact landscapes. These values are particularly meaningful to those of us who live in and depend upon mountain communities. Roads and the development they facilitate can permanently alter those landscapes. I fully appreciate the need to confront wildfire risk. But wildfire policy should be based on the evidence. The evidence presented by the Forest Service itself does not establish that building more roads into currently roadless areas will make our forests or our communities safer. I respectfully request that the Forest Service retain the 2001 Roadless Area Conservation Rule rather than rescind it. Thank you for considering my comments. Sincerely, Erika Krainz Dillon, Colorado

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I regularly backpack, and roadless areas offer the best opportunities for solitude. It's necessary decompression from the stresses of modern life. The roadless areas in PA (Tracy Ridge, Allegheny Front) and WV (Dolly Sods, Cranberry) are areas I've camped that are closer to home, but I'm always thinking about new places to explore for vacations. Habitat fragmentation is a significant driver of population declines in migratory songbirds and other wildlife species. Once these refugia are impacted by roads and logging, it takes decades to recover. Centuries, if the area contained old growth forest. Such areas are already a small percentage of our total land area; these should be the highest priority areas for conservation. The agency's own fire data should stop this proposal in its tracks. The DEIS states that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The DEIS also quantifies this directly: "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 cannot claim wildfire management as a rationale for rescission while its own analysis documents that road access raises ignition rates by that margin. I ask the agency to quantify the expected increase in human-caused ignitions from new road access and weigh it explicitly against the claimed reduction in wildfire hazard, and to explain why the proposal departs from its own prior findings as reflected in DEIS Table 21. The Forest Service manages for multiple uses, and a large percentage of land is already utilized for timber and supports recreation opportunities accessible by existing roads. Roadless areas support uses that cannot be replicated once these areas are fragmented. Intact mature habitat is a conservation use. It's also a recreation use for those (like me) who enjoy finding solitude in nature, and getting away from crowds. These are just some of the reasons why I strongly opposed the rescission of the Roadless Rule. Sincerely, Brian Slaby Maple Heights, Ohio

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.The forests, wetlands, mountains, and deserts from Vermont and New Hampshire, Maine to Florida, through Pennsylvania, Utah, the Dakotas, Wyoming, Colorado, Utah, Nevada, and more, through to California have been my family, in the truest sense of that word. It's peaceful and soul rejuvenating for me to be in wild nature that I am also a part of. When I hike and camp, I am visiting my non-human family. That relationship, and my daughter's right to continue it and one day pass it on to her own children, is what this rescission puts at risk. I oppose it without reservation.Bread Loaf in Vermont's Green Mountain National Forest represents exactly what the 2001 Roadless Area Conservation Rule was written to protect: 1,768 acres where intact interior habitat can sustain life, including wildlife, native plants, fungi, the full web of macro and micro flora and fauna that has just as much right to exist as humans do. Those species have a place now because roadless areas exist. The proposal would shrink that guarantee, and I want the record to reflect that shrinking it is not acceptable. Lands without damaging roads, is absolutely and inherently necessary to support everything, including humans.On wildfire, the agency's own text 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." Fire is far more prevalent in areas with roads than without them, and roads and logging increase wildfire intensity. The proposal nonetheless advances road construction as part of a fuels management rationale. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile this 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.Roads cause erosion, carry invasive species into intact habitat, and fragment the interior forest that vulnerable species depend on. Maine holds 5,988 acres of inventoried roadless land, and 286 municipal water intakes in the Eastern region, which includes Maine, sit in watersheds containing affected roadless areas. These are not abstract numbers. They represent the kind of quiet, intact places where I have hiked and where I have taken my daughter, places that support everything, including humans. The agency's own analysis acknowledges that roads and their facilities can produce the overwhelming majority of sediment from a timber sale. I ask the agency to explain on the record how opening these watersheds to road construction serves the public interest when the sedimentation consequences are already documented in its own record.The economic case for rescission is no stronger. The agency's 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's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, all while the existing road system carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those figures and explain how expanding a road network the agency cannot currently maintain serves a coherent fiscal purpose.The history of this rule also deserves a direct answer. The agency's own record quotes its prior dissatisfaction with "the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach,' 70 Fed.Reg. at 25,656," a dissatisfaction that led to the state-by-state experiment the Ninth Circuit subsequently rejected. The agency must address its own prior finding that local, incremental decision-making erodes nationally significant roadless values, and it must explain what has changed that would allow a state-by-state approach to survive the same legal scrutiny it failed before.Finally, the rule as written alre