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

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.

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.

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

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 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

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.

I am in opposition to the plan the rescind the 2001 Roadless Area Conservation Rule. The proposed regulation claims that road construction in previously preserved areas will decrease wildfire risk. However, evidence from a 2020 study by USFS ecologist Sean Healy (1) showed that areas with and without roads burn at the same rate, suggesting that fires caused by humans using the roads offset the benefit of areas being more accessible by fire control services. Furthermore, a lack of roads in protected areas has not deterred fire prevention. The discontinuation of the Roadless Rule will have no positive effect on wildfire control and will likely increase wildfire prevalence due to logging. A 2006 study investigated wildfire severity in Sierra Nevada's unthinned and mechanically thinned forests, finding that thinned forests are more likely to be overtaken by wildfires (2). I trust the judgement of the peoples who have lived across this continent since time immemorial. As expressed in the Regulatory Certifications section of the Supplementary Information, Tribal governments majorly oppose the rescission of the Roadless Rule. Conservation of roadless areas preserves water quality, gathering areas, and sacred ancestral lands. I am in assent with either of the most frequently requested alternatives by Tribal Nations: retaining the existing rule or a strengthened roadless rule. In order to protect our forests, our wildlife, the communities who depend on them, and most importantly our Earth, it is integral that the Roadless Rule is retained. Thank you. References (1) Healy, S. P. 2020. Long-term forest health implications of roadlessness. Environ. Res. Lett. 15, 104023. (2) Hanson, C.T., Odion, D.C. 2006. Fire Severity in mechanically thinned versus unthinned forests of the Sierra Nevada, California. In: Proceedings of the 3rd International Fire Ecology and Management Congress, November 13-17, 2006, San Diego, CA

Clean water and wild country are not abstractions to me. I am a cancer survivor, and having clean water is critical to my continued health. The Ocala National Forest feeds my water, and I am asking the Forest Service to keep the protections that make that water trustworthy. I also go out there hoping to see bobcat, bears, and red-cockaded woodpeckers. And I want to know that I did everything I could to give my grandchildren the opportunity to enjoy the last bastion of pristine wildlife. That is why I oppose rescinding the 2001 Roadless Area Conservation Rule. The agency's own document states, at Scope of the Analysis, 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 the rescission is likely to adversely affect hundreds of ESA-listed species and designated critical habitats, and the effects chapters describe permanent road construction and old-growth removal as reasonably foreseeable outcomes. Those are irreversible commitments by any plain reading. The Forest Service must explain, directly and specifically, how those two positions can both be true. The agency also argues, at Rationale for the Proposed Rule, that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." But the same document cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it notes that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The forest health rationale cannot rest on a premise the agency's own findings undercut. I want the agency to reconcile that contradiction in its response. Finally, the agency reports that a preliminary biological assessment produced a "may affect, likely to adversely affect" determination for 327 species and 71 designated critical habitats, as disclosed in the ESA-Listed Species and Regional Forester Sensitive Species section, yet formal Section 7 consultation with the Fish and Wildlife Service and NOAA Fisheries has not been completed. A final rule that reshapes management across every inventoried roadless area in the country should not rest on preliminary, unconsulted findings. Complete the consultation, disclose the resulting Biological Opinion, and let the public respond before any rule is finalized.

I write today in support of the current recission of the 2001 Roadless Rule. I am a lifelong Alaskan who has spent my entire life being molded by the Tongass, and have come to realize just how lucky we are to grow up with something of this magnitude in our backyards. Its with this deep respect, that I believe those who know the land the best should be the shepherds of its future. The Roadless rule is something that works for lower 48 states, with minimal federal forestry land, but when you apply it to the southeast Alaska region, many important Alaskan decisions are made for us. The Tongass was not supposed to be included in the 2001 Roadless Rule in the first place. Congress had already set aside 5.7 million acres of Wilderness and 775,524 acres of Legislative LUD II Areas (Similar to Roadless Areas) in ANILCA and the Tongass Timber Reform Act of 1990 (TTRA). The No More clause of ANILCA (1326(a) was supposed to prevent such additional land set asides that were over 5,000 acres without an Act of Congress. The Tongass was thus not added to the 2001 Roadless Rule until the Record of Decision was promulgated. Fed. Reg. Vol. 85, Oct. 29, 2020, at pages 68690-68691. So, there is every reason to remove it from Roadless designation. The Final EIS exempting the Tongass on October 29, 2020, pointed out that road construction would increase from 994 miles under the No Action Alternative to 1043 miles (49 miles) under Exemption over the next 100 years. Only 186,000 more acres of the 16.9-million-acre Forest would be available for timber harvest. Fed. Reg. Vol. 85, Oct. 29, 2020, at page 68691 (middle column). Additionally, a repeal of the Roadless rule would advance hydroelectric capabilities for a region that sees some of the highest rainfall on average. The 1947 Waterpower of Southeast Alaska Report, conducted in part with the Forest Service, identified over 200 potential hydropower sites in Southeast Alaska. There is thus no reason why all Southeast Alaska should not be on hydropower. Moreover, excess power from Southeast Alaska can be exported to the Lower 48. On November 13, 2000, Congress authorized construction of a Southeast Alaska-wide intertie, which included the Tongass National Forest. Pub. Law 106-511, 114 Stat. 2365 (Nov. 13, 2000). Future hydropower and support facilities, such as those envisioned by Report #97- 01, are subject to the prohibition on road construction. See 66 Fed. Reg. at 3256 (“The final rule retains all the provisions that recognize existing rights of access and use. Where access to these facilities is needed to ensure safe operation, a utility company may pursue necessary authorizations pursuant to the terms of the existing permit or contract.”) (Emphasis added). This exception is subjective and fails to provide clear direction. Future transmission projects do not fall within that exception. The Swan-Tyee Intertie (STI) is an example of a transmission project that, because of no road access, resulted in exceedingly high construction costs. If road access is unavailable for construction, the utility is limited to the use of helicopters. Helicopters are extremely expensive. This resulted in a construction cost for STI of about $2 million dollars/mile. The STI is 57 miles long and the total construction cost including permitting, design, etc., was about $110 million. To put that in perspective, the proposed Kake-Petersburg (KPI) line, which has roads in place, has an estimated cost of around $45 million. The length of the KPI is about the same as the STI. Of more significance is the cost to maintain a line that is constructed without road access. The rights-of way (ROW) for these lines have to be maintained and brushed continually. The structures must be inspected on a rotating annual basis. With roads, this work can be done by a crew in a truck. Without roads, this work must be helicopter supported, which is very expensive. Moreover, transmission lines that do not have road access must also have helicopter pads near the structures. These pads must be maintained and brushed every couple of years. This work must be done by helicopter. For these reasons above, I support repealing the roadless rule, and allowing for Alaskans to finally have the opportunity to make decisions on our forest as we see fit. Thank you for your time.

**Re: Proposed Rescission of the 2001 Roadless Area Conservation Rule** To the USDA Forest Service: I am a mountain biker and hiker, and I am writing to oppose rescinding the Roadless Area Conservation Rule. Pisgah and the North Cascades are among my favorite places in the country. They make me feel human. That is not something a timber sale or a road can give back once it is gone. Roughly 58 million acres of roadless national forest belong to every American, and protections that have held for a generation should not be removed without a far stronger justification than the agency has offered. **Recreation.** Roads bring more traffic, more noise, and more pressure, and they cut long trail corridors into fragments. Roadless areas generally remain open to mountain bikes, unlike designated wilderness, so this rule has preserved some of the best non-motorized riding and hiking on public land. Outdoor recreation also supports gateway communities nationwide, and its value should be weighed honestly against short-term timber revenue. **Taxpayers.** The Forest Service cannot afford to maintain the roads it already has; its deferred road and bridge maintenance backlog runs into the billions of dollars. Rescission would allow new roads in the steepest, most remote, and most expensive terrain, creating permanent maintenance obligations in exchange for one-time timber revenue. Please quantify in the final EIS the long-term cost of the roads you expect to be built or reopened, and show that the public benefit justifies it. **Wildfire.** I support protecting communities, but the 2001 rule already allows fuel-reduction work, including removal of small-diameter trees, where needed to reduce fire risk. Treatment that protects homes and towns largely occurs outside roadless areas. Research shows people cause most wildfires and that ignitions cluster near roads, and roads spread invasive grasses that make landscapes burn more often. Please document how many acres of fuel treatment the rule has actually blocked and explain why its existing exceptions are inadequate. **Water, fish, and wildlife.** Roadless areas protect headwaters that supply downstream communities. Roads are a leading source of sediment in forest streams, which degrades spawning habitat for native trout and salmon. Roadless lands also give elk, deer, bears, lynx, and other species the large undisturbed blocks of habitat they need. Please analyze cumulative effects on watersheds and on threatened, endangered, and sensitive species. **Irreversibility and process.** Once a road is built and an old stand is cut, roadless character is gone for generations. The 2001 rule came from years of work, hundreds of public hearings, and well over a million comments. A case-by-case system would force the public to defend each area, forest by forest, indefinitely. Please retain the national rule, or at minimum preserve its protections for the most ecologically valuable and least-roaded areas. Please respond directly in the final decision to the concerns above, including cost assumptions, the wildfire rationale, and effects on water, wildlife, and recreation. Thank you for your consideration.

My tax money funds the National Forests, and I hike and camp in them. I want this land managed responsibly. Rescinding the 2001 Roadless Area Conservation Rule does not meet that standard. The agency claims in the Rationale for the Proposed Rule that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." I do not dispute that the rule limited certain management actions. But the document the agency produced to support this rescission also cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land, and it notes that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. Both things cannot drive the same conclusion. The agency needs to reconcile its forest health rationale with those findings from its own document, and I ask that it do so plainly. The fire argument troubles me just as much. Under the Fire Control section, the agency asserts that "With increased road access, initial attack success rates would be expected to increase." The document does show a difference in initial attack success between roadless and other forest land. But it also acknowledges that less-than-full suppression strategy is used more often in roadless areas, which skews that comparison, and it expects most new roads to be temporary timber spurs rather than strategically placed fire roads. No analysis in the document isolates the effect of roads from suppression strategy. Before roads are built through land I hike on, the agency should separate those two variables in its comparison and estimate how many fire-useful roads would realistically be built given actual funding constraints. I ask the agency to put that analysis on the record. Responsible management means showing your work. This proposal does not. Headed to: Forest Service Read the official notice &rarr;

I am commenting on the USFS plan to rescind the 2001 Roadless Rule. The plan to rescind the Roadless Rule is ill-conceived and I urge selection of the No Action Alternative. The DEIS fails to address the protections and values the Roadless Rule provides and fails to adequately analyze the impacts road building and other resource disturbing activities would have on these areas. Roads are the primary cause of habitat fragmentation, sedimentation, and invasive species introduction in forest ecosystems. While the DEIS discusses the impacts from rescinding the Rule, it never addresses the “so what” question. In other words, recognizing there will be impacts doesn’t fully address what the consequences are from those impacts. I.e. the DEIS acknowledges sediment loading, from road building, impacts to water quality, but it never adequately analyzes how this would impact drinking water for communities that rely on these water sources. Implying BMPs will offset any impacts doesn’t fully analyze the negative impacts to water quality and how that would impact communities, fisheries, etc. The same goes for introduction of NNIS. The DEIS acknowledges building roads will lead to the introduction of NNIS but never adequately analyzes the impact that will have on native species, especially T&E species, or on the difficulty of forest regeneration with the introduction of NNIS. Roadless areas provide clean drinking water to many downstream communities. Peer-reviewed research published in PLOS Water found that these areas serve as the primary protection mechanism watersheds that supply drinking water to 25 million U.S. citizens. I live in Western North Carolina, and the South Mills River Roadless area in the Pisgah NF is source of drinking water to the city of Hendersonville. Allowing roads to be built in this area would degrade the water quality for that community. This area recieves a large amount of rainfall and intense rain events. No amount of BMPs can provide adequate protection to that situation. Roadless areas also provide world-class hiking and mountain biking trails, supports local businesses, and offer unmatched experiences for visitors looking to get away from the noise and commotion of roads. Getting rid of the Roadless Rule puts all these incredible benefits at risk. I live in an area that is a gateway to the Pisgah NF. Our community relies heavily on tourism and a major draw is mtn biking, especially in the South Mills River roadless area. Allowing roads to be built in the area would negatively impact the backcountry nature of this area and enjoyment many gain from that experience. While the EIS claims getting rid of the Roadless Rule will help prevent wildfires, the facts don’t back that claim up. Wildfires are 4 times more likely to start near a road than in a roadless forest. Roads are ignition corridors, and about 89 percent of wildfires nationally are human-caused. Far from preventing wildfire, building roads boosts wildfire ignitions. The DEIS fails to adequately address this discrepancy. Additionally, the Roadless Rule already allows the Forest Service to do wildfire prevention work and fight fires in roadless areas. The rule does not prohibit wildfire fuel reduction work; projects like prescribed burning and vegetation thinning can and do take place within these protected zones. Nearly 2 million acres of roadless areas have received hazardous fuel treatments since the rule was adopted in 2001 The majority of these roadless areas contain steep slopes which makes road construction extremely expensive and exacerbates the impacts to soil and water resources. Opening these areas to road construction will only add to the issue the Forest Service has with road maintenance, which is severely underfunded. The Forest Service is not able to maintain the over 370,000 miles of road it currently has, and has a $5.4 billion deferred maintenance backlog for roads. It receives a fraction of the funding needed to maintain what it has, much less any new roads in rugged terrain. Unmaintained roads can lead to landslides and lower water quality, which threatens the health of entire ecosystems. The agency can’t afford what it has and should not worsen the situation by adding more roads. How will adding to the maintenance costs be addressed and resolved? The DEIS is written in a pre-decisional manner. It appears to be written to justify rescinding the roadless rule and downplays the value of these roadless areas while understating the impacts from opening these areas up to road construction. One of the main arguments that these areas need to be opened up to address wildfire potential just doesn’t hold water. The Roadless Rule has been in effect for 25 years, providing clean water for many municipalities, habitat for many plant and animal species needing unfragmented forest conditions and unmatched back country recreational opportunities. These values deserve to be protected.

Draft Comment Blueprint Attn: Joshua White, Acting Director, Ecosystem Management Coordination Docket No: FS-2025-0001 | RIN: 0596-AD66 Re: Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule I am writing to express my strong opposition to the full rescission of the 2001 Roadless Rule. As a regular visitor to the White Mountain National Forest, the justification provided by USDA Deputy Secretary Stephen Alexander Vaden, claiming that a nationwide rollback is required to grant "access" for active forest management and wildfire reduction, is explicitly contradicted by the agency’s own data. Proceeding with this rule constitutes a textbook case of fiscal waste, administrative abuse, and analytical fraud for the following substantive reasons: 1. A Personal and Generational Stake in Intact Backcountry: Some of my earliest memories from childhood are my mom taking me on a backpacking trip up Mount Lafayette at age six. The deep wilderness experience of standing on Lafayette depends entirely on the pristine, unfragmented backcountry visible below it. Devastatingly, vital access points like the Liberty Springs Trail coming out of Franconia Notch are not off-limits if this rule gets revoked. Please don’t take this opportunity away from other parents and children by disrupting forests in their areas! Furthermore, commercial logging or logging roads near the Appalachia trailhead would completely ruin the gateway to the northern Presidentials like Mount Adams and Mount Madison, creating visual and noise pollution for hikers climbing out of the valley. I just went back to the Whites with my mom 20 years later. We hiked out of Appalachia and shared a similar special moment. Having lived near major metropolitan areas like New York and Boston since graduating college due to my career, traveling to these designated roadless areas is a vital escape that my peers plan for, look forward to, and rely on to maintain their well-being amid urban sprawl. 2. Fiscal Waste (The Road Maintenance Backlog): The U.S. Forest Service currently faces a multi-billion-dollar backlog in maintaining its existing public road network. Rescinding the rule to allow new commercial timber roads will severely exacerbate this deficit. According to the findings of the USDA’s own Draft Environmental Impact Statement (DEIS), repealing the rule will inherently inflate federal road maintenance costs while yielding little to no fiscal return. Spending taxpayer dollars to build new infrastructure when the agency cannot afford to maintain its current assets is a blatant waste of public funds. 3. Analytical Fraud (The Deceptive Wildfire Rationale): Deputy Secretary Vaden’s primary assertion that restrictions "exacerbate rising wildfire risk" is an arbitrary and unsupported narrative. The 2001 Roadless Rule already permits active fuel reduction and thin-burning management without building permanent roads. Furthermore, peer-reviewed fire science consistently demonstrates that roughly 90% of wildfires originate within a half-mile of a road. By introducing new roads into the backcountry, the USDA is actively increasing human-caused wildfire risks to nearby communities—the exact opposite of the rule's stated intent. Presenting a policy as a "wildfire solution" when agency data demonstrates it increases long-term risk and spending is a fraudulent manipulation of the NEPA process. 4. Abuse of Discretion (Disregarding Downstream Economic Damages): The DEIS admits that rescinding the rule will cause widespread environmental and economic harm. Over 25 million Americans rely on intact roadless watersheds for clean municipal drinking water. Commercial logging and subsequent road erosion will drastically increase sedimentation and turbidity. This will shift massive capital costs for advanced water treatment onto downstream local governments and taxpayers. Ignoring these quantified downstream economic liabilities to benefit private commercial extraction constitutes an abuse of the agency's public land mandate. Conclusion: Because the proposal relies on arbitrary claims that fly in the face of the USDA's own cost-benefit analysis and DEIS data, the agency must select the No Action Alternative (Alternative 1) and keep the 2001 Roadless Rule fully intact.

Dear Chief Schultz, My name is Nolan, and I live in Indiana. I may not live near a roadless conservation area, but this issue is still extremely important to me. The rescission of the Roadless Rule is the exact opposite of climate crisis mitigation that the country’s vast forest areas work hard to achieve. I want the Roadless Rule to stay. Keeping our forests roadless will leave forest carbon work undisturbed, which will maintain a source of healing for the climate in its current time of crisis. I have never been to Mogan Ridge or any section of Hoosier National Forest, but I imagine it offers a lot more to discover and more habitats to be amazed at as the woodland areas past my backyard and where I hike through. I would like for my local section of the Hoosier National Forest to stick around for me to explore it someday. One time I walked through a roadless area was when my family and I hiked the Hemlock Cliffs trail in Crawford County, Indiana. We were in awe at the massive cliff rocks that we were able to stand under and the bright green plants. The rescission of the Roadless Rule takes the possibility of hiking the Mogan Ridge Trail, if not the enjoyment of hiking it, away from me. Nobody would want to walk through a state park with a four-lane road through the middle of it. The level of exposure to vehicle emissions would be perilous in a place where that shouldn’t be a problem. Paving roads through Mogan Ridge will drastically increase sediment levels. That excess sediment rushing through road ditches and stream will reduce oxygen for the Pink Mucket species that Mogan Ridge is known for. In other words, the bursts of sediment originating from roads will kill the Pink Mucket species. Regarding the Mogan Ridge in the Hoosier National Forest, Indiana: Interior Forest Conditions for Shade-Intolerant Oak Regeneration — The dry and dry-mesic upland forests of Mogan Ridge contain mature white oak and hickory trees that are essential seed sources for the oak-hickory forest type. These species require specific light and fire regimes that are maintained in roadless areas where natural disturbance patterns persist and where the absence of fragmentation allows seed dispersal and seedling establishment across large, unbroken forest blocks. Road construction introduces edge effects—increased light penetration, invasive species colonization, and altered microclimate—that favor shade-tolerant competitors like American beech and sugar maple, permanently shifting the forest composition away from oak dominance. The DEIS must conduct a site-specific, watershed-level analysis of road construction impacts on aquatic habitat in the Mogan Ridge IRA, Hoosier National Forest, for Pink Mucket (Lampsilis abrupta, Critically Imperiled). A programmatic EIS that treats all roadless areas as interchangeable fails to satisfy NEPA's requirement for analysis proportional to the significance of the resource at risk — and a G1-ranked aquatic species is a significant resource. "Future projections indicate a basinwide maximum 7-day average of daily maximum stream temperature increases of 1.42°C–2.04°C for the midcentury, and 1.84°C–3.24°C by the end of the 21st century. These increases reduce the most thermally suitable habitats for steelhead, coho, Chinook, and bull trout by an average of 27%–36% during the mid-century time period, and 35%–51% by the end-of-century time period." — Journal of Environmental Management / ScienceDirect, 2025 The Department should take seriously how much I, along with millions of Americans treasure protected forest lands. Although hiking is closest to my heart, there are many other important purposes protected areas serve. Rescission is a slap in the face to anyone who has ever spent a single minute in a preserved area such as the Hoosier National Forest. Regards, Nolan CommentID: RLC-20261007-FB7671

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I was, born, raised and still live in Arkansas, a state whose identity, economy, recreation, wildlife, and quality of life are deeply connected to our forests, rivers, streams, and other public lands. I grew up near the border of the Ozark National Forest and there’s simply no replacing the decades of hardwoods, biodiversity, dark skies, and beauty of this area. I care about protecting the remaining wild and relatively undeveloped areas of our national forests because once roads and development fragment these landscapes, the ecological and recreational values they provide cannot simply be restored by closing a road later. The Roadless Rule has protected millions of acres of National Forest System lands for more than 25 years. These lands provide clean water, wildlife habitat, carbon storage, opportunities for hunting, fishing, hiking, camping and solitude, and places where natural ecological processes can continue with relatively little human disturbance. Those benefits belong to all Americans, including people who may never have the opportunity to visit a particular roadless area. I am particularly concerned about the Forest Service's rationale that rescinding the Roadless Rule is necessary to provide greater flexibility for wildfire prevention and forest health. The Draft Environmental Impact Statement does not adequately demonstrate that removing the Roadless Rule will meaningfully reduce wildfire risk. In fact, the DEIS acknowledges that under Alternative 1, the No Action alternative, the occurrence and severity of wildfire would likely remain similar to recent decades. It also acknowledges that prescribed burning and other activities that do not require new roads or extensive tree cutting could continue under the existing rule. The analysis therefore does not establish that opening roadless areas to additional roads and timber harvest is necessary to achieve meaningful improvements in wildfire outcomes. The DEIS also does not adequately quantify the potential consequences of increased road construction. The document repeatedly characterizes road construction, road mileage, and deferred maintenance as more or less likely under the alternatives, but does not provide a sufficiently concrete estimate of how many miles of new roads could ultimately be constructed, what those roads would cost to maintain, or how the Forest Service's already substantial road maintenance backlog would be affected. This is particularly important because building roads creates a long-term management obligation rather than a one-time benefit. I am also concerned that the analysis does not adequately account for the effects of roads and associated development on water quality, wildlife habitat, fragmentation, invasive species, erosion, and recreation. The DEIS itself concludes that Alternative 1 provides the greatest protection for water quality and that biodiversity impacts would likely be least under Alternative 1. Those are not minor differences. They represent real public benefits that should be given the same level of consideration as potential timber and management benefits. The agency should also fully consider the cumulative effects of opening previously protected roadless areas to development at a time when forests are already experiencing increasing pressures from drought, extreme temperatures, wildfire, insects, disease, development, and habitat fragmentation. The fact that forests face changing conditions does not by itself demonstrate that removing a longstanding conservation protection is the appropriate response. Finally, the Forest Service should not assume that protections provided through individual forest plans, project-level NEPA review, or other existing laws will provide an equivalent substitute for the national Roadless Rule. The Roadless Rule provides a consistent baseline protection for some of the nation's least developed federal forest lands. Replacing that protection with a series of future, site-specific decisions would make the protection dependent on future budgets, priorities, management plans, and individual project decisions. For these reasons, I ask the Forest Service to fully consider the environmental and public benefits of retaining the Roadless Area Conservation Rule, including clean water, intact wildlife habitat, biodiversity, recreation, solitude, scenic values, and the preservation of wild places for future generations, like our 10 year old daughter. I oppose the proposal to rescind or weaken the Roadless Rule and support Alternative 1, the No Action alternative. Public lands belong to all of us. Once an intact forest is fragmented by roads and development, we cannot simply put it back the way it was. The Forest Service should retain the Roadless Rule and protect these irreplaceable public lands for current and future generations.

I am an Environmental Engineer in the state of Georgia, currently employed in a regulatory field. The roadless areas closest to me are in the Chattahoochee National Forest, the Nantahala National Forest, and the Great Smoky Mountains. I spend a considerable amount of time recreating in these areas on my weekends and off hours. I have also taken trips across the country and recreated in roadless areas in Washington and California. I have experienced firsthand the beauty and value of these areas, and wish to highlight the importance in conserving them. I am writing this comment to oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. According to the USDA Forest Service's own assessment, rescinding the roadless rule will NOT meaningfully decrease wildfire risk - it is actually more likely to INCREASE wildfire risk. Page 86 of the DEIS report states: "the incidence of human-caused fires generally increases with proximity to roads." Additionally, there is already an exception in the existing Rule for cutting and removing small timber as a means of reducing wildfire risk. Page 102 of the DEIS states that "timber projects are the primary motivation and funding source for new roads", NOT reducing wildfire risk. However, the Forest Service already lacks the budget to maintain its existing roads and infrastructure, with a current deferred maintenance backlog of $7 billion. The DEIS states, on page 45: "revenue generated by timber sales or other...activities would be used for some road-related system management but would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." So where is the money needed to build these proposed new roads, at an estimated cost of $2 million per mile (as stated in page 42 of the DEIS), coming from? Rescinding the Roadless Rule will have negative impacts on soil, water, and air quality. Increased timber harvests will increase soil erosion, compaction, and landslide probability. Page 120 of the DEIS states that there are 7,000 municipal water intakes within watersheds in designated roadless areas, supplying water to nearly 5 million people just within the Pacific Southwest. Water quality will be degraded by the addition of new roads, as roading and timber harvest degrade water quality by increasing sediment and nutrient runoff into streams, creating warmer and hypoxic conditions (page 117, DEIS). Removing tree canopies will alter the timing of spring snowmelt and runoff. Increases in timber harvest will also result in increased emissions from trucks and other equipment (page 128, DEIS). Page 160 of the report states that roadless areas "overlap the range of more than 300 threatened, endangered, and proposed species, 79 final or proposed critical habitats managed by the USFWS, and 19 critical habitats...listed under the ESA". The DEIS projects negative impacts that include habitat loss and degradation, introduction and spread of non-native and invasive species, increased human-wildlife conflict, and detrimental impacts to fish and game species. (Pages 142, 151, 152) Though the current administration is waging a war against the Endangered Species Act, the USFS IS CURRENTLY STILL REQUIRED to comply with the ESA. It is unclear how the USFS plans to do so when its own report states that rescinding the Roadless Rule will directly lead to noncompliance with the ESA. Circling back to the financial questions posed in the second paragraph, it is known that recreation and tourism are more profitable than roadless timber. In 2024, visitors to roadless areas spend $8.5 billion total in local communities (DEIS page 212). Meanwhile, timber harvest value in 2024 across ALL national forest land was just $151 million (DEIS page 220). Roadless timber is only expected to generate $2.2-$11.4 million dollars annually (DEIS page 220). Even a 1% loss in visitation to roadless areas due to rescission of this rule could lead to a projected loss of $9 million annually. So again I ask, who stands to profit from these timber harvests? Seemingly not the USFS, since we have covered that profits from timber harvests will not be enough to cover the costs of building the roads required for such projects, and likely not the local economies poised to lose millions tourism dollars either. If there is no clear benefit, financial or otherwise, to increased timber harvests, then why is it being proposed? Who stands to benefit? In the current era of constant threats to our natural environment and the health and financial wellbeing of the American people, we must place the highest importance on protecting and conserving what natural resources we have left. Due to the financial concerns and projected negative impacts on wildfire risk, soil quality, water quality, air quality, biodiversity, recreation, and tourism as outlined above, I must oppose the recission of the Roadless Rule, and urge all others to do the same.