Read the comments.

Thank you for the opportunity to provide public comments and extending the public comment period. While the 2001 Roadless Rule clearly stated how it aligned with the national policy to encourage productive and enjoyable harmony between people and the environment- the 2026 proposed rule pays no mind to the policy and instead focuses on the finite Executive Orders and directives of the current Administration. In doing so, the USDA is proposing to weaken its ability to protect watershed health, an obligation Congress imparted on the Agency when establishing the National Forests. The United States government has an obligation to be transparent with the taxpayers that it is divesting in watershed health to prioritize private development of public lands. Additionally, the 2026 proposed rule relies on BMPs to meet its regulatory requirements to protect water quality (e.g. CWA) but also acknowledges it lacks sufficient funding to implement those requirements and properly maintain roads. This contradiction, which may conflict with the requirements of the Administrative Procedures Act, should be addressed in the final rule and NEPA analysis by analyzing the budgetary needs to implement the regulatory requirements/BMPs over time (e.g. 70 years); disclose historic and projected budgets available to implement those requirements and perform road maintenance; and disclose the anticipated impacts to watersheds and water quality due to the lack of available funding.

i am 15 years of age and not very political. i’m not political because all of the politics suck. the world is becoming more corrupt and chaotic as the days continue, with crazy leaders controlling and servallancing our every move it’s not surprising they want to destroy our wildlife. The things that created us, what natives and nomadic people used for centuries to survive, is no longer protected or respected. The leaders want change and an infinite world but our nature is life. Nature is life and without it we are nothing, we cannot be. Without protected waters or any clean system to drink from how will any ecosystem survive? If we take away only a few trees that means only a few animals will have to migrate and it will increase the wildfire chance just by a little bit, but if we multiply this by how many acres of land that has been invaded and how many species have been endangered because of our careless actions, we have no more trees or animals to spare. We have no money to give no voice in our government and no way to go back from all of this. I beleive that my voice matters because if there’s one of me, theres many others that agree with me and want to help the world and support life. the nature, the animals, fresh air, the fertile soil, the beaches, trees, waterfalls, they all matter just as much as i do. We are all everything together and it’s depressing so many humans settle to living a miserable life when they can actaully support a better future. I know i can’t vote, but i can pick up litter i can stop contributing to profit of industrialization and i can make a difference. Organizations like yours and plenty others that contribute to saving and raising awareness for the world encourage me to be the best i can and help me see beauty in this uniform society. Absence of Quantified Nationwide Cumulative Timber Harvest, Road Construction, Sedimentation, and Fragmentation Analysis The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29).

While the proposal to repeal the roadless rule has the noble goal of improving forest health, the Draft Environmental Impact Statement (DEIS) provides little evidence that the repeal will achieve this goal. It is true that research shows that fuel reduction projects and other scientifically based management activities tend to improve forest health, the DEIS offers little proof that the repeal will encourage or enable such projects and activities. In fact, existing evidence supports that allowing human access to formerly protected areas will increase the risk of wildfire and ecological harm, particularly because this repeal is intended to increase extractive uses and development on public land. The DEIS also fails to address how the repeal of this rule will impact clean drinking water and also, the biodiversity necessary for a healthy forest. This is particularly concerning because one of the primary reasons National Forests were created was to protect watersheds. Available evidence shows that wildfires are 4 times more likely to start within 50 meters of a road and that human activity is responsible for about 90% of wildfires. Increasing road access will likely exacerbate the risk of wildfire and make catastrophic wildfires more likely. Existing exceptions in the roadless rule allow for for non-commercial thinning and fuel reduction activity in protected areas. Beyond the harm this repeal would likely cause, another reason I oppose this repeal is a practical one. Due severe budget reductions, the Forest Service is unable to appropriately manage and maintain lands and roads outside these roadless areas. Forests were already severely understaffed prior to 2025 and were decimated by the DRP, VERAs, and firing of probationary employees in 2025. It is unlikely that the Forest Service would be able effectively manage lands with increased access. Building and maintaining roads is a costly, long term endeavor that can also introduce particular ecological harms such as invasive species and fragmentation of habitat. These harms outweigh any benefits provided by increased access. I strongly oppose this blanket repeal of the roadless rule as it exists. However, as noted, it has a welcome goal of improving forest management and reducing wildfire risk. Rather than a blanket repeal, a far better solution would be to approach the issue forest by forest, allowing each forest and community to create an EIS that appropriately considers all factors and allows for increase road access only where it makes sense.

I object to the agency's primary assertion in the Draft Environmental Impact Statement (DEIS) that a total rescission of the 2001 Roadless Area Conservation Rule is required to protect communities from rising wildfire risks. The DEIS fails to adequately evaluate how expanding the road network into currently protected Inventoried Roadless Areas (IRAs) will drastically increase human-caused wildfire ignitions. According to the agency’s own historical data, roughly 90% of wildland fires are caused by human activity. Independent research has also shown that wildfire ignitions are up to four times more likely to occur in close proximity to roads than in unroaded backcountry. In removing the 2001 protections and facilitating new road construction for timber extraction, the agency is inadvertently building "ignition corridors" into these ecosystems. The introduction of motorized traffic, recreational equipment, and industrial machinery into these remote areas significantly elevates the probability of catastrophic, human-caused starts—undermining any theoretical fire-reduction benefits gained from mechanical thinning. In addition to that, the agency's rationale that the 2001 Roadless Rule acts as a barrier to critical fuel reduction projects is factually incorrect. Under the existing framework (36 CFR § 294.12 and § 294.13), local forest managers already possess explicit authority to cut, thin, or remove timber, and conduct prescribed burns within IRAs if the project maintains or restores ecosystem traits and reduces the risk of wildfire effects. The Forest Service has not demonstrated that the current exceptions are insufficient for community protection. Given the agency's own data showing that 90% of wildfires are human-caused, what specific empirical evidence or scientific modeling did the Forest Service rely upon to conclude that the fuel-reduction benefits of new road construction would outweigh the documented fourfold increase in human-caused ignition risks associated with those very same roads?

Keep the roadless rule in place. The roadless rule is an important tool for conservation, preservation, responsible use of forest and wild areas. There is plenty of area already available for destructive uses such as timber harvesting, resource extraction, and off-road motorized recreation. If any changes should occur, it should be limited to temporary access only on closed travel ways for authorized fire-fighting agencies in an active fire or emergency situation and limited to the duration of the active fire. Any destruction from this temporary, authorized only use must be repaired upon conclusion of the firefighting. When the rule was implemented, hundreds of public meetings occurred. None have occurred for this rescinding proposal. This is improper and fails to meet the burden of adequate public participation. This constituent does not support this proposal.

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The rule's own justification is centered on wildfire risk, particularly in the wildland-urban interface. If that is the real concern, the response should be a targeted fuel-treatment and access authority for that specific problem instead of a blanket rescission. The Department's own analysis undercuts the broader rationale: only ~16% of forested roadless acreage is rated operable for timber harvest, high-end harvest projections are called "unlikely," and the Forest Service already has a $6.9 billion road maintenance backlog. The proposal also concedes that more roads can increase human-caused ignition risk, which directly undermines the wildfire-safety rationale, while estimating $6.1M/year in lost recreation value. A narrower path exists: retain the national rule and expand its existing exception process for fuel treatment and fire-related access in the wildland-urban interface, rather than eliminating protections nationwide.

As representatives of Michigan’s snowmobile community, we believe the Rule should recognize the unique nature of over-snow vehicle (OSV) recreation and protect reasonable access to National Forest System lands. We support establishing an “open unless closed” presumption for over-snow vehicle use. Existing roads, trails, and appropriate riding areas should remain available for snowmobile use unless a closure or restriction is required by law or supported by a documented resource, safety, or management need. For forests that do not already have winter travel plans, existing snowmobile access should serve as the starting point rather than requiring riders to continually justify long-established winter recreation. Our tracks melt with the snow. When adequate snow conditions exist and riders operate responsibly, snowmobiles can travel across the winter landscape without creating the permanent roadbed, rutting, or soil disturbance associated with ground-contact travel. For Michigan snowmobilers, a better policy would: Establish an “open unless closed” approach for appropriate OSV use, with closures based on documented resource, safety, legal, or management needs. Recognize the seasonal and temporary nature of snowmobile travel over adequate snow cover and frozen ground. Maintain existing snowmobile access unless there is a demonstrated reason to restrict it. Require the Forest Service to consider new trails, connectors, roads, and riding opportunities during forest-level planning. Encourage local Forest Service officials to work directly with organized snowmobile groups when developing winter travel plans. Protect natural resources while recognizing that responsible recreation and conservation can coexist.

The Roadless Area Conservation Rule should not be overturned. Roadless areas were established p to protect remaining undeveloped national forest lands from commercial logging, new road construction, and industrial development. There is even more urgency today to protect our National Forests for the same reasons. Since 1970 there has been a 27 percent decline in our bird populations. I started watching birds in 1970 and my journals are full of observations of seeing birds in abundance. Now I visit forest areas, and the woods are empty just a few species. It is like walking in an empty city. The 44 million acres of roadless are crucial to the survival of birds, mammals, insects, plants and the survival of intact ecosystems. The focus should instead be on adding an additional 45 million acres to the Roadless Area inventory. Peter Gorman 4109 Half Moon Circle Silver City , New Mexico

The complete overturn of the Roadless Rule may be broader than necessary to accomplish greater flexibility to respond to changing conditions (wildfire risk, insect and disease impacts, and infrastructure needs). Currently, the rule conserves over 58 million acres of public lands managed by the United States Forest Service that provide optimal places to hunt and fish. The USDA should analyze a narrower alternative that preserves a national baseline for inventoried roadless areas while creating exceptions for demonstrated local management needs. The USDA could retain the general restrictions on road construction and timber harvesting while allowing individual forests to obtain exceptions for projects shown to be necessary for wildfire mitigation, forest health, public safety, or infrastructure access.

I agree entirely with recinding the roadless rule to allow a greater portion of our National Forests to be managed for the purposes for which they were intended. I am a hunter, hiker, fisherman, naturalist and birdwatcher. Many of the species that I like to see depend on forest openings, young forests, early successional and managed habitats. I want to see more management done with a focus on habitat for ruffed grouse, migratory warblers, and other species that require a diversity of forest types and forest ages. I greatly appreciate the many benefits of having roads in our forests, but I would recommend that roughly half of them be maintained as administrative access roads that exclude (or seasonally limit) public vehicular access.

Please do not rescind the roadless rule. I live in Central Oregon, in the path of wildfire. Not only do I fear for my self and the town of Sisters, I fear for the habitat and lives of the wildlife that surround us. I understand that roads would allow more clearing but the damage that comes by too much access would be consequential. Already the forest service uses helicopters to lift debris and other obstacles from the ground so clearing for prevention could take place. Even minimal logging could happen where necessary. A prevision that allows workers into wilderness for surveillance or supervision could happen by small motor vehicles such as motorcycles or being dropped into an area via helicopters could be added to the rule along with stiff fines for anyone other than qualified individuals entering the area other than on foot. Please, do NOT rescind the roadless rule laws. Thank you.

As an active public-land hunter, I see firsthand the severe fire risk and massive deadfall from beetle-killed pine in our national forests. While I strongly support active forest management to address fuel loads, I firmly oppose a blanket repeal of the Roadless Rule. Stripping these protections will cause severe habitat fragmentation, destroy critical security cover, and drive big game off public lands onto private ranches where the average American hunter cannot go. Instead of a broad rollback, the USDA should adopt a targeted, common-ground approach that balances fuel management with wildlife conservation through the following measures: Prioritize High-Risk Zones: Focus heavy mechanical thinning and fuel breaks on the Wildland-Urban Interface (WUI), major roads, and utility corridors, leaving deep backcountry security intact for wildlife. Mandate Strict Road Decommissioning: Require by law that any temporary access roads built for timber removal are fully re-contoured, culverts pulled, and physically closed to all motorized traffic immediately after project completion. Utilize Surgical Exceptions: Expand target-specific safety exceptions under the existing 2001 rule to treat severe beetle-kill hotspots rather than revoking protections across millions of acres. Invest in Low-Impact Forestry: Increase funding for winter logging on snowpack and expanded prescribed fire programs to clear dense deadfall without carving permanent road networks into the landscape. Empower Local Collaboratives: Work directly with state wildlife agencies and local hunting groups to tailor management plans to specific units rather than enforcing top-down federal shifts. We can protect our communities from catastrophic wildfire without sacrificing the quiet, roadless backcountry that sustains our big game populations and hunting traditions. Please pursue a surgical, common-sense alternative to full repeal.

One of the biggest problems with this proposal is something the Forest Service’s own analysis reveals. In 2001, the Forest Service concluded that the Roadless Rule’s restrictions on road construction and timber harvest could benefit threatened and endangered species and their habitat. Both the U.S. Fish and Wildlife Service and NOAA Fisheries agreed with that determination. Now, the current DEIS concludes that removing those protections is likely to adversely affect 327 ESA-listed species and 71 designated critical habitats. Yet the DEIS never adequately explains how those two findings are reconciled. If the science or the condition of these species and their habitats has changed since 2001, the Forest Service should clearly explain what changed and provide the evidence. If nothing biologically significant has changed and this reversal is being made primarily for policy reasons, the agency should say so plainly. Simply saying that individual projects will undergo future Endangered Species Act review does not answer the larger question. The 2001 determination was made at the national-rule level, so the decision to reverse that policy deserves an explanation at the same level. Before finalizing this rule, the Forest Service should directly address its 2001 finding, explain why it is departing from it, and reconcile that finding with its own conclusion that rescinding the protections is likely to adversely affect hundreds of listed species.

I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. While I understand the USDA's intention to provide local management flexibility, the full repeal of this rule poses severe, unmitigated threats to our wildlife, communities, and the global climate. Unconsidered Detrimental ImpactsClimate & Forest Resilience: Overwhelming data demonstrates that large, undisturbed forests serve as critical carbon sinks. Constructing new roads fragments these habitats, accelerating carbon loss and disturbing soils that store immense amounts of carbon. Wildlife & Watershed Disruption: Road construction degrades critical headwaters and migration corridors. For example, data shows that the vast majority of vital cold-water trout streams are protected by these roadless tracts. Roads introduce invasive species and permanently shatter intact ecosystems. Human Safety & Landslides: The draft proposal fails to properly weigh the human toll of road infrastructure. Roads severely increase landslide risks in steep forest terrains. Furthermore, studies show that over 80% of wildfires are human-caused. Opening roadless areas increases human access, which inadvertently increases fire risks rather than lowering them. Flawed Data Conclusions: The justification that the Roadless Rule has "failed" forest health is not backed by objective data. The current 2001 rule already provides specific exceptions allowing for localized active management, hazardous fuel reduction, and wildfire response without building permanent roads. Blaming the rule for broader climate-driven wildfire patterns draws an unreasonable conclusion that ignores existing policy flexibility. The Burden vs. Benefit Disconnect: There is a severe inequity in who bears the cost of this amendment versus who benefits. Local communities, recreationists, and future generations will bear the long-term ecological and financial costs, including a multi-billion-dollar backlog in forest road maintenance. Meanwhile, the short-term economic benefits of commercial logging and development will be reaped primarily by private industry. A Potential Alternative: A reasonable alternative Instead of a total national rescission, the USDA should adopt an alternative that mirrors the Colorado and Idaho state-specific roadless frameworks. This alternative would preserve the overarching national ban on commercial timber harvesting and road building while carving out specific, tightly defined, and data-driven community protection zones around urban wildland. This protects intact backcountry ecosystems while genuinely giving local managers the tools they need to protect communities from fire. I urge the USDA to withdraw this proposal and maintain the foundational protections of the 2001 Roadless Rule.

I oppose the proposed elimination of 8 C.F.R. § 214.1(l)(2). My concern is not simply that eliminating the 60-day grace period would create hardship. The more fundamental problem is that the proposal appears to rely on an incorrect administrative premise: that eliminating the grace period will simplify adjudication by eliminating difficult inquiries into when employment ceased. It does not eliminate that inquiry. It makes the inquiry more consequential. Under the current rule, uncertainty of several days regarding the date employment ceased is often absorbed within a grace period of up to 60 days. Under the proposed rule, the same uncertain factual determination would become the dividing line between maintenance of status and immediate failure to maintain status. In other words, the proposal converts a timing problem with a tolerance interval into a timing problem with a legal cliff. DHS itself recognizes in the NPRM that the date employment ceased may be difficult to determine and that payroll or other employment records may not always establish a definitive last day of employment. Yet the proposed rule would make the day after that uncertain event legally dispositive. That raises three questions that should be addressed before the rule is finalized. First, what exactly constitutes “cessation of employment” for purposes of the proposed rule? Employment does not always end through a single, uniform event. An employee may receive advance notice of termination, stop performing productive work while remaining on payroll, enter a paid notice period, use accrued leave, remain on benefits, or receive salary continuation or severance. The date duties end, the date payroll ends, the employer-designated termination date, and the date immigration-related notice is provided may differ. If DHS intends immediate failure to maintain status to occur after “cessation,” the triggering event should be defined with sufficient precision that workers, employers, adjudicators, and reviewing courts can identify the same date prospectively. Second, has DHS evaluated the increase in adjudicative error costs created by eliminating the grace period? Under the present framework, a disagreement of several days concerning the termination date frequently does not alter the outcome because the subsequent filing remains within the 60-day period. Under the proposed framework, even a one-day error could become outcome-determinative. The underlying evidentiary problem therefore remains, while the legal consequence of error becomes substantially greater. If DHS believes the proposal will reduce administrative burden, it should explain why converting an uncertain date into an immediate status cutoff will not instead increase disputes over termination dates, requests for evidence, and the need for precise factual reconstruction. Third, DHS should distinguish between eliminating a grace-period calculation and eliminating the underlying timing problem. Even after repeal, USCIS may still need to determine precisely when employment ended whenever maintenance of status is relevant to a later petition or application. The agency would no longer ask whether a filing occurred within 60 days, but it may need to answer a harder question: exactly when did lawful maintenance of status cease? That is not necessarily administrative simplification. It may instead be a transfer from a forgiving timing inquiry to a high-consequence day-zero inquiry. This issue also bears on DHS’s broader rationale that employment-based nonimmigrant status should remain closely connected to qualifying employment. Even assuming DHS may reasonably adopt that policy objective, it does not follow that a zero-day transition is operationally necessary. There is a meaningful distinction between saying that employment is the basis of a classification and saying that any factual cessation of employment must produce immediate failure to maintain status without a transitional interval. If immediate cessation is a policy choice rather than a statutory requirement, DHS should evaluate the administrative consequences of that choice directly rather than treating them as inherent in the structure of the statute. For these reasons, I respectfully request that DHS not finalize categorical elimination of the grace period on the present record. At minimum, DHS should first: 1. define an administrable event that constitutes “cessation of employment”; 2. evaluate how often that event can be identified reliably from existing records; 3. assess the error costs created when uncertainty regarding that event immediately determines maintenance of status; and 4. demonstrate that eliminating the grace period actually reduces net adjudicative burden rather than merely making the same factual determination more consequential.

The roadless rule should not be rescinded. Justifications for doing so are false. More fires are started by humans near roads therefore it would make sense that by building more roads there could be potential for more forest fire starts. There is already an almost 7 billion dollar backlog of work that needs to be done on current roads. Building more will take more tax dollars and only put us further behind in road/bridge maintenance in the future. It is said that roadless areas are inaccessible however per the national forest service reports more than half of visitations and time is spent in roadless areas annually. The real reason is to appeal to mining companies and logging. I know we need both logging and mining to occur to keep this country functioning. However, I am quite familiar with NFS lands in each category with roads and without. There are still plenty of NFS lands that already have roads and could still be timbered, but get tied up in litigation before can be logged. A better middle ground would be to keep the roadless rule intact and instead create a way to fast track logging in areas that already have roads. This will be cheaper therefore more profitable.

I am a student interested in nature and conservation. I do not think that the 2001 roadless area conservation rule should be rescinded because the risks and harm outweigh the possible benefits. The benefits and consequences of rescinding the rule should be evaluated based on its impacts on ease of access, resource management, natural disaster response and prevention, environmental protection, and environmental and ecosystem impacts. Ease of access: roads will make more remote or dense areas easier to access by humans and our machines that might be necessary for management. Mapping will need to be completed and updated. Resource management: allowing more roads will make resource management like forest thinning easier, and will also allow more access to mineral extraction and mining. It will allow easier access to biologists and researchers who help influence or make important management decisions. Increased activity in the area and habitat fragmentation may damage the integrity of said resources through chemical maintenance runoff into the soil and water (harming plants and animals), and/or particulate pollution from dusty roads (especially important when a road is near water, which is greatly compromised as a habitat when there is too much particulate suspension blocking light and increasing heat). Depending on the type of road and how difficult or dangerous it’s crossing is for animals and fish, wild populations can be limited in migration and range, and also become genetically bottlenecked. This will damage the integrity of hunting in the area if allowed. Natural disaster response and prevention: Road access will make wildfire response easier and faster, (this is already an exception for why a road might be necessary under the current rule) and if strategically built and wide enough, may act as a fire break. However, most wildfires are anthropogenic, and can be prevented by limited or no human interaction. Occasional wildfires are important to maintaining healthy forests, and roads, especially roads being used by humans may inhibit animals paths as they flee from a fire. Property needing to be protected should usually already have roads for access, so there is limited need for more. Environmental protection: allowing smaller governing bodies to make decisions regarding roads tailored to their local areas means that management plans may be incorporated sooner and with greater ease. However, rescinding the rule will significantly reduce environmental protection from unnecessary human involvement. Allowing roads in protected areas to be built without being required to go through strict scrutiny for whether or not they are needed for public health and safety or existing rights and state-specific rules means that unnecessary environmental harm is likely to take place. Although it is not guaranteed that new roads will be built in protected natural areas if the rule is taken away, it opens the door for decisions that should be thoroughly thought over and examined for necessity and all possible impacts to instead be made quickly and perhaps rashly. Environmental and ecosystem impacts: the information made easier to access and gather by roads is important for preserving a healthy ecosystem which can also support human needs. Roads can invite air, soil, water, noise, and light pollution, and can also break up important wildlife corridors for migration, mating, and feeding. This also applies to fish and other aquatic animals, as roads may need to intersect a stream or river, possibly creating an unnatural barrier to fish passage. In short, I think that the potential for harm in removing the 2001 Roadless Area Conservation Rule completely is much too high. Instead, I propose that the criteria for “necessary” roads stays, especially when considering permanent roads, and approval for temporary roads that are required to be removed within a certain amount of time is made easier, given that they are mindful of key habitat areas and bodies of water. The rule should not be removed altogether, but an exception or amendment might be made to allow temporary roads to be built for temporary access needs more easily.

I am writing to oppose the USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule), which established broad prohibitions on road construction, road reconstruction, and timber harvesting within inventoried roadless areas on National Forest System lands. I have worked in the conservation field for over 20 years, but more importantly, I am a parent and family member of US citizens who have an appreciation for wildlife and public health and recreation and tourism and our rural and indigenous communities. The government’s own analysis makes the case against rescinding the roadless rule: * Wildfire. The DEIS states that “as the density of roads increases, so does the probability, number, and frequency of fire ignitions.” Vehicles can accidentally throw sparks, and people drop their cigarette butts and leave campfires unattended. These are all ignition sources that are much less likely to happen without roads. * Wildlife. Roads fragment habitats and cars kill wildlife. The DEIS states that rescinding the Roadless Rule is “likely to adversely affect” 327 threatened and endangered species, including the northern spotted owl, grizzly bears, and various fish species. Additionally, 71 designated critical habitats are at risk. This map from Defenders of Wildlife ties specific at-risk species to the roadless areas that could be impacted. * Economics. The DEIS estimates that between $5-$11 million in revenue could be generated through new logging projects in roadless areas. This number pales in comparison to the current $7 billion USFS road maintenance backlog, the cost of new road construction, and the losses in revenue for local businesses from tourism. * Tribal Sovereignty. Though opinions among Tribes are not monolithic, the DEIS states that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission.” Roadless areas across the country are important to Tribal communities as ancestral homelands and landscapes where they express reserved hunting, fishing, and gathering rights. I hope you will respect what I believe will be a resounding rejection of this proposal to rescind the roadless rule. Sincerely, Heather Tausig

I oppose full rescission of the 2001 Roadless Rule. The rule is a blunt 2001 map, and the existing fuels exceptions are too hard to use. That is not a reason to delete the national floor on 44.7 million acres, including the Tongass. Do this instead: keep a ban on permanent roads and regeneration harvest in core roadless areas; allow temporary roads and thinning only in mapped WUI and high-hazard stands near existing roads; re-inventory compromised polygons; separate the Tongass; extend the comment period.

Subject: Comment Opposing Proposed Rule to Rescind the 2001 Roadless Area Conservation Rule Docket: (FS-2025-0001) I am submitting this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. My comment focuses on statutory inconsistencies, analytical deficiencies in the Draft Environmental Impact Statement (DEIS), and unaddressed cumulative impacts that materially affect the agency’s obligations under the National Forest Management Act (NFMA), the Forest and Rangeland Renewable Resources Planning Act (RPA), and the Administrative Procedure Act (APA). --- 1. The proposed rescission is inconsistent with NFMA’s non‑declining sustainability mandate • NFMA_sustainability_requirements — NFMA requires the Forest Service to maintain ecological conditions that support long‑term forest productivity. Roadless areas disproportionately contain intact hydrological systems, mature forest stands, and high‑function biodiversity corridors. The DEIS does not demonstrate how devolving protections to individual forest plans will maintain these conditions at a national scale. • Fragmentation_risk — Road construction is the single largest driver of fragmentation in national forests. The DEIS acknowledges fragmentation risk but fails to quantify how rescission increases cumulative fragmentation across multiple planning units. --- 2. The DEIS does not adequately address hydrological and watershed impacts • Watershed_integrity — Roadless areas contain some of the highest‑value watersheds in the National Forest System. Roads increase sedimentation, alter flow regimes, and elevate downstream flood risk. The DEIS does not provide a national‑scale hydrological model or cumulative watershed impact analysis, despite the fact that rescission enables road construction across millions of acres. • Climate_resilience — The DEIS does not evaluate how removing national‑level protections reduces climate resilience, particularly in regions where intact forest blocks buffer extreme precipitation events. --- 3. The cost‑benefit analysis omits long‑term ecological and economic costs • Ecosystem_services — The analysis does not quantify the economic value of intact forest services such as water filtration, carbon storage, erosion control, and biodiversity support. These omissions materially bias the cost‑benefit conclusions. • Deferred_maintenance — The Forest Service already faces billions in deferred road maintenance. Allowing additional road construction without a national‑level constraint increases long‑term fiscal liabilities that the DEIS does not address. --- 4. The rescission undermines the purpose of national‑level consistency under RPA • RPA_consistency — RPA requires national‑scale planning to ensure coherent management across forests. Rescinding the Roadless Rule shifts critical decisions to individual forest plans, creating inconsistent standards and weakening national‑level resource stewardship. --- 5. The DEIS does not evaluate cumulative impacts across multiple forest plans • Cumulative_impacts — The agency cannot rely on future forest plans to address cumulative impacts created by a national‑level rescission. The DEIS must evaluate cumulative effects at the national scale, including fragmentation, hydrological degradation, carbon loss, and species‑range disruption. --- Conclusion Because the proposed rescission is inconsistent with NFMA and RPA obligations, lacks a defensible cumulative impact analysis, omits critical hydrological and ecological data, and underestimates long‑term economic costs, the agency has not met its burden under the APA to provide a reasoned explanation for reversing longstanding protections. I respectfully request that the USDA withdraw the proposed rule and retain the 2001 Roadless Area Conservation Rule.