Read the comments.

I writing to urge you to choose Alternative 1: Status Quo/No Action in your final ruling on the proposed Roadless Rule Rescission. There are many compelling reasons to oppose the rescission. I’ll list just a few of them, focusing on ones that are particularly pertinent in Montana, which is where I live. I’m sure that you’re hearing about most of these from other folks, so I don’t think there’s a great deal of need for me to go on and on. The public is opposed—overwhelmingly so—to removing protections for roadless areas. More than 99% of responses received thus far are against the rescission of the Roadless Rule. Even amongst folks who can’t be bothered with writing letters, support for Roadless Areas has been around 76%. These are public lands we’re talking about, and how the public would like to see them used ought to weigh heavily in the decision-making process. Municipal Watersheds will be degraded. Building more roads in our National Forests will increase erosion, which will add to run-off and water purification costs. More than a third of Montanan’s water comes directly from or is downstream of roadless areas. Wildlife habitat will be further fragmented. I’m lucky enough to make my home in the Greater Yellowstone Ecosystem (outside Livingston, MT), which is “the most intact temperate ecosystem in the world,” according to wildlife biologist Doug Smith. Removing the roadless buffer along the edges of this ecosystem will harm wildlife habitat if/when extractive industries move in. The Greater Yellowstone area draws visitors from around the world and has been studied and written about by many. We need more protections—not fewer—for an ecosystem as important as this one. Recreation Economy. Tourism is a big deal Montana, supporting 1 in 11 jobs. Outdoor recreation is also important to Montana residents, making up 4.9 percent of Montana’s GDP. 5.9 of Montanans work in fields related to outdoors recreation. Much of this recreation takes place on public lands that are easily accessible from cities and towns, and these places often include IRAs. It seems unlikely that the extractive industries enabled by rescinding roadless protections will provide a net gain for Montana’s economy, since tourism and outdoor recreation would likely suffer. Maintenance Backlog for Existing Forests Service Roads. If we can’t take care of the ones we already have, we probably don’t need more. Enough said. Private Inholding Access. This is a big one, especially for those of us who live near or like to recreate in the Crazy Mountains. The Crazy Mountains are made up of “checkerboard” public and private land ownership, though some sections (not the right ones, in my opinion) were consolidated a couple of years ago. Most of the checkerboard is currently within the Crazy Mountain IRA. If roadless protections are removed, it will be easier for owners of private inholdings to petition for permission to build a road to their property. These roads would fragment wildlife habit, disrupt public recreation, and have a negative impact on tribal resources. The boon this would provide for owners of formerly difficult-to-access private inholdings is substantial, and casts new light on the checkerboard consolidation deal brokered by the Yellowstone Club in 2025. Wildfire Reduction. This is one of the primary reasons given by the Forest Service for its need to rescind the Roadless Rule. However, scientific evidence does not support the building of roads as a way of reducing wildfire risk—in fact, human caused ignitions in Montana are more than 8 times higher within 100 yards of a road than they are on more remote forest service land. I live a couple of miles from an IRA that runs along the northern edge of Absarokas, and the wildfires we’d had in this area since I’ve lived here tended to be fought by air. Some ignitions occurred on private property (often, a vehicle was involved), others were caused by lightning strikes, but the outcome was the same: the sky was abuzz. At times, firefighters were dropped into wilderness areas to fight fire on the ground—but roads provided little in the way of meaningful firefighting access. Plus, there’s enough wiggle room in the current Roadless Rule to allow for forest thinning and controlled burns in the WUI. Though it will never be perfect, I believe that the Roadless Rule and wildfire protection for our towns and neighborhoods in the urban interface can successfully coexist. Thanks for hearing me out. There’s plenty more I could say, but I believe I’ve gone on for long enough. I hope you make a decision that serves the general public, not a select few. Please go with Alternative 1. The other options serve neither our forests nor the people who love them.

Re: Docket FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I urge USDA to keep the 2001 Roadless Rule and make targeted improvements to it, rather than rescinding it. I support fiscal discipline, active wildfire management, and responsible use of public resources. A full rescission works against all three. It would add costs for taxpayers and take something valuable from sportsmen and rural communities. 1. Fiscal responsibility: The Forest Service already has an estimated $6.9 billion backlog in road and bridge maintenance. Every new mile of backcountry road becomes a permanent liability on the federal balance sheet. Taxpayers should not be asked to pay for new roads when the agency cannot maintain the ones it has. The agency's own analysis finds only about 4.8 million acres where timber operations would be both allowed and physically feasible. That is a small share of the roughly 45 million acres affected, so the economic return does not justify the cost. 2. The rule is not what's stopping wildfire work. The agency's own management records show that fuel treatments in roadless areas have been carried out at a higher rate per square kilometer than elsewhere in the National Forest System. Research covering three decades of data found that wildfire ignitions are least dense in roadless and wilderness areas. Areas within about 160 feet of a road see up to four times as many ignitions, mostly from human causes. Mitigation dollars do the most good near homes and communities, not in remote backcountry. If you want to address wildfire risk, increase funding to the Forest Service. 3. Hunting and fishing heritage: Roadless areas hold some of the best big-game habitat left in the country. About 58% of them overlap elk habitat, and about 70% hold native trout or salmon. The hunters and anglers who use these areas bring steady revenue to gateway towns across the West, and that revenue depends on secure, undisturbed habitat. Sportsmen's groups such as Backcountry Hunters & Anglers and Trout Unlimited have urged USDA to keep the rule. As an Idaho resident, hunting and fishing access are important to me personally, but also to ours state's economy in the form of tourism. People come here to see pristine, undisturbed areas and hunt game that require undisturbed habitat. 4. Clean water for local communities. Roadless areas protect the headwaters of 354 municipal watersheds. For many small towns, intact forest is the cheapest water treatment available. If that protection is lost, local ratepayers will face treatment costs they cannot easily absorb. And it will be mostly rural, low-resource communities that feel this most. 5. National forests are owned by all Americans: the hunter in Idaho, the angler in Ohio, and the rancher in Montana alike. Decisions about their most intact backcountry should not depend on whoever has the most influence in a given planning cycle or statehouse. The 2001 rule was adopted after more than 600 public meetings and 1.6 million public comments. It has given land users, businesses, and communities 25 years of predictable rules. Rescinding it would replace that certainty with forest-by-forest decisions that can change with every plan revision, and with years of costly litigation. I respectfully ask USDA to withdraw the proposed rescission. Instead, the agency could clarify and streamline the rule's existing exceptions for fuels reduction and wildfire response, and increase funding to the Forest Service to better manage and protect these lands. That would deliver the management flexibility the agency is seeking while keeping America's best remaining backcountry intact for the public that owns it.

Dear Joshua White, Hi my name is Greta Healy and I live in Southeast Alaska. My favorite places in Southeast are the old growth forests. Old, massive trees, mossy forest floors, quiet serene places. The 2001 Roadless Rule has safeguarded the world's largest intact temperate rainforest for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economy, and ecosystems of Southeast Alaska. I live in a town where logging roads have totally changed the forests. The woods that have been logged are dense and the undergrowth is impossible to walk through. Small trees that were undesirable for selling still were cut down but instead of being hauled out they were left in place. Walking through a second growth forest is not conducive to recreating and diminishes habitat for wild animals. I fear more roads and logging will further impact ecosystems that our wildlife depend on. Lets use roads we already have. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity. The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience. Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed 13 of Southeast's 16 hydroelectric projects are located in Roadless areas. A strong future for Alaska would involve investing in ecotourism. Getting people into these wild places with the goal being to appreciate nature. Not extraction. Extraction is unsustainable and eventually will end. Once the trees are gone the logging *money* will go away- yet the roads and the people who love this wild place will still exist and will once again need to figure out how to survive. Why not figure that out now. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Greta Healy

Dear Joshua White, I am a person of faith who cares about protecting the Pacific Northwest fishery, clean water and old-growth and legacy forests. The 2001 Roadless Rule has safeguarded the world's largest intact temperate rainforest for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economy, and ecosystems of Southeast Alaska. Increased road building may increase human incursion into areas prone to wildfire. Mining will pollute pristine waters that support the Alaskan fishery. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity. The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience. Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed 13 of Southeast's 16 hydroelectric projects are located in Roadless areas. I would like the Forest Service to protect watershed integrity and intact ecosystems in the vast and beautiful northern forest. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Kathleen D Delbecq

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My husband and I are hikers and birdwatchers, and the best birdwatching, in our experience, is sitting in a quiet forest in a spot you have hiked to reach. The biodiversity is amazing. That is why the proposed rescission of the 2001 Roadless Area Conservation Rule troubles me deeply. I live near the Wasatch-Cache National Forest, and the roadless area of Mt. Olympus encompasses 9,982 acres of it. We have hiked a portion of that forest and value the peace and quiet of no roads. What is at stake here is not abstract to me. The birds are the reason my husband and I seek out quiet forest. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Those findings apply directly to the kind of birdwatching we do in the Wasatch-Cache, where the silence itself is the habitat. The DEIS also states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is striking, and it appears in the record without any projection across the 40.1 million acres of potentially affected environment. I ask that the agency apply the cited fragmentation range to those 40.1 million acres before finalizing any decision, so that the public and the decision-makers can see what the numbers actually mean at scale. The forest my husband and I walk into above Salt Lake City is quiet because it has no roads. That quiet is what makes the birds findable and the biodiversity visible. The agency's own citations confirm that roads reduce richness, fragment habitat, and cost the treasury more than they return. The record contains the facts needed to reach a defensible conclusion. What it lacks is the work of applying those facts to the decision being made. I oppose the rescission and urge the agency to complete that analysis before proceeding. Sincerely, Lenora Olson Salt Lake City, UtahRe: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001

I am a citizen with an appreciation for nature and a concern for our climate and ecosystems. I oppose removing the 2001 roadless area conservation rule and ask you to conduct a full and transparent environmental review. This policy has protected over 44million acres of land filled with various ecosystems and wildlife. These areas protect so many species, including endangered and proposed endangered species. I was lucky to visit some areas in Oregon and Washington, and have a such respect of how nature handles itself and got to learn about how trees will become nurse logs to others. Visiting roadless areas mean more to me than having to drive a road through it, which brings me to say that myself and plenty of visitors brought money into small towns and communities. Based on pages 212-214, in 2024 visitors brought in about $8.5 billion and there are economic benefits to these communities year after year as people such as myself partake in outdoor recreation or wildlife/nature viewing. . Data from the last thirty years shows wildfires predominantly caused by humans or within 50mile radius of roads (https://link.springer.com/article/10.1186/s42408-026-00450-2 ). They are 4x likely to start near roads. On page 102, the DEIS essentially says timber projects are a primary motivator for this removal of protection. This concerns me because timber harvesting can increase soil erosion, aka head towards more landslides. This can have direct impact on tribal communities stretched along these areas (see DEIS pgs 201-2). As said by Dave Werntz, a Science and Conservation director, “Forest policy must be grounded in science, shaped by collaboration, and accountable to the generations that will inherit these lands,” (https://conservationnw.org/in-rescinding-the-roadless-rule-the-usda-will-shatter-habitats-and-upend-decades-of-conservation-gains/ ). Thank you for your time.

As a resident of southwest Montana I use and benefit from roadless areas regularly and thus I oppose rescinding the roadless area conservation rule. I most regularly visit the roadless areas on the Custer-Gallatin National Forest to hunt, hike, and camp. The allure of these areas also brings a lot of money to our local businesses and economy. The roadless rule has conserved some of our nation's most intact fish and wildlife habitat for 25 years. It protects critical water resources and offers outstanding backcountry recreation opportunities. I feel that Secretary Rollins' statements on how recission would reduce wildfire risk, open vast timber resources, and improve recreation opportunities for the American public are unsupported. The Forest Service's own DEIS does not support these claims, but rather highlights research on how wildfire ignitions increase with greater road access and the timber value is way less than the cost to remove it. We also need to remember why the roadless rule was developed in the first place--there is a $10.8 billion backlog of deferred maintenance on some 370,000 miles of road. I support science-based forest management to address wildfire risk, forest health, and responsible access but rescinding the roadless rule is not the answer. Roadless does not mean unmanaged, and the current rule allows flexibility to address hazardous fuels reduction, grazing, hunting, fishing, and recreation. These multiple uses are important to many Americans! Please keep roadless areas wild so that future generations may experience that wildness and all that it offers as wildlife habitat and recreational opportunity.

The Roadless Rule protects river headwaters that sustain native salmon, steelhead, bull trout, and treaty-protected fisheries. USDA has not shown that the existing Rule prevents necessary fuels treatments; the Rule already permits substantial hazardous-fuels work. Removing protections is inconsistent with the Forest Service’s documented inability to maintain its existing road system. The DEIS fails to quantify foreseeable new road mileage, stream crossings, sediment and passage risks, and human-caused ignition risks. The proposal requires a fuller analysis of effects on treaty fisheries and meaningful government-to- government consultation with affected Tribes. USDA should withdraw the rescission and retain the 2001 Roadless Rule.

I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule (henceforth “Roadless Rule”), and I urge the Forest Service to select the 'No Action' alternative. Please see my detailed comments in my attached file. A summary of my arguments in the detailed comments is below. My comments and concerns about the Proposed Alternative primarily fall under the following categories: -Personal and Professional Experiences -Existing Exemptions, under No Action -Financial Costs of Proposed Action -Executive Orders, and relation to Proposed Action. For the Final EIS, the Forest Service should evaluate potential ecological impacts of the Proposed Action before finalizing any decisions. These impacts should include effects on hydrology, water quality, and sediment transport in mountain watersheds; effects on aquatic ecosystem habitats, not just for threatened or endangered species but also for other sensitive native species such as aquatic invertebrates, amphibians, fish, birds, and other mammals; biodiversity of forest plants, trees, and subsurface species; and impacts to non-motorized human recreation in the affected areas. The potential for road access to actually increase the frequency of wildfires should also be assessed. Impacts to tribal and other indigenous artifacts, sacred and cultural sites, and tribal treaty rights also must be considered. The FEIS should also explain why the option of Exceptions under the existing 2001 Roadless Area Conservation Rule are inadequate for the needs expressed in the Proposed Action, such that the No Action Alternative doesn't adequately meet those needs. Roadless areas in National Forests are public lands that belong to all Americans and are not just for private industry and resource extraction. The EIS must demonstrate that the Proposed Action provides benefits to all Americans above and beyond the values that Roadless Areas provide under the No Action Alternative, and not just to the timber or mining industry. It needs to show that the value, both in financial and ecological terms, of timber industry and mining under Proposed Action will offset the value of intact streams and water treatment, aquatic and terrestrial habitats, and reduced wildfire and management costs under No Action. This is a very tall order.

I am a resident of Utah, and I strongly oppose the proposed rescission of the 2001 Roadless Rule. I urge the Department to select the no-action alternative and keep the rule in place. 1. The rule works, and the public supports it. The 2001 Rule has protected undeveloped national forest land for 25 years, and the public supported it through extensive comment and hearings. Rescinding it removes a durable, nationwide protection. Each forest plan could then be revised more easily, with less public attention, to allow roads and logging. 2. The wildfire rationale is weak. The proposal says the rule limits wildfire suppression and active management. The rule already contains exceptions for road building related to public safety, and it has never prevented firefighting. Most fire ignitions and home losses occur near communities, not in remote roadless interiors. The Department should show data for any claim that the rule has blocked suppression, and it should weigh that against the evidence that new roads increase human-caused ignitions and spread invasive species. 3. Roads are a long-term liability. The forest Service already has a maintenance backlog on its existing road network. Building new roads in steep, remote terrain adds costs that taxpayers carry long after any timber sale ends. The draft EIS should present full lifecycle road costs, including maintenance, erosion, and decommissioning. 4. Utah's watersheds, wildlife, and economy depend on roadless land. Wasatch Front communities rely on national forest watersheds for drinking water. Roadless areas also provide big-game and native trout habitat, dispersed recreation, and the backcountry that sustains Utah's outdoor economy. The analysis should quantify harm to municipal water supplies and recreation revenue. 5. The rescission removes a safeguard against disposal and development. Utah's congressional delegation has openly advocated selling federal lands. Rescinding the Roadless Rule would strip protections from land that could later be targeted for sale or intensive development. Land with an existing road network is more likely to be developed, and roads would make it easier to justify transferring this land out of public hands. The Department should explain what it would do to ensure that rescission does not enable disposal. 6. The process is inadequate. Rescinding protections on roughly 45 million acres through a short comment window, with an extension of only 15 days does not allow meaningful public review of a draft EIS this large. The Department should extend the comment period and hold public hearings in the affected states, including Utah.

Dear Director: I am submitting these comments as an individual who has worked in mineral exploration in Southeast Alaska since 2009, and has lived in Ketchikan, Prince of Wales Island and Juneau. I now work as an independent consultant to companies exploring in the region, and these comments are my own. My first work in Southeast was at the Niblack project on Prince of Wales Island, where I was Project Manager from 2009 to 2020. Niblack has tidewater access and roads on patented mining claims, which supported underground development and exploration drilling. The Tongass had been temporarily exempted from the Roadless Rule in 2003, and in 2009 the Forest Service approved exploration drilling at Niblack in a Decision Memo. When a federal court reinstated the 2001 rule on the Tongass in 2011, its judgment allowed the drilling approved in 2009 to continue. However, our drill sites had since been revised based on underground exploration results, so the Forest Service halted our helicopter-supported surface program on National Forest land mid-season. At significant cost to budget and schedule, we moved crews to another project and returned in the fall to drill only from patented claims. A separate 2012 authorization allowed surface drilling to resume, and that was the last field program I managed before the project went into care and maintenance. That is the practical effect of the rule on Tongass projects. Since 2009 I have watched the Tongass move in and out of the 2001 rule with court rulings and changes in administration. The status of the Tongass under the rule has been reversed four times, in 2003, 2011, 2020 and 2023. Approval of exceptions has also changed four times: the Secretary reserved it from 2009 to 2012, it was delegated to regional foresters in 2012 and 2018, and in 2021 pending decisions were elevated to the Department again (DEIS pp. 3 and 6). Each change resets the planning assumptions for projects on the forest. This unpredictability makes it difficult to raise investment for exploration in Southeast and even more difficult to execute programs when the money is raised. Companies and investors generally understand that exploration in Southeast works with helicopters and barges. Most of the programs I've managed in my career, in and outside of Alaska, have been helicopter-supported, because it isn't practical to build a road to a prospect without a proven resource. However, drill pads and landing zones require cutting trees, which in my experience can fall under the same scrutiny as road building in the Tongass. Access for developing and operating a mine comes later, when a project succeeds and needs a road to advance. The companies I work with in Southeast have projects on state, BLM and private land, where access is decided project by project. Southeast is a mineral district, and its mineral belts don't follow political or ownership boundaries. Inside a Tongass roadless area, a mining road also needs a discretionary exception, on top of the environmental review and plan approval it already requires. Whether a successful project can build a road depends on which side of that boundary it sits. I was the Director of the Center for Mine Training at the University of Alaska Southeast in Juneau, which prepares people from the region for well-paying mining careers. In 2025 the average annual mining wage in Southeast was $134,545, more than twice the regional average of $66,796 (Southeast Conference, Southeast Alaska by the Numbers 2026). Jobs like these let people build a life without leaving Southeast. The operating mines, Greens Creek, Kensington and Dawson, provide most of them today. New ones depend on new discoveries advancing, and on the Tongass that relies on access. I support Alternative 2, rescission of the 2001 rule. Not once while working in the Tongass for over 15 years did I encounter someone wanting to build a network of roads throughout the forest. The residents of Southeast Alaska are among some of the most environmentally aware people I have met and care deeply about protecting what they enjoy about living here. Every road would still require site-specific environmental review, consultation with Tribes, the subsistence protections of ANILCA and approval under the Forest Service's minerals regulations. I would rather those decisions be made project by project, by people who know the ground, than set nationally and reversed every few years. Thank you for considering these comments.

The Forest Service should keep the Roadless Rule intact exactly as it is, utilizing Alternative 1 in the current DEIS. I am deeply disappointed by the proposal to remove the Roadless Rule. The areas currently protected by this policy provide critical benefits to communities across the country, including clean drinking water, wildlife habitat, opportunities for outdoor recreation, and protection from the many destructive impacts of overdevelopment. Opening these lands up to logging and other development strongly increases the risk of wildfires, which already destroy an average of 7 million acres, thousands of structures, and an average of 20,000 people each year from SMOKE alone. This fails to take into account those who die directly from these fires. The Forest Service itself said in 2025 that it was difficult to estimate such effects of this rule being repealed. Our greed for more possessions and money should never be given priority over the protection of life and the well-being of people, which necessitates the protection of clean water and air and access to unadultured nature. These lands are an important part of the character and identity of many communities and provide places for people to hike, hunt, fish, camp, ski and otherwise enjoy the outdoors. The Roadless Rule has provided consistent, nationwide protections for these special places for decades. The Forest Service should not weaken those protections or open currently protected roadless lands to new development. I fervently request the Forest Service to pursue Alternative 1 and retain or preferably, strengthen the existing Roadless Rule protections.

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I am someone who has hiked and camped in the National Forest System and understands what could be lost by implementing the proposal. As is, the rule protects about 44 million acres of the last undeveloped land in the National Forest System, which provide fish and wildlife habitat, supply drinking water, and offer backcountry recreation. Rescinding it would remove the only national protection these areas have, opening them to logging, and mining and energy development. The wildfire rationale does not justify full rescission. To begin with, new roads can often raise fire risk, since most wildfires are started by people. And the 2001 rule already allows cutting of small-diameter trees to reduce wildfire risk and permits road construction when needed to protect public safety from an imminent threat of fire. The agency's own figures show that 11.3 million acres of roadless land are already near existing roads. Lack of access therefore cannot explain why only 5% of high-hazard roadless acreage has been treated since 2014. Limited funding and staff appear more likely. The proposal's purpose and changes extend beyond wildfire policy. The USDA announcement ties the proposal to executive orders directing expanded timber production, energy development, and resource extraction in Alaska. This suggests the rule would mainly open roadless areas, such as Alaska's Tongass National Forest, to commercial extraction. Commercial logging often removes the large, fire-resistant trees that fuel treatments are meant to preserve and protect. The Forest Service also has a multibillion-dollar backlog of deferred road maintenance. Adding roads it cannot maintain would increase erosion and sediment in the streams that supply drinking water to downstream communities. I urge the Forest Service to withdraw the proposed rule, keep the 2001 Roadless Rule in place nationwide, and address wildfire risk through the underused fuel treatments that are already permitted. Thank you for the opportunity to comment.

I am writing to oppose dropping the 2001 Roadless Rule and to ask you to choose Alternative 1, No Action, to retain that rule. I am a wildlife biologist, an outdoor recreation enthusiast, and someone who lives on a family farm that relies on clean water and functioning ecosystem processes for economic production. North America is a hotspot of global biodiversity for many freshwater species. Roads have both short and long-term negative effects on our native freshwater species. They can lead to both pulse and chronic sediment input through erosion, can permanently isolate populations where they cross streams when hanging culverts, extensive shading, or loss of natural substrate occur. A recent review documents the effects of roads on freshwater biodiversity, and these factors should have been given serious attention (Algera et al. 2026). There are many other aspects of ecosystem function and biotic integrity that are at risk with increased roads, as documented in a review by Midlrexler et al. (2026). Important ecosystem processes such as nutrient cycling and water cycling are driven by complex interactions among native plants, microbes, insects, and salamanders (often the most abundant vertebrates and major components of biomass) on the forest floor. When invasive plants spread in our forests and grasslands, there are cascading effects on leaf litter decomposition and soil chemistry, drastically changing the ability for our native species, including some of our important timber trees and medicinal plants, to grow and survive (Liebhold et al. 2017, Jones and Grenz 2023). Forest roads and skid trails are a major source of the spread of invasive plants (Buhaly et al. 2025, Dai et al. 2025). This spread creates risks and costs to forest industry, one of the most important economic drivers in many regions of our country. The costs of invasive species to the forestry and agriculture industries in Canada has been estimated at over $7.5 billion per year and in the US costs of damage from invasive plants has been estimated at $21 billion per year, with $700 million of that being costs to forestry operations (Jones and Grenz 2023). Until we develop much improved practices for reducing the spread of invasive plants, we would be wise to continue to restrict road-building and protect healthy forests. The proposed rule contradicts current scientific understanding of the effects of roads on wildfire risk in our national forests (Kilbride et al. 2026). High risk to humans from wildfires occurs at the interface of residential development and forests, not in large expanses of roadless areas. Legitimate concerns among the public about wildfire danger should not be used as an excuse to rescind the Roadless Rule, when other approaches should be prioritized. Knowing how popular recreation is in roadless areas, I was surprised by the statement in the Summary of Potential impacts that “Losses in economic benefit to recreationists are most likely to be associated with the operable areas of current IRAs and could be an estimated $6.1 million annually.” Then in a subsequent section on Minerals and Energy, the summary states “Under this proposed rule, there is additional flexibility for potential future leasable mineral development (primarily oil, gas, and coal) opportunities and it is reasonably foreseeable that some development could occur in potentially affected inventoried roadless areas, resulting in associated costs and benefits. . . . Although the estimated annual economic effects span a wide range, the additional impacts associated with the proposed rule could exceed $100 million. Some industries, including recreation and tourism, could experience trade-offs as a result of the proposed rule.” If eliminating the roadless rule would allow an additional $100 million in economic activity from mineral and energy extraction, certainly that would have a negative impact on recreation, but only the roads themselves, not the extraction that would follow, were accounted for in your estimate of costs to recreation. It is unreasonable to calculate costs to recreation from the roads alone, and not the increased mining and energy development, but then to compare that to the economic benefits of mineral and energy development. The value of healthy forests for clean water, recreation, and as seed and soil microbial banks and reserves for a healthy forest industry, seem to be undervalued. I did not see any of the literature cited above (references in attached document or below) included in the Draft Environmental Impact Statement. The Draft EIS glossed over some of these concerns, but did not thoroughly evaluate the severe negative consequences of building roads in forests that have been protected in recent decades. It appears that both the environmental and economic analyses are flawed. Please take the no action alternative and continue the 2001 Roadless Rule.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and urge USDA to select the No Action alternative. The agency's own analysis does not demonstrate benefits sufficient to justify eliminating nationwide protections. USDA estimates that if annual timber harvest occurred across all identified operable areas—a scenario the agency itself describes as unlikely because of budget, operability, and market constraints—the resulting revenue to the Treasury and Forest Service would be approximately $5.2–$11.4 million per year. At the same time, USDA estimates approximately $6.1 million per year in lost economic benefits to recreationists. The agency further acknowledges that potential management efficiencies would be incremental and constrained by road costs, maintenance funding, and other limitations. Removing national protections from tens of millions of acres should not rest on benefits this modest and uncertain. USDA should provide a transparent accounting of the reasonably expected costs and benefits of rescission, including non-market values such as carbon storage, water quality, wildlife habitat, scenery, and opportunities for quiet and remote recreation. Some of the most consequential reasonably foreseeable effects are deferred to future forest-plan and project-level decisions. Rescission would remove the national prohibitions that currently constrain road construction and timber harvest, while future forest-plan amendments could permit additional development within currently protected roadless areas. Those later decisions are central to understanding the practical consequences of rescission. USDA should analyze a reasonable range of foreseeable management responses, including effects on carbon storage, wildlife habitat, water quality, road construction, and timber harvest, before making a final decision. A national conservation floor remains necessary. Colorado and Idaho developed state-specific roadless protections through extensive, state-focused processes, and the proposed rule appropriately leaves those protections in place. Elsewhere, rescission would shift responsibility to individual forest plans and subsequent amendments. That would fragment decisionmaking and require the public and Tribal governments to participate repeatedly in separate processes to preserve protections now supplied by a uniform national rule, while well-resourced commercial interests can sustain pressure across many forests at once. A nationwide baseline provides consistency while still allowing appropriate exceptions. Climate effects also deserve fuller analysis. Intact roadless forests store carbon and provide ecological resilience. Additional road construction and timber harvest can reduce stored carbon and affect future sequestration. The final EIS should quantify, to the extent reasonably possible, the carbon consequences of rescission under realistic management scenarios rather than limiting the analysis to the immediate regulatory act. This is not the time for us to ignore the climate crisis. Wildfire management does not require wholesale rescission. The existing rule does not categorically prohibit hazardous-fuels treatment, although USDA has identified circumstances in which its restrictions can constrain mechanical treatment or suppression. If particular restrictions impede necessary work near communities or critical infrastructure, USDA should evaluate narrower amendments or streamlined exceptions targeted to those circumstances, without removing protections from remote backcountry. USDA should also account for its own acknowledgment that increased road access can increase human-caused ignitions. The rulemaking process also raises concerns. USDA reports receiving more than 220,000 comment letters on behalf of over 625,000 individuals and organizations during scoping, and independent tallies indicate the overwhelming majority opposed rescission. USDA also reports that most Tribal governments it consulted oppose rescission and identified inadequate government-to-government consultation as a central concern. Before final action, USDA should complete meaningful Tribal consultation and provide additional opportunities for public participation. For these reasons, I urge USDA to withdraw the proposed rescission and select the No Action alternative, retaining the 2001 Roadless Area Conservation Rule. Seattle, WA Bruno

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This reckless action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the Agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in New York, NY and spend time recreating in upstate New York, along the Appalachian Trail. The Tongass National Forest in Alaska has long been a place I've dreamed of visiting. Under the agency’s proposal, protections for nearly 45 million acres of wild, public lands would be eliminated. The economics of these attacks on the Roadless Rule do not add up. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads rarely, if ever, used. According to the DEIS, the Forest Service could build new roads across 18.2 million acres. This would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion according to the DEIS. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access, resulting in a loss of $9 million in annual visitor spending in local communities. Beyond the economic folly, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and serve as critical carbon sinks in the fight against climate change. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. How would the agency ensure these populations and their habitats aren’t further degraded without protection of the Roadless Rule? The DEIS also states that “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” Communities across the country would lose protections to their drinking watersheds. How would the agency ensure that these watersheds remain intact and that water sources are not compromised from increased risk of erosion and sedimentation? Once roads and clearcuts fragment these landscapes, the damage is permanent. In the DEIS, the agency admits that “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. I am concerned that removing Roadless Rule protections would increase fire risk in our nation’s backcountry forests. Lately, I am appalled by the USDA’s decision to pursue this rollback through an abridged and inadequate public comment process. The original Roadless Rule was created after the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. During last fall’s comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with over 99% of comments opposing the proposed rescission of the rule. During the legally required Tribal consultation process, the agency found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission. Its analysis concedes that timber harvest and road construction in these areas “could have long-term negative effects on Tribal rights and interests.” Now, the agency is attempting to dismantle these protections through a rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. Despite the shortened comment periods, the American public has already made their voice clear: keep the Roadless Rule in its full form in place. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Instead of rolling back protections, the agency should strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Sixty years of returning to the Wallowa-Whitman National Forest, watching it become more frequented as more Americans discover its beauty, has given me a conviction that what remains wild there must not be handed over to roads and extraction. My grandfather hunted elk and deer on the forested slopes near the Grande Ronde River. I hiked and camped there as a girl with my mother and sisters, in country that was beautiful, quiet, and isolated. The Tower wilderness area, all 52 acres of it, and the Upper Grande Ronde wilderness area, 11,723 acres in the same forest, represent exactly the kind of untrammeled ground that the 2001 Roadless Area Conservation Rule was built to protect. I am writing to oppose its rescission without reservation. The economic case for this rescission cannot bear examination. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal production, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from negative $92 million to positive $199 million. That range does not establish a net benefit. It also does not account for a road maintenance backlog already standing at $6.9 billion. I ask the agency to reconcile this proposal with its own numbers and explain how construction that cannot demonstrate a net benefit justifies expanding a system the agency already cannot afford to maintain. The agency has tried state-by-state approaches before and failed in court. Its own record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and 1,522 municipal water intakes in the Pacific Northwest region sit in watersheds containing affected roadless areas. Fragmenting that protection through local decision-making is precisely what the Ninth Circuit rejected. The agency must explain how this proposal avoids the legal deficiencies identified in that prior litigation. I think about clean water every time I think about that forest. The soil and cover of unroaded country filter what flows downstream, and what flows downstream eventually reaches people. The agency's own analysis finds that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. That sediment enters the same watersheds that feed municipal intakes and the same streams where the animals I have watched for sixty years, elk, mule deer, bear, the mink and beaver and birds of the Tower area, depend on clean, cold, undisturbed water. The agency must account for these downstream consequences and explain what replaces the filtration function that intact roadless watersheds currently provide. The Tower area's 52 acres are already small. Putting a road through it would break up the habitat of mule deer, cougar, bobcat, bear, and the many other creatures that cross that ground, and fragment their social structures. The agency's own citation found elk survival rates rose during a road closure and fell again when the gates were removed. Its own record on mule deer documents that roads built for extraction may alter migration routes and increase movement speed. Its own record on bear notes that open roads increase contact, conflict, habituation, and ultimately mortality. What this proposal would do to what remains of that country is not a projection. The agency has already documented the mechanism. I expect a direct response on how the proposal addresses these findings as they apply to the inventoried roadless areas in the Wallowa-Whitman. Finally, my sixty years of returning to this forest, and my grandfather's generation before me, are precisely the kind of reliance interest the agency invited when it solicited, in its own words, "any reliance interests in the current rule that could be affected by this proposal" at 91 FR 53830-31, and then weighed none of them in its Cost Benefit Analysis. Under the legal standards governing agency reversals, that omission is not a procedural footnote. These comments, and the thousands like them, must be identified, considered, and weighed before any final action is taken. Our public lands belong to generations to come, and this generation has not been given the authority to trade them away for less than half a percent of national timber output. Sincerely, Polly Estabrook, Los Angeles, CA

Dear Secretary Rollins and Chief Schultz, I am writing to voice my strong opposition to rescission of the Roadless Rule--a very popular and flexible rule that has thus far successfully protected forests, wildlife, the climate, and communities across the country. I am particularly concerned about climate change and follow climate policy as a citizen. This rescission ignores the carbon implications it entails--a grave omission. The Roadless Rule matters to me. It respects the value of intact ecosystems and their role in maintaining health--not just of the forests themselves and the flora and fauna those forests contain--but our own human health. Roadless Rules protect clean air and clean water. They mitigate climate impacts. Geographic locations with roadless areas in place have even been shown to increase local revenue and standard of living. The Roadless Rule reflects human inclusion in the whole of the environment. I live in western Oregon and am always filled with awe when I hike in the forests here. The clean air, the smell of evergreen, and the silence always bring me a sense of peace and wholeness. We disturb these intact forests, through roads and industry, at our own peril. It makes me proud of my country when we decide to protect the beauty and sanctity of nature from unconstrained human development. Regarding the Eagle in the Mt. Hood National Forest, Oregon, near where I live: Without the Roadless Rule, the Eagle IRA in Mt. Hood National Forest loses the protection that currently maintains Pacific Northwest Lowland Mixed Hardwood-Conifer Forest (North Pacific Lowland Mixed Hardwood-Conifer Forest) (GNR, 1.1%, ~178 acres) as intact habitat for Oregon Sullivantia (Sullivantia oregana, G2,). The species is documented present and ecologically associated with this ecosystem through two independent data sources — rescission puts both at risk simultaneously. "70% of remaining forest is within 1 km of the forest's edge, subject to the degrading effects of fragmentation. A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time, with average species loss >20% after 1 year and >50% after 10 years." — PMC / Science Advances, 2015 Oregon Sullivantia (Sullivantia oregana, G2,) does not merely occupy the same space as Pacific Northwest Lowland Mixed Hardwood-Conifer Forest (North Pacific Lowland Mixed Hardwood-Conifer Forest) in Eagle — NatureServe documents an ecological dependency. Road construction that compacts soils, disrupts hydrology, opens canopy gaps, and introduces invasive species into this ecosystem directly undermines the habitat conditions this imperiled species requires for persistence. There are SO many reasons that rolling back the 2001 Roadless Rule is a bad idea. I have only commented on a few here but could have spent hours outlining countless more. I trust other citizens will have touched on these concerns. It strikes me from the research that I have done that the authors of the rescission have not fully addressed the myriad detrimental effects that opening further areas to roadbuilding will create. The Roadless Rule is a popular and successful rule, supported by individuals on both sides of the political spectrum. It is flexible, allowing for roads when they are truly necessary and allowing individual states to modify the guidelines as appropriate. Rescinding this rule, it seems to me, will benefit only the owners of the extractive industries who can take advantage of opened-up wild spaces, to the detriment all others. Even the argument that the rescission will help with fire suppression strikes me as unfounded based on studies showing that wilderness and inventoried roadless Areas have the lowest ignition densities of any land category studied. Please do not rescind this rule. With appreciation, Stacey A. Danner

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain it and select the No Action alternative. The Roadless Rule protects approximately 58.5 million acres of inventoried roadless areas across our National Forest System. These lands provide clean water, wildlife habitat, hunting, fishing, hiking, camping, solitude, scenic values, and opportunities to experience public lands without permanent roads and intensive development. The Department describes this proposal as returning decisionmaking to local Forest Service officials. In reality, it removes a national baseline protecting these landscapes from road construction, road reconstruction, and most commercial timber harvesting. USDA’s own analysis acknowledges that rescission could create opportunities for permanent road construction on approximately 18.2 million acres and expand timber-management opportunities on approximately 4.8 million acres of forested roadless areas. It also acknowledges that future forest-plan amendments could expand these impacts. Wildfire does not justify nationwide rescission I support targeted, science-based wildfire mitigation where necessary to protect communities and infrastructure. However, wildfire risk does not demonstrate that protections should be removed from 58.5 million acres. The Forest Service’s own research examining nearly two decades of monitoring found that forests with and without roads burned at similar rates and that the absence of roads had not prevented fuel-management activities in roadless areas. It also found non-native plants were twice as common near roads. Roads may provide access for some fire-management activities, but they also fragment habitat and increase human access and potential ignition sources. If specific areas require treatment, the Forest Service already has authorities and exceptions under the existing rule. NEPA is not a substitute The proposal relies on future NEPA review and existing forest plans as safeguards. These are important, but they do not provide the same protection as the Roadless Rule. NEPA is primarily procedural; it does not prohibit road construction or timber harvesting. The Roadless Rule establishes a substantive landscape-scale baseline before individual projects are proposed. Removing that baseline means the public may have to fight repeatedly, forest by forest and project by project, to preserve landscapes already identified as deserving protection. Economic and infrastructure costs USDA’s analysis estimates approximately $6.1 million in annual recreation-related losses and acknowledges that additional economic effects could exceed $100 million. The analysis should fully account for recreation, tourism, clean water, wildlife habitat, carbon storage, and scenic values that could be lost. The Forest Service also faces approximately $6.9 billion in deferred road and bridge maintenance. Expanding the permanent road network would create additional construction and long-term maintenance obligations. Before opening millions of acres to new roads, the Department should demonstrate why this is financially responsible. Tribal concerns The proposal states that the majority of Tribal governments consulted opposed rescission, citing threats to Tribal sovereignty, cultural survival, sacred sites, traditional gathering areas, water quality, subsistence, and ancestral homelands. These concerns deserve substantial weight. Removing a nationwide layer of protection should not proceed while Tribal governments are warning that it could harm these resources and relationships. Preserve the national baseline Local knowledge is important, but some public-land values are national in character. A national standard prevents roadless areas from receiving dramatically different protection simply because priorities differ between forests or regions. Once a permanent road enters an intact landscape, its fragmentation and development footprint cannot simply be reversed if anticipated benefits fail to materialize. I respectfully request that the Department: 1. Withdraw the proposed rescission and retain the 2001 Roadless Rule. 2. Select the No Action alternative. 3. Fully account for recreational, ecological, cultural, water, wildlife, and economic benefits that could be lost. 4. Demonstrate that rescission is necessary to accomplish wildfire and forest-health objectives that cannot be achieved under the existing rule. 5. Give greater weight to Tribal concerns. 6. Consider the long-term cost of expanding the Forest Service road network. Our national forests belong to all Americans. Inventoried roadless areas are an increasingly rare public resource. We should not trade permanent landscape values for uncertain future opportunities to build roads and harvest timber. I strongly oppose rescinding the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain these protections.

I strongly oppose the proposal to rescind the 2001 Roadless Rule (the Rule) and wholesale open about 45 million acres of national forest roadless areas to logging, mining, drilling, roadbuilding and other development – without more careful consideration of the great value each area provides to Americans, such as: A)Providing critical watershed and clean water supply to an increasingly drought-stricken West and other parts of the country. B)Offer essential habitat for wildlife, fish and plants that suffer from shrinking, fragmented and climate-shifting habitats. The roadless areas provide refuges them to retreat to, and migrate across, as their habitats shrink or shift. C)Give important recreational opportunities -- and a vital escape from civilization -- for hikers, bikers, campers, horse riders, hunters and fishermen. These contributions, which have enormous economic value to nearby communities and the whole nation, are usually irrevocably lost when the roadless areas are developed. Finally, a main justification for rescinding the Rule is wildfire risk. There are two flaws in that justification: 1) Research cited by the Wilderness Society shows that wildfires are less likely to ignite in roadless forested areas vs. areas with roads; and 2) Wildfire risk does not justify removing protection for some of the most pristine, fish & wildlife rich, and spectacular roadless areas - the approximately 14.7 M acres of roadless areas in the Tongass and Chugach national forests —roughly one-third of area protected under the Rule. With their maritime climates, these forests tend to have a dramatically lower fire risk, e.g., the Tongass recorded only five wildfires totaling approximately 0.6 acres in 2025. Thus, I urge the Administration to reconsider rescinding the Rule. My opinion is based on: 1) my experience as a citizen involved in national forest planning going back to the mid-1980s; 2) my experience as a volunteer wilderness ranger in Wenatchee National Forest; and 3) My visits to scores of national forests around the country and several of the affected roadless areas.