Read the comments.

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

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.

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

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.

Docket No. FS-2025-0001 Document: FS-2025-0001-223869 Proposed Rescission of the 2001 Roadless Area Conservation Rule Comment of Nicholas E. Holshouser, nicholas@wanderingnature.com (roadless.org; Wandering Nature, LLC) I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and ask the agency to select the No Action alternative. This submission has two attachments. Attachment 1 is my Statement of Record Deficiencies. Attachment 2 is my full comment. This text is the cover; the attachments are the comment. Who I am. I developed roadless.org to support opposition to the rescission. I have advocated for the Pisgah and Nantahala National Forests for more than twenty years, and I know their roadless areas on the ground, the Middle Prong Addition above all. Part One of Attachment 2 states my interest and the harm the rescission would do to habitat connectivity, migratory birds, cultural resources, recreation and local economies, and water quality, with references. The record is not reviewable as published (Attachment 1). The Draft EIS record cannot be fully checked by the public asked to comment on it: of 224 factual claims examined, 164 carry no citation; of 398 entries in the DEIS bibliography, 105 cannot be obtained; 49 entries are never cited; 14 claims cite sources silent on the figure attributed to them; 12 rest on internal agency sources; seven sources the footnotes rely on are absent from the References section; and the government-letters volume is misfiled in the record index. Across the five record documents, 927 of 1,461 cited sources checked remain paywalled, print-only, or dead-linked after a renewed effort to obtain them; Appendix B of Attachment 2 lists them. On September 10, 2026, I filed FOIA Request No. 2026-FS-WO-07195-F for the agency's copies. I request that the agency produce or link those sources in the docket, cure the citation gaps, and extend or reopen the comment period so that the public may review a checkable record. I reserve the right to supplement this comment upon production. What the comment contains (Attachment 2). 267 numbered items, each a self-contained concern on a specific passage of the Draft EIS, its Cost Benefit Analysis, the two draft Biological Assessments, the Tribal consultation summary, or Volume III, with a pinpoint citation and a specific request. The items are organized under the Draft EIS's own subjects, Parts Two through Eighteen, and consolidated into eight requests in Part Nineteen. Appendix A indexes every item. I request that the agency respond to each item individually in the Final EIS and cite where each action taken is accounted for. AI and software in comment processing. Item 267 asks the agency to disclose every software and AI tool used to sort, classify, summarize, or respond to the comments on this rule, to validate those tools, and to place the complete record of their use in the administrative record. Attachments: (1) Holshouser_Deficiency_Statement_FS-2025-0001.pdf, 5 pages; (2) Holshouser_Comment_FS-2025-0001.pdf, 654 pages, a single file containing Parts One through Nineteen and Appendices A and B.

Dear Joshua White, I was born and raised in Anchorage, Alaska, in a family shaped by the health and wellbeing of our lands. My childhood memories are full of fishing, hiking, camping, and reveling in the wonder of public lands. I have spent much of my adult life in these same places, and have grown to have a close relationship with the Tongass through my family purchasing and tending to 75 acres of land immediately adjacent to the national forest on Kupreanof Island. It is a deep and precious privilege to be shaped by the places we spend our time together, and to care for them for the rest of my life. 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 have had the experience of living in places across the West coast, and have known what it means to have no connection or proximity to intact and healthy ecosystems. It is an astoundingly precious thing to know what a place is like when it is whole, abundant, and cared for. The Tongass is singular in this regard, and the value of that touches so many dimensions of Alaskan and American life. From the subsistence and recreation driven by the wildlife and fish who call the forest home, to the industries built up around these same resources - sport fishing, guiding and hunting, commercial fishing, and tourism. These industries are sustained in perpetuity, consistently and reliably in a way that few if any other industries in our state are. To consider any action which would disturb or threaten these industries would be a grievous mistake, and one that Alaskans would be left to bear the brunt of. The prospect of building road systems and increased scale of logging would undeniably hurt the exact realities which make this place so valuable. I ask the Forest Service to retain the roadless rule. 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. If anything, the greatest priority the Forest Service could hold is the restoration, protection, and maintenance of the health of the ecosystems and populations which inhabit the Tongass and other roadless areas within our National Forests. I say so with much gratitude for the work which has already been done, and the hope that this work will continue for generations. 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 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. Jonas Banta

I have lived in Sitka since the 1990s and raised my three sons here. I am writing to ask the Department to withdraw its proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66) and leave the rule as it stands. In the decades since we made our home here, wild food has been at the center of how my family eats: deer from the forest, salmon from the water around us, and boys who grew up knowing where their food comes from. The roadless parts of this forest are not empty space on a map. They are the reason the deer and the salmon are still here, and they are where we have hunted, fished, and gathered for as long as we have lived in this town. The proposal asks us to trade that for very little. The department's own analysis puts the best case for the timber industry at $4.6 to $10.6 million a year, against annual impacts that could exceed $100 million, and it acknowledges that new road building would be limited by budgets and by a $6.9 billion backlog of maintenance on roads that already exist. That is a bad trade on its own terms. What the numbers cannot capture at all is what the deer and the salmon are worth to a household, and that is the part that, once gone, does not come back. The Forest Service plans to hold ANILCA Section 810 subsistence hearings on this proposal. I ask that those hearings happen before any final decision and that what families like mine say in them carry real weight. For us this is not an abstract land-use question. It is a question of where our food comes from and what will be left for our sons. Please withdraw the proposal and leave the rule as it stands. Sincerely, Jenn Lawlor Sitka, Alaska

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to urge the Department to withdraw the proposal and select the No Action alternative in the Draft Environmental Impact Statement. I live in Seattle and spend much of my free time hiking, camping and paddleboarding in and around our national forests. I have hiked on the Pacific Crest Trail in California, Oregon, and Washington, and have personally experienced the value that these undeveloped spaces provide to outdoor recreation enthusiasts. I also work professionally in land use planning, and I would like to comment from both perspectives. 1. The rule already allows the forest-health work the Department says it needs. The proposal frames the rule as a barrier to forest management. But the 2001 rule already permits cutting small-diameter timber to reduce wildfire risk and improve habitat. It also allows road construction for public health and safety and for reserved rights. The DEIS should identify specific fuel-reduction projects that the rule actually prevented. If those cases are rare, a full rescission is far broader than the problem it claims to solve. 2. New roads add risk and cost rather than reducing them. Roads are a major source of human-caused ignitions, sediment in streams, and invasive species. The Forest Service already has 370,000 miles of forest roads with a multibillion-dollar maintenance backlog on its existing road system. Diminishing protections for nearly 45 million acres would add to a liability the agency cannot fund today. The cost-benefit analysis should fully account for long-term road maintenance and decommissioning costs, along with downstream water quality impacts. More than 60 million Americans depend on these watersheds for drinking water. In addition, the roadless areas offer abundant outdoor recreation opportunities such as hiking, hunting, fishing, camping, and other activities. Combined, the outdoor recreation economy generates $730 billion annually, far more than timber sales. 3. Durable, predictable rules have value. In land use, a stable framework that everyone understands is worth a great deal. That predictability helps communities, recreation businesses, Tribes, and local governments plan. For 25 years, the Roadless Rule has given that certainty. Replacing it with forest-by-forest decisions would mean decades of plan amendments, litigation and uncertainty. The proposal does not account for these transition costs. 4. The public has already spoken, and the process has been too short. USDA's August 2025 Notice of Intent drew more than 600,000 comments, about 99% of them opposed to rescission. The current comment window is also far shorter than past rounds. Before the original rule was adopted, the agency held more than 400 public meetings across the country after issuing the proposed rule. During the 2005 rescission attempt, the comment period totaled 182 days. A decision affecting nearly a third of the National Forest System deserves a comparable process. I respectfully ask the Department to withdraw the proposed rule and retain the 2001 Roadless Area Conservation Rule.

Dear Joshua White, I've lived in Sitka on the Tongass almost all my life. I process fish deer caught on the Tongass to fill my families' freezers, I harvest mushrooms and berries in the woods and I depend on these places for recreation, health and artistic inspiration. This place is special, and I'm frankly tired of telling the USDA every year why it's so special. 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 don't want to endanger Alaskans' ways of life by rescinding the Roadless Rule. It will hurt our economies, like our visitor industry and commercial fishing. 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. These are things I've said at past Roadless hearings, and heard Alaskans say multiple times for the last 8 years when I moved back to my hometown here in Sitka. There are so many better things that the Forest Service can support. In fact, I believe many great ideas from Alaskans exist in a new Forest Plan draft: keep the Roadless Rule, invest in recreation and young growth timber, support commercial fishing. Do these things instead. 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. Ryan Morse

Dear Joshua White, Visiting the Tongass was one of the most life-altering events of my 40 years on this planet. The unspeakable beauty of such a special, sacred land has stuck with me since my trip over ten years ago. 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. The planet is in crisisthe last thing we should be doing is further jeopardizing the small amount of untouched land we have left. Both humans and non-humans alike will suffer by opening up this land to capitalistic interests. 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. Protect the land and the animals and people who live on it! The Forest Service should serve the forests first and foremost, and increased logging and construction has no place in being a steward of this precious land. 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. Christine Forster

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. For the reasons below, I urge the agency to adopt Alternative 1, the No Action alternative. I live in rural West Marin, California. Ancient forests have been central to my life since childhood; camping and hiking among old trees has connected me to my mother, to her family, and through them to my ancestors. I'm writing about the Dark Divide Roadless Area in southwest Washington, which conservation groups describe as one of the largest remaining old-growth forests in that part of the state. Ancient forests are where I have most directly experienced the sacred. They are also a tangible example of how complex systems evolve over centuries, and how diverse species adapt and sustain one another. The delicate balance of interdependency found most fully in old-growth forests, achieved over long spans of time, is an irreplaceable living model as we work to preserve ecosystems across our planet, to overcome short-term thinking, and to foster a culture that is more cooperative and less extractive. Cutting roads into old growth is like cutting into a living body: it opens the way to logging and careless heavy use that can wound what took centuries to form. We have very little of this natural space left. Public forests belong to all of us, including places I may never walk through. Rescission would remove the national protection that keeps roads and logging out of areas like the Dark Divide. Old-growth stands cannot be restored on any human timescale. The DEIS itself concedes that rescission would "adversely affect" 327 threatened and endangered species and 71 designated critical habitats, and that road construction is the largest source of sediment from timber harvest, a major cause of water-quality degradation. It also acknowledges that road density raises the number and frequency of human-caused wildfire ignitions, which undercuts the claim that rescission serves wildfire safety. I ask the agency to explain how it would prevent these harms in the Dark Divide if the national rule is removed. The economics also don't add up. The DEIS says new roads could be built across 18.2 million acres, adding to a maintenance backlog already above $6.9 billion, while rescission would reduce recreation spending in nearby communities by an estimated $9 million a year. The process is also inadequate. More than 99% of comments in the 2025 round opposed repeal, and the agency's own Tribal consultation found that most Tribal governments consulted oppose rescission. Decisions of this scale deserve a longer comment period and a real response to what the public has said. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1. Laura Trippi

Dear Secretary Rollins and the U.S. Forest Service, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge you to retain the rule in its entirety. The wildfire rationale does not hold up • The Forest Service’s own draft environmental impact statement found that repealing the rule would deliver little or no wildfire risk reduction while increasing federal road maintenance costs. • Ninety-five percent of wildfires are started by people, and nearly two-thirds of those ignite along roadsides. Building more roads would likely increase, not decrease, fire starts. • The analysis projects only a 5–10% increase in timber harvest—adding roughly $5–11 million a year to a $288 billion industry—a trivial gain against the loss of protections for nearly 45 million acres. The timber production argument is contradicted by current industry conditions • U.S. sawmill capacity has dropped 6% in a single year, production has fallen for two straight quarters, and the mill workforce is at its lowest level since 2010. • Thirty-five hardwood sawmills closed in 2025 alone, and the industry has lost around 40,000 jobs since 2022. • In South Carolina, Canfor closed its Darlington sawmill in June 2025, and Interfor recently curtailed production at its Summerville plant, laying off about 90 workers. • The problem is demand, not supply. Weak housing construction and collapsing pulpwood markets mean there are no buyers for additional timber. Opening more forest to harvest does not create markets that do not exist. The rule protects critical resources and has broad public support • It safeguards drinking water for roughly 25 million Americans across 82,000 miles of streams. • Removing the national baseline would fragment wildlife habitat and shift decisions to local plans without guaranteed public involvement or environmental review at that scale. • The rule has survived 25 years of litigation. In the 2025 notice-of-intent period, more than 600,000 comments were submitted, over 99% opposing repeal. I have a deep personal connection to these landscapes. I have spent time in the roadless areas of the Pisgah and Nantahala National Forests in North Carolina (including Big Ivy, South Mills River, Craggy Mountain, and Wilson Creek) and in the Francis Marion and Sumter National Forests in South Carolina (including the Andrew Pickens district). I have also spent time in the Pike-San Isabel National Forest near Buena Vista, Colorado, where the Collegiate Peaks, Mount Massive, and Mount Elbert roadless areas provide world-class backcountry recreation. While Colorado’s lands remain protected under the state’s own 2012 roadless rule, the principle matters everywhere: these places are irreplaceable. Once roads and logging enter them, their character is gone forever. I respectfully request that the Forest Service select the alternative that retains the Roadless Rule as is. Sincerely, Matt Lugar

I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This 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 Kenai, Alaska and spend time recreating in nearby Roadless Areas like the Chugach National Forest. I also hope to visit other Roadless Areas across Alaska to hike, camp, fish, forage, and enjoy nature. Under the proposal, Alternative 2 and 3 would eliminate protections for millions of acres of wild, public lands in Alaska. The economics of these attacks on the Roadless Rule do not add up. Building logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely used. According to the DEIS, the Forest Service could build new roads across 18.2 million acres in the short term. This would significantly inflate the deferred maintenance backlog. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. Beyond the economics, 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 a changing climate. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In Alaska, this includes listed species such as the Chinook salmon, among others that are understudied and therefore not fully understood. 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.” Alaska has exceptional water quality, largely due to the protections of the pristine wilderness areas. Roadless Areas would lose protections under both Alternatives 2 and 3. 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.” I am concerned that removing Roadless Rule protections would increase fire risk in our nation’s backcountry forests. The DEIS also acknowledges that increased road construction and timber harvest are likely to “introduce and spread invasive plant species due to ground disturbance.” Invasive plants tend to be more flammable, leading to higher wildfire risk, and often outcompete native plant species, further endangering our pristine public lands. The USDA’s decision to pursue this rollback through an abridged and inadequate public comment process is appaling. 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 the comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with majority 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 for decisions of such sweeping consequence. The public comment period should be extended to no shorter than a total of 120 days. The American public has already spoken: keep the Roadless Rule in its full form in place. The Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. For the reasons listed above, I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

To the USDA Forest Service: I live in Tumalo, Central Oregon, between Bend and Sisters. Wildfire threatens my home, my property, and my livelihood. The Forest Service says rescinding the Roadless Rule will help with wildfire. I am writing to urge you to retain the rule in full (Alternative 1), because the evidence says rescission would make me less safe and would not address the real problem. Forest Service Chief Tom Schultz says more than 40% of inventoried roadless areas have high or very high wildfire hazard potential, but that only 5% have received fuels reduction. That gap reflects what treatment is funded, not what the Roadless Rule permits, and the rule already allows fuel reduction. An agency that cannot maintain the roads it has will not become safer by taking on more of them. Public monies need to be spent on fuels reduction, not roads. For the last two summers, I have watched two large fires burn near my house. The Flat Fire in August 2025 burned about 23,000 acres two miles from Sisters, destroyed five homes, and threatened nearly 4,000. The Akawa Butte Fire in July 2026, started by lightning, burned about 27,000 acres northeast of Sisters. What stands between fires like these and my house is defensible space, hardened homes, and fuel treatment near communities, not new roads in remote backcountry. Rescinding protections across roughly 44.6 million acres would not have changed either fire, and it would pull money and attention away from the places where my community is actually at risk. Most importantly, roads bring ignitions. People start the large majority of U.S. wildfires, about 84% in Balch et al. (PNAS, 2017), and ignitions concentrate where people can drive. New roads in currently roadless country would add ignition sources near communities like mine. Fire and smoke are already costing me my livelihood. I run a short-term rental and my income depends on guests who come to Central Oregon for its forests, clean air, and outdoor recreation. In 2026, my bookings fell about30% during fire and smoke events because of smoke and closures. I am not alone. An Oregon State University analysis of Bend lodging data from 2021 to 2025 found that a sustained 10-point rise in August air quality index was associated with about $472,000 in lost lodging revenue, with losses growing as smoke persists. That analysis counted only lodging, not the restaurants, guides, and shops that depend on the same visitors. Because my livelihood rides on how this region handles wildfire, the Forest Service's wildfire case needs to be right. Money and attention spent on new road access in remote backcountry are not spent on the fuel treatment near communities that protects both homes and the local economy. My guests also come for the quiet, undeveloped backcountry the Roadless Rule protects. Roadless watersheds also protect my community's water. Bridge Creek, a tributary of Tumalo Creek, is Bend's main source of drinking water. It flows through the 14,829-acre Tumalo Mountain Roadless Area, which the Roadless Rule currently protects. Forest roads are a documented source of fine sediment to streams. A study of Oregon forest roads found that clearing vegetation from the cutslope and ditch increased sediment production about sevenfold (Luce & Black, Water Resources Research, 1999). Research in Oregon's Cascades found roads were a net source of sediment in the basins studied (Wemple et al., Earth Surface Processes and Landforms, 2001). Sediment degrades spawning habitat, warms streams, and raises treatment costs. New roads upstream of a municipal water supply would add crossings and culverts that will eventually fail, and downstream users and fish would pay for it. Roadless lands protect wildlife. Roads fragment habitat and cut connectivity. For example, esearch at Oregon's Starkey Experimental Forest shows elk select habitat away from roads (Rowland et al., Journal of Wildlife Management, 2000). Central Oregon's migratory and sensitive species depend on intact core areas like Tumalo Mountain. Already, deer populations have dropped nearly 50% in the area where I lived. Rescinding the Roadless Rule will only further threaten this species, too--as well as countless others. Quiet and solitude are a public value. I specifically live in Central Oregon to hunt, hike, and ride in places where it is still quiet. Once a road is built, that character cannot be restored. Already, there are too many roads. I'll end by stating this process is inadequate. A 32-day comment period for a rule affecting tens of millions of acres is far shorter than the periods used when the rule was adopted and in the 2005 rescission attempt, which exceeded 120 days. A decision this large warrants a longer period and public meetings in affected regions, including Central Oregon. I ask that you retain the Roadless Rule in its entirety and direct fire funding to fuel treatment adjacent to communities. Sincerely, Carrie Walker Bend, Oregon

I am writing to express my strong opposition to the U.S. Department of Agriculture’s (USDA) and U.S. Forest Service’s proposal to fully rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). I strongly urge the agency to select Alternative 1 (the No Action Alternative) to maintain critical protections for our remaining 45 million acres of undeveloped National Forest System lands. As an avid hiker and outdoor enthusiast who frequently explores our public lands, I urge the Forest Service to maintain the existing protections for our 45 million acres of inventoried roadless areas. The backcountry trails in our National Forests provide an irreplaceable sanctuary from the noise and development of modern life. For me, hiking through pristine, undeveloped backcountry is not just a recreational hobby; it is a vital necessity for mental and physical well-being. Knowing that I can step onto a trail and experience a landscape largely unchanged by industrial activity is a privilege unique to the American public lands system. Repealing the Roadless Rule to open these wild spaces to expensive road construction and industrial logging would permanently alter the landscapes that millions of hikers, backpackers, and families enjoy. Beyond recreation, these intact ecosystems provide critical benefits that cannot be easily restored once damaged. They secure clean drinking water for millions of Americans, safeguard vital habitat for threatened wildlife, and act as an essential buffer against climate change by storing vast amounts of carbon. The Forest Service already struggles to manage an expansive existing road system that stretches hundreds of thousands of miles. Prioritizing the construction of new roads for corporate exploitation at the expense of ecological integrity and public recreation is a step backward. . The Draft Environmental Impact Statement (DEIS) fails to provide a rational, science-based justification for a full repeal. The agency's analysis contains severe deficiencies that must be addressed before any final decision is made: 1.Flawed Wildfire Risk Analysis The DEIS frames the full rescission of the Roadless Rule as a necessary measure for wildfire protection. This rationale fundamentally contradicts established fire ecology and the agency's own historical data. National Forest Service data demonstrates that approximately 90% of wildfires start within one-half mile of a road, largely driven by human activity. Constructing new roads into pristine backcountry forests will inherently increase human access and significantly elevate the baseline risk of fire ignitions. Furthermore, the USDA's own DEIS findings indicate that repealing the rule delivers little to no wildfire risk reduction. The final EIS must reconcile how expanding road infrastructure aligns with a stated goal of reducing wildfire prevalence. 2.Arbitrary Restrictions on Active Management The justification that the 2001 Roadless Rule acts as an absolute barrier to necessary ecological restoration and active management is inaccurate. The current rule already includes flexible, limited exceptions allowing for targeted timber harvesting and fuel reductions to protect communities and restore forest health. The agency has failed to demonstrate why a complete, sweeping rescission—which opens pristine habitats to commercial logging and permanent industrial road building—is a proportionate or necessary tool compared to utilizing existing rule mechanisms. 3.Inadequate Assessment of Local Economic Damage and Deficit Spending The DEIS fails to fully account for the severe economic externalities of a repeal. The agency currently faces a massive road maintenance backlog. Forcing the federal government to assume the long-term maintenance costs of new logging roads is a fiscally irresponsible use of taxpayer funds. Concurrently, the DEIS undervalues the robust, self-sustaining outdoor recreation and tourism economies that rely explicitly on backcountry, roadless characteristics. 4.Failure to Quantify Cumulative Impacts on Ecosystem Services The DEIS lacks a rigorous cumulative impacts analysis regarding the degradation of municipal watersheds, carbon sequestration capacity, and critical wildlife corridors. Road building is a primary driver of soil erosion, stream sedimentation, and the fragmentation of continuous habitats required by threatened and endangered species. For these reasons, the proposal to eliminate the Roadless Rule is arbitrary, capricious, and environmentally damaging. I request that the Forest Service abandon the proposed rescission and uphold the durable protections of the 2001 Roadless Rule. I strongly support the "No Action Alternative" to leave the 2001 Roadless Rule fully intact. Please protect our nation’s last remaining wild forests for current and future generations of hikers, campers, and outdoor stewards. Thank you for your time and for considering my comments.

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I have personally maintained miles of wilderness trails throughout the Mt. Hood National Forest, such as the timberline trail and parts of the PCT, that have awed me in their beauty time and time again. Working with the Parkdale Forest Service trail crew helped me understand the importance of motor-less maintaince of those beautiful wilderness areas, and how much appreciation recreationers have for our efforts to clear their favorite trails. I strongly oppose rescinding the 2001 Roadless Rule because of the negative impacts it will have on the lands diversity and resilience, wildlife habitat, water quality, and recreational hiking and camping areas. Environmental Impacts • Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. The science is clear: road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. Fire Nearly 85% of wildfires are human-caused, and most ignite within a few hundred feet of roads. • New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. • The current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary. • Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. Clean Water • National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. • Forested watersheds filter and store water more effectively than developed lands, reducing sediment and pollutants. • Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. Economic Considerations • The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. • The text of the Roadless Rule itself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. • On the local level, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. • The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale for rescission—addressing wildfire risk and giving states more decision-making power—rings hollow when no funding is allocated to meet those goals. Rescinding the Roadless Rule Contradicts Public Opinion • The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. • Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. • Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. Closing The awe that comes from exploring untouched natural areas will always baffle me. I am grateful to have had the opportunity to backpack through the Mt. Hood wilderness and experience these marvels first hand. Based on the reasons listed above and my personal connection to these protected natural areas, —I strongly oppose rescinding the 2001 Roadless Rule. I ask that before moving forward, the agency: • Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; • Guarantee that no watersheds will be negatively affected by rescission; • Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; • And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Please protect America’s remaining roadless areas for current and future generations. Kim Lewis

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. Under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections, including the ones I listed above. The economics of these attacks on the Roadless Rule simply 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 that are rarely, if ever, used. According to the DEIS, the Forest Service could build new roads across 18.2 million acres (44.5% of current IRAs) in the short term. 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 to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In Oregon, this includes listed species such as Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet, Northern spotted owl, Oregon silverspot butterfly, Oregon spotted frog, Sierra Nevada red fox, and steelhead, among others. How would the agency ensure these populations and their habitats aren’t further degraded without protection of the Roadless Rule? 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. The DEIS also acknowledges that increased road construction and timber harvest are likely to “introduce and spread invasive plant species due to ground disturbance.” Invasive plants tend to be more flammable, leading to higher wildfire risk, and can outcompete native plant species. 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. The public comment period should immediately be extended to no shorter than a total of 120 days. 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.

Hello, Under this proposal to rescind the Roadless Rule, the Summary of Potential Impacts identifies several key areas this decision will affect. From an initial observation, I find it concerning to see that the impacts to fish, wildlife, and their habitat were not clearly defined, despite being listed as a management priority under The National Forest Management Act. It is well documented that roads and habitat fragmentation, noise pollution, and traffic patterns alter migration and habitual movement of animals, and cause undue stress on their ability to feed, breed, and carry on essential life functions. As a hunter, fisherman, and conservationist who has spent countless hours recreating in these roadless areas, I have been able to see firsthand the incredible opportunities that these places have to offer, because of the increased benefits provided by remote, roadless areas. For those of us who have been lucky enough to hike, hunt, fish, and explore these gems, we understand firsthand these benefits. The roadless rule takes out the need for individual rulemaking at a local level, which in turn increases efficiency when addressing the management objectives to maintain and improve wildlife, watershed and recreation areas. I am also aware of several dozen fish-passage barriers located within my local national forest that have continued to worsen over the years. These existing structures are culverts, bridges, and infrastructure that has not received funding for repair, spent years in restoration design (only for the project to be abandoned) and ultimately leaving populations of threatened and endangered species left to fend for themselves. I have deep concern that the Forest Service will not be able to manage new roads, let alone maintain and operate the existing road infrastructure that already exists. This makes sense, considering the draft EIS states that the National Forest roads system has a backlog of $6.9 billion in deferred maintenance. What kind of safeguards will be in place to ensure that any new roads will be guaranteed to remain fish-passage barrier free in perpetuity? I see no guarantees of any sort within this proposal, yet these requirements are essential. The system with the roadless rule is not broken; it was partly created to increase opportunity for recreationists who value its benefits to wildlife, ecosystem function, and seclusion, and partly to increase the habitat value for wildlife. I believe that this recission will put those fragile (and rare) benefits at risk. This proposal and the Summaries of Potential Impacts show the disconnect that the Forest Service places between wildlife habitat and recreation. Without the roadless rule, there will be negative impacts to those of us who recreate in these areas for their benefits that I have explained. I, as well as the 300,000+ commentors in opposition to this proposal (one of the largest public comment periods in opposition to any rulemaking proposal in U.S. history) strongly advise the USDA to eliminate their proposal to rescind the roadless rule. We The People have spoken on this matter, and we are relying on those who serve The People to listen. Thank you, A concerned citizen. Kukuła K, Bylak A. Barrier removal and dynamics of intermittent stream habitat regulate persistence and structure of fish community. Sci Rep. 2022 Jan 27;12(1):1512. doi: 10.1038/s41598-022-05636-7. PMID: 35087139; PMCID: PMC8795198. Fullman TJ, Wilson RR, Joly K, Gustine DD, Leonard P, Loya WM. Mapping potential effects of proposed roads on migratory connectivity for a highly mobile herbivore using circuit theory. Ecol Appl. 2021 Jan;31(1):e2207. doi: 10.1002/eap.2207. Epub 2020 Aug 18. PMID: 32632940; PMCID: PMC7816249.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike and camp in National Forests to enjoy landscapes, bird and wildlife spots, and enjoy solitude, quietness and dark sky. Public lands must be managed for the current and future public good.That means envisioning the value our public lands have for recreation, wildlife survival, climate change control, water quality, and ensuring there are still undeveloped wilderness areas for future generations. I photograph wildlife, landscapes, and waterfalls and rivers. Road development impacts all of those by changing the scenery, impacting wildlife migrations and homes, and decreasing water flow and water clarity. The kids in my life instinctively notice the difference in a roadless area: the tree canopy, the sound of a waterfall or birdsong not competing with traffic noise. We don’t have the right to deprive future generations of undeveloped national forests. I want an explanation of why this proposal has not included multiple public meetings where the public can make their voices heard in person. Water wars are here. Climate change is fueling water scarcity. Development is fueling water quality issues. Watersheds fed by roadless areas are part of protecting our nation's water quality. Explain how roads and logging won't have a negative impact on watersheds and water quality. Hells Canyon NRA, includes some of Wallowa-Whitman NF, and was on my 2026 photography trip. Birds and butterflies abounded, and Snake River ran clear through the canyon. Proud locals bragged about their forest and generations of family trips to the remote areas. Development would impact the recreation industry and the livelihoods of those who depend on it. Birds would leave based on vehicle noise alone. Deschutes National Forest and a stay in Three Sisters Wilderness area this summer didn’t do it justice. Locals bragged about the lava tubes and waterfalls. Roads would destroy its viewscapes and pristine environment, and negatively impact the tourist and recreation economy. I've explored Daniel Boone NF and the Wolfpen area twice (2022, 2025) to photograph different plants and cliffs and rock formations that change color with morning light, and search for the elusive hellbender. Roads and logging would change that. The next generation deserves the right to experience the area as I have: undeveloped and peaceful. My 2026 visit to the Rogue-Umpqua Divide included hiking to waterfalls deep in the forest. This area is a watershed for drinking water for millions. Developing or building roads through this forest will destroy water quality, impact waterfall viewscapes, and impact the "wow" factor of the area including Crater Lake National Park that has viewscapes of the Rogue-Umpqua Divide. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Wallowa-Whitman NF (515,000 acres), Wallowa-Whitman NF, Oregon - Deschutes National Forest (136,000 acres), Deschutes NF, Oregon - Wolfpen (2,835 acres), Daniel Boone NF, Kentucky - Rogue - Umpqua Divide (6,728 acres), Rogue River NF, Oregon - Three Sisters (7,687 acres), Deschutes NF, Oregon I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

I strongly oppose the proposal to rescind the roadless rule. Public lands are for the benefit of all community members of the United States. It is abundantly clear (through structured surveys and the comments from this proposal themselves) that the vast majority of Americans oppose additional commercial activities on public lands. As an ecologist, I know well that this proposal, if accepted, would allow additional roads to be built in wilderness areas. Roads are the primary vector for invasive plant dispersal, and invasive and introduced plants contribute disproportionately to fire risk. Further, roads bring people, and people (not remote wilderness) are the primary cause of severe wildfires. A 2026 study in Fire Ecology led by Gregory Aplet found that fires were four times more likely to ignite within 50 meters of a road than in roadless forest, a pattern that held in every Forest Service region. The same research found no meaningful difference in final fire size between roaded and roadless areas once a fire escapes initial suppression, meaning roads buy no protection against the catastrophic fires this proposal claims to prevent. These facts fly in the face of the agency's claim that constructed roads will reduce fire risk; a claim that contradicts the Forest Service's own 2001 environmental impact statement, which concluded that road construction would likely increase human-caused ignitions. Allowing construction of roads will also result in further degradation of our country's biodiversity and ecology. These roadless areas are not incidental. They provide unfragmented habitat and connectivity corridors for sensitive and migratory species and safeguard the drinking water supply of downstream communities. In fact, we cannot even maintain the roads we already have. The Forest Service carries a multi-billion backlog in road maintenance and building more into the last of our wild places is both an ecological nightmare and a fiscal one. It would be a decision that serves narrow commercial interests at the permanent expense of the public lands and the public will. This proposal is another disgraceful disregard of the will of all Americans and future generations to come.