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.

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

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.

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 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.

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 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.

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I care deeply about our national forests because I recreate in Mt. Hood National Forest, rely on forest watersheds for clean drinking water. I strongly oppose rescinding the 2001 Roadless Rule because of Environmental Impacts * The Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. * 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 Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. * 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 * Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. * 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 effectivelythan developed lands, reducing sediment and pollutants. * Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. Intact Landscapes * With climate change and development already fragmenting ecosystems, rescinding the Roadless Rule would jeopardize some of the last large, undeveloped tracts of land in the U.S. * Only 3% of the world’s ecosystems remain intact. We can’t afford to abuse what little remains. 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 Ruleitself 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 Reportcalled 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. * Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. 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. * USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans.

I oppose rescinding the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and ask the Department to select the no-action alternative. I am a climber, and I use national forest land for climbing and other recreation all the time. The undeveloped, roadless character of these places is the reason I go. New roads and logging would permanently change the backcountry areas that I and many other climbers, hikers and campers rely on. The agency's own analysis does not justify this change. It describes the new management opportunities as modest and localized, and estimates at most $11.4 million a year in added timber revenue to the government, against an estimated $6.1 million a year in lost recreation value. Meanwhile the Forest Service has a $6.9 billion backlog of road and bridge maintenance. Building new roads it cannot afford to maintain is not responsible management. Wildfire does not justify repeal either. The 2001 rule already allows cutting small-diameter trees to reduce wildfire risk, and allows roads needed to protect public health and safety from imminent threats such as fire. If those exceptions are slow or inconsistently used, the fix is to streamline them, not eliminate the rule. The proposal itself acknowledges that more road access can increase human-caused ignitions. Leaving protection to individual forest plans is not an equivalent safeguard. Plans can be amended forest by forest, and the proposal admits later amendments could open more land than the draft EIS analyzes. A national rule gives the durable, consistent protection that people, communities and businesses have relied on since 2001 for clean drinking water, wildlife habitat and backcountry recreation. Finally, the Department reports that most Tribal governments it consulted oppose the rescission. That should carry real weight. Please keep the 2001 Roadless Rule in place.

I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule. Rescinding it would be an irreversible act, and a shameful one. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That asymmetry alone should give the agency pause. What is built can sometimes be corrected. A road through a roadless landscape cannot be unbuilt. The wildlife, the habitat, the carbon, the character of these places: these are not recoverable once the decision is made. I want this record to show that the agency was told so, and I want it to show what the agency intends to do about every specific deficiency named here.

As an avid outdoors person and concerned citizen from Arizona, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This proposal would remove protections for 45 million acres of the wildest and most intact public lands across our National Forests, including 1.174 million acres in Arizona where I live and recreate. It would allow road construction, development, and commercial logging in currently protected Inventoried Roadless Areas. Particularly of concern to me it that rescinding the rule would increase fire risk in backcountry forests. The area near where I live has been beset by numerous forest fires in recent years. The economic, environmental and social effects of these forest fires can be devastating. For me personally, frequent forest fires have resulted in being unable to open any windows or go outside without wearing an N-95 for weeks on end due to horrible local air quality, concerns that I or friends and co-workers might have to evacuate, inability to access important local recreational areas, potentially indefinitely and increased flooding locally. The Roadless Rule helps protect areas that are fire resilient and less prone to wildfire ignitions. Studies show that fires are 4x more likely to start near a road than in a roadless forest, and logging can increase fire hazard. Publicly available data from the National Interagency Fire Center shows that since 1992, there have been over 8,000 fires that started within 100 meters of a road in Arizona, 6x greater than the number of fires that have started in roadless areas during the same timeframe. The density of wildfire ignitions within 100 meters of a road is also much greater than within roadless areas, with over 18 wildfire ignitions per 1,000 hectares compared to 3 per 1,000 hectares in roadless areas. Arizona continues to grapple with frequent wildfires amid historic drought conditions. We cannot afford to increase our wildfire risk by 4-fold. This proposal would also impair habitat for sensitive species and degrade our most intact and resilient ecosystems. Roadless areas provide some of the last best habitat areas that are still developing under the natural processes and landscape patterns that wildlife evolved with. Many of these areas in Arizona serve as critical habitat for threatened and endangered species like the Mexican spotted owl, Apache trout and jaguar. Opening roadless areas to logging and road-building will create more degraded and fragmented habitat that is already vastly over-abundant. This proposal ignores the will of the American public. When the Clinton Administration first proposed the Roadless Rule back in 2000, it received well over a million public comments supporting the rule, more than any administrative proposal in US history at the time. When the Trump Administration initially proposed rescinding the Roadless Rule last September, over 600,000 Americans submitted public comments, with over 99% of comments urging that the Roadless Rule be retained. 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.

To the United States Forest Service and Department of Agriculture: My name is Megan Lingle and I am writing as a [local resident / commercial fisherman / outdoor recreationist / concerned citizen] to express my strong opposition to the proposed full rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to reject the preferred alternative and maintain full, permanent roadless protections for the 9.3 million acres of the Tongass National Forest and all 44.7 million acres of inventoried roadless areas nationwide. The agency's Draft Environmental Impact Statement (DEIS) fails to provide a scientifically sound or economically rational basis for stripping these protections. I request that the agency address the following critical deficiencies in its current analysis before finalizing any rule: • Ecological Flaws in Wildfire Justification: The proposal relies heavily on active management and wildfire mitigation as a blanket rationale for road building and timber harvesting. While this may apply to dry forest ecosystems in the Intermountain West, it is ecologically invalid when applied to the temperate rainforest of the Tongass. The Tongass does not experience high-severity crown fires. Using wildfire mitigation to justify opening pristine old-growth rainforest to road construction misrepresents local forest health needs. • Underestimation of Carbon Sequestration Loss: The Tongass National Forest is one of the world's most vital terrestrial carbon sinks, holding roughly 8% of the total carbon stored in all U.S. forests. The DEIS fails to adequately calculate the long-term economic and climatic costs of releasing this stored carbon through clearcutting and industrial road fragmentation, directly undermining national climate resilience goals. • Degradation of Watersheds and Salmon Habitat: Road construction inherently increases soil erosion, triggers landslides on steep Alaskan slopes, and causes stream siltation. These impacts directly threaten the pristine watersheds that fuel Southeast Alaska’s multi-billion-dollar wild salmon industry. The Forest Service has not demonstrated how it will mitigate the cumulative watershed damage to subsistence, commercial, and sport fisheries. • Negative Economic Impacts on Tourism and Fishing: The economic drivers of Southeast Alaska are sustainable industries—namely fishing and tourism—which depend entirely on intact, wild landscapes. Reopening these areas to taxpayer-subsidized timber roads harms local economies for the benefit of a declining industry that accounts for a fraction of regional employment. • Failure to Respect Tribal Sovereignty and Subsistence: The cultural heritage, food security, and traditional ways of life for Alaska Native Tribes are explicitly tied to intact roadless areas. Stripping these baseline federal protections disregards the inputs of local sovereign Tribes and threatens the fish and wildlife populations essential for subsistence. For these reasons, the Forest Service must preserve the 2001 Roadless Rule in its entirety. Thank you for considering these substantive points. Sincerely, Megan Lingle

To the U.S. Department of Agriculture and the Forest Service: I write in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I urge the Department to adopt Alternative 1, No Action, and keep the Roadless Rule fully in place. I equally oppose Alternative 3, which would open most inventoried roadless areas in the East to logging. The wildfire rationale is contradicted by the evidence. A peer-reviewed study published in Fire Ecology in January 2026 found that from 1992 to 2024, wildfires were four times more likely to ignite within 50 meters of a road than in forest without motor vehicle routes. Ignition density in Inventoried Roadless Areas was 1.97 fires per 1,000 hectares, compared with 7.99 near roads. Fires that escaped initial attack, the ones that become large and catastrophic, showed no meaningful size difference between roaded and roadless areas. The Forest Service reached the same conclusion itself: its 2001 environmental impact statement found that building roads into roadless areas would likely increase human-caused fires, and that prohibiting road construction would not increase acres burned or the number of large fires. The rule already allows hazardous fuels reduction and other management where needed. Repeal is not a wildfire solution. Roadless areas protect water and wildlife. The Roadless Rule protects drinking water in 354 municipal watersheds. Seventy percent of roadless areas are home to native trout or salmon. These benefits cannot be rebuilt once roads and logging fragment these lands. The public has spoken, repeatedly. The original rule followed 600 public meetings and 1.6 million comments gathered over 18 months. In the 2025 comment period, more than 99% of comments opposed repeal. 164 members of Congress have urged the Department to retain the rule. Leading conservation organizations, including The Wilderness Society, Sierra Club, Trout Unlimited, Earthjustice, the Natural Resources Defense Council, Outdoor Alliance, and MountainTrue, all oppose this rescission. A short comment window with no public meetings is not adequate for a decision of this scale. This is personal for me. I am a native of Western North Carolina. About 15% of the Pisgah and Nantahala National Forests are Inventoried Roadless Areas, places like Linville Gorge, Craggy Mountain, the Black Mountains, and the headwaters of the South Mills River. Hellbenders, warblers, and trout depend on them. These mountains and the protected forests within them are worth more to me than almost anything. They are, without doubt, one of the most valuable jewels in our nation's possession, and they, along with the countless other forests across our nation, deserve our protection and stewardship. As Wendell Berry wrote, "There are no unsacred places; there are only sacred places and desecrated places" We must not allow our public lands to become desecrated. Please retain the 2001 Roadless Rule in full. Sincerely, Matthew Metcalf Asheville, North Carolina