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

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

Here are some of the concerns that I would like to share that are based on the Forest Service’s own analysis Wildfire: More roads could increase human-caused wildfire ignitions, while the additional wildfire-treatment capacity from rescission would likely be only “modest.” (DEIS pp. 24, 225) Water: Roads are major sources of sediment from timber operations. Mitigation can reduce — but not eliminate — these effects, and the Eastern and Southern Regions are most susceptible to additional impacts. (DEIS pp. 111, 122–23) Wild character: Rescission could diminish primitive recreation, scenery and solitude and alter special places to which people have a strong “place attachment.” (DEIS pp. 224–26) Importantly, the current Roadless Rule already contains exceptions allowing certain road construction and timber cutting for public safety, resource protection, ecosystem restoration and other purposes. (DEIS p. 14) The Southern Environmental Law Center (SELC) notes that the Forest Service estimates it already has at least 20,000 problematic road-stream crossings nationwide, which SELC estimates would cost at least $1.2 billion to address. Please take into account these factors and reconsider this misguided legislation. Respectfully yours, Sam Rodman

To whom it may concern, I am writing to express my opposition to the Rescission of Conservation and Landscape Health Rules. I support conservation of our public lands. It is imperative that we, the people and the land managers, preserve what is left of the limited areas of wild land in the US. So much of our land is already developed with roads; we do not need more roads. The current roads cutting through our wild lands have already negatively impacted the natural ecosystems and the natural migration patterns of wildlife. In order to maintain the health of our country – America, the beautiful – we need more conservation, not less. The Rescission of Conservation and Landscape Health Rule states: "Repeal of the 2024 Rule will, therefore, improve the BLM’s management of the public lands by restoring the more efficient processes in place prior to that Rule’s promulgation and removing any thumb on the scale in favor of conservation at the expense of productive use and development of the public lands and their many important resources." The rule repeal fails to address the fact that "productive" and "resources" are not solely defined by what we can access with a motorized vehicle or extract from the land. As a mental health professional, I must inform the stakeholders involved in this decision: natural, undeveloped green spaces have been shown to be mental health RESOURCES, which lower stress levels (e.g., Donnelly & MacIntyre, 2019; Ulrich, 1984; and Wolf et al, 2017). By extension, time in these spaces protects against many psychological and physical stress-related pathologies, which include leading causes of death reported by the CDC: cardiac illness, diabetes, substance abuse, and others (CDC.gov). Therefore, our conserved lands are a public health RESOURCE, which promotes a PRODUCTIVE society. The Rescission of Conservation and Landscape Health Rules would be devastating to the land and our public health. Please do not support this rescission. Sincerely, Josie McKee

Weakening or repealing the Roadless Rule is an embarrassingly transparent ploy to increase accessibility of extractive projects against the wishes and pleas of the pubic. Claiming there is any justification for reducing fire threats is laughable. The USFS's Environmental Impact Statement clearly indicates that repealing the Roadless Rule could increase fire ignitions, as well as countless other pieces of empirical evidence. The policy to protect our forests and other public land not only receives bipartisan support time and time again, it also helps to safeguard our future against misguided, shortsighted individuals and entities that fail to see the irreparable damage they can cause for the sake of lining their own pockets. Our forests provide us with so much value. Recreation revenue, healthier/happier citizens, and resilience against wildfire, drought, and other natural disasters. I understand the need for resources and protections from wildfire threats, but this is not an answer. Repealing or weakening the Roadless Rule clearly does not reflect decades of scientific rigor or the public's desire. Please reflect the will of the people and keep the Roadless Rule intact exactly as it is.

Public Comment: Oppose Rescission of the 2001 Roadless Area Conservation Rule Docket Number: FS-2025-0001 | RIN: 0596-AD66 I strongly oppose the USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule. As citizens, we own these public lands. They are a collective inheritance held in trust for all Americans, not the private property of extractive industries or government agencies. Our public lands are heavily developed, leaving little preserved in a natural state. The Forest Service manages over 148 million acres with roads, crisscrossed by 370,000 miles of existing routes supporting resource extraction. In contrast, Inventoried Roadless Areas (IRAs) total just 44.7 million acres—only 23% of National Forest System lands. Because three-quarters of our forests are already roaded, keeping remaining roadless acres intact is a critical necessity. We must prioritize the absolute conservation and preservation of all species relying on these final, undisturbed sanctuaries. Crucially, the proposal represents a severe regression in federal trust responsibilities. It threatens Tribal rights secured under historical treaties, risking a direct violation of binding legal agreements. Industrial exploitation of these lands will once again put the federal government out of compliance with treaty obligations and continue to treat Native Americans unfairly. For generations, Indigenous nations have seen sacred sites, traditional hunting grounds, and cultural gathering areas fragmented by development. Stripping protections ignores Tribal sovereignty, disrupts access to treaty-protected resources, and perpetuates environmental injustice against Native communities. The Forest Service must withdraw this proposal and maintain durable protections based on clear evidence: • Increased Wildfire Risk: While the USDA claims rescission reduces fire risk, forest science and the agency's Draft Environmental Impact Statement (DEIS) show the opposite. Roughly 85% to 90% of wildfires are human-caused, and over 78% occur within a half-mile of a road. Introducing roads into protected backcountry will drastically increase ignition density. Furthermore, road construction spreads highly flammable, invasive plant species due to soil disturbance, compounding fire risks. Forest Service data proves fuel treatments already occur within roadless areas at similar or higher per-acre rates compared to roaded areas; the rule does not hinder public safety. • Damage to Watersheds and Biodiversity: Repealing the rule will increase soil erosion, landslide risks, and sediment pollution. This directly threatens pristine watersheds supplying clean drinking water to 47 million Americans. Road construction strips away critical ecological buffers. The DEIS explicitly acknowledges that a full repeal is "likely to adversely affect" 327 threatened and endangered species and 71 designated critical habitats. Intact roadless areas act as final strongholds, preventing extinction by preserving crucial migration corridors for species like grizzly bears, elk, and native fish. • Detrimental Impacts on Outdoor Recreation: The undeveloped character preserved by the rule is the backbone of outdoor recreation. Building roads introduces noise, light pollution, motorized vehicles, and enables illegal dumping into primitive spaces, degrading experiences for any outdoor user groups. Erasing protections directly degrades the outdoor activities enjoyed by citizens which are made possible by the Roadless Act. • Economic and Fiscal Losses: The outdoor recreation economy generates $1.3 trillion in economic output. Visitors to national lands covered by the rule generated $8.5 billion in local community spending in 2024 alone. The DEIS projects that degrading backcountry spaces will cause an immediate multi-million-dollar loss in annual visitor spending. Furthermore, the Forest Service faces a staggering $10 billion road maintenance backlog on its existing system. It is fiscally reckless to build new roads the agency cannot afford to maintain, especially when the DEIS shows construction costs heavily outweigh minor timber revenues. Over 99% of historical public comments have opposed rolling back these protections. As the rightful owners of these lands, citizens demand that the federal government protect our remaining roadless areas. Keep the 2001 Roadless Rule fully intact.

Hello, I’m a citizen of Portland OR and I oppose the rescinding of the roadless rule. One of the reasons given for rescinding the rule is to allow greater fire protection. But the Forest Service’s own draft Environmental impact study found that the addition of more roads would increase the risk of wildfires through vectors like vehicle sparks and human activity. Furthermore, preserving roadless areas for recreational use is a worthwhile purpose. The ability to experience natural areas free of the noise and pollution that accompanies roads is one of the things our country has to be proud of and is one of the ways we stand out from countries that have failed to preserve their natural spaces from incursion. As for returning power to responsive local officials and governments, it can be difficult for citizens to monitor or influence them, and they can be vulnerable to pressures from powerful interests.

I oppose Alternative 2 and support Alternative 1, no change to the existing 2001 Roadless Rule, and continued, nationwide prohibitions for inventoried roadless areas to provide lasting protection for these long-established habitats. Receding this rule will negatively affect wildlife and wildfire risk by creating further habitat fragmentation, increasing the opportunities for invasive species to spread, and could result in more wildfires. On pages 89–90 of the Draft EIS, the Forest Service reports much higher rates of human-caused wildfire ignitions on other National Forest lands than in affected roadless areas and states that human-caused ignitions increase with proximity to roads. Removing nationwide road-building restrictions would increase human-caused ignition and invasive species risk. The proposal cites increased access for recreation, but does not address the many poorly maintained roads that already exist. Furthermore, I am concerned that the majority of the roads would be used solely for logging in currently protected habitat and would not be created with recreation in mind. More roads also increase the opportunity for sediment runoff during rain events and could impact the health of our waterways. I support Alternative 1 (no change) and believe that the short-term benefit of logging potential is not worth the long-term harm this repeal would cause to our nation and its roadless areas.

Secretary Rollins I'm writing to you after a full day of working in a hospital and parenting young children to tell you I oppose the administration proposal to in any way rescind the Roadless Rule. I have lived near, played in, and worked with Roadless Areas for a large chunk of my adult life. They have given me a peace and knowledge far deeper than I could ever find in civilization. They are places that should be off limits, to the greatest possible extent, to the influence of humans. It sounds like a platitude, but I want my children and their children to know what it means to visit a place beyond the reach of civilization, or just know that there is such a place. I believe any attempt to degrade Roadess Area integrity is short sighted and cynically misinformed. I understand that one of the main "arguments" for repealing roadless protections is to increase access for fire mitigation and landscape scale prevention. This contradicts the Forest Services own findings, published in the DEIS which states fire danger will increase with greater human access. I find it baffling that the administration would actively assert otherwise and does not indicate a good faith argument. Sadly that is just the beginning of the horrible and absolutely unnecessary adverse of effects of both Alternatives 2 and 3. For instance it is well known that the Forest Service has a deep backlog of deferred maintenance. How more roads will add to the administrative burden is clear. We have more Forest Service roads than we can handle. It would be wasteful to create more liabilities for future generations to worry about. I am appalled that I have to take from my day to berate my own government about management decisions. It is your job to thoughtfully consider the best choice. You literally have the public resources to do the right thing. Yet here I am after a long day, advocating for one of our most important and valuable resources. I am deeply embarrassed by this administration. It's late y'all. I am almost out of time to get this in and have so much more I wish I could add here. But I'm pressed on time and need sleep. Because of the above stated reasons, I believe that Alternative 1 is the wisest choice, and I firmly oppose Alternatives 2 and 3, or any other attempt to degrade Roadless Area protections.

I am writing to express my firm opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. Growing up, one of my fondest memories was the long drive to Lake Tahoe. It was looking outside and seeing the snow-dusted pine trees, endless blankets of glimmering white, and an occasional deer darting through the brush. These landscapes may be beautiful, but more importantly, they are also the home to countless species of wildlife. Rescinding the Roadless Act would fragment ecosystems like these, whose vulnerable inhabitants rely on unbroken habitats, while invoking irreparable harm to natural and cultural resources. Despite the rescission being proposed to decrease the likelihood of wildfires, it has been found that 84% of US wildfires are caused by humans, with the main vector being roads (Aplet et al., 2026). Thus, the proposed rescission would directly result in an increase in wildfires. Since the agency’s stated justification is fundamentally contradicted by such scientific evidence, the agency should withdraw the counterproductive proposal. Sometimes it’s better to simply take the long route and appreciate the scenic view. I urge the USDA to maintain the current Roadless Area Conservation Rule protections. Thank you for your time and consideration.

I oppose fully or partially rescinding the roadless rule because it would: Remove protections for 45 million acres of the wildest and most intact public lands across our National Forests, allow road construction, development, and commercial logging in currently protected inventoried Roadless Areas; Increase fire risk in backcountry forests. 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; Allow increased logging and roads that threaten clean drinking water sources. The Roadless Rule helps safeguard watersheds that provide drinking water, 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. Opening roadless areas to logging and road-building will create more degraded and fragmented habitat that is already vastly over-abundant, threaten Indigenous cultural values and sources of traditional foods, fiber, and medicines. The draft EIS states that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission”; Increase taxpayer burden. The existing National Forest road system already has a $6.9 billion deferred maintenance backlog according to the draft EIS. The Forest Service already lacks enough staff and funds to maintain existing roads, and building more roads in forests will only increase that backlog; Ignore 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 preserved.

I am writing to oppose the repeal of the Roadless Area Conservation Rule. The lands affected by this rule are less than 1/4 of the total lands managed by the forest service. As currently managed, the value of these lands in maintaining biodiversity, ecological resilience, and opportunities for people to directly experience nature far outweigh the value of natural resources that might be extracted from them. Furthermore, the bulk of the value returned by resource extraction is likely to occur over just a short few years while significantly degrading the value of the land for biodiversity, ecological resilience, and nature recreation for at least a few decades and possibly much longer depending on subsequent activity in these areas. I also believe that several of the key justifications provided for the proposed rule change are misguided, specifically the risk of wildfires and the need to return to local control of these areas. While wildfires are a significant and growing concern, the data does not support the idea that further road construction in the areas covered by the Roadless Area Conservation Rule will mitigate that risk. Research has shown that 90% of all wildfires start within 1/2 mile of a road and 88% are human-caused. Additional road construction in these areas is likely to increase the risk of fires in them rather than reduce it. The majority of firefighting risk and resulting economic damage from fires occurs in areas containing people and structures. Road constructions will almost certainly increase the number of people and structures in these areas. Finally, given the forest service already manages 370,000 miles of forest roads and estimated the maintenance backlog of current roads at $8.6 billion in 2023, it is unlikely that there will be resources to maintain these roads much less actively manage surrounding lands to reduce wildfire risk. I believe that local control is most appropriate when the benefits and drawbacks of the change will primarily effect the population making the decision. I do not believe that is true in this case. While there may be some temporary economic benefit to the local population from resource extraction in additional jobs, the majority of the economic benefit will accrue to the large corporations managing that activity, who are unlikely to be local. Meanwhile, the overwhelming public support in the comments on this rule when it was originally proposed demonstrated that there are many people with an interest in the management of these lands, myself included, who are not "local" and who would consider further resource extraction a significant drawback. A local decision-making process is far less likely to solicit and value the input of these additional stakeholders. For all of these reasons, I believe the Roadless Area Conservation Rule should not be repealed and should remain in effect.

The wildfire rationale is weak: the rule already allows fuel-reduction work, and new backcountry roads add ignition sources. The proposal also contradicts itself. The agency says rescission authorizes no projects and increases no logging or roads. If so, it delivers no wildfire benefit. I live in Colorado, where a state rule tailored protections through real public process while keeping limits on backcountry roads. Full rescission replaces a national floor with nothing. If the rule isn't kept, Alternative 3 is the minimum: it targets the wildland-urban interface, where community fire risk actually is, and protects true backcountry. Finally, 45 days with no hearings for 44.7 million acres falls far short of the 2001 process. Please retain the Roadless Rule.

A forest isn’t something you can patch back together. Once a road cuts through it, the trees come out, the soil washes into the creek, and the quiet is gone for good. Once you amputate part of it, you can never get it back. The administration says it needs to scrap this rule to fight wildfire. But roads don’t stop fires. Roads start them. The Forest Service’s own report finds that fires start about four times less often in roadless areas, and it admits any gain in fire prevention would be “modest.” The rule already lets crews thin forests and fight fires. Building roads to stop wildfires is like handing out matches to stop wildfires. And that’s not all. The same report lays out the damage: These forests feed watersheds that supply drinking water to about 24 million Americans, and repeal would bring more erosion, landslides, and mud into them. The plan is “likely to adversely affect” 327 threatened and endangered species. Nearby communities could lose up to $9 million a year in visitor spending. Tribal nations consulted overwhelmingly oppose repeal, citing threats to sacred sites and treaty-protected hunting and fishing. Your comment isn’t just shouting into the void. It’s evidence. When the government changes a rule like this, everything the public submits goes into an official file called the docket. If the administration scraps the rule and conservation groups sue, that docket becomes the record a judge reviews. Courts don’t look at Instagram posts or protest signs. They look at what’s in the record. The law says the agency has to respond to the major concerns the public raises. If we put the facts on the record and the agency ignores them, that becomes the heart of the legal case. They were warned, they had the proof, and they chose not to listen. Judges can throw out a rule for that. Courts also often refuse to consider an argument that nobody raised during the comment period. If it’s not in the docket, it may as well not exist.

Docket ID: FS-2025-0001 Subject: Scientific and Environmental Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule To Whom It May Concern, As an environmental science student, I am writing to formally oppose the full nationwide rescission of the 2001 Roadless Area Conservation Rule. Stripping protections from nearly 45 million acres of public lands across the United States ignores established ecological science and undermines long-term climate resiliency. The agency's central justification—that road building is a necessary tool for nationwide wildfire risk reduction—is fundamentally flawed and directly contradicted by established fire ecology and the agency's own Draft Environmental Impact Statement (DEIS). The DEIS explicitly admits that ignition density is roughly four times greater on forest lands with roads than in roadless areas, noting that increased road access will elevate human-caused wildfire ignitions. Furthermore, the administration’s decision to preserve state-specific roadless rules in Colorado and Idaho proves a blatant double standard; it acknowledges that roadless protections are vital for local landscape management while stripping those exact same protections from public lands across the rest of the nation. On a national scale, a full repeal will trigger severe habitat fragmentation across contiguous biological corridors, directly threatening 327 endangered species. This infrastructure expansion poses a catastrophic risk to aquatic ecosystems, destroying critical riparian zones and causing massive soil erosion and sedimentation. This directly chokes out sensitive fish populations—including native trout and salmonids—and destroys the benthic macroorganism communities that form the foundation of these food webs. The Forest Service cannot legally or scientifically justify opening intact watersheds and ecosystems to widespread degradation under the guise of forest health. The agency must maintain the "No Action" alternative.

To the U.S. Department of Agriculture and U.S. Forest Service: I urge you to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. My opposition is grounded in three considerations: (1) Federal jurisdiction is necessary for cross-state environmental protection. Wildlife migration, watershed integrity, and carbon sequestration transcend state boundaries. Allowing a state-by-state approach creates regulatory arbitrage where environmental outcomes depend on political geography rather than ecological science. (2) The USDA's own DEIS confirms environmental harm. Your agency acknowledges that repeal risks damage to forests, wildlife, and water resources, with little demonstrated wildfire benefit. Fire frequency is demonstrably lower in existing roadless areas, contradicting the stated rationale for this change. (3) National forests serve a national public interest. Forty-five million acres of protected land represent a shared inheritance. Consistent federal standards ensure that economic pressures in individual states do not undermine collective benefits—clean water, climate stability, and biodiversity—that all Americans rely upon. I oppose this rescission and request that the Roadless Rule remain in effect to preserve these public values for future generations.

Dear USDA: Please do not rescind the Roadless Rule. The reasons why it should be kept in place permanently include, but are not limited to: increased, maximum, and optimized forest health; Landslides occur after modern forestry techniques and cutting roads into forests will only increase the immense damage landslides create; and USDA U.S. Forest Service’s current and $5.98B FY2025 road maintenance backlog. Please do not rescind the Roadless Rule for these reasons below (and so many more): Increased, maximum, and optimized forest health: Mature, intact (not bisected by roads) forests are complex and naturally more fire resistant. Intact, mature forests and lands provide food, shelter, and long-term survival for our wildlife and healthy, diverse ecosystems that sustain us and our way of life. They also capture more carbon via photosynthesis and stabilize local climates by retaining moisture and absorbing heat better than second growth or industrially managed forests do. Intact, mature forests contain a greater diversity of tree species with different ages, canopy heights, tree circumferences, and spacing -- mature trees are naturally more fire resistant. Their branches are higher above the forest floor, and they retain moisture and slow the flow of rain within their complex roots systems, promoting still more water retention by the diverse understory trees and plants grow in mature, intact forests. Their species and ecological diversity, shade, and moisture retention creates natural firebreaks and fire-resistant individual trees that will regenerate the forest. In opposition, the younger, even-age, densely packed trees of second growth forests feature a tight, all-one-height canopy that does not promote ecological diversity along the forest floor. Instead, these low diversity second growth forests are a source of fine ladder fuels of drier twigs and branches, essentially kindling, that are quick to burn hot and violently, with fire spreading rapidly along their densely packed tracts of young, trees and drier soils and limited, drier understory plants. The intensity of these forest fires are not natural to mature and intact forests. Extreme fires are characteristic of previously logged, second growth forests. This is true of clear, strip, shelterwood, or seed tree cutting industrial logging regimes, which cannot replicate natural processes. The largest trees are logged and removed, leaving the fine ladder fuels behind on disrupted and drier soils, which is quicker to ignite and spread along roads into the tree canopy of these logged areas and second-growth forests, resulting in more frequent, more violent fires. And more danger to our local communities and fire fighters. Also, after hot, fast, catastrophic fires occur in previously logged, second growth forests and along new roads, it is the U.S. Government and the U.S. taxpayer that will need to step in and help those communities that the USDA Forest Service effectively harmed by easing access for, thereby promoting, industrial extraction of our publicly shared resources and creating unhealthy ecosystems with even more problems. The proposal to rescind the Roadless Rule just does not make fiscal, logical, or ecological sense; it’s just not sound. To manage the incidence of fires, the USDA Forest Service should start by requiring proper management second growth forests through ecological thinning and controlled burns in coordination with local and indigenous communities. USDA U.S. Forest Service’s $5.98B FY2025 road maintenance backlog: Why would the federal government allow / promote more roads in our public forests, which again, promotes the spread of wildfires, if the USFS doesn’t have the staffing or funds to maintain the roads it already has in its portfolio? The U.S. Forest Service is already over $5,980,000,000, that’s $5.98 Billion dollars, behind in deferred maintenance road projects as of FY2025. This astounding $5.98M figure does not even include roads for high clearance vehicles or basic custodial care of roads (source: Fiscal Year 2025, Quarter 1 Deferred Maintenance Needs https://www.fs.usda.gov/sites/default/files/fy25-q1-deferred-maint-report.pdf). This plus the USFS's current backlog does not support creating more roads to maintain, which are shown to increase the incidence of fire, not reduce it. Landslides occur after modern forestry techniques and cutting roads into forests will only increase the immense damage landslides create: Landslides are also most likely to occur on clearcut second growth mountainsides. The federal government helps local communities recover when such a horrific landslide event occurs (if one can even recover from the loss of life, community, and land) via U.S. taxpayer dollars, yet the conditions for a landslide were really due to the private logging industry which disrupted the stability of a once intact, mature forest and mountainside.

I strongly oppose rescinding the Roadless Rule and urge adopting Alternative 1 (no action). The currently intact wild lands are popular for recreation. Making up just 2 percent of the land in the lower 48 states, they irreplaceably provide important habitat for 57% of vulnerable terrestrial wildlife. Roadless areas help protect against human-cause wildfires — that’s because wildfires are four times more likely near roads, according to the DEIS. It states that “ignition density is approximately four times greater on other NFS lands compared to potentially affected IRAs and wilderness.” One reason the Roadless Rule was implemented in the first place was the Forest Service doesn’t have the money to maintain the roads it currently has. Roads are a costly expense. They also diminish water quality, fragment habitat areas, and irretrievably impact the scenery and self-renewal offered by hiking, hunting, birdwatching, backpacking and otherwise enjoying intact woods. The DEIS acknowledges the significant socio-economic loss in “non-commodity values” if the rule is rescinded. An economic analysis by Earth Economics found that the Roadless Area Conservation Rule brings $24 billion in benefits annually. I join the chorus of fellow citizens calling for abandoning the proposed rescission of the Roadless Rule. Select “No Action” on the DEIS. Sources: Dietz, M. S., et al. “The importance of U.S. national forest roadless areas for vulnerable wildlife species.” Global Ecology and Conservation, vol 32, e01943, 2021, doi.org/10.1016/j.gecco.2021.e01943. https://www.sciencedirect.com/science/article/pii/S2351989421004935?via%3Dihub Delaney, G. “Roadless Area Conservation Rule Brings $24B in Benefits.” Earth Economics, https://www.eartheconomics.org/news/roadless-rules.

I would address this comment with : To all whom this may concern; but truly this is a concern to all people. To all Americans, to all beings living on this land. Please keep nearly 45 million acres of forests under the protection of the Roadless Rule. I stand with the notion to keep the Roadless rule as is and oppose rescinding. The effects of rescinding lead to major risk of unnecessary wildfire, losing wildlife, economic loss, and contamination of water. “The DEIS states that rescinding the Roadless Rule is “likely to adversely affect” 327 threatened and endangered species, including the northern spotted owl, grizzly bears, and various fish species. Additionally, 71 designated critical habitats are at risk. The DEIS estimates that between $5-$11 million in revenue could be generated through new logging projects in roadless areas. This number pales in comparison to the current $7 billion USFS road maintenance backlog, the cost of new road construction, and the losses in revenue for local businesses from tourism. 25 million Americans source their clean drinking water from roadless areas. Undoing the Roadless Rules rolls back protections for 80,000 miles of protected rivers.” (De Man, 2026) These are all examples and facts of the major impacts that can happen if the administration decides to move forward with rescinding the 2001 Roadless Rule. I am amongst the 76% of people that agree this would be a poor decision. Please respect the responsibility we have to upkeep public lands for future generations. For the best of All. De Man, W. C. (2026, August 23). Let me teach you how to defend the Roadless Rule (again). National Park History. https://nationalparkhistory.substack.com/p/let-me-teach-you-how-to-defend-the-e63

The Forest Service is moving to rescind the National Roadless Rule that protects 45 million acres of National Forest lands outside of Idaho and Colorado. The Forest Service’s own analysis shows that eliminating the National Rule will increase human-caused wildfires, degrade habitat for fish and wildlife, and threaten drinking water supplies. This is an outrage!