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I have hiked and mountain biked for years in the Angeles National Forest (specifically in the Strawberry Peak and Arroyo Seco roadless areas) and hope to explore other National Forests soon. These protected public lands are our national treasures, and they must be preserved—with exactly the kind of protections the Roadless Rule provides. Rescinding this rule and opening these protected lands to road building and logging would dramatically harm them, irrevocably damaging sensitive ecosystems that in many cases are not protected elsewhere (within the National Park System, for example). The Roadless Rule is a sound, common-sense regulation. It does not prohibit multi-use activities within the areas it protects—it simply ensures damaging roads are not built. We must be good stewards of our public lands and ensure they remain healthy, thriving, and undeveloped for future generations. Please keep the Roadless Rule intact.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public land should be managed for wildlife diversity, conservation, and to be enjoyed by future generations. The proposal before the agency fails all three of those purposes, and it fails them using the agency's own record. The DEIS cites 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. That is not a peripheral finding. It is in the agency's own draft environmental impact statement, and it speaks directly to the kind of habitat that keeps Arroyo Seco and Magic Mountain worth entering. These areas sit within Angeles National Forest, part of a state that holds 381 inventoried roadless areas totaling 4,389,760 acres. The birds I photograph are sensitive to exactly the disturbance that roads introduce. The agency must explain how opening these landscapes to road construction is consistent with the bird abundance and species-avoidance data already in its record. On wildfire, the agency's own text states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on fuels and fire management grounds. That justification runs directly into the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain on the record why the proposal departs from its own prior findings on fire occurrence and reconcile the rescission with those numbers. Clean water is a universal human right. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer roads mean cleaner source water. That relationship is not speculative; it is in the agency's own data. The agency must address that relationship directly, and state plainly how the rescission protects, rather than degrades, the source water those intakes depend on. The economic case does not hold together either. The agency's record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal extraction volumes, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million. The road system already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with an analysis that cannot establish a net benefit and explain how expanding a deficit-carrying road network is justified by figures this small. The proposal also argues that state-specific approaches can substitute for one national rule, and invokes what it describes as a preference for flexibility over uniformity. The agency's own record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already examined a state-by-state replacement and found it wanting. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies identified in that litigation. Finally, the proposal questions whether the 2001 rule exceeded statutory authority. A court already answered that. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and concluded it did not create de facto wilderness. The agency must state the legal basis for any position to the contrary, and explain why that holding does not govern here. Sincerely, Kaitlin Callahan North Hollywood , Ca

I oppose rescinding the 2001 Roadless Rule and ask the USDA to keep these protections in place. Through my work with the Greenfield and Salinas Community Science Workshops, I help connect children and families in Monterey County with science and the outdoors. Places like Arroyo Seco and the Los Padres National Forest are important to this work. They give young people opportunities to explore, ask questions, and learn about the natural world firsthand. For the communities we serve, protecting these places means protecting opportunities for children and families to experience them. It also means caring for the water, wildlife, and landscapes that are part of our home. I am particularly concerned about preserving the headwaters of Santa Lucia Creek near Arroyo Seco. Keeping roadless protections in place will help safeguard this area while efforts toward permanent wilderness protection continue. Please retain the Roadless Rule. Our children deserve the opportunity to know and enjoy these places, and we have a responsibility to care for them. José S. Sánchez

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The place I return to is Angeles National Forest. I go there to reconnect to myself and to those around me, and to maintain respect and a sense of awe for our natural world. The roadless areas within that forest, including Strawberry Peak, Arroyo Seco, and San Gabriel Add, are part of what makes that possible. The 2001 Roadless Area Conservation Rule protects them. I oppose rescinding it. The agency's own record destroys the wildfire rationale for this proposal. The agency found that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding sits in the agency's own draft environmental impact statement alongside ignition data showing far higher fire density on roaded land than inside inventoried roadless areas. Angeles National Forest, where I hike at Strawberry Peak and along Arroyo Seco, is exactly the kind of fire-prone landscape that finding describes. I ask the agency to reconcile this proposal with DEIS Table 21 and explain why its current position departs from its own prior findings on fire occurrence in roadless areas. The economics do not hold up either. The agency's own analysis shows that the total timber volume affected by the rule at issue is less than 0.5 percent of total United States production, and the oil and gas production from all National Forest System lands is about 0.4 percent of national production. Those are not numbers that justify dismantling protections for the roadless areas I visit in California, a state holding 381 inventoried roadless areas totaling 4,389,760 acres. The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. It establishes uncertainty. And it does not account for the fact that the existing road system already carries a $6.9 billion maintenance backlog. How does adding more roads to that backlog serve the public interest? The agency should answer that question directly before this proposal moves any further. The proposal also argues that state-by-state management can replace a single national rule. The record shows the agency has tried that before. It "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That state-petition approach was challenged in court, and the agency lost. The Ninth Circuit identified specific deficiencies in that approach, including the agency's own prior finding that local, incremental decision-making erodes nationally significant roadless values over time. The 1,034 municipal water intakes in the Pacific Southwest region sitting in watersheds containing affected roadless areas illustrate what is at stake when those values erode piece by piece. The agency should explain how this proposal avoids repeating the same legal deficiencies the court identified before. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. That argument has already been tested. The Tenth Circuit exercised jurisdiction pursuant to 28 U.S.C. Section 1291, reversed the district court's order granting declaratory relief and issuing a permanent injunction, and remanded the case for the district court to vacate the injunction. The court found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and that it did not create de facto wilderness. The agency owes the public a clear, on-the-record explanation of the legal basis for any position that contradicts that holding. I visit Angeles National Forest to feel awe. That feeling depends on places that remain whole. These areas deserve the protection the 2001 rule provides. Sincerely, Evangeline Stout Los Angeles, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Escaping to isolated sections of forest is a major part of my recreation, and it is extremely important and valuable to me. I photograph the natural sites that inspire me: forest-covered hills and mountain peaks that are untouched, places that recall the way the land looked for thousands of years before people altered the large majority of it. The areas I am most concerned about include Sespe-Frazier in Los Padres National Forest, where I carry many fond memories of hiking and backpacking in my twenties and which is wonderful for how accessible it remains from the greater LA area; the rugged landscapes of the San Gabriel Add and Arroyo Seco units in Angeles National Forest, which provide an important escape from the nearby sprawl of LA; Pyramid in Eldorado National Forest, a wonderful place to hike and experience beauty and solitude; and Tioga Lake in Inyo National Forest, a place of immense natural beauty. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and these places represent what remains. We cannot restore a landscape once it is destroyed. So little is left already, and we must save what is left for our children and further descendants. Preserving natural beauty and places of solitude should have a higher priority than wealth extraction. That is the principle I ask this agency to apply in reviewing this proposal. The agency offers wildfire management as part of the justification for rescission, but its own findings contradict that rationale. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The places I hike and photograph, these untouched forest-covered hills, carry value precisely because they have remained unroaded. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale fares no better on examination. The agency's own record acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The solitude I seek in places like Sespe-Frazier and the beauty I photograph at Tioga Lake are not abstract values; they represent the kind of recreation that the agency's own cost-benefit analysis recognizes as carrying real economic weight. The same analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal also argues that state-specific approaches can replace a single national rule, but this ground has been tested before. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." California's 4,389,760 roadless acres, including the watersheds that supply 1,034 municipal water intakes across the Pacific Southwest region, were protected under the national framework precisely because local, incremental decision-making was found to gradually erode nationally significant roadless values. How does this proposal avoid the deficiencies the Ninth Circuit identified the last time the agency substituted a state-by-state approach for the national rule? Finally, the proposal contends that the 2001 rule exceeded statutory authority. But the Tenth Circuit addressed that question directly. The court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state plainly on what legal basis it departs from that holding. The places I have described are finite. The Pyramid roadless area covers 24,347 acres. Sespe-Frazier covers 106,910. These numbers do not grow back once a road goes in. I ask the agency to answer each of the questions raised above before proceeding further. Sincerely, Erik Krumrey San Rafael, CA

Dear Brooke L. Rollins, I am a reproductive surgeon and healthcare sustainability researcher Studies show that natural and green spaces improve the mental and physical health of those who live nearby. Having green spaces in the middle of LA improves access to those who otherwise cannot get out of the city. Repealing the rule reduces health benefits of natural spaces and exposes patients to more traffic related pollution. This increases healthcare costs for all and creates and weakened population. Regarding the Arroyo Seco in the Angeles National Forest, California: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the Arroyo Seco, Angeles National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Your actions transfer increased health costs to other governmental agencies, for what benefit? This is a formal objection to rescission, entered for the record.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I grew up in are not abstractions. My father took me hunting deer through the Angeles Forest, around Barley Flats and into the backcountry, and what I carried home from those days was not just game but something harder to name: appreciation for the land and its beauty. We may be hunters, but stewardship always comes first. The elk, deer, and bear we hunt need a refuge. We need to be stewards. Now the agency proposes to rescind the 2001 Roadless Area Conservation Rule, and I am filing this comment in opposition to Docket FS-2025-0001 because that decision would open the very ground those animals depend on. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The areas I named in the Angeles National Forest, including Arroyo Seco, Strawberry Peak, Magic Mountain, and San Gabriel Add, and the Tuolumne River area in the Stanislaus, are part of that inventory. I spend weekends and holidays camping and hiking throughout the Angeles, Inyo, Tahoe, and Stanislaus forests to explore the natural beauty of California, and I want to keep experiencing it, others to experience it, and this land protected for the next hundred years and beyond. These mountains are where I photograph wildflowers in spring, deer, and one day a mountain lion. But mountain lions need protected forests and mountains to have a home. Roads are the core threat to that home. The agency's own record states that elk avoid areas near roads and select habitat away from them, that ideal summer elk habitat is unroaded land with cover and forage, and that elk survival rates rose during a road closure and fell again when the gates were removed. The DEIS also cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the rule's own Tribal record credits its protections with the recovery of deer populations in Alaska by preserving old-growth winter shelter. On bears, the DEIS quotes the federal grizzly recovery plan directly: increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation, and food reward all increase with the use of even secondary unpaved roads. I ask that the agency explain, as part of the record before it closes, how rescinding the rule is consistent with these findings, each of which comes from its own documents. The wildfire rationale the proposal offers fares no better on its own terms. The agency's record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding is the agency's own. I ask that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from its own prior findings. The economic case is equally strained. The agency's record concedes: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Across the Pacific Southwest region alone, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, a cost the proposal does not adequately account for. Finally, on statutory authority: a federal appellate court has already answered the question the proposal re-opens. The Tenth Circuit held, "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain, with specificity, the legal basis for any contrary position it now takes. Sincerely, Elizabeth Harris San Jose, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The point of going to the Arroyo Seco, the San Gabriels, or the Sierra Nevada is to get away from roads, away from the noise and hecticness of the city, and to immerse myself in the fresh air and beauty of these wild lands. Rescinding the 2001 Roadless Area Conservation Rule would do exactly what I go there to escape: put roads in. I oppose this proposal, and I ask the agency to respond to the following on the record. The agency's own wildfire analysis undermines the justification for this rescission. Its record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The San Gabriels hold rare native California species of plants and animals that could never be replaced if lost, as I put it, to roads. The agency must explain how it intends to square a wildfire-management rationale for rescission with a finding, from within its own environmental review, that roading these landscapes fivefold increases the human-caused ignition risk. The agency must reconcile the proposal with the ignition data in its own draft environmental impact statement, DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and it must do so with specificity, not in general terms. The water issue is just as direct. The agency's own analysis has found that roads can produce up to 90 percent of the sediment from a timber sale, which in turn can affect the watersheds that are the source of drinking water. Water is already scarce, and clean drinking water even scarcer. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. It does not make sense to jeopardize this natural resource, and the agency must explain, with reference to its own sediment and watershed data, how expanding the road system into these areas protects rather than degrades that supply. The economics of this proposal do not hold up. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Public lands should be managed for everyone, including future generations, not only for those who want to build roads for their own gain. The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and it must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The rule as written already accommodates the permitting concerns the agency cites. Its own text confirms it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." California holds 381 inventoried roadless areas totaling 4,389,760 acres. The Arroyo Seco alone covers 4,703 acres of the Angeles National Forest, and the San Gabriel Add covers 2,527 acres of the same forest. These are not abstractions. The agency has not identified which specific administrative burdens are not already addressed by the existing exceptions. It must do so, and must quantify them. My 10-year-old daughter deserves to live on an Earth that has sustainable resources and wildlands. 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. Why have you held no public meetings to see what the citizens of this country think of the possibility of rescission? These are the last unroaded third of the national forests. A logged stand grows back. A road does not. The agency must withdraw the rescission proposal or conduct full public process and substantively address each of these points before proceeding further. Sincerely, [Your Name] [Your City, State]

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The trails I walk in Angeles National Forest, along Arroyo Seco and across this country, give me what I need most: a chance to recharge, to get inspired, and to reconnect to what matters. I take nothing out but photos and memories. I am writing because the proposal to rescind the 2001 Roadless Area Conservation Rule would put that at risk, and because the agency's own documents make the case against it better than I can. The fire argument troubles me most. I live with the aftermath of the Eaton and the Palisades fires… The agency justified this rescission in part on wildfire and fuels management grounds, but its own record says: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding does not support opening roadless areas; it argues the opposite. The agency's own data reinforce this: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." That is not a narrow gap. I ask the agency to quantify the expected increase in human-caused ignitions that would follow from new road access and to weigh that increase honestly against whatever reduction in wildfire hazard is claimed. The wildfire rationale cannot stand on one side of the ledger only. I ask the agency to explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and to reconcile the rescission with the ignition figures its own DEIS Table 21 reports, which show fire density on roaded land vastly exceeding that inside the affected roadless areas. Finally, the agency invited reliance interests and then did nothing with them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is a reliance interest. I plan my travels, choose my destinations, and build my life around the expectation that these forests remain intact. I believe, as a matter of principle, that public lands should be managed for seven generations forward, because we are only stewards. That belief rests on rules that hold. When an agency changes course, it owes the public an accounting of what those who relied on the prior policy now stand to lose. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The 2001 rule has shaped how millions of people relate to these forests. Angeles National Forest, the Arroyo Seco corridor, and wild places across this country carry value that compound interest cannot measure. The agency must account for what it proposes to undo. Sincerely, Irina Tehrani Marina del Rey, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Eastern Sierras are where I take my children and sisters to marvel at the outdoors, and the Arroyo Seco roadless area in the Angeles National Forest is the kind of place that makes that possible for the residents of Los Angeles County. Opening it up to roads and logging would be a net negative to the quality of life for people in this urban area, and I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The stated economic rationale does not survive contact with the agency's own numbers. The record before the agency states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." These are marginal figures. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million, a range so wide it cannot establish a net benefit. Meanwhile the Forest Service carries a $6.9 billion maintenance backlog on the road system it already has. I ask that the agency reconcile this proposal with those figures and explain how expanding a road network it cannot afford to maintain is justified when its own analysis cannot demonstrate a positive return. The small-business certification accompanying this proposal is contradicted by the analysis sitting beside it. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The businesses that hold permits in and around areas like Arroyo Seco are not the national average firm; they are small, place-specific operations whose livelihoods depend on the character of these landscapes. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the permits actually at stake. I ask that the agency withdraw the certification and conduct an assessment of the small entities actually operating in the potentially affected roadless areas. I love seeing new birds, even when I cannot name the species. That experience depends on something the agency's own record documents. The DEIS cites 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) Arroyo Seco offers that quiet to the people of Los Angeles County precisely because it remains unroaded. The agency has not explained how it weighs this documented biological cost against the marginal economic gains it projects. The agency must answer that question directly. The proposal also solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have brought my children and sisters into these landscapes under the expectation that what Teddy Roosevelt fought for over a century ago would remain protected. People plan trips, choose where to live, build businesses, and raise families around these landscapes. The agency is legally required to identify and weigh the reliance interests its prior policy created, and I ask that it do so with respect to the comments it receives, including this one. Finally, the agency's own fire data undercuts a central premise of the rescission. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." In a state where wildfire is already the defining land-management challenge, building roads into the Arroyo Seco and places like it carries a calculable human-caused fire risk that the agency has not quantified. I ask that the agency produce that quantification and weigh it against whatever wildfire-hazard reduction it claims to anticipate. Sincerely, Cassia Roth Claremont, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Angeles National Forest was my playground growing up. Hiking through it taught me to love and respect the natural world, and that immersion gave me something I still use today: I can identify the majority of the flora and fauna in my region, native, introduced, and invasive alike. I use that knowledge to teach friends and loved ones more about the environment around us. By knowing their names, we become more connected to the flora and fauna around us and the world as a whole. That connection is what I am fighting to protect when I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. In the roadless areas near me, finding rarer or less common bird species becomes more likely, and those sightings support local and national initiatives to track wildlife populations. The agency's own evidence explains why. 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. That is not a contested claim from outside critics. It is the agency's own cited science, and then the agency proposes to open these areas anyway. I want my children and their children to hear more birdsong than I did, not less. I ask that the agency explain, directly and specifically, how it reconciles the bird-abundance findings it cites with the direction this rule takes. The agency cites fragmentation science and then does nothing with it. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is stated and then abandoned. No projection follows for the 40.1 million acres of potentially affected environment. A range that wide matters enormously at that scale, and the public deserves to know which end of it is more likely under each alternative. I ask that the agency apply the cited fragmentation range to the 40.1 million acres before any final decision is made. I also photograph what most people walk right past: the tiniest flowers along the Arroyo Seco and through the Angeles National Forest. Showcasing the little guys matters. Biodiversity is not only the charismatic species. The same DEIS that acknowledges fragmentation harms also tells us: "The agency's 428-page draft biological assessment closes: 'Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats.' The DEIS tallies the determinations: 'may affect, likely to adversely affect' for 327 ESA-listed species and 71 designated critical habitats." The agency anticipates the harm. It names 327 species. It identifies no mitigation for any of them. The public is owed a species-by-species account of how those likely adverse effects will be avoided, and ESA consultation must be completed and published before any final rule is issued. On the economics of roading: our money and taxpayer dollars are better spent supporting the local communities of flora and fauna, ensuring they have the right conditions to grow, thrive, and expand. The agency is already billions behind on maintaining existing roads. Opening roadless country to new construction compounds a maintenance burden the agency cannot currently meet. That spending choice deserves a direct answer on this record. Finally, the climate argument the agency raises and then drops. "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The DEIS concludes these lands will continue to store carbon, yet analyzes no scenario involving the harvest and roading this rescission would enable. What happens to that carbon if these areas are opened? The agency must quantify the change in storage and sequestration under each alternative before it acts. Public land should be managed for communal use and appreciation, to ensure that future generations have the same, if not better, opportunities I had to learn to love and connect with nature. The rule being rescinded made that possible. The evidence the agency itself assembled argues against rescinding it. I urge the agency to withdraw this proposal. Sincerely, Elena Mindry-King Altadena, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Angeles National Forest is part of our backyard in Southern California. The largest metropolitan region in the country depends on one of its only connections to nature, and what happens to Arroyo Seco, Strawberry Peak, West Fork, and the San Gabriel roadless areas inside that forest is not an abstraction to me. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The fiscal case for rescission does not hold together. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." If you can't maintain the roads we currently have, how does building more make any sense? The agency is already billions of dollars behind on maintaining its existing road system. Most logging operations run at a net loss, meaning this proposal would cost taxpayers more money for no real financial benefit. I ask that the agency reconcile this proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, and that it explain how an action whose own analysis cannot establish a net benefit justifies expanding a road network already carrying a $6.9 billion maintenance backlog. On the fire argument: there is already a provision in the existing roadless rule that allows for forest management roads. Claiming this rule change is about protecting communities from wildfire is simply not true, and it is an insult to the hundreds of people, including many of my friends, who lost their homes and livelihoods in the recent Eaton Fire in Los Angeles. The rule as written already permits road construction necessary for public health and safety. The agency's own text confirms this: the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." I ask that the agency identify specifically which burdens are not already addressed by the rule's existing exceptions, including those covering public health and safety, existing mineral leases, and community wildfire protection, and quantify those burdens with evidence. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The communities served by those intakes, and the people who hike, camp, and find any contact with nature through places like Arroyo Seco and Strawberry Peak, are precisely the small operators, guides, and outfitters the agency was obligated to assess. Instead, the proposal certifies no significant impact on small entities while, by its own accounting, booking lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than assessing the operators actually holding permits in the affected areas. The agency should withdraw that certification and assess the impact on the small entities actually working in these roadless areas, not the national average firm. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The communities, the water users, and the people who have built lives around the assumption that places like the Angeles National Forest roadless areas remain protected have relied on this rule for more than two decades. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Jason Wise Los Angeles, CA

Dear Chief: My name is Kevin, I'm a composer, and I stand for preserving our pristine backcountry. I oppose rescinding the roadless rule. I have many memories from peaceful walks, time with friends, and creative inspiration provided by Arroyo Seco. A favorite story of mine is hiking the Arroyo Seco Primitive Trail and camping for a few nights with some friends I was able to share backpacking with friends and family at Arroyo Seco, for many being the first time they tried it. Bulldozed road beds would disrupt or end that experience. Regarding the Arroyo Seco in the Angeles National Forest, California: Most listed species are declining, not recovering. A review of all ESA-listed species found that 52 percent had declining status trends, compared with 8 percent improving. The authors concluded that threats are persistent and pervasive, funding has been insufficient, and at least ten times more species probably qualify for listing than have been listed (Evans et al. 2016). — Evans et al., 2016 (https://doi.org/10.1002/bes2.1308) We need to stop infringing upon the natural world for our own means, even with the guise of wildfire protection, which the data shows isn't accurate. We need to support the environment first, as it's our remarkable home that provides endlessly. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “Early quantitative analysis showing roadless areas substantially complement biodiversity conservation, with many roadless areas overlapping areas important for imperiled species. — DeVelice & Martin, 2001 (https://doi.org/10.1890/1051-0761(2001)011[1008:ATETWR]2.0.CO;2)” Quantified Caribou Sensitivity in the Biological Assessment (1% Roads → 42% Decline) Never Carried Into the DEIS Effects Analysis The Draft Biological Assessment for USFWS species states at page 66: "The research predicts that for every 1% increase in roads in the matrix habitat, there will be a 42% decline in southern mountain caribou abundance (Lochhead et al. 2022)." This is the agency's own screening document quantifying an extraordinary sensitivity of a listed species to precisely the activity the rescission would newly allow — yet the DEIS's effects analysis nowhere presents, applies, or even acknowledges this ratio in evaluating alternatives. NEPA requires that an EIS contain "a reasonably thorough discussion of the significant aspects of the probable environmental consequences," and general statements do not substitute for the quantified analysis the agency itself possesses. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1213 (9th Cir. 1998); Klamath-Siskiyou Wildlands Ctr. v. Bureau of Land Mgmt., 387 F.3d 989 (9th Cir. 2004). I request that the DEIS incorporate the Biological Assessment's quantified road-density findings for southern mountain caribou into its species effects analysis and disclose the projected consequences of foreseeable road construction in affected matrix habitat. The Department's consideration of this comment and its underlying position — that the Rule should be retained — is appreciated. Best regards, CommentID: RLC-20260909-RGD2QJ

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Arroyo Seco roadless area is a treasure to our community. Living in Altadena and working in Pasadena, I hike frequently in this area, and having 4,703 acres of roadless land so close to home matters in ways that are difficult to overstate. The 7,245-acre Strawberry Peak area, which I have summitted multiple times, offers pristine views of the San Gabriel Mountains, and its unspoiled, rugged slopes would be fundamentally altered by roads. The 2,527-acre San Gabriel Add, though close to Los Angeles, carries you deep into a genuinely wild region of forest where the city disappears entirely. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) because each of these places in the Angeles National Forest, and the communities that depend on them, would be harmed by that rescission. The agency's stated rationale rests in part on wildfire and fuels management concerns, yet the agency's own record undermines that justification. According to the Forest Service, "more than 90 percent of wildland fires are the result of human activity, and ignitions are almost twice as likely to occur in roaded areas as they are in roadless areas (USDA Forest Service 1998, 2000)." The Arroyo Seco and Strawberry Peak areas I hike regularly sit in a region where fire is a constant threat to nearby communities. Opening these landscapes to roads would bring exactly the ignition risk the agency's own science identifies. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition density data in its own DEIS. The agency also suggests the current rule creates administrative and permitting burdens that rescission would relieve. That justification is difficult to square with what the rule actually allows. The rule states: "The rule recognizes the need for tree cutting to reduce the risk of wildfire to at-risk communities. It allows tree cutting in non-upper tier within 0.5 miles from the boundary of an at-risk community, or up to 1.5 miles if certain conditions exist and the area is within a Community Wildfire Protection Plan (CWPP). A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." The communities near the Angeles National Forest, including those I live and work in, are already served by these provisions. Introducing permanent roads into the San Gabriel Add or across the slopes of Strawberry Peak to accomplish what a temporary road already can accomplish would destroy the unique wilderness character of these areas without any demonstrated necessity. I ask the agency to identify, specifically and on the record, which burdens are not already addressed by the rule's existing exceptions for public health, safety, existing mineral leases and community wildfire protection, and to quantify those burdens with evidence rather than assertion. The regulatory flexibility analysis accompanying this proposal certifies no significant impact on small entities, yet the agency's own DEIS names outfitters, guides and tour operators as affected parties, and the Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading estimated losses across every small firm in the sector nationally rather than assessing the outfitters and guides who actually hold permits and operate inside the affected roadless areas. The scenic trails and rugged slopes that draw visitors to Strawberry Peak and the Arroyo Seco support exactly those kinds of businesses. The agency cannot in good faith certify no significant impact on the firms most directly exposed while simultaneously booking millions in annual recreation losses in the same document. The agency must withdraw that certification and conduct a meaningful assessment of the small entities actually operating in these areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. For over two decades, communities near these Angeles National Forest roadless areas have planned recreation, conserved adjacent land and understood these landscapes as protected. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The reliance that has accumulated across that landscape is real and quantifiable. The agency invited those interests and then ignored them in its own analysis. It must identify and genuinely weigh the reliance interests submitted in this comment period before taking any final action. Sincerely, Dr. Charles D Edwards, Jr Altadena, CA 91001

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The mountains outside Los Angeles shaped my childhood. My family camped and hiked there in the summers and sledded and threw snowballs in the winters, and those experiences left me with a simple, persistent wish: that places like the Arroyo Seco roadless area in the Angeles National Forest remain places where people can be with nature for generations and generations to come. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens that, and I oppose it. The agency's own numbers undermine its regulatory flexibility certification. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification is reached by averaging the projected expenditure loss across every small firm in the sector nationally, rather than examining the outfitters, guides and tour operators who actually hold permits inside the affected roadless areas, including those serving the Angeles National Forest. The analysis itself concedes that some firms may lose those receipts entirely. Averaging a harm across thousands of uninvolved businesses to make the harm appear trivial is not analysis. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency has also invited reliance interests and then declined to weigh them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." My family's decades of recreation in the Arroyo Seco area, and my expectation that those 4,703 acres would remain protected for future generations, are exactly the kind of reliance interest the solicitation invites. An agency that changes course after twenty-four years of established protection is obligated to account for the expectations its prior rule created, not simply collect comments describing them and set them aside. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency's own fire data argues against opening these areas to road construction. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The Angeles National Forest sits at the edge of one of the most densely populated regions in the country. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. A ratio of nearly eight human-caused ignitions to one between roaded and roadless land is not a footnote; it is a finding that cuts directly against the proposal's stated rationale. The agency must quantify the expected increase in human-caused ignitions that new road access would bring to areas like Arroyo Seco and weigh that increase against whatever reduction in wildfire hazard is claimed, before this rescission can proceed. Sincerely, Los Angeles, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My job is demanding, and the time I spend camping in Millard Canyon, riding along the Arroyo Seco, and hiking into the park along the Upper Arroyo is not recreational luxury. It is how I keep my heart rate down. I am also a volunteer in habitat restoration, including replanting native plants and removing invasive fire hazards in the Angeles National Forest after human-caused wildfires. I attend Audubon classes to learn about native birds and participate in a raptor study as a volunteer in the field. I send photographs of the Arroyo Seco, nearby parks, wildlife, rivers, and forests to friends all over the world, and many of them come here as tourists because of what they see. America's "endless" wilderness is the draw. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this letter be placed in Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The Arroyo Seco inventoried roadless area, 4,703 acres inside the Angeles National Forest, is part of the landscape I restore on weekends and where I observe the birds I study. The agency's own DEIS cites 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. Opening this country to new roads does not merely disturb habitat at the road corridor; it degrades the surrounding soundscape that birds require. I ask the agency to explain, on the record, how it weighs that documented impact against any projected benefit of rescission. The wildfire justification offered for rescission contradicts the agency's own findings. I help restore the Angeles National Forest precisely because human-caused fires have already damaged it. The agency's record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must explain why the proposal departs from this prior finding and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The forests that filter and mineralize drinking water and hold erosion in check are exactly what is at stake. The agency's own analysis finds that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. We do not want water wars, and losing functioning watersheds would bring them closer. The agency should explain what specific analysis it conducted on watershed protection for California before proposing this rescission. 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. Our kids and future generations should see a more beautiful America than exists now. Too much has already been ravaged. The agency owes the public a full accounting before it undoes what millions of people fought to protect. Sincerely, Resident in Glendale CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The land from Arroyo Seco toward Big Bear Lake is where I go for trees, wildlife, peace, and clean air. I watch scrub jays and red-tailed hawks there. My son and I once tracked a mountain lion and never did see it, but that memory stays with me. That country, and the birds and animals in it, is why I am filing this comment against the proposed rescission of the 2001 Roadless Area Conservation Rule. My view on public land is straightforward. We have reached a point where the impact of humans on the land has resulted in destruction. Land should be open for people, but with the needs of the environment considered first, and first means wildlife before extractive use. The birds I watch depend directly on what roads do to forested habitat. The DEIS cites 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. Opening these areas to road construction would reach into the habitat where I watch birds and expect to keep watching them. The agency has not explained how that loss is acceptable or reversible. I ask that it do so on the record. Bears matter to me in this same country, and the DEIS is direct about what roads mean for them: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. The agency must explain, specifically, how rescinding a national protective rule advances any recovery interest for bears that depend on roadless conditions. The agency's stated preference for state-by-state management is not new. The agency tried that local approach before and lost in court. I ask that the agency address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. The justification that the current rule creates unworkable permitting burdens is not supported when the rule's own text is read carefully. It generally banned road building subject to limited exceptions including: the preservation of "reserved or outstanding rights" or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The flexibility the agency claims it needs is already in the rule. I ask that the agency identify which specific burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases and community wildfire protection, and that it quantify those burdens on the record. Clean water underlies all of this. It protects all life, human and animal. Groundwater directly impacts ocean water, and the water cycle keeps our food supply safe, in addition to plants, animals, and humans. It is as basic to our survival as anything. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Opening roadless watersheds to construction puts that sediment into water that feeds into every system downstream. The agency should answer, specifically, how it reconciles that finding with any claim that rescission is without significant environmental impact. The regulatory flexibility certification does not hold up. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The guides and outfitters working the areas I hike are not a national average. They are permit holders in specific places, and spreading aggregate loss across every firm nationally conceals real harm to real people. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the agency invited comment on reliance interests and then did not weigh any. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My reliance is real. I plan my hiking and birding and time with my son around land that the rule protects. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Rescind this proposal. Sincerely, Margaret MacMillan Van Nuys Ca.

Dear Chief Schultz: As someone who has gotten out on public land in all kinds of conditions and knows the difference a road makes — to noise, to use patterns, to what the land becomes — I'd urge the Department to hold this rule. Regarding the Arroyo Seco in the Angeles National Forest, California: Approximately 13,056 acres of shared ecosystem types — California Chaparral — connect Arroyo Seco and Magic Mountain across 15.4 miles in Angeles National Forest. This combined refugia footprint supports 7 climate-threatened species. Neither area alone provides sufficient refugia extent; the ecosystem network spanning both areas does. Road construction in Arroyo Seco degrades climate adaptation capacity not just within Arroyo Seco but across Magic Mountain as well. The 7 species shared between both IRAs lose access to the full 13,056-acre refugia network. The same is true in reverse: development in Magic Mountain diminishes the refugia value of Arroyo Seco. Under NEPA's cumulative effects mandate, the DEIS must evaluate how rescission affects the climate refugia network connecting Arroyo Seco and Magic Mountain in Angeles National Forest. Analyzing 7 climate-threatened species and 1 shared ecosystem types area-by-area violates 40 CFR 1508.7 by ignoring the network-level impact. "In an 18-year experimental study, connected plots showed rates of plant extinction decreased by 2 percent per year, and rates of plant colonization (new plant species coming in) increased by 5 percent per year over the duration of the study. The effects compound over time — plant biodiversity has increased by 14 percent over 18 years and is still going up. Connecting habitat fragments via corridors can not only stave off biodiversity loss, but also encourage biodiversity gain that compounds over time." — Save the Redwoods League, 2019 Failure to Substantively Respond to Content of Majority-Opposition Comments [challenge-008] The Notice of Intent section reduces overwhelming public opposition to a bare percentage, stating that "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support," without any accompanying discussion of what those commenters actually said. No substantive response section addressing the content categories raised — water quality, carbon storage, invasive species spread — appears associated with this passage. Independent research the agency should engage directly documents that roads cause "increased mortality from road construction," "spread of exotic species," and sediment delivery that is "long-lasting and cumulative and cannot be effectively mitigated" (Trombulak & Frissell 2000). Did the agency consider comments raising these documented mechanisms, and if so, where in the record is that consideration explained? Reducing majority opposition to a percentage without engaging its substance violates the requirement that agencies give reasoned consideration to public comment under Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978), and is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request a substantive, topic-by-topic response to the content of majority-opposition comments before this rescission is finalized. Failure to Address Confounding Causal Factors for Forest Health Decline [challenge-021] The Rationale for the Proposed Rule attributes forest health decline to the 2001 Rule's limits on active management, stating that the Rule "has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns" (pp. 18-19). This single-cause narrative ignores other well-documented drivers of the same trend, including decades of fire suppression policy, climate-driven drought and insect mortality, and wildland-urban interface development pressure that independently affect forest health regardless of roadless status. Nowhere in this section does the agency analyze or rule out these confounding factors, or explain why roadless designation, rather than these alternative causes, should bear responsibility for the observed conditions. Under State Farm, 463 U.S. at 43, an agency cannot ignore an important aspect of the problem, and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), requires reasoned engagement with contrary explanations. I request that the agency add an express analysis distinguishing roadless-attributable effects from these confounding causes, consistent with APA 5 U.S.C. § 706(2)(A). Rescission should not be finalized; the Roadless Area Conservation Rule should remain effective. Hopefully, CommentID: RLC-20260904-W5VTDL

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The natural environment should be protected for needed resources and habitats and for the future of future generations. That is the standard I hold my public land managers to, and the proposed rescission of the 2001 Roadless Area Conservation Rule fails it completely. I oppose this action and ask that my comments be entered into Docket FS-2025-0001. The agency's own evidence on fire is the place to start. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I live in California, where the Arroyo Seco and San Dimas roadless areas within Angeles National Forest sit inside a landscape that needs no introduction to the consequences of wildfire. The agency now proposes rescission partly on the grounds that it will improve fuels management, while its own record documents that roads bring more human ignitions, not fewer. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold together either. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I want my tax dollars spent on protecting and preserving the natural environment, not on exploitation and extraction of treasured resources. That principle takes on specific weight when the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service set against recreation losses of at least $6.1 million a year, and when the net present value of the action spans -$92 million to +$199 million. The agency cannot establish a net benefit with its own numbers, yet it proposes to expand a road system already carrying a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with those figures and explain how an action whose own analysis cannot confirm a net benefit is justified. Clean water is more than life-giving; it should and must be a right of every American. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, according to DEIS Table 35. The Arroyo Seco and San Dimas areas drain into a watershed system that supplies one of the most water-stressed urban regions in the country. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The rule as written already addresses the hardship cases the agency invokes as justification: it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If existing exceptions already cover public health and safety, the agency should say so plainly and identify which specific burdens are not already addressed by those provisions. It has not done that. I ask that the agency quantify the claimed administrative burdens that fall outside the rule's existing exceptions and put that accounting before the public. Finally, the alternatives analysis is not a real alternatives analysis. Protective options were not weighed against the proposal on the merits of forest conditions. Instead, the agency built its purpose around deregulation and eliminated anything that did not fit: "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose statement written as a directive to deregulate forecloses the comparison NEPA requires. The Arroyo Seco and San Dimas areas, and the habitats and water resources they contain, deserve analysis that begins with forest conditions, not with a predetermined outcome. The agency must restate the purpose and need in terms of actual on-the-ground conditions and analyze at least one full protective alternative before this rulemaking proceeds. Sincerely, Paul Irving Los Angeles, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I've lived in Los Angeles for 50 years and my husband and I love the outdoors and hiking. Since the Angeles National Forest is in our backyard, we have gone there in our RV in many sites in the forest. Specifically we love going to Mount Baldy where we hike, birdwatch, and enjoy the wildflowers in the spring and watching nature change throughout the year. What I photograph out there: "I photograph birds, wildflowers, and nature." I photograph a variety of birds, including grackle, turkey vultures, and so many more. We stay on the trail and cover many trails in the Angeles National Forest. This is beautiful land hosting many ecosystems upon which our human well-being is dependent. We understand now more than ever before. We, humans, cannot exist in a vacuum without the many species around us. We are all interdependent. I want my grandchildren to see this interdepency for themselves and realize it is our job to protect it. The ground filters rainwater. We depend on rainwater to refill our aquifers. In this mediterraneam climate this is vital. I have lived through the terrible fires in January 2025 in Pacific Palisades and Eaton Canyon. Friends lost their homes, animals were killed or displaced, environments were wiped out. And humans and animals were breathing polluted air. We know how to stop this problem from growing - by reducing our Greenhouse gases and increasing natural solutions. Our forests help us do this. We don't have many roadless areas left. We cannot develop them for short term gain when we now that this is not in our long term interests. We are already behind in repairing the roads that we have. It does not make fiscal sense to build more roads when we cannot keep up with those we have. I do not want my taxes to go to this. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - San Gabriel Add (2,527 acres), Angeles NF, California - Sheep Mountain (21,098 acres), Angeles NF, California - Arroyo Seco (4,703 acres), Angeles NF, California - West Fork (1,169 acres), Angeles NF, California - Strawberry Peak (7,245 acres), Angeles NF, California I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Cipra Nemeth Los Angeles, CA