Read the comments.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Bridget Corwin, and I am an avid hiker based in the beautiful state of Michigan. Although our state has fewer Roadless Areas than many others out West, the ones we do have are extremely special and beloved by local and visiting hikers, anglers, hunters, and campers. I have spent time in the roadless areas of the Hiawatha and Huron-Manistee National Forests, and they are truly incredible places that I believe would be negatively impacted by rescinding this Rule. For example, Bear Swamp in Huron-Manistee National Forest contains the headwaters of Muckwa Creek and Black Creek, which feed into the Big Sable River system—a network that supports cold-water fish populations dependent on stable water temperatures and unobstructed migration corridors. The swamp's vegetation and hydrological function moderate water temperature and maintain baseflow during dry periods- conditions that are critical for fish spawning and survival. Road construction in headwater areas directly threatens this temperature regulation function and creates barriers to fish movement, degrading aquatic habitat throughout the downstream network. Additionally, if roads were built and logging was allowed in this area, sediment from bare slopes and road surfaces would wash into the creeks, smothering the gravel and organic spawning substrate that cold-water fish require for reproduction. Although I understand concerns that the Roadless Rule in its current form may hinder wildfire mitigation efforts, studies have shown that timber harvesting often leads to homogenous forested areas that will then burn at a more uniform, sustained high intensity (https://www.fs.usda.gov/treesearch/pubs/34437). Instead of more roads and logging, I believe we need better planning around the wildland–urban interface and more regular and controlled prescribed burns. It is critical that we allow federal lands like these to stay undeveloped not only to preserve the unique and wonderful plants and animals that live there, but also to protect the activities and places that are special to us as humans both today and for future generations. For this reason, I oppose the proposal to rescind or alter the Roadless Rule and support the No Action alternative.

As a Michigan resident and Trout Unlimited supporter, I urge the Forest Service to retain the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). Inventoried roadless areas in Michigan's national forests — including Bear Swamp in the Huron-Manistee — protect the cold-water headwaters and habitat that sustain the fisheries and wild places I value. The Rule has worked for 25 years while still allowing responsible recreation, grazing, fuels reduction, and habitat restoration. Opening these lands to new roads and industrial extraction would put water quality, wildlife habitat, and the outdoor economy I rely on at risk. Please keep the Roadless Rule in place.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Quiet, peace, nature, and water: those are the things I go to the woods and lakes for, and the 2001 Roadless Area Conservation Rule has protected the places where I find them. I oppose its rescission. I paddle Lake Michigan and Lake Superior. I hike and camp near lakes in Northern Wisconsin and have traveled to Shawnee National Forest in Illinois. The roadless areas I care about most directly, including Bear Swamp in the Huron-Manistee National Forest in Michigan, the island and lake units of the Chequamegon-Nicolet National Forest in Wisconsin, and the Burke Branch, Ripple Hollow, Burden Falls, Bay Creek, Eagle Creek, and Clear Springs areas in the Shawnee, are public land. They are for the public to enjoy, not for logging or mining. That is not a slogan; it is the conclusion I have reached after traveling to these places repeatedly over the years. The agency justifies rescission in part on wildfire and fuels management grounds, but its own record directly contradicts that argument. The agency's prior findings state: "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 sentence does not describe a fringe position; it is the agency's own language, drawn from its own environmental review. Bear Swamp sits within Michigan's 16,124 acres of inventoried roadless land, and the Eastern region, which includes Michigan, contains watersheds holding 286 municipal water intakes inside the affected areas. Opening those landscapes to road construction would increase ignition risk precisely where the agency's own data says roaded land burns harder. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, 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 economic case for rescission is no stronger. The agency's own record concedes that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal gain, the agency's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service, set against recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a span so wide it cannot establish a benefit. The Forest Service already carries a $6.9 billion road maintenance backlog. I ask that the agency reconcile the proposal with those numbers and explain how it justifies expanding a road system that the agency cannot currently maintain, when its own analysis cannot confirm a net gain. The permitting burden rationale fares no better under scrutiny. The rule as written already provided that 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 exceptions for public health, safety, existing mineral leases, and community wildfire protection are already in the rule. The agency has not identified, with specificity, which burdens those provisions fail to address. I ask that the agency name the particular burdens the existing exceptions do not resolve, and quantify them on the record. Finally, the regulatory flexibility analysis certifies no significant impact on small entities, but the record itself names outfitters, guides, and tour operators as affected, and books a minimum recreation benefit loss of $6.1 million a year. The certification is reached by spreading expenditure losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in these specific roadless areas. The Thornapple and Le Roy Creek areas in the Chequamegon-Nicolet, along with the Shawnee units I named above, all support recreational use that feeds exactly those small businesses. A certification built on a national average rather than on the affected permit holders is not an analysis; it is an assumption. The agency must withdraw that certification and assess the impact on the businesses actually operating in these areas. These places belong to the public. Rescission serves none of the purposes the agency claims for it, and the agency's own record says so. I urge that the 2001 Roadless Area Conservation Rule be retained without modification. Sincerely, Katrina Burmeister Sleepy Hollow IL

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting since I was 12, now 54 years in, I have watched what happens to country when roads find it. That experience shapes every word below, and it is why I oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed under Docket FS-2025-0001. The inventoried roadless areas in Wisconsin and Michigan that I care about, including Round Lake Study Area, Shelp Lake, Chase Creek, Bear Swamp, Wheeler Lake Islands, and Shoe Lake Islands, hold values that roads and the disturbance that follows them do not restore. Every species benefits from large areas of untrammeled land. That is not sentiment; it is what 54 years of hunting teaches you. The moment a road enters a landscape, something changes about how animals use it. The quiet is gone, the patterns shift, and the habitat those animals depend on starts to fray at the edges. More disturbance is not good for habitat, and that is reason enough to keep the protection in place. I have been fishing for many species for 58 years, and fish depend on clean, well-oxygenated water. Many species depend on cold water. Trout in particular are sensitive to what happens to a stream when a road sits nearby. I have seen sediment wash off a road during a rainstorm and turn the water turbid, and I know what that does to a trout stream. The agency's own record confirms the mechanism: roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and sedimentation from harvest can promote excessive substrate movement and cause egg and juvenile mortality and reduced suitable habitat for fish such as bull trout. Wisconsin alone holds 16 inventoried roadless areas totaling 68,987 acres, and across the Eastern region 286 municipal water intakes sit in watersheds containing affected roadless areas. I would hope that clean water is everyone's concern. Keeping our wilderness watersheds in good condition benefits us all, and more roads do not help. I ask that the agency explain specifically how it expects to protect trout and the cold, clear streams they require if the sediment controls that come with roadless status are removed. The opportunity to hike into remote areas is one of the greatest gifts we have in this country, and I camp all over it. I am always in search of species I have not observed previously, and that search depends on places that remain intact. These are not abstract amenities. They are what these areas actually provide, and the proposal does not account for what is lost when they are gone. On wildfire, the agency argues that rescission serves fuels management, yet its own 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 this proposal departs from that finding and how it reconciles 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. On economics, the agency's own analysis 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." The agency's cost-benefit analysis 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 the Forest Service already carries a $6.9 billion road maintenance backlog. The agency cannot establish a net benefit from this action and must reconcile that with the proposal on the record. On prior legal authority, the agency now questions whether the 2001 rule was within its statutory power. A federal appellate court already answered that question, reversing a district court injunction and ruling that the rule was valid. The court 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." The agency must address the Tenth Circuit's holding that the 2001 rule fell within authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and it must state clearly the legal basis for any position to the contrary. The record does not support this rescission. I urge the agency to withdraw the proposal. Sincerely, Charles Johnson Verona, Wi

The lakes and forests I am describing here, Bear Swamp in Michigan's Huron-Manistee National Forest and the roadless areas of Wisconsin's Chequamegon-Nicolet, including Wheeler Lake Islands, Shoe Lake Islands, Shelp Lake, Perch Lake, and Foursection, are places I care about, and I am filing this comment because their protection depends on the 2001 Roadless Area Conservation Rule remaining in place. I oppose its rescission.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The loudness of the current world is nearly unavoidable. Places like Bear Swamp in the Huron-Manistee National Forest in Michigan give me solitude and peace that I can only thank God for. I go to those places to photograph landscapes and wildlife, and I go to show others what is there, the way I one day want to show my kids, so they can protect and grow what remains. Rescinding the 2001 Roadless Area Conservation Rule would put that directly at risk, and I am filing this comment to oppose Docket FS-2025-0001. Michigan holds 6 inventoried roadless areas totaling 16,124 acres. Bear Swamp, at 3,915 acres, is among them. These are not abstract acres. They are places I visit to photograph wildlife, bears included, and to find the kind of quiet that has become genuinely rare. The agency's own record notes that increased contact and conflict from open roads in bear habitat can end in bear mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Opening roadless areas to new road construction does not leave wildlife where it is. I ask that the agency explain, with specificity, how it intends to protect bear populations in areas like Bear Swamp if the national rule is removed and local decisions are made without a binding floor. The proposal argues that state-by-state approaches can replace a single national rule. The agency's own record shows it has been down that path. The 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. That approach was challenged and found wanting in federal 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 proposal also argues the 2001 rule exceeded the agency's statutory authority. A federal appellate court reviewed that exact question and held otherwise. The record states: 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. The Tenth Circuit held that 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. I ask that the agency explain on the record the legal basis for any position contrary to that holding. Across the Eastern region, which includes Michigan, 286 municipal water intakes sit in watersheds containing affected roadless areas. Clean resources matter to me. The agency should account for downstream water quality effects on those intakes if the rule is removed, and it should explain what specific protections would remain for those watersheds. On the economic analysis: 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 spreading losses across every small firm in the sector nationally, not the firms actually permitted in the affected areas. 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. 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. I think public land needs to be managed for the good of all, for clean resources, for mental stability, to show our children the world that once was, and to avoid destroying any more of what once was. I have planned around the assumption that Bear Swamp and places like it would remain protected. That is exactly the kind of reliance interest the agency invited and then declined to assess. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Bryce Voss Elgin, Illinois

I would like it to be known that the most special places on this planet are the ones least touched by humans. I was born and raised in the United States of America, a proud American, and honestly all of my fondest experiences are in remote areas of this beautiful country. It’s beauty comes from the untouched landscapes. I stand for keeping the Roadless Rule in place. As I mentioned, because I cannot emphasize it enough, I am passionate about the natural, untouched beauty of this country, and this planet. I have long been a landscape photographer, having gone to school for photography, specifically to photograph the landscape of our beautiful areas. I also partake heavily in outdoor pursuits, away from the chaos of cities. It cleanses me, and provides a reset to my system to endure the daily stresses of our society. I've lived in Michigan, and explored the Manistee National Forest, where Bear Swamp is now threatened by this potential rescinding of the Roadless Rules Act. I’ve lived in Colorado a good part of my life exploring in the backcountry, and summiting many 14ers, including the now endangered Mt. Antero. Then there’s Wyoming, where I’ve backpacked in the Teton National Forest, Montana, Idaho, Utah, California, and New Mexico. I’ve hiked along all three major trails systems that are threatened as well, which include, The Pacific Coast Trail (and John Muir Trail), the Continental Divide, and the Appalachian Trail. I’m living in western North Carolina where I now call home, and I frequently hike and bike in areas that are currently protected by the Roadless Rule Act, like South Mills River (bordering the Cradle of Forestry, the birthplace of forestry), Bearwallow, Craggy Mountain, Laurel Mountain, Linville Gorge, Sam Knob, to name a few. I can’t imagine experiencing the same joy, wonder, and awe that I have if these places were to be developed in any way, or in other words touched by humans in any destructive manner, including roads or otherwise. Not only that, but the impact it would have on the ecosystems, and the biodiversity, including all of the native plants and animals, it would be devastating. I’ve also worked in the outdoor industry, and it is largely because of my passion for the outdoors. I know firsthand that it is a thriving industry, and it is for the reason of having places like the ones that are currently protected under the Roadless Rules Act (Wilderness recreation and passive-use values are economically substantial. Economists estimate Western wilderness areas hold passive-use value — the value people place on knowing an area remains intact — at roughly $168 per acre. Wilderness recreation alone generates an estimated $574 million annually in economic value, based on an average of $39 per recreation day. Road construction in roadless areas would not destroy these values everywhere at once, but it would change the conditions on a substantial share of acreage where they currently exist (Loomis 2000; Izon et al. 2010)). There is a reason the Act was put into place, and the reason is to support something that is greater than all of us, even though it is a part of all of us. I am in full support of keeping the Roadless Rule Act in place. It is serving a need that goes far beyond humans. The old growth in many of the forests that are now threatened by the rescinding of the Roadless Rules Act, are likely a part of the reason that global warming hasn’t expedited any faster that it already has (old-growth forests store 35 to 70% more carbon, including in the soils, compared to logged stands — DA et al., 2022 (https://doi.org/10.3389/ffgc.2022.979528)). These forests are also home to many endangered species, and other animals who continue to lose their territory to human development. We need to keep the Roadless Rules Act in place, for all life, including this one planet that we all share. There is much to lose, including but not limited to, home to many endangered species, a wealth of biodiversity, carbon sinks for our planet to sustain, outdoor pursuits that provide rejuvenation to so many, no matter the color or their skin, or who they vote for, and once it’s gone, it can never be replaced. I’m concerned that the rescinding of the Roadless Rule is for reasons that reach far beyond mere wildfire protection, and more for profit. I believe that there are better alternatives to go about wildfire protection and mitigation, while keeping the Roadless Rule in place. I strongly urge your consideration to keep the Roadless Rule in place.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Boundary Waters draw me back to paddle them. The forests along those shores are what I photograph. I believe public land should be managed for preservation, not private profit, and the areas I am writing about make that principle concrete: Foursection, Shelp Lake, Chase Creek, Bear Swamp, Shoe Lake Islands, and Wheeler Lake Islands, all in the Chequamegon-Nicolet and Huron-Manistee National Forests. Rescinding the 2001 Roadless Area Conservation Rule would put every one of them at risk, and the agency's own record does not support doing so. Wisconsin holds 16 inventoried roadless areas totaling 68,987 acres. Foursection, at 2,037 acres, holds wetlands, forest, and wildlife whose whole ecosystem needs protection. Shelp Lake, at 285 acres, is remote, and that remoteness is precisely what makes preservation so important: keeping it untouched by development depends on the rule staying in place. Chase Creek, at 6,140 acres, is a spring-fed stream worth preserving on those terms alone. Across in Michigan, Bear Swamp, at 3,915 acres, is a fen and wetland whose ecological health is not incidental to its value but the point of it. The Shoe Lake Islands, just 7 acres, support waterfowl including black ducks, harbor endangered bats, shelter wild eagles, and the transition land between forest and water there is culturally important to the Ojibwe. The Wheeler Lake Islands, 5 acres, are wild lakes and should stay that way. What all of these places share is that they are protected now, and this proposal would end that. The agency justifies rescission partly on wildfire and fuels management grounds, but its own record undermines that argument. 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." The agency must 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 proposal also rests on claims about timber and energy economics. 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." I want the agency to reconcile the proposal with its own economic 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 spanning -$92 million to +$199 million, and to explain 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 argues that state-by-state approaches can replace a national rule. The agency's own record notes 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." But the Ninth Circuit already reviewed that state-by-state strategy and found it wanting. I ask that the agency address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies. The proposal also questions whether the 2001 rule was within the agency's statutory authority. The Tenth Circuit resolved that question. Its holding reads: "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." The agency must address that court's conclusion that the 2001 rule fell within authority granted by the Organic Act and MUSYA and did not create de facto wilderness, and state plainly what basis it claims for any contrary position. More than 300 threatened, endangered, and proposed species live in the affected area. The agency's own draft biological assessments conclude the action may affect, and is likely to adversely affect, hundreds of listed species and dozens of designated critical habitats. Across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. The Shoe Lake Islands waterfowl, the Bear Swamp fen, the Chase Creek stream corridor: these are not abstractions. The agency must respond to these specific harms before any rescission moves forward. Sincerely, Annemarie Adams Madison, Wisconsin

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests closest to me, and every forest in this country, are at stake in this proceeding. I watch for birds, including migrating birds, and other wildlife, and I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The roadless areas I am most connected to include Perch Lake, Shelp Lake, Shoe Lake Islands, and Wheeler Lake Islands in the Chequamegon-Nicolet National Forest in Wisconsin, as well as Bear Swamp in the Huron-Manistee National Forest in Michigan and Mogan Ridge in the Hoosier National Forest in Indiana. These are places worth protecting without qualification, and the agency has not made a credible case for opening them. The record the agency assembled does not support rescission on economic grounds. The DEIS itself states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, 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, with a net present value spanning negative $92 million to positive $199 million. That range cannot establish a net benefit. It also cannot explain how expanding a road system that already carries a $6.9 billion maintenance backlog is fiscally responsible. I ask the agency to reconcile the proposal with these figures in the record and explain how a Cost Benefit Analysis with that spread justifies this action. Bird richness declines with road presence in forested habitat. The DEIS documents this directly, finding that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I watch for birds, including migrating species, in these forests. The areas I named are among the nearest to me, and Perch Lake alone covers 2,390 acres of the Chequamegon-Nicolet, part of a Wisconsin roadless inventory totaling 68,987 acres across 16 areas. Fragmentation of that habitat does not produce a modest, manageable effect. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then disappears; no projection across the 40.1 million acres of potentially affected environment follows. I ask the agency to apply that cited range to the full affected acreage and explain what it means for bird populations specifically. The agency documents the relationship between roads and wildlife and then sets the finding aside. "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." No population-level effect on big game is projected anywhere in the document. The agency should project the effects on big game populations and hunter opportunity before finalizing any alternative. Carbon storage is acknowledged and then effectively ignored. "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 sequester and store carbon, but that conclusion does not account for harvest and roading under the action alternatives. The agency must quantify the change in carbon storage and sequestration under each alternative, not assert continuity while proposing development. We do not want roads going through our parks, our forests, our sacred lands. That is a simple and sufficient statement of interest, and it applies to every single forest in this country, not only the ones nearest to me. Wisconsin's roadless watersheds also supply drinking water to communities: across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. Fragmenting these forests and expanding the road network puts both ecological integrity and water supply at risk. The agency has not answered the basic question its own data raises. I ask that it do so. Sincerely, Jen Curley Chicago, IL

Dear Chief Tom Schultz, As a freshwater ecologist, I understand the importance of intact and undisturbed ecosystems. Rescinding the 25-year-old Roadless Rule would put those untouched forests in jeopardy and would be a true loss for the American people. Pre-European settlement, Michigan was once home to 10.7 million acres of wetlands. Since 1978, that number has dropped to 6.47 million acres. Bear Swamp in the Huron-Manistee National Forest is an intact wetland protected by the Roadless Rule. Bear Swamp is home to federally protected species such as the Eastern Massasauga rattlesnake and Blanding's Turtle. Additionally, Bear Swamp is home to the Brook Trout, a species I studied in college and is an indicator of high water quality. “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” If this rule is rescinded, we lose the pristine headwaters of Muckwa and Black Creek that feed into the larger Big Sable River system. These waters protect important and imperiled cold-water species such as the brook trout. Building roads leads to disconnects in rivers that make fish migration difficult and alters the temperatures of those rivers. Additionally, roads are huge sediment polluters, especially when crossing critical stream/ river habitat. Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan: Communities downstream of the Bear Swamp IRA, Huron-Manistee National Forest, receive clean water because this watershed has no roads. Municipal water supplies, agricultural irrigation, and recreational fisheries all depend on the sediment-free, thermally stable flows that the roadless condition delivers. Road construction transfers the cost of degraded water quality to every downstream user. The Bear Swamp IRA, Huron-Manistee National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently. The DEIS must evaluate the cumulative effects of road construction in the Bear Swamp IRA, Huron-Manistee National Forest, on downstream water users, including changes to turbidity, temperature, and flow regime. The analysis must include the cost of increased water treatment required by downstream municipalities and the economic impact on downstream fisheries and recreation. "Riparian shade restoration (2000s climate) could decrease mean August stream temperatures by 0.62°C across the study network. Removing the current riparian shade resulted in a nearly 50% loss of habitat meeting the numeric temperature water quality criteria (12°C 7DADM) for char spawning and rearing, while restoring vegetation only increased the proportion of fish habitat meeting the criteria by ~10%. The linear relationship established in our models between reach shade and stream temperature indicates an increase of ~40% reach shade should cool a stream reach by ~1°C." — Restoration Ecology (PMC/Wiley), 2022 The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. I'd rather see the Department focused on strengthening forest protections, not rolling them back. This proposal moves in the wrong direction. Sincerely,

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I fish, camp, and hike in the mountains of Colorado. Rivers, lakes, trails, the views, the quiet solitude, and wildlife like elk, bighorn sheep, and mountain goats are what I go there for. Logging and road construction in those areas would destroy it. I want my kids to be able to enjoy these areas intact and protected , and the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule does the opposite. The agency's own record is the most damaging witness against this proposal. The agency's prior analysis found that "a human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands," and that "building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. The agency must explain the basis for departing from its own findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale is no stronger. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year 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. The agency must 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. The agency also argues that state-by-state rulemaking can replace a national rule. The record shows the agency once "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 experiment was reviewed by the courts, and the Ninth Circuit found it wanting. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies identified when the national rule was last dismantled piece by piece. On authority: a court has already reviewed whether the 2001 rule exceeded statutory power. 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." The agency should address that holding, explain how it squares any contrary position with the Tenth Circuit's conclusion that the rule fell within authority granted under the Organic Act and MUSYA, and did not create de facto wilderness. The areas at stake to me are not abstractions. Mt. Evans Adjacent Area in the Arapaho-Roosevelt National Forest defines Denver's skyline and the character of the land surrounding it. Indian Peaks Adjacent Area, also in the Arapaho-Roosevelt, looks straight out of a painting, especially at sunset. Green Mountain in the Pike-San Isabel National Forest deserves a visit before anyone considers letting it be logged. The agency's own record confirms that elk avoid roaded areas and that their survival rates rose during a road closure and fell when the gates came back off. It also confirms that bird richness declines with road presence, and that road noise cut bird abundance by over a quarter in a roadless area, with 31 percent of species avoiding the noise entirely. The elk, bighorn sheep, mountain goats, and birds I look for in these places depend on keeping roads out. Bear Swamp in the Huron-Manistee National Forest in Michigan is a wetland, and protecting it is critical. So many wetlands have been lost to development already. The Allegheny Front in the Allegheny National Forest in Pennsylvania is a place for hiking and camping, remarkable in the fall, and that experience would be ruined by logging. The agency built Alternative 3 specifically because commenters asked for protections for big game habitat, fisheries, and wildlife connectivity, then chose the alternative that protects none of it. The agency should explain that choice. The Forest Service held more than 600 public meetings and received 1.6 million comments before writing the 2001 rule. It has held none to undo it. My kids should not inherit fewer of these places than I did. Sincerely, [Your Name] [Your City, State]

I want to urge you to leave the Roadless Rule intact. I live within the boundaries of the Huron Manistee National Forest, and I am very knowledgeable regarding the establishment of the Roadless Area Bear Swamp. My husband is retired from the USFS, and in the late 1990’s and early 2000’s spent a lot of his work time involved in doing all of the survey work to gain this specific designation. I know how much effort and public review went into this, and I imagine the same process occurred for all other RARE2 roadless areas around the country. These special areas were not designed to merely reduce timber harvest, but were meant to protect critical habitat, crucial water quality areas, and unique wildlife populations. In the specific roadless area, Bear Swamp, in my part of the world, a last remaining, historic, winter deer yarding range was protected. This unique cedar swamp has the ability to support a significant deer herd in the rare, but occasional severe winter. Amazingly, deer that have never experienced severe winter conditions will innately migrate into such deer yards when the need arises. These unique yarding areas have been mostly eliminated, and saving the remaining areas are crucial. In addition to benefiting wildlife, there are numerous unique plants that occur in this area. Plants that are important in filtering the headwaters of the Sable River, which is a watershed where most residents in the watershed rely on well water for their daily existence. Keeps this water source protected is critical for safe drinking water. I believe roadless areas not only protect habitat, but also reduce illegal activities such as illegal timber harvest, drug activity and hunting and fishing violations. Even in regular roaded areas, the USFS has been closing roads in recent years, as a measure to save on maintenance costs and efforts. They know that closing roads has reduced illegal activities and helped to reduce maintenance due to road degradation by off road vehicles. As I am mostly experienced with the Bear Swamp roadless areas, I imagine that similar situations exist all around the country. Roadless areas were not enacted on a whim, and it is important to maintain this relatively small percentage of USFS land as unique, special places. Please leave the Roadless Rule in tact.

I am a retired US Forest Service biologist. I worked on the establishment of the Bear Swamp Roadless Area on the Huron-Manistee Nation Forests. I assure you that this area was selected as a roadless area for very specific and important reasons. It was not chosen for random and meaningless reasons. The Bear Swamp Roadless Area provides critical and necessary winter habitat for whitetail deer, several sensitive plant species are found in this area, it is important to the water quality of the Sable River, and is a quiet area for people as well as animals. There exists an extensive network of roads and motorized trails in the area; more are not needed. Please retain this roadless area and those on all National Forests; quiet areas are valuable and necessary for both wildlife and humans. I am retired from the US Forest Service and worked on the establishment of the Bear Swamp Roadless Area. This area was selected as a roadless area for very specific and important reasons. Bear Swamp provides important and critical winter habitat for whitetail deer, several rare and sensitive plants species are found here, and it helps protect the water quality of the Sable River. There already exists an extensive network of roads and motorized trails, more are not needed in this area. Please retain this Roadless Area and those throughout the US Forest Service. Quiet areas are necessary for wildlife and humans alike.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Bear Swamp in the Huron-Manistee National Forest is 3,915 acres of Michigan roadless land I want to see protected. Michigan holds 6 inventoried roadless areas totaling 16,124 acres. What happens to those acres under this proposal is what I am addressing here. The agency's stated rationale for rescission includes wildfire and fuels management, but its own record undercuts that argument directly. 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." If the agency now proposes to open roadless areas including Bear Swamp to road construction on fire-safety grounds, it needs to explain why it is departing from that finding and how the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside the affected roadless areas, supports rather than defeats the proposal. The economic case for rescission is no stronger. The agency's own record concedes 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." Set against that, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. That range does not establish a net benefit. The agency should explain on the record how an action whose own analysis cannot demonstrate a net positive outcome justifies expanding a road system already carrying a $6.9 billion maintenance backlog, and what that means for the 286 municipal water intakes in the Eastern region that sit in watersheds containing affected roadless areas, including those in Michigan. The proposal argues that state-by-state approaches can replace a national rule, but the agency's own prior rulemaking record expressed dissatisfaction with a one-size-fits-all nationwide approach when it previously replaced the 2001 rule. That replacement was challenged in court and the Ninth Circuit identified specific deficiencies in that state-petition approach, including that local decision-making can incrementally erode nationally significant roadless values. The agency has not explained how this proposal avoids those same deficiencies. That question requires a direct answer, particularly for a state like Michigan where the total roadless inventory is small and any incremental loss is disproportionate. On the question of statutory authority, the agency cannot treat the matter as unsettled without confronting what courts have already decided. The Tenth Circuit, in reversing a district court injunction against the 2001 rule, 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 within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and found that it did not create de facto wilderness. The agency owes the public a clear explanation of the legal basis for any contrary position and how it weighs that appellate holding in its current analysis. Bear Swamp is a small piece of ground. Taken together, Michigan's roadless acres are modest by any national measure. What the agency is proposing is permanent, and the record it has assembled does not support the action. I ask that all four of these points receive a substantive response before any final decision is made. Sincerely, CS Manistee, MI

Dear Secretary and Chief: Climate-concerned citizen, late-night reader of EPA reports — I want the record to show a vote against rescinding one of the rare federal protections that's working. I have always enjoyed exploring the many miracles of nature this Earth has to offer. Being outdoors in a natural, roadless environment has many benefits for humanity, from physical to mental health. They are also great places to learn and find meaningful connections. What I've described took a long time to exist. It won't take long to destroy. The rule is what slows that down. I have countless lovely memories of traveling to national parks. I want to protect these spaces now so that many generations to come can experience the same joy that I have. Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan: Huron-Manistee National Forest's Bear Swamp IRA contains 5.0% coverage (~197 acres) of Great Lakes Northern Pine-Oak Forest (Laurentian-Acadian Northern Pine-(Oak) Forest) (GNR), which NatureServe independently identifies as habitat for Indiana Myotis (Myotis sodalis, G2). The species is separately documented present in the area. Road construction degrades this ecosystem and the imperiled species that depends on it. "Wetland species diversity is negatively correlated with paved-road density up to 2 km from wetlands. The effects of roads on wetland diversity take about 3-4 decades to be fully realized. Of 43 species of woodland breeding birds, 26 species (60%) showed reduced densities near highways, and traffic noise explained the most variation in bird density in relation to roads." — Transportation Research Board and National Research Council, 2005 The ecological association between Indiana Myotis (Myotis sodalis) and Great Lakes Northern Pine-Oak Forest (Laurentian-Acadian Northern Pine-(Oak) Forest) means road construction in Bear Swamp operates through a specific degradation pathway: roads alter the physical structure and ecological processes of the ecosystem, which in turn eliminates or degrades the habitat conditions the species requires. The 5.0% coverage (~197 acres) represents the spatial extent of this vulnerability. The rescission of the Roadless Rule will negatively impact the health of the planet by fracturing ecosystems, destroying wildlife habitats and potentially putting crucial species at risk of endangerment/extinction, and disrupt sacred and cultural sites. It would also negatively impact humanity by unnecessarily using up more of our already limited natural resources and spending unnecessary money on maintenance of the roads, etc. These lands deserve better than this. Thank you for your time and consideration. With hope, Sadie Schrodeder CommentID: RLC-20260902-V4TNM3

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: the Hiawatha National Forest, home to the Fibre (7,431 acres) and Delirium (188 acres) Roadless Areas; the Ottawa National Forest, including Norwich Plains and Trap Hills, totaling about 4,600 acres; and the Huron-Manistee National Forest, home to Bear Swamp (3,915 acres). These are Michigan's last large roadless forests. The Roadless Rule keeps these lands free of new road construction and large-scale logging. That is exactly what makes them valuable for mountain biking, hiking, backcountry skiing, snowshoeing, hunting, and paddling today. Rescinding the rule would allow new roads and increased logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently I love to walk in the forests. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States. Sincerely, Alison Stankrauff 120 Seward Apartment 408 Detroit, Michigan 48202

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: the Hiawatha National Forest, home to the Fibre (7,431 acres) and Delirium (188 acres) Roadless Areas; the Ottawa National Forest, including Norwich Plains and Trap Hills, totaling about 4,600 acres; and the Huron-Manistee National Forest, home to Bear Swamp (3,915 acres). These are Michigan's last large roadless forests. The Roadless Rule keeps these lands free of new road construction and large-scale logging. That is exactly what makes them valuable for mountain biking, hiking, backcountry skiing, snowshoeing, hunting, and paddling today. Rescinding the rule would allow new roads and increased logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently offer. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States. Sincerely, Andrew Heer, Highland MI

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: the Hiawatha National Forest, home to the Fibre (7,431 acres) and Delirium (188 acres) Roadless Areas; the Ottawa National Forest, including Norwich Plains and Trap Hills, totaling about 4,600 acres; and the Huron-Manistee National Forest, home to Bear Swamp (3,915 acres). These are Michigan's last large roadless forests. The Roadless Rule keeps these lands free of new road construction and large-scale logging. That is exactly what makes them valuable for mountain biking, hiking, backcountry skiing, snowshoeing, hunting, and paddling today. Rescinding the rule would allow new roads and increased logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently offer. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States. Sincerely, Mark Johnson Wyoming, MI 49519

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: the Hiawatha National Forest, home to the Fibre (7,431 acres) and Delirium (188 acres) Roadless Areas; the Ottawa National Forest, including Norwich Plains and Trap Hills, totaling about 4,600 acres; and the Huron-Manistee National Forest, home to Bear Swamp (3,915 acres). These are Michigan's last large roadless forests. The Roadless Rule keeps these lands free of new road construction and large-scale logging. That is exactly what makes them valuable for mountain biking, hiking, backcountry skiing, snowshoeing, hunting, and paddling today. Rescinding the rule would allow new roads and increased logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently offer. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States.

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: Hiawatha, Ottawa, and Huron-Manistee. The Roadless Rule protects remote forest lands from new road construction and large-scale logging. Roadless areas provide very special outdoor recreation opportunities for people who love mountain biking, hiking, backcountry skiing, snowshoeing, fishing, hunting, and paddling. Roadless areas also provide critical wildlife habitat for threatened and endangered species unique to Michigan. Rescinding the Roadless Rule would allow new roads to be constructed and increase logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently offer. My husband and I have lived in Michigan since 1996. We have raised our two teenage daughters here. We are avid outdoorspeople, and have made countless trips to our National Forests over the years to enjoy mountain biking, hiking, and camping as a family. We appreciate the very special character of roadless areas for remote backcountry recreation experiences. We also value our roadless areas like Bear Swamp in the Huron-Manistee National Forest for the ecosystem services it provides, including serving as a boreal conifer swamp refuge for cold-climate species, wetland-dependent reptile and amphibian habitat for species like Blanding's turtle and the Eastern Massasauga rattlesnake, headwaters stream connectivity and coldwater fishery support for the Big Sable River system, and native pollinator habitat for species like the Monarch butterfly. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States. Sincerely, Jessica Pitelka Opfer Kalamazoo, MI