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I strongly urge the US Forest Service to retain the current Roadless Area rule as it exists and not be modified or eliminated. As a hunter and angler, I have enjoyed many roadless areas in the United States and especially within my home state of West Virginia. Such designated roadless areas as the Seneca Creek, North Fork Mountain, and Cheat Mountain roadless areas in the Monongahela National Forest and Sugar Knob area in the George Washington National Forests are among my favorite places in West Virginia to hunt, hike, camp, and fish. With a graduate degree in plant ecology, I can also attest that the forests in these areas are much healthier than adjoining federal lands managed for timber. This is to a large degree due to our Central Appalachian forests being heavily susceptible to invasive plant invasions which are often severe in managed lands but typically much less common in roadless areas. That is a simple reality that cannot be dismissed based on any sound science. Furthermore, roadless areas by definition are less fragmented than managed areas of the national forests. The Central and Southern Appalachians have many species that have great difficulty dispersing across roads, even relatively small forest roads. This is especially true for many if not most regional endemics such as land snails, lungless salamanders, and perennial plants. While highly mobile species like birds may often benefit from management actions, that is not the case for these other species that depend on these landscapes for survival. Considering the roadless areas occupy less than 1% of West Virginia, it is impossible for me to see how those of us that enjoy hunting, fishing, and hiking in these backcountry landscapes or the very large number of species that benefit from their existence would not be harmed by this proposed rule. I finally would like to say that I am a life-long, tenth-generation West Virginian. As a landowner and full-time resident within the Monongahela National Forest, I am disappointed that the Forest Service has proposed such a poorly justified rule change.

I strongly oppose the USDA's proposal to fully or partially rescind the Roadless Area Conservation Rule. I have lived in Tucker County, West Virginia for more than 40 years and spend time recreating in and around the Monongahela National Forest. A large part of Tucker County’s economy is driven by tourism as people flock to the state’s National Forest and Roadless Areas in particular. Professionally, I have provided place-based education opportunities and administered the building of multi-use trails within the Monongahela National Forest, including the Canaan Mountain Roadless Area. My life, and that of my family and community, are richer because we have the option of recreating, hunting, fishing, and seeking solace on these public lands. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Our national forests are public lands, and they should be protected for the benefit of everyone not opened to greater roadbuilding, more commercial logging, and expanded natural resource and mineral extraction. These lands are part of the public trust, and it is the government's charge and responsibility to be responsible stewards now and for future generations. The Roadless Area Conservation Rule, as it exists, helps protect and preserve the naturalness and wildness of these designated public lands as well as protecting the fish and wildlife habitats that are ALL Americans' birthright and that should not be used to financially benefit commercial industries and interests. The economics and reasoning for the rescission of the Roadless Rule simply do not add up. The Roadless Rule took away “industrial scale” logging, not forest health treatments; and it allows the Forest Service to meet its multi-use mission. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads. There is already over $6.9 billion deferred maintenance backlog according to the DEIS. Timber revenue typically does not cover the cost of the log itself, let alone pay forward to fund the maintenance or decommissioning of roads built to harvest the logs. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. The Forest Service has argued that rescinding the Roadless Rule could help address wildfire risk, but recent peer-reviewed research suggests otherwise. A 2026 study found that wildfires are approximately four times more likely to ignite near roads than in roadless areas. Roads increase human access and human-caused ignition sources. More wildfire mitigation has occurred in Roadless Areas on USFS lands than in roaded areas since the Roadless Rule was put into place. According to Forest Service data, roadless areas represent 21% of the forested landscape in national forests, and yet 34% of the total fuel treatment activities. Opening intact backcountry forests to additional road construction is not a sound wildfire prevention strategy. The lands designated in 2001 by the Roadless Rule represented the best remaining public lands. Experienced foresters, ecologists, and land managers within the Forest Service widely agree that they have adequate decision-making authority to protect and manage their local lands within the Roadless Rule. In four western states alone, there are currently 15 million grazing allotments in Roadless areas; and Utah alone has 83,000 acres of mineral leases in Roadless areas. Political appointees overseeing the agency, who generally lack the land management experience and multi-use conservation understanding of veteran Forest Service employees, are simply trying to meet a political deregulation agenda. In 2001 when the Roadless Rule was enacted, over 1.6 million people commented during the NEPA process with 90% of those comments offering overwhelming support. In 2025 during the initial comment period, the vast majority of comments were against revoking the Roadless Rule. Don’t ignore the voice of the public and let this well-vetted and beautifully simple regulation be rescinded simply because of the current administration’s focus on deregulation when there is no rationale or USFS data to support its removal. These wild landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. please preserve the Roadless Rule to continue to protect our protect our shared public lands through this policy for future generations.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around the Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Having visited the Monongahela National Forest many times over the past 25 years, I have never felt that the Forest required greater or more extensive road access. The existing Forest Roads are more than sufficient to provide reasonable access for recreation and occasionally sanctioned commercial activity, and thus to expand road building on the Mon into previously undisturbed areas and sensitive plant and animal habitat would go against the entire rationale behind our National Forests and the Mon in particular. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Bradley Stephens 248 Franklin St Morgantown, WV 26501-6906 brad.w.stephens@gmail.com

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around the Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Having visited the Monongahela National Forest many times over the past 25 years, I have never felt that the Forest required greater or more extensive road access. The existing Forest Roads are more than sufficient to provide reasonable access for recreation and occasionally sanctioned commercial activity, and thus to expand road building on the Mon into previously undisturbed areas and sensitive plant and animal habitat would go against the entire rationale behind our National Forests and the Mon in particular. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Bradley W. Stephens Morgantown, WV

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Don’t do it. Ever. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, John

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Herons & bald eagles over Dolly Sods plateau, the cold headwaters threading down through Cheat Mountain & Glady Fork, the spruce-bog country on the highest points of the Monongahela National Forest: this is what the rescission of the 2001 Roadless Area Conservation Rule would put at risk. I oppose the proposed rescission, and I ask the agency to answer the specific questions this comment raises. The Monongahela's 20 inventoried roadless areas total 174,885 acres & protect headwaters that feed the Potomac & eventually the drinking water of Washington, D.C. Across the Eastern region, which includes West Virginia, 286 municipal water intakes sit in watersheds containing affected roadless areas. I understand that runoff, sediment, & water quality after logging and roadwork greatly diminish the health and quantity of fish, if they do not kill them off entirely. The agency's own data holds that roads and their facilities can produce up to 90%of the sediment from a timber sale. Fewer than 12% of the watersheds fed by these roadless areas have impaired streams today. I ask the agency to explain, with specificity, what watershed protection it intends to substitute for the rule's current protections, and how it expects sediment loads in these headwaters to remain within safe limits without them. 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. The spruce-bog ecosystems of the Monongahela, relics of the last ice age clinging to the highest ridges, support species found nowhere else in this region. The agency has not explained how the bird communities of these areas survive a road network that its own cited science says reduces their abundance and drives a third of their species away. I ask that the agency address this finding directly and explain what mitigation it considers adequate to offset documented, rule-cited losses to avian biodiversity in the affected areas. The proposal justifies rescission in part on wildfire and fuels management grounds, yet the agency's 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 its own prior findings on fire occurrence, and must 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 agency carries a $6.9 billion maintenance backlog against a road budget of approximately $73 million a year. 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." The agency must reconcile this proposal with its own economic 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 explain how expanding a road system already carrying that backlog serves the public interest when the agency's own Cost Benefit Analysis cannot establish a net benefit. The agency's record also 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 already reviewed a state-by-state replacement for this rule 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 those same deficiencies. Finally, the courts that reviewed the 2001 rule's statutory authority 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 was within the authority Congress granted and did not create de facto wilderness, and state plainly the basis for any contrary legal position it now advances. 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. The agency owes the public clear answers to every question this comment raises. Sincerely, Sally Morrison Bentleyville, PA

I strongly oppose the proposed repeal of the 2001 Roadless Rule. As a West Virginian and a citizen of the United States of America, I demand that this craziness of destroying the protected lands end. This Roadless Rule does not serve anyone who cares about the land of America. The creators of this 2001 Roadless Rule are self serving and do not care about this country and the beauty of our protected lands, protected for a reason because there are too many who would deface her and fall in line with the coal companies and other corporations that have defiled our land and waters rather than fulfill their promises to protect and restore the land and waters after they got what they wanted. There is no need for this total lack of compassion and empathy in our country. Our "representatives" have broken their word to represent the people. Enough is enough. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Mary Jane Oref 515 Greenbrier Ave White Sulphur Springs, WV 24986-2009 orefkane@hotmail.com

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 These forests are gifts from God for us to protect. I hike in the Monongahela National Forest in West Virginia, the Ocala National Forest in Florida, and the Francis Marion Forest in South Carolina. I go there for beauty and inspiration. I look for all wildlife, even squirrels and raccoons, because signs of wildlife are signs of a healthy ecosystem. There are so few wild animals left on the planet. They deserve a place to roam free, and we deserve to see them. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The Monongahela holds 174,885 acres across 20 inventoried roadless areas, protecting headwaters that feed the Potomac and the drinking water of Washington, D.C. Verified species there include the West Virginia northern flying squirrel, the Cheat Mountain salamander, the snowshoe hare, and the northern long-eared bat. These are not abstractions to me. When I walk those ridges and catch any sign of wildlife, I know the land is intact. The Ocala, which sits directly on top of the Floridan Aquifer, holds 4,855 acres across 2 inventoried roadless areas. Alexander Springs pumps 80 million gallons of crystal-clear water per day through karst limestone that makes road construction a direct contamination pathway to the drinking water supply of central Florida. Red-cockaded woodpeckers recovered there from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. The Florida scrub-jay, found nowhere else on the planet, depends on surrounding scrub that roads would break apart. These are the places I photograph, looking for beauty and inspiration. I ask that this agency explain in this docket how rescinding the rule is consistent with protecting the species and water supplies these specific forests shelter. The proposal invokes wildfire management as a reason for rescission. The agency's 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." I do not understand how opening these forests to new roads reduces fire risk when the agency's own findings say the opposite. The agency must explain why this proposal departs from those prior findings and 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 economics do not justify what is being proposed either. 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." 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 spanning -$92 million to +$199 million. That analysis cannot establish a net benefit. Meanwhile the agency is already $6.9 billion behind on maintaining the roads it has, on a road budget of about $73 million a year. Maintain the roads already in place. It makes no sense at all to construct new ones when we cannot afford to maintain the ones we have. How does expanding a road system already carrying a $6.9 billion maintenance backlog serve the public interest when the agency's own numbers cannot confirm a positive return? Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. The Tenth Circuit resolved that question. Its holding 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 court found the rule was within authority Congress granted and did not create de facto wilderness. The agency must address that holding directly and state in this docket the legal basis for any contrary position. Our public lands should be managed and preserved for us to enjoy and for future generations. To destroy these forests is irresponsible and short-sighted. I urge the agency to withdraw this proposal. Sincerely, Katie Mulligan Myrtle Beach, SC

The views expressed in this comment are my own. I am submitting as an individual and do not speak for or on behalf of the University of Maryland Center for Environmental Science. I am a doctoral candidate at the University of Maryland Center for Environmental Science, Appalachian Laboratory in Frostburg, Maryland, where my research focuses on migratory bird conservation. I live in western Maryland and spend much of my recreational time in the forests and protected areas of neighboring West Virginia, including Monongahela National Forest. I ask that the environmental impact statement (EIS) examine the following issues: 1) Wildfire risk, the stated basis for this proposal. The Forest Service has justified rescission as a way to reduce wildfire risk, but the claim should be rigorously tested. A 2026 peer-reviewed analysis of national forest wildfires from 1992-2024 found ~8 ignitions/1,000 hectares within 50m of roads, compared with ~2/1,000 hectares in Inventoried Roadless Areas, roughly 4x as many. Ignition density fell with distance from roads (1). The authors conclude that building roads into roadless areas is likely to result in more fires due to increased human access and ignition sources (e.g., campfires, cigarettes, vehicle sparks). The EIS should weigh access benefits for suppression against increased ignition risk and road maintenance costs. It should also analyze eastern forests separately because central Appalachian fire regimes and fuels differ from those of western forests. 2) Habitat fragmentation and forest-interior birds. The central Appalachians hold breeding habitat for Birds of Conservation Concern, including Cerulean Warbler and Wood Thrush (7). Roads cause habitat loss, fragmentation, disturbance, mortality, invasive species spread, and changes to adjacent environments (5, 6). Traffic and industrial noise can reduce reproductive and pairing success in songbirds and alter bird communities near roads (2-4). The EIS should quantify how road construction, logging, or development in currently roadless areas would reduce interior forest habitat and affect declining species. 3) Migratory and flyway-scale effects. Large, intact Appalachian forests provide breeding and stopover habitat for birds moving along the Appalachian ridge corridor. The EIS should assess cumulative impacts on migratory birds protected under the Migratory Bird Treaty Act and how habitat loss on National Forest lands would compound pressures elsewhere in their ranges. 4) Headwater water quality. Monongahela National Forest contains headwaters of rivers that supply drinking water downstream (i.e., Potomac and Ohio River basins). Roads are a source of sediment and altered stream hydrology (6). The EIS should evaluate effects on cold-water streams, sensitive aquatic species, and source water for downstream communities, including those in Maryland. 5) Threatened and endangered species. Please assess impacts on federally listed Appalachian species, including Cheat Mountain salamander and Indiana bat, whose habitats depend on intact forests and clean water. Please include a “no action” alternative that keeps the 2001 Rule in place, along with alternatives that keep roadless protections at the state or regional level rather than rescinding them nationwide. Thank you for considering my comment. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Francis, C. D., Ortega, C. P., & Cruz, A. (2009). Noise Pollution Changes Avian Communities and Species Interactions. Current Biology, 19(16), 1415-1419. https://doi.org/10.1016/j.cub.2009.06.052 Habib, L., Bayne, E. M., & Boutin, S. (2007). Chronic industrial noise affects pairing success and age structure of ovenbirds Seiurus aurocapilla. Journal of Applied Ecology, 44(1), 176-184. https://doi.org/10.1111/j.1365-2664.2006.01234.x Halfwerk, W., M. Holleman, L. J., Lessells, M., & Slabbekoorn, H. (2011). Negative impact of traffic noise on avian reproductive success. Journal of Applied Ecology, 48(1), 210-219. https://doi.org/10.1111/j.1365-2664.2010.01914.x Kociolek, A. V., Clevenger, A. P., St. Clair, C. C., & Proppe, D. S. (2011). Effects of Road Networks on Bird Populations. Conservation Biology, 25(2), 241–249. http://www.jstor.org/stable/27976457 Trombulak, S. C., & Frissell, C. A. (2000). Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology, 14(1), 18-30. https://doi.org/10.1046/j.1523-1739.2000.99084.x U.S. Fish and Wildlife Service (2024). USFWS Bird Species of Concern [fact sheet]. https://www.fws.gov/media/usfws-bird-species-concern

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Don’t do it. Ever. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, John Robeson 201 Brooks St Edgefield, SC 29824-1004 robesonjohn@gmail.com

Look, am I a hiker? No. But, guess what? For every lazy old slouch like me there are a thousand young and old people who enjoy these roadless areas! They like them for lots of reasons, but the main one is—you guessed it—because they are ROADLESS. A road less traveled is for Frost and for thousands of wanderers who want to see birds, not Buicks—or even bikes! They want to see and hear the beauty of the natural world. So do I, for that matter, even if I have my own places to visit that are not as hard on my old bones as some of these places. I want there to be undisturbed land for my grandkids to wander and explore without the noise, the pollution, and the ugliness of the vehicles that will surely mar these areas should this rule be dismissed. So, yes, I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. It would be just grand of you to leave our wild, wonderful WV wild and wonderful, and wooded and whimsical. Enough already. Stay away from these beautiful areas. Sincerely, Jodi Jones Sincerely, Jodi Jones PO Box 764 Davis, WV 26260-0764 jodijones1362@gmail.com

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Andrew Moore, I live in Pittsburgh, Pennsylvania, I am an environmental journalist and the author of two books of natural history, The Beasts of the East: The Fall and Rise of America’s Eastern Wilderness (Mariner Books, 2026) and Pawpaw: In Search of America’s Forgotten Fruit (Chelsea Green, 2015); and I am a member of the Pennsylvania Native Plant Society and the Wild Ones Western Pennsylvania Area Chapter. In my personal life, I am also an outdoor enthusiast and frequent Roadless Areas in both Pennsylvania and West Virginia. Areas that are especially important to me include the Clarion River Inventoried Roadless Area and the Hearts Content Inventoried Roadless Area, within the Allegheny National Forest; and the numerous and irreplaceable Roadless Areas of West Virginia, including Canaan Loop, Cheat Mountain, Cranberry Glades Botanical Area, Dolly Sods Roaring Plain, Gauley Mountain, and the Seneca Creek Inventoried Roadless Area, among so many others. I have also visited and backpacked in Roadless Areas in the Sierra Mountains of California, and I credit experiences in those wild, roadless mountains for teaching me about the vastness and the irreplaceable beauty and biological heritage of the United States of America. Furthermore, I place immense value on roadless areas in the West and other parts of the United States, places I may not have been to yet, but which I had planned to visit in the near future. The preservation of these landscapes by previous generations of Americans are among our most noble national achievements. We must honor that work and maintain our Inventoried Roadless Areas. I am also the father of a six-year-old boy, a Tiger Cub in Scouting America, and I look forward to taking my son into Roadless Areas so that he, too, can experience the value and wonder of a wild, roadless America. And it is my hope that in the preservation of these Inventoried Roadless Areas, future generations of Americans will be inspired to become the land stewards we so desperately need. Roadless Areas are our National Heritage and Must Be Preserved From Alaska’s vast Tongass to the red spruce forests of the West Virginia highlands, our national forests are an invaluable inheritance, providing innumerable benefits: Habitat for wildlife, including threatened and endangered species; safeguarding the water of farms, aquatic wildlife, and human communities; and unmatched and irreplaceable opportunities for hunters, anglers, hikers, and other appreciators of nature. The 58 million acres within inventoried roadless areas provide these opportunities and services like no other landscapes, while also supporting millions of visitors each year. These places unite all Americans who value the natural world, across the political spectrum. For more than two decades, inventoried roadless areas have helped the U.S. Forest Service meet its statutory mandate to “improve and protect the forest[s]” under its control. The Forest Service introduced the Roadless Rule in 2001 to implement a National Forest System management approach that would allow it to consider the "whole picture" of landscapes across the country, in order to protect the nationally significant ecological and social values of roadless areas. The Forest Service has previously warned that managing inventoried roadless areas on a forest-by-forest basis could allow incremental road construction and timber harvest, leading to the erosion of roadless qualities nationwide, while increasing the agency’s maintenance, and fiscal burdens. As such, the Roadless Rule advances essential goals of forest management: protecting wildlife, preserving clean water, and preventing wildfires. Opening inventoried roadless areas to development jeopardizes our natural heritage without providing the means to address potential harm. Road construction scars forest ecosystems: as Forest Service ranger Elers Koch has said, “Roads are such final and irretrievable facts.” When roads cause contribute to the local extinction of wildlife, those species may never return. When roads increase sedimentation in our waterways, they may remain “dirty” indefinitely. Roads can induce wildfires, and when those road-attributed fires burn through our national forests, old-growth trees, which have grown for thousands of years, can be destroyed in flash. And as we’ve seen, forest roads can only be removed with heavy machinery—and even decommissioned roads can persist for decades, or indefinitely. The protections inherent to the Roadless Rule are more pressing than ever: Megafires, accelerating habitat loss, and diminishing water supplies have heightened the need for coordinated forest management across the national forest system and increased the value of inventoried roadless areas. (COMMENT CONTINUED IN ATTACHED FILE)

To whom it may concern, I am a lifelong resident of Morgantown, WV and a lover of our precious forests, in and outside of her borders. Cheat Mountain, one of countless sites that would be impacted by reversing these protections, is like a second home to me. Beloved to scores of people (and animals) who not only live in this area, but visit as they pass through, lifting these protections would have a devastating impact on some of the last of the protected land we have left. West Virginia. Mountain Mama. Our homes aren't structures with four walls - they are the hills. They are the mountains. They are the trees. They are the rivers. Please preserve our true HOME. I beg you NOT to reverse this rule, keeping construction out of these areas, and leaving our trees to stand. Citizen and voter, Elissa Momen

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. They are set aside as having potential for wilderness designation. Allowing the construction of roads and other human infrastructure would destroy that potential. Even while not designated, they provide an important alternative in the full spectrum of National Forest land use and recreational opportunities. Roadless areas can be preserved without significant degradation as potential wilderness while still providing opportunities not available in designated wilderness, such as recreational bicycle use and hunting carts and other mechanical equipment not permitted in wilderness. The role of roadless areas as an in-between alternative to full wilderness and motorized lands open to timbering and other development is important and must not be compromised. Once roadless areas are degraded, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, David Johnston PO Box 42 Dryfork, WV 26263-0042 dsjohnstonWV@gmail.com

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. The whole purpose of protected natural lands is to enjoy them without the encroachments that will ensue if this is passed. I for one specifically visit these parts to enjoy being away from what the repeal would create. These are protected lands and should remain as such. Forests such as these are natural treasure that should be protected so all can enjoy them. Sincerely, Matt Kasprzak 1134 Colonial Ave Alexandria, VA 22314-1325 kasprzakmatt@gmail.com

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking and camping is one of the most important and meaningful ways my family and I connect to each other, decompress from the stresses of life, and find joy in living. Places like Seneca Creek and the Dolly Sods Roaring Plain in the Monongahela National Forest are within driving distance of our home in Maryland. It is a place my family has been and a forest I look forward to further exploring with my family. It disturbs me to my core to think this forest could be stripped of its wilderness, chopped down, habitats of living creatures paved over, polluted with runoff from roads, and the dark starry night skies blotted out with light pollution. This land belongs to the people of the United States, and I say this is NOT what I want done to my land. These places give my life meaning. They give my family connection. To spend time in the presence of roadless wilderness is one of the most awe-inspiring human experiences. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I ask that it be entered and addressed in full on the record. The Monongahela's 20 inventoried roadless areas total 174,885 acres and protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C. Seneca Creek alone covers 22,287 acres. The Dolly Sods Roaring Plain covers 13,392 acres. These are not abstract statistics. They are the places where my family breathes. The ecosystems at Dolly Sods are spruce-bog remnants more reminiscent of northern Canada than West Virginia, relics of the last ice age clinging to the highest ridges. The Monongahela shelters the West Virginia northern flying squirrel, the Cheat Mountain salamander, the snowshoe hare, the northern long-eared bat, and the red spruce. Road access will not leave any of this intact. It will open these irreplaceable places to being gutted by logging industries and other industrial uses. Why should my generation and the next be robbed of the very few remaining intact forests left in this country? The agency says the rule's permitting burden justifies rescission. But the rule already provides for what the agency claims it cannot do. 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 agency has not shown which specific burdens those existing exceptions fail to address. 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 with specificity. Across the Eastern region, which includes West Virginia, 286 municipal water intakes sit in watersheds containing affected roadless areas. West Virginia alone holds 25 inventoried roadless areas totaling 195,455 acres. My family, driving from Maryland to reach these forests, is among the users whose reasonable expectations were shaped by two decades of the rule's protections. 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. That is not a procedural footnote. It is a legal deficiency. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Finally, the agency's own fire data undermines a core justification for 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. The agency claims new road access will reduce wildfire hazard. Its own numbers say the opposite. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire risk before this proposal advances another step. Keep the Roadless Rule. Protect Seneca Creek, the Dolly Sods Roaring Plain, and the Monongahela National Forest. Let all 58.3 million acres of wild National Forests remain intact, wild, beautiful, and the absolute American priceless treasure that they are to all living creatures. Sincerely, Rachel Smith Baltimore, Maryland

As a state that relies heavily on eco-tourism, i vehemently appose destruction of our natural resources and land for more roads. We are moving into wv specifically because of its eco tourism small business opportunities. Do not do this! I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Megan Bailey 697 Lancaster Pike Oxford, PA 19363-1132 mbailey.k9connect@gmail.com

Please preserve the Roadless Rule and protect our shared public lands for future generations. I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Margaret Reishman 30 Bradford St Apt 7 Charleston, WV 25301-3056 bella_gardens@outlook.com

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. I am adamantly opposed to removing the Roadless Rule and support it' in it's current state. There is no reason to remove it. Sincerely, stephen jones 3621 Carswell Pl Jefferson, MD 21755-8223 jonesst195@gmail.com