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I learned about the recindence of the roadless rule while on a trip to the Dark Divide wilderness in the Gifford Pinchot National Forest of Washington. While there I traveled by foot through old growth forests and witnessed some of the most amazing trees. Some over 700 years old. The United States is a very special country where we have public lands with the most diverse variety of landscapes for the world to see. Logging these old growth forests and destroying these wilderness regions for short term gains will be one of the irresponsible things we can do. Short term gains for few people who have never seen these natural wonders. Please consider the long term gains which always end of being more valuable and not rescind the roadless rule. Tha k you.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Dark Divide felt like nothing else I've seen in the Cascades. I ran a 100 mile race there in September, moving through country where you could go mile after mile without seeing a car or a road. That is what roadless areas make possible, and it is what this rescission would end. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I am an ultra trail runner. The acreage to run without seeing cars or roads in roadless areas is my favorite way to experience the National Forests. The Dark Divide, at 52,483 acres in the Gifford Pinchot National Forest, gave me that. So does Drift Creek, 6,333 acres in the Siuslaw National Forest, which sits surrounded by private clearcut logging and stands as an echo of the majesty of what the Oregon Coast Range temperate forest used to be before extractive colonialism stripped it. Hebo 1a, another 13,930 acres in the Siuslaw, is another small remnant of what remains of that rainforest. These places are also where old growth forest still stands, and old growth is where I go to photograph, where biodiversity is greatest, and where, even as summers grow hotter and drier, the forest still feels cool and damp. What remains of that old growth is rare. Roadless areas help balance the conservation mission of the Forest Service by protecting some of the 4% of remaining old growth in this country. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The agency should say plainly, on the record, what share of remaining old growth in Oregon would be exposed to road construction and timber extraction if those areas lose their protection. The agency's own analysis undermines the wildfire rationale it offers for this rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." 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. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard, and that it explain how the proposal departs from its own prior findings as recorded in DEIS Table 21. Intact forests protect and clean water for communities and wildlife. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. My tax dollars should go toward protecting those ecosystem services, not toward building new roads into country that has none, especially when the agency already carries a $6.9 billion maintenance backlog against a road budget of roughly $73 million a year. The record the agency itself assembled 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 the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system the agency cannot afford to maintain? The rule as written already accommodates the concerns the agency invokes. 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)." I ask that the agency identify specifically which burdens are not already addressed by those existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify each claimed burden with evidence in the record. I commented on this rescission in 2025. By the agency's own count, 99.5% of comments were against it. That the administration proceeds regardless raises a direct question about its obligations under the Administrative Procedure Act and the notice-and-comment process. The agency must address in the record how a response rate of that character is consistent with its duty to consider public input rather than to discard it. Sincerely, Brian Dugovich Corvallis, Oregon

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. For the reasons below, I urge the agency to adopt Alternative 1, the No Action alternative. I live in rural West Marin, California. Ancient forests have been central to my life since childhood; camping and hiking among old trees has connected me to my mother, to her family, and through them to my ancestors. I'm writing about the Dark Divide Roadless Area in southwest Washington, which conservation groups describe as one of the largest remaining old-growth forests in that part of the state. Ancient forests are where I have most directly experienced the sacred. They are also a tangible example of how complex systems evolve over centuries, and how diverse species adapt and sustain one another. The delicate balance of interdependency found most fully in old-growth forests, achieved over long spans of time, is an irreplaceable living model as we work to preserve ecosystems across our planet, to overcome short-term thinking, and to foster a culture that is more cooperative and less extractive. Cutting roads into old growth is like cutting into a living body: it opens the way to logging and careless heavy use that can wound what took centuries to form. We have very little of this natural space left. Public forests belong to all of us, including places I may never walk through. Rescission would remove the national protection that keeps roads and logging out of areas like the Dark Divide. Old-growth stands cannot be restored on any human timescale. The DEIS itself concedes that rescission would "adversely affect" 327 threatened and endangered species and 71 designated critical habitats, and that road construction is the largest source of sediment from timber harvest, a major cause of water-quality degradation. It also acknowledges that road density raises the number and frequency of human-caused wildfire ignitions, which undercuts the claim that rescission serves wildfire safety. I ask the agency to explain how it would prevent these harms in the Dark Divide if the national rule is removed. The economics also don't add up. The DEIS says new roads could be built across 18.2 million acres, adding to a maintenance backlog already above $6.9 billion, while rescission would reduce recreation spending in nearby communities by an estimated $9 million a year. The process is also inadequate. More than 99% of comments in the 2025 round opposed repeal, and the agency's own Tribal consultation found that most Tribal governments consulted oppose rescission. Decisions of this scale deserve a longer comment period and a real response to what the public has said. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1. Laura Trippi

Re: Docket No. FS-2025-0001, RIN 0596-AD66 — Proposed rescission of the 2001 Roadless Area Conservation Rule My name is Kari Hansen. I live in rural Washington County, Oregon, five miles down a gravel road from the nearest pavement. The woods are not scenery to me. They are where I live. I live in the Tualatin Mountains on the edge of Oregon's Coast Range, so the Siuslaw National Forest is my neighboring national forest. Places like the roadless ridges around Mount Hebo are the kind of country I live beside. The Mt. Hood National Forest's roadless acres matter to me too. And across the river in Washington, the Dark Divide in the Gifford Pinchot National Forest is the largest unprotected roadless area in the Cascades, and it deserves to stay that way. I oppose rescinding the 2001 Roadless Rule. It has protected some of the last large undeveloped forests in this country for 25 years. Once the roads go in, the quiet goes, the clean water goes, and the habitat goes, and none of that comes back. Please keep the 2001 Roadless Rule in place. Kari Hansen North Plains, Oregon

I am writing to ask the US Forest Service to keep the Roadless Rule in place. I value hiking, camping, flyfishing and taking photos in the beautiful, untrammeled, undeveloped country that Roadless Areas consist of. They should not be compromised. We do not need roads, timber harvesting, mining or development in these places that have remained largely untouched for decades. These places represent the closest thing to true wilderness, and most of the Roadless Areas should be considered for wilderness designation. Here, near my current home on Whidbey Island, WA, we have the Dark Divide Roadless Area that stretches between Mount Admas and Mount St. Helens, providing high ridges and dense old-growth forests—a rarity anywhere in the country today. I’ve hiked Sauk Mountain in a Roadless Area in the Mount Baker-Snoqualmie National Forest, and cross-country skied out of Winthrop in a Roadless Area on the Okanagan-Wenatchee National Forest. These places are highly cherished by locals and visitors alike. They protect our watersheds and wildlife. They provide open space and recreation and incredible scenic beauty. There is no going back once roads are built into Roadless Areas. Everyone and everything —people, wildlife, and our planet—stand to lose the valuable treasures that have been protected from development. For these reasons I support keeping Roadless Rule in place. Please.

Dear Forest Service and Department of Agriculture Leadership: I am writing as a concerned citizen, outdoor enthusiast, and taxpayer to express my strong opposition to the proposed elimination or weakening of the 2001 Roadless Area Conservation Rule. I urge the U.S. Forest Service (USFS) to select Alternative 1 (No Action) and keep the 2001 Roadless Rule fully intact. The 2001 Roadless Rule safeguards over 58 million acres of inventoried roadless areas across our National Forest System. These undeveloped lands provide vital ecological, economic, and social benefits that would be permanently damaged by opening them to industrial road building and commercial logging. I oppose the proposed action for the following substantive reasons: 1. Backlog and Maintenance Burden The Forest Service already struggles with a multi-billion-dollar deferred maintenance backlog on its existing network of over 370,000 miles of forest roads. Allowing new road construction in previously protected areas creates an additional, unsustainable financial burden for taxpayers while the agency cannot afford to properly maintain or repair its current infrastructure. 2. Increased Wildfire Risk and Human Ignition Building new roads into remote areas dramatically increases the risk of human-caused wildfire ignitions. Statistics consistently show that the vast majority of wildfires originate near existing road corridors. Intact, roadless forests maintain natural canopy cover and soil moisture, providing higher wildfire resilience compared to fragmented forests heavily fragmented by roads and clear-cuts. 3. Protection of Clean Drinking Water Supplies Roadless national forest lands act as natural water filters for millions of Americans, providing clean, cost-effective drinking water to downstream communities. Constructing roads and conducting commercial timber harvests in these steep watersheds significantly increases soil erosion, sedimentation, and runoff, threatening municipal water quality and aquatic habitats. 4. Biodiversity, Wildlife Refuges, and Habitat Connectivity Inventoried roadless areas serve as crucial strongholds for threatened, endangered, and sensitive species. They provide undisturbed corridors necessary for wildlife migration and climate adaptation. Fragmenting these contiguous blocks of habitat will accelerate biodiversity loss and exacerbate threats to sensitive wildlife. 5. Local Economies and Sustainable Recreation Unfragmented public lands drive a multi-billion-dollar outdoor recreation economy supporting hunting, fishing, hiking, camping, and local small businesses in rural communities. Replacing these long-term sustainable economic benefits with short-term resource extraction undermines local economies reliant on intact natural landscapes. Personal Impact: I regularly visit national parks and local forests for hiking and camping frequently. Protecting these quiet, roadless spaces ensures that my family and future generations can enjoy the same clean water and wild experiences that I rely on. I am particularly concerned about the potential loss of protections for specific Inventoried Roadless Areas that I utilize, including the Pikes Peak West IRA in the Pike-San Isabel National Forest and the Dark Divide IRA in the Gifford Pinchot National Forest. Allowing road construction or resource extraction in these named units would destroy contiguous wildlife corridors and compromise critical municipal headwaters. For these reasons, the Forest Service must abandon the proposed rescission and maintain full protections under the 2001 Roadless Area Conservation Rule. Sincerely, Lindsey Sandillo Wheat Ridge CO 80033

Hello, I am submitting public comment in disapproval of the U.S. Department of Agriculture’s (USDA) proposal to rescind the 2001 Roadless Area Conservation Rule. Public opinion from Pew research polling indicates over 70% of US voters oppose repealing the roadless rule. This rule was passed in broad support in 2001 and has not been contentious piece of regulation. The roadless rule provides imminence environmental protections that do not just serve recreationists who hunt and hike into these areas but preserves the environmental resources that then stem out beyond roadless areas. They protect sources of clean water, habitat for animals and forests. Some of these areas are small but impactful like the Dark Divide of Gifford Pinchot National Forest in Washington whose watersheds support salmon runs that help bolster the broader Columbia River watershed salmon runs and has some of the healthier forests in the region. Other roadless areas such as the Tongass in Alaska are large and keep a healthy and large forest that acts as a large carbon sink to buffer the increasingly challenging climate conditions. While the environmental protections are of the top priority for me, the economics of rescinding the roadless rule does not make much sense either. The National Forest Service does not have the budget to properly maintain the forest roads and trails that exist already. This is large reason why the roadless rule was enacted to begin with as many of the roads were too burdensome to maintain. It does not make sense to rescind the rules when there is not sufficient governmental support to build and maintain roads. Logging and mining operations were also already long on the decline prior to the roadless rule’s enactment. Industry towns that prosper today do so for having built a healthy tourism and recreational industry and diversified their economy with other businesses while still operating scaled back and more sustainable logging operations. The protected watersheds that bolster salmon runs along the west coast can only be damaged by the rescinding the roadless rule which again notes another negative economical impact. In the Klamath watershed, after years of debate, we as a community in Oregon and California, determined the impact of dams along the Klamath River cost us more benefits than we received from the energy of the hydroelectric dams. The dams were recently removed, and the speed of the fish restoration has been nothing less than historic. To then begin degrading this watershed by building new roads and logging mountainsides all actions that lead to significant erosion and sediment loading of the creeks and rivers would be a tragedy to the recent work and progress within the Klamath National Forest that has been hailed as a huge victory. I implore the USDA to drop the proposal to rescind the 2001 roadless rule. The proposal will have many negative impacts to both the environment and the economy at large. The few economic benefits of increased logging will only benefit a few of the most wealthy and not the communities at whole. Sincerely, Harrison Holzgang Concerned Citizen and Industrial Environmental Manager

I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, and in support of the No Action alternative. The proposed rule's stated justification is wildfire prevention, but the evidence does not support it. The 2001 rule already permits fuel reduction and fire management through exceptions. More importantly, a 2026 assessment of ignition data from 1992 to 2024 across all eight contiguous Forest Service regions found that wildfire ignition density is highest within about 165 feet of roads and lowest in designated wilderness and inventoried roadless areas. Human-caused ignitions account for roughly 84 percent of wildfires nationally. Building roads into roadless areas introduces ignition sources into the lowest-ignition lands we have. The draft Environmental Impact Statement does not adequately reconcile this evidence with the claim that road building reduces fire risk, and I ask that it do so before any final decision. The rule's own analysis undercuts its rationale. It estimates that only about 4.8 million acres, 16 percent of forested roadless land, are operable for timber, and that full harvest, which it calls unlikely, would produce at most a 5 to 10 percent increase in sawtimber harvest. The agency itself describes the benefit as marginal, modest, and localized. It also anticipates no net change in oil, gas, and coal production. I do not believe a permanent change to the most intact forest lands in the National Forest System is justified by a benefit the agency concedes is this small. The costs, by contrast, are real and lasting. Roadless areas are the source watersheds for a large share of the nation's drinking water, supplying at least 25 million people according to a 2026 study in PLOS Water. They provide cold-water habitat for threatened species, including bull trout, which the Forest Service's own science shows do not occur in watersheds with more than 1.7 miles of road per square mile. Roads are the single largest source of sediment on Forest Service lands, and the damage to water quality and fish habitat is not reversible on any meaningful timescale. These are the reliance interests the proposed rule invited comment on, and they weigh heavily against rescission. The economics are also backwards. The Forest Service already carries a $6.9 billion deferred maintenance backlog for roads and bridges, and cannot maintain the more than 386,000 miles of road it already has. Authorizing new road construction on land it cannot afford to maintain is poor fiscal stewardship, and the cost ultimately falls on taxpayers. I am particularly concerned about the Olympic National Forest and Mount Baker–Snoqualmie National Forest, and the Dark Divide Roadless Area. The ONF and Mount Baker hold tributaries for some of Washington State's largest watersheds, including the Cowlitz, Soleduc, and Upper Skagit. Increasing sediment within these watersheds will have huge impacts on water quality, not just for humans, but also for the animals that rely on these tributaries. The sediment impact has not been fully addressed in this DEIS and needs to be quantified before making a decision. The Dark Divide is one of the largest unroaded areas left in Western Washington, removing the guardrails that currently keep new roads out is a decision that cannot be reversed. Once that area is opened up, the stillness that makes that place a refuge for many Washingtonians will be gone. This is the kind of place-specific harm the national prohibition currently prevents, and the draft EIS does not adequately analyze it. For these reasons, I urge the Department to retain the 2001 Roadless Rule by selecting the No Action alternative. Becky Dilba, Washington

I am writing to reject and oppose the proposed recission of the 2001 Roadless Rule. As noted in the background summary, the Roadless Rule was established to "provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System". The rule has been effective in its stated aims, which is to protect areas that are not designated Wilderness and maintain them for the benefit of US citizens. Here in Washington, I have been a beneficiary of these roadless areas. One such area I have enjoyed regularly with my family is the Alpine Lakes Adjacency, an area of over 50,000 acres that provides recreational hiking opportunities for my family. The quiet that pervades this space is a welcome escape from the busy lives we have every day. Similarly, the Goat Rocks Adjacency, Packwood Lake, White Pass, Carlton Ridge, Dark Divide, and other inventoried roadless areas are places I visit and recreate in. Rescinding the roadless rule will bring these areas irreparable harm. Rescinding the roadless rule will lead to resource degradation (introduction of invasive species, water contamination, etc.) which will counteract one of the stated aims of increased recreational opportunity. Mineral, Timber, and other extractive industries will reduce the available recreational areas and the damages are multi-generational. Public lands should remain available for public recreational use without these negative impacts. Furthermore, one of the rationale used to promote recission is to decrease wildfire risk. The data tell a different story. Research from the Pacific Biodiversity Institute show that the vast majority of wildfires start within half a mile of roads. Extending roads will simply increase wildfire acreage. Another study by The Wilderness Society bolsters this claim in finding that roaded areas have a 4x increased likelihood to have wildfire starts than roadless areas. The toll from these wildfires is both economic and emotional. Wildfire has consumed countless acres, homes, and businesses in addition to lives lost by residents and firefighters. Rescinding the roadless rule will increase wildfires. The existing rule allows for emergency wildfire response and allows for fuel management; these benefits can can be obtained while maintaining the rule. The Forest Service currently struggles to maintain the existing roads because the current and past administrations have raided their funds for other projects. Just a few weeks go, I hiked on a trail in a Forest Service area that has not been maintained in several years and is blocked by multiple blowdowns. The Department should not consider expanding the road system, but rather should concentrate efforts on maintaining current roads, trails, and infrastructure. Maintaining a strong national organization can allow consistency across units and allocate resources to the most critical areas while allowing local units to advocate for important local needs. I appreciate the opportunity to share my concerns. Again, I am opposed to rescinding the Roadless Rule and urge the Department to move in a direction more consistent with the requests of hundreds of thousands of Roadless Area enthusiasts.

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to adopt the No Action alternative and retain 36 CFR part 294, subpart B. I live in Seattle and spend much of my life in Washington's national forests, trail running, backpacking, and climbing in the Mt. Baker-Snoqualmie, Olympic, and Gifford Pinchot National Forests. Washington holds roughly two million acres of inventoried roadless areas, including places like the Dark Divide and the Kettle River Range. These are not abstract acres on a map to me. They are the intact backcountry that makes this state's public lands worth living near. They also anchor an outdoor recreation economy that depends on undeveloped landscapes, clean rivers, and quiet trails. First, the Forest Service cannot maintain the infrastructure it already has. The agency manages more than 370,000 miles of roads and carries a deferred maintenance backlog of more than $5 billion. USDA's own Inspector General found that the agency has been unable to reduce that backlog and lacks a strategy to do so. Anyone who uses national forest trails sees the result: washed-out tread, blowdown left for seasons, and access roads degraded past passenger-car use. Opening 45 million more acres to road construction would add permanent maintenance liabilities to an agency that already cannot meet its obligations. Every new road mile built under this rescission will eventually become another deteriorating, sediment-shedding liability that taxpayers fund and no one maintains. Second, the wildfire rationale offered for this rescission is unsupported. Peer-reviewed research found that humans started 84 percent of U.S. wildfires over two decades, and human ignitions concentrate where people can drive. Extending roads into currently roadless areas is more likely to increase ignitions than to reduce fire risk. The 2001 rule already allows fuel-reduction treatments and access for fire suppression, so rescission is not necessary to meet the wildfire goals the Department cites. Third, the process here does not justify overturning the rule. The 2001 rule emerged from one of the largest public engagement efforts in the agency's history, with hundreds of public meetings and well over a million comments. By contrast, the public was given 45 days, including a 15-day extension, to digest a 300-page draft environmental impact statement for a rule affecting tens of millions of acres. The Department's own analysis of comments on last year's Notice of Intent found that commenters overwhelmingly supported keeping roadless protections. The record before the agency points in one direction, and it is not rescission. Roadless areas protect drinking water sources, salmon habitat, and the last undeveloped backcountry in the National Forest System. Rescinding these protections would be fiscally irresponsible, counterproductive on fire, and contrary to the clearly expressed will of the public. I urge the Department to withdraw this proposal and select the No Action alternative.

I oppose rescinding the 2001 Roadless Area Conservation Rule. I live in Washington State, where nearly 2 million acres of national forest, including places like the Dark Divide and the Kettle Range, would lose protection from new road building and logging. These roadless areas supply clean drinking water, cold streams for salmon, and habitat for wildlife, and the existing rule already allows management and emergency action for wildfire risk. Please keep the Roadless Rule in place.

Please keep the Dark Divide wild. PLEASE. There’s enough development elsewhere. We need the wilderness for our soul.

I strongly believe the roadless rule should remain intact. I work in the outdoor recreation industry, and these areas are vital for places where tourism and recreation play a large roll in the economy. The argument that these forest need more "management" is ridiculous. I was just visiting the Dark Divide roadless in Washington State. There are trees there that are thousands of years old. The forest don't need management, they need to be left alone. There really aren't that many places left in this country that don't have roads. The people pushing to change the roadless rule don't care about healthy forest, they want to exploit those forest for profit.

I am writing to support Roadless Rule Alternative 1, and the maintenance in full of all roadless areas. According to the government’s own analysis this alternative is the most effective at limiting wildfire risk, continues to provide essential tourism income to rural communities, and is the most responsible approach to spending less taxpayer money, as the income from resource extraction in roadless areas will not cover the cost to tax payers of building and maintaining new roads. I am a frequent user of roadless areas in Washington including the Dark Divide (Gifford Pinchot National Forest), Angels Staircase (Sawtooth Inventoried Roadless Area, Okanogan-Wenatchee National Forest) and Alpine Lakes (Okanogan–Wenatchee National Forest and the Mt. Baker–Snoqualmie National Forest). I visit these areas several times a year as a cyclist and hiker, and share the trails there with hunters, motorbikes, and other off-road vehicles. These three roadless areas are regional and national draws for outdoor recreation because of their wild and remote beauty, and the ability to travel without permits and with a variety transportation, serving a different set of users than the backcountry areas of our national parks. Because these areas are realtiviely remote, most trail users spend time and money in adjacent towns (Packwood, Trout Lake and Twisp) whose economies are largely reliant on outdoor recreation. I am most concerned about how the recession of the roadless rule will increase wildfire risk, harm the economies of rural towns with large outdoor recreation sectors, and increase existing revenue shortfalls for the Forest Service – ultimately increasing burden on tax payers. Rescinding the Rule Increases Wildfire Risk •Increased Human Ignitions: The DEIS highlights that as road density increases, the probability, number, and frequency of wildfire starts also go up. Roadless areas currently have significantly lower ignition rates, approximately four times fewer than other forest lands, and remove this rule will lead to more wildfires, more loss of private property, and more harmful wildfire smoke affecting our families. •Limited Fuel Treatment Gains: Although the administration frames the rescission as a tool to expand fuel treatments, the Forest Service itself acknowledges that due to budgetary and terrain constraints, any increase in treatment capability will likely be modest at best. •Contradictory Claims: Despite the stated goal of improving wildfire response by enabling road access, the DEIS admits that newly built roads may make wildfires more frequent and ignition hotspots, undermining wildfire safety objectives. Rescinding the rule hurts rural economies •Recreation Value Loss: The Forest Service’s economic analysis predicts up to $9 million annually in lost visitor spending. This stems from reductions in trail-based and wildlife-related recreation in areas that would become less scenic or accessible. •Rural Community Strains: Repealing the rule could cost taxpayers and rural communities money, not just through lost tourism but also through higher maintenance burdens. Rescinding the rule increases tax payer costs and creates new construction and maintenance costs the Forest Services is unable to foot the bill for. •Revenue Shortfalls: The DEIS estimates that forest-related revenue increases from new timber sales would likely fail to cover the costs of constructing and maintaining the new roads needed to access remote areas. •Maintenance Backlog Growth: The proposal would further burden the Forest Service’s already substantial backlog of road maintenance, currently around $6.9 billion, adding more miles to the inventory without new funding. Please move forward with Roadless rule alternative 1 and maintain prohibitions in all inventoried roadless areas. Becca Book

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The solitude of hiking and camping as far off the beaten path as possible is healing. That is not a preference I can replicate elsewhere, and the places I have named here cannot be replicated at all once roads divide them. I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule and to ask that the agency respond to the specific concerns below. The Gifford Pinchot is one of the most special places in the Pacific Northwest because of the roadless rule. I can do almost all of my favorite things there, from bikepacking the Dark Divide to hiking, foraging, and watching wildlife. The wild and rugged beauty is unmatched, and there are not many places like this left in the USA. This is our natural and cultural legacy, and that is priceless. The Tumwater roadless area at 8,676 acres, the Deer Creek area at 882 acres, and the roughly 213,000 acres of inventoried roadless land in Gifford Pinchot National Forest form the landscape that makes all of this possible. Stumbling upon elk or moose, seeing bears, hearing unfamiliar bird calls: these are the experiences that define the place for me, and none of them survive a landscape carved open by new roads. The agency's own record shows what roads do to those animals. Elk avoid areas near roads and select habitat away from them, and the DEIS documents that elk survival rates rose during a road closure and fell again when the gates were removed. For moose, the DEIS notes they are drawn to road corridors for road salt, which increases human-moose interactions and conflict. And for bears, the agency's own draft environmental impact statement quotes the federal grizzly recovery plan: "the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads." If the agency proceeds with rescission, I ask it to explain how opening roadless habitat in Washington's 139 inventoried roadless areas, totaling 2,014,832 acres, is consistent with its own documented findings on roads and wildlife survival. The proposal justifies rescission partly on wildfire and fuels management grounds. 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 ask that the agency explain why the proposal departs from that finding, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic justification is equally unsettled. 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 timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. The agency should explain on the record how a proposal whose own analysis cannot confirm positive returns justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal also argues that state-by-state approaches can substitute for a national rule. The agency's own record quotes its prior position: "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 agency should address what the Ninth Circuit found deficient the last time it substituted local decision-making for the national rule, and explain how this proposal avoids repeating those deficiencies. I have spent a decade in the Upper Skokomish, 9,311 acres in Olympic National Forest. I scattered the ashes of my golden retriever Soma there because it was that meaningful to both of us. The South Quinault roadless area, 11,081 acres in the same forest, belongs to the same landscape and the same kind of memory. These places deserve the protection the 2001 rule provides, and the agency has not shown on its own numbers that removing that protection serves the public. Sincerely, Makaela Kroin Olympia, WA

I oppose any changes to the Roadless Rule. I love so many of the roadless areas and have recreated in them regularly- Oregon Dunes, Iron Mountain, Larch mountain, Dark Divide. There are dozens of places that I have spent the last 50 years that would be hurt if the Roadless rule is repealed or changed in any way. I am concerned about the wildfire increase that the Forest Service has noted. Oregon has had a horrible wildfire season and I can't imagine what the increase will be if the Roadless Rule is changed. The effect on wildlife is enormous, and we lose species every day due to the roads we have, we don't need more.

Please keep the roadless act. My family lives for being in the great outdoors as nature intended. Visiting places, like the dark divide in Washington, let’s us reset from our hectic work and school life. We come back better people Able to work harder, love stronger. Adding roads will go beyond destroying our countries beauty. It will destroy our peoples sanity.

Docket # FS-2025-0001-223869 Roadless Area Rule Rescission_Proposed Rule_Draft EIS Vol 1 I am opposed to the proposed rescinding of the 2001 Roadless Area Conservation Rule. I want the Forest Service (FS) to keep the protection for Inventoried Roadless areas in place. We should not be putting important protections for our remaining wild area up for development and extractive purposes. We need to protect these intact ecosystems across the nation from being further fragmented. Additionally, this change will not decrease wildfires since the current increase in wildfires is most likely due to climate change which this rule change will not affect. Putting roads into what is currently roadless will increase the already high risk of wildfires and will create long-term maintenance costs. The FS is already underfunded for carrying out the multiple responsibilities it has as an agency. Currently, the FS has a huge backlog of road maintenance. We need to take care of this backlog before building additional roads. It is time for the FS budget to be increased to take care of its existing responsibilities particularly in the area of critical trail maintenance. We need public meetings to be held around the country. The Roadless Area Rule protects our remaining ecosystems contributing to the Nation’s biodiversity. These areas protect clean water, provide for hunting and fishing and wildfire resilience in a time of climate change. These are benefits which are being dismissed by the proposed rule and the draft environmental impact statement. I hike weekly in the Washington Cascades and in eastern WA. Many of the places I hike are in roadless areas protected by the Roadless Rule; places like the Dark Divide, the Teanaway, the Selkirk Range, the Quinault Rainforest, and the Lower Gray Wolf River in the Quilcene to name a few. I get energized and refreshed by spending time hiking trails with mature and old growth forests. It is priceless. There are roadless areas in other states that I would like to hike and I would like to leave a legacy of wild places for my children and grandchildren. Over the 250 years the country has been in existence we have lost nearly all of our wild lands. What remains must be protected. I am opposed to rescinding the Roadless Rule and I support Alternative 1 – the No Action alternative in the Draft Environmental Impact Statement. I also want to have public meetings and hearings to be held around the country. Best Janet Thompson Janet Thompson 11331 Alton Ave NE Seattle, WA 98125

I'm writing as an outdoor enthusiast who spends significant time in the Gifford Pinchot National Forest, Goat Rocks Wilderness, and the Okanogan-Wenatchee National Forest around the Alpine Lakes Wilderness, to strongly oppose the USDA's proposal to rescind the 2001 Roadless Rule. These landscapes matter to me personally. In the Gifford Pinchot, the inventoried roadless areas — including the Dark Divide, the largest roadless area in the forest — form the connective backcountry between Mt. Adams and the Goat Rocks Wilderness, protecting one of the last stretches of old-growth forest left in southwest Washington. More than 60,000 acres there are at risk under this proposal. In the Okanogan-Wenatchee, the Forest Service has inventoried roughly 184,000 acres of roadless land in its portion of the Alpine Lakes alone, including the Icicle River corridor near Leavenworth — country I hike and climb in regularly, and which buffers the wilderness from the industrial development this rule change would allow. Beyond my personal stake, this proposal threatens real economic harm to the towns, cities, and state economies that depend on these forests. Outdoor recreation contributes roughly $26.5 billion annually to Washington's economy and supports around 264,000 jobs statewide, much of it concentrated in small gateway communities like Leavenworth, Packwood, and Randle that rely on hikers, climbers, hunters, and anglers passing through. Statewide, visitors spend nearly $1 billion a year in communities surrounding the national forests this rule protects. Opening these roadless areas to logging and road construction would degrade the very backcountry character that draws that spending in the first place — trading a short-term timber yield for a long-term hit to tourism-dependent local economies. It's also worth noting the rule itself saves taxpayers money: the Forest Service already carries a nearly $6 billion road maintenance backlog, and building new roads into remote, often economically marginal terrain would only add to that burden. I understand the agency frames this as a wildfire and forest-management issue. But inventoried roadless areas make up roughly 28% of Forest Service land while accounting for only a small share of wildfire starts — and roads themselves are one of the biggest drivers of human-caused ignitions. Removing this rule doesn't address the workforce and funding shortfalls that have actually limited the Forest Service's fire mitigation work; it just opens pristine backcountry to new roads and logging under the banner of fire policy, at a real economic cost to the communities that depend on that backcountry staying intact. I've built years of hiking, backpacking, and climbing trips around the wild character of these forests — quiet, roadless country you can't manufacture back once it's fragmented, and one of the state's genuine economic assets. I ask the USDA to withdraw this proposal and keep the Roadless Rule fully intact. Thank you for considering my comment.

We appreciate that roadless areas are some of the last, best places on our public lands in Washington State that are free from any industrial development. Also, we are learning this means country like the Liberty Bell in Okanogan-Wenatchee National Forest, Abercrombie-Hooknose in Colville National Forest, and the Dark Divide in Gifford Pinchot National Forest are absolutely beautiful places to visit. We (my family and I, four taxpaying and voting adults) have lived on the North Olympic Peninsula for the last 20 years, so appreciate that roadless areas provide the wildland connectivity for wide-ranging wildlife such as lynx, wolverine, black bear and elk. We appreciate that much of the wildlife restoration efforts being made are protected by these areas and all of that depends on habitat free from human development. We know there are already more roads on national forests than can be affordably maintained. Over the years we have watched as the forest service in Montana closed hundreds, then thousands of miles of roads. We understand the Forest Service still has some 380,000 miles of roads with a growing maintenance backlog. Why would you want to allow more road development? We also understand the current roadless rule allows restoration thinning and prescribed burning in the roadless areas, but that it limits commercial timber harvest in steep backcountry terrain. We think there is actually constraint from the topography and economic cost of road development in such rugged areas. We are aware that roads fragment and degrade wildlife habitat, and they dump sediment into fish habitat and spawning beds each year. Those cold, clear rushing streams not only spawn fish, but also provide beautifully clean water for local downstream communities and ranching operations. We understand in Washington State, about 85% of fires are caused by people each year and the roads act as pathways for human fire ignitions, not the regulations or thunderstorms. We think we need our wild country way more than we need new forest roads and the mining of our remaining patches of forest. Please keep our roadless areas that also support Indigenous cultural and subsistence practices and some of the best backcountry recreation available in the state. Our rural economies are supported by the hunting, fishing, paddling, hiking, backpacking, off road riding and bird and botany watchers that abound. Thank you! Mike & Dan Brant and Dan & Lys Burden