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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Green Mountain, the White Mountain, Piscah, George Washington, and Je!erson National Forests (to list a few) are where I go for my spirit to feel wild, for peace of mind. That is the plain reason I oppose this rescission, and I want the agency to read these concerns carefully. Protecting wilderness (as through the Roadless Rule) is a moral imperative. In the words from Edward Abbey's Desert Solitaire, "Wilderness is not a luxury but a necessity of the human spirit, and as vital to our lives as water and good bread. A civilization which destroys what little remains of the wild, the spare, the original, is cutting itself o! from its origins and betraying the principle of civilization itself." I'm deeply concerned for the vistas, mountain creeks, and forests I've lived and loved in my entire life. Elliott Knob, inside the George Washington National Forest in Virginia, is a serene place. Enough accessible roads sit close by, yet it remains far enough into the wilderness to stay wild. That balance is what the 2001 Roadless Area Conservation Rule protects. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. Elliott Knob at 9,380 acres is one of them, alongside Crawford Mountain at 9,892 acres, Saint Marys Addition at 1,454 acres, Adams Peak at 7,135 acres, Rough Mountain Addition at 1,142 acres, and Jerkemtight at 16,687 acres, all in the George Washington. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing a!ected roadless areas. Roads bring sediment. Rescission puts those intakes at greater risk, and I want the agency to say plainly how it intends to protect those drinking water sources if this rule falls. The agency's own record undermines its wildfire rationale for rescission. The 2001 rule states: "Building a road into a forest at high risk from uncharacteristic wildfire e!ects 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 this proposal departs from that prior finding 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 a!ected roadless areas. The economics do not hold up either. The agency's own record acknowledges: "the total timber volume a!ected 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." It does not make sense to ignore the billions of dollars inmaintenance backlogs on roads already accessible to the public. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year? The agency must reconcile those numbers in this record before proceeding. The agency argues that state-specific approaches can substitute for a national rule. But the agency's own prior record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide approach.' 70 Fed.Reg. at 25,656." That experiment was tried before and failed judicial review. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state scheme. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911, which authorized federal purchase of private land for national forests, was passed because of what happened when New England's mountains were clearcut. I have hiked those forests. I know what is at stake. The agency should leave the 2001 rule in place. Sincerely,

To the Roadless Rule Rulemaking Docket: As someone who has explored public land in roadless and roaded areas, I can tell you they are not comparable. I've spent many days and nights exploring many roadless areas in Washington, and it's difficult to describe the spiritual and emotional connection I have to these places. It is such a critical part of what makes the wilderness in Washington pristine and second to none. Setting aside all of the environmental benefits of untouched wild places on the watershed and carbon capture and wildlife, the serene beauty of these places is a priceless resource that we will never fully get back once it is lost Exploring the Notch Pass trail with my wife was such a special experience. We saw a pair of bald eagles soaring above the trees, and the beauty of the dense vegetation around the whole green mountain area is nothing short of a fairy tale. These types of places would not be the same with roads cut through them. Regarding the Green Mountain in the Olympic National Forest, Washington: Population-level impacts of Moderate or 11-30% pop. decline severity across Restricted (11-30%) scope are documented for Cascades Frog (Rana cascadae, G3,) in the Green Mountain IRA, Olympic National Forest, driven by 6.1 - Recreational activities. "Frequent human disturbance caused by mining development and road construction in the Kalamaili Mountain Ungulate Nature Reserve (KNR) — inhabited by >80% of Chinese khulan (Equus hemionus) — has interfered with or completely blocked their movement and access to parts of the reserve. The habitat of khulan in KNR went from a good natural habitat in 2005 to deterioration due to mining development in 2011. In 2019, road construction likely hindered its recovery to pre-mining levels. Our study revealed the significant impacts that mining development and road construction have had on the distribution of core habitats, ecological corridors, and movement of khulan." — Biological Conservation (ScienceDirect), 2022 The persistence of Cascades Frog in Green Mountain under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 6.1 - Recreational activities to one that accelerates it. Roadless wilderness areas are truly one of our most precious resources for all to enjoy, and once they are disturbed with roads cut through and commercial operations, they can never be returned to their natural beauty again. I beg you to please protect these places. They mean so much to so many people. Most respectfully, Denali Jones

I am a Vermont resident and lifelong fan of open spaces. Vermont has over 25,000 acres of land in the Green Mountain National Forest. If the Roadless rule is revoked this will leave our National parks/treasures open for assault. We are well aware that men destroy and demean everything they touch. Our country is defined by open spaces. Vermont is identifiable by uninterrupted bucolic views. Leave it that way. Find some other way to destroy our heritage. FDT

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.The forests, wetlands, mountains, and deserts from Vermont and New Hampshire, Maine to Florida, through Pennsylvania, Utah, the Dakotas, Wyoming, Colorado, Utah, Nevada, and more, through to California have been my family, in the truest sense of that word. It's peaceful and soul rejuvenating for me to be in wild nature that I am also a part of. When I hike and camp, I am visiting my non-human family. That relationship, and my daughter's right to continue it and one day pass it on to her own children, is what this rescission puts at risk. I oppose it without reservation.Bread Loaf in Vermont's Green Mountain National Forest represents exactly what the 2001 Roadless Area Conservation Rule was written to protect: 1,768 acres where intact interior habitat can sustain life, including wildlife, native plants, fungi, the full web of macro and micro flora and fauna that has just as much right to exist as humans do. Those species have a place now because roadless areas exist. The proposal would shrink that guarantee, and I want the record to reflect that shrinking it is not acceptable. Lands without damaging roads, is absolutely and inherently necessary to support everything, including humans.On wildfire, the agency's own text states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Fire is far more prevalent in areas with roads than without them, and roads and logging increase wildfire intensity. The proposal nonetheless advances road construction as part of a fuels management rationale. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile this 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.Roads cause erosion, carry invasive species into intact habitat, and fragment the interior forest that vulnerable species depend on. Maine holds 5,988 acres of inventoried roadless land, and 286 municipal water intakes in the Eastern region, which includes Maine, sit in watersheds containing affected roadless areas. These are not abstract numbers. They represent the kind of quiet, intact places where I have hiked and where I have taken my daughter, places that support everything, including humans. The agency's own analysis acknowledges that roads and their facilities can produce the overwhelming majority of sediment from a timber sale. I ask the agency to explain on the record how opening these watersheds to road construction serves the public interest when the sedimentation consequences are already documented in its own record.The economic case for rescission is no stronger. The agency's record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, all while the existing road system carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those figures and explain how expanding a road network the agency cannot currently maintain serves a coherent fiscal purpose.The history of this rule also deserves a direct answer. The agency's own record quotes its prior dissatisfaction with "the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach,' 70 Fed.Reg. at 25,656," a dissatisfaction that led to the state-by-state experiment the Ninth Circuit subsequently rejected. The agency must address its own prior finding that local, incremental decision-making erodes nationally significant roadless values, and it must explain what has changed that would allow a state-by-state approach to survive the same legal scrutiny it failed before.Finally, the rule as written alre

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I am writing to respectfully oppose the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). I urge the Forest Service to abandon this proposal and select Alternative 1, No Action.Rescinding the Roadless Rule would remove an important nationwide layer of protection and return management of these areas largely to individual forest management plans. That would weaken protections that have been in place for more than 25 years.In the White Mountain and Green Mountain National Forests alone, the Roadless Rule protects approximately 260,000 acres—roughly one-fifth of these two national forests. These areas include some of New England’s most iconic landscapes, including the Presidential Range, Franconia Notch, Mount Moosilauke, and Mount Chocorua.The Forest Service’s stated rationale is that the 2001 Roadless Rule has become an obstacle to effective forest management. I do not find that justification persuasive. The proposed rescission would eliminate a long-standing layer of protection rather than address a demonstrated need to remove it. In my view, the stated rationale does not justify such a sweeping change to the management of these lands.Finally, I urge my members of Congress to co-sponsor and support passage of the Roadless Area Conservation Act of 2025, H.R. 3930 and S. 2042, which would provide lasting statutory protection for inventoried roadless areas within the National Forest System.Thank you for your consideration and for your service to the American people.ColemanNew Hampshire

My name is Ryan Williams, and I am a conservation biologist from Massachusetts. As a lifelong New Englander, I cherish what little public land we have in the northeast. Our landscape was rapidly deforested in the centuries following European settlement and it has taken generations for our forests to rebound. Inventoried Roadless Areas (IRA) protected by the 2001 Roadless Area Conservation Rule are some of the few remaining wildlands left in the northeast. I vehemently oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. It would be an environmentally and socially irresponsible act to needlessly log some of our few remaining public wildlands. Therefore, I am writing in support of "Alternative 1", the "no action alternative", which would maintain the 2001 Roadless Rule. Roadless Areas are a bastion of biodiversity, providing critical habitat for innumerable wildlife species. A recent study found that 308 of 537 species of conservation concern in the United States have habitat contained within our Inventoried Roadless Areas (Dietz et al., 2021). What measures will the Forest Service take to minimize impacts to biodiversity associated with the proposed action? Wide-ranging species, like the federally threatened Canada lynx, require large core habitat areas connected by corridors throughout the landscape. Many of the existing large forest blocks required by these species are comprised of Inventoried Roadless Areas. A study by Forest Service researchers found that maintaining unfragmented forested corridors from source populations in Canada with lynx habitat in their southern range periphery is critical (Squires et al., 2013). This study was focused on lynx populations in the Northern Rockies. However, in the northeast we have our own population of this threatened species. How does the proposed action by the Forest Service account for any impacts to the Canada lynx specifically in northeastern states? Will the proposed action impact lynx recolonization into previously occupied habitat in northeastern states? Inventoried Roadless Areas provide countless opportunities for passive wildland recreation. In my own “backyard”, the Forest Service recognizes 25,000 acres of IRA’s in the Green Mountain National Forest (Vermont) and 241,000 acres in the White Mountain National Forest (New Hampshire and Maine) that fall under the protection of the Roadless Rule. This is over 20% of the national forest in New England. Many of these areas contain some of the region’s most popular hiking trails and access to iconic mountains and ridgelines. Areas that local hikers hold sacred include Franconia Ridge (Pemigewasset IRA), the Presidential Range (Presidential-Dry River Ext IRA), and the extensive trail network maintained by the Randolph Mountain Club in the northern Presidentials (Great Gulf Ext IRA). How will the proposed action impact trail use in these IRA's? How will potential road building and logging projects in these areas impact their scenic and recreational values? One of the main justifications for the proposed action is the reduction of wildfire risk. However, this proposal would do little to prevent national forests from burning. A recent study found that the density of wildfire ignitions increased as distance from roads decreased. That is, there were more fires started on and near roads than within intact forests. Furthermore, wildfire ignition density was lowest in Wilderness and Roadless Areas (Aplet et al., 2026). How might the proposed action increase the risk of wildfire ignition due to an increase in roads on our national forest lands? Is there any research in northeastern forests showing that more road building and logging would successfully prevent wildfires? For the reasons above, I strongly oppose the proposal to fully or partially rescind the Roadless Rule.

The Roadless Rule remains the best idea the Forest Service ever had. It conserves vital wild places in forests that are important to me - the green mountain, Mt. Baker- Snoqualmie, Gila, Tongass, Mt Hood, Olympic, nez perce-clearwater, Nantahala-Pisgah and more. Without designated protections, the highest values of these areas stand to be lost. The Forest Service had the good sense to create the policy in 2001. They solved multiple problems - protecting wild places, curtailing fiscal expenditures on road maintenance, and satisfying overwhelming demand from the American public - with one policy. All of those remain as important as they were then. Repealing the Roadless Rule would mean reintroducing forest management problems of the past without any reasonable justifications.

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.I live in a Massachusetts town traversed by the Appalachian Trail and just across the border from the beginning of the Long Trail. The beauty and wild character of our region is critical for our local health and well-being, as well as our tourism-driven economy. As this letter makes clear, the Roadless Rule plays a crucial role in preserving the rural character of our region.For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million-acres of National Forest System lands, or about a third of all lands managed by the USDA Forest Service (Forest Service). In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the White and Green Mountain National Forests, combined. Iconic landscapes protected by the Rule include places like New Hampshire’s Franconia Notch, Mt Moosilauke, Mt Chocorua, and the Presidential Range, as well as Vermont’s White Rocks. The famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.In the context of the current biodiversity crisis, we should be doing everything in our power to preserve wild areas to support intact ecosystems and endangered species.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.AnneMassachusetts

Comment on RIN 0596-AD66: Retain the 2001 Roadless Area Conservation Rule I urge the Department to withdraw this proposal and keep the 2001 Roadless Rule in place. My connection to these lands spans the country. I lived in Vermont, where the Green Mountain National Forest holds the largest roadless areas in the state. Those intact hardwood forests protect clean water and wildlife in a region where wild land is scarce. My family owns property in Montana just outside Yellowstone, next to the Custer Gallatin National Forest. Its roadless lands are part of the connected habitat that grizzly bears, elk, and other wildlife use to move across the Greater Yellowstone ecosystem. Breaking that habitat up with roads would harm the very thing that makes the region extraordinary. And as an avid explorer of Wisconsin's parks and forests, I value the roadless areas of the Chequamegon-Nicolet as some of the last undeveloped forest in the Upper Midwest. The draft EIS does not adequately analyze how new roads would fragment wildlife corridors or degrade headwater streams. It also fails to account for the economic value these areas bring to nearby communities through recreation and tourism, value that depends on their staying wild. These protections took years of public process and more than a million comments to create. They should not be removed through a short comment window with no public hearings. Please retain the 2001 Roadless Rule. Maureen Gribble, Wilmette, Illinois

Please keep the roadless rule! As a resident of Connecticut I know it impacts nearby public lands like Vermont's Green Mountain National Forest. I recently enjoyed wilderness camping there with my son. For the sake of wildlife and for people who enjoy the outdoors, it is critical that we maintain this policy.

My name is Emilie and I oppose rescinding the roadless rule because intact forest ecosystems are so incredibly valuable and a substantial part of my career as well as my mental health - especially in the White Mountain National Forest where my career in wildlife first started alongside my love for hiking the 48 four thousand footers majority of which lie within the forest and are protected by the roadless rule. In addition to my personal enjoyment of these lands, I am concerned about rescinding this rule for the following reasons: the impact on surrounding wildlife and plants, and the push this will create on logging efforts within the forest boundaries in protected and intact forest ecosystems - which are far and few between. Roadless areas currently contain habitats for 57% of vulnerable species of wildlife - in the White Mountain National Forest this includes species like Bicknell’s Thrush, Canada Lynx, Northern Long-Eared bat, and many more. Two of those species I personally have studied and have a different understanding and a close personal connection to them and their importance in the ecosystem. Roads and clearcut logging cause habitat fragmentation that acts as a barrier for migration, breaks up important habitat, creates noise that can cause animal distress and lead to population decline, increase the likelihood of motor vehicle accidents, introduce invasive species, and create runoff in aquatic environments. As far as timber harvests, clear cuts, and logging goes, from an ornithologist perspective as someone who worked for the research branch of the forest service in the White Mountain National Forest, studies show that different types of cut styles and techniques have different impacts on bird species abundance and diversity as well as breeding success rates and migration. Certain species of birds thrive in a maintained forest with single tree selection, group selection, or clear cuts, while other species rely on old growth forest ecosystems. The forest service knows this and actively manages forests accordingly for various species of wildlife, not just for birds, in a way that benefits everyone. Without the roadless rule, it will no longer be managed and organized for the benefit of everyone, it will be far spread and wide for the benefit of a few. This will negatively impact so many wildlife species that use these areas for breeding purposes. Some species in the White Mountain National Forest can only breed there - Bicknell’s Thrush being a prime example. They are so selective, they can only breed in high elevation sub-alpine forest ecosystems that are only found in the higher elevations of the White Mountain National Forest, Green Mountain National Forest, and parts of Maine. This species is already of greater conservation concern even with the extensive efforts to manage their habitat accordingly, we cannot afford to take that away or we may lose this species as a whole. For these reasons, I support the Alternative 1, "No Action" alternative. Keep these roadless areas protected! Sincerely, Emilie

My comments of 19 September 2025 still stand and continue to be largely ignored in these documents. My business is a small entity and will be greatly impacted by this proposed rule; the agency's inability to see / comprehend the full scope of businesses impacted by usage of federal lands is a limitation on the agency's ability to conduct analysis of impacts deriving from this action. Many Forest Plans and their supporting documents are outdated, expired, and originating from a previous century. They are so far beyond usefulness that much of the public no longer holds any faith or trust in the agency to do meaningful or scientifically valid work. Public trust is at stake here. With recent changes to the NEPA process and additional changes to forest monitoring protocols, agency staff have greater license to use their best judgment and the best available science in decision-making. This flawed approach opens doors to conflicts of interest as well as sheer ignorance of conditions on the land. Green Mountain National Forest documents on non-native invasive plants clearly stated almost 20 years ago that most roads and trails on the forest have NOT been assessed or inventoried. That situation has only gotten worse with staff reductions and budget cuts, yet the agency somehow thinks blind judgment calls are a good idea? Partners could theoretically help rectify this dire scenario, but some of those such as Audubon and The Nature Conservancy, recreation interests, and game organizations have financial relationships with the agency that continue to bring potential for conflicts of interest. These special interests or Friends Groups cannot be the solution for an underfunded / under-resourced federal agency. This ill-conceived rescinding of the 2001 Roadless Conservation Rule will work in tandem with the proposed Travel Management Rule to further economic divides in this country. It will continue to provide opportunity for recreation to the elites while leaving most Americans excluded from the benefits of their national forests. It will also open the land to "exploitation without consequence" by corporations and special interests, while again bringing no benefit to the majority of Americans. Future generations will have fewer resources because of the greed exemplified by this rule. The Forest Service is not equipped with the funding or personnel to assess its current conditions or the impacts of its actions. Societies and the world at large have changed drastically while the agency has not; in fact, the Forest Service is so locked into its behaviors and internal culture that it cannot evolve. With such limitations, there are a handful of "goods" that the agency could perform, but poorly conceived, short-term actions like eliminating the Roadless Rule are not a "good." With adoption of this rule, the Forest Service will continue to fail the people it is charged to serve. Thank you for taking my comment.

Subject: Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule, 91 FR 53827 (Docket No RIN 0596-AD66) Dear Forest Service Rulemaking Team, I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to urge the Department to select the no-action alternative, which retains the Rule in full. Because i live in NYC, in part for work-related reasons, my greatest pleasures are escaping to wilderness, roadless areas for recreation. I am an active fly fisherman and have hiked, backpacked and fished in many roadless areas, my personal favorites include the Clark Fork Region in the Idaho Panhandle National Forest and in the Green Mountain National Forest in Vermont. To hoghlight my objections to changing the current rule: 1. The current rule protects irreplaceable forests at a modest cost, keeping out nearly 45 million acres of national forest free of new road construction and most industrial logging. These areas supply clean drinking water, provide core habitat wildlife and offer some of the last undeveloped and most spectacular areas for backcountry for hiking, hunting, fishing, and quiet recreation. Once a road is built, these qualities cannot be restored. 2. The wildfire justification is not supported by the agency's own analysis. The proposal is framed as a wildfire-risk measure. But I understand the Draft Environmental Impact Statement itself acknowledges that increased road density raises the likelihood and frequency of human-caused ignitions. The Rule already allows thinning and fuel treatments near communities, including road work needed to protect life and property. The agency has not shown that the Rule is what limits effective fuels work, particularly when [the Forest Service faces large maintenance backlogs on the roads it already has]. Adding new roads to a system the agency cannot currently maintain would worsen the problem. 3. The Forest Service cannot afford more roads. The agency already has a multibillion-dollar deferred maintenance backlog for its existing road network. Opening inventoried roadless areas to new construction would add long-term liabilities for taxpayers, along with erosion, sedimentation, and invasive-species spread that degrade water quality and fish habitat. 4. The public process has been rushed and not vetted sufficiently. A rule affecting about 45 million acres deserves a full, unhurried comment period. Draft EISs of this scale commonly receive 60 to 90 days, yet this one was offered only 30 before a brief extension. I also ask that the Department make the records of Tribal consultations publicly available in the docket so the public can evaluate how treaty rights and trust responsibilities were considered. 5. And most importantly, this proposal is out of step with public opinion. The 2001 Rule drew an unprecedented volume of public comment, and the overwhelming majority supported it. As a city dweller, my respite and relief has always been my ability to retreat into nature – these roadless areas represent one of America’s crown jewels. My hope is that the enormous pleasure these wild areas have provided my generation will be available to my grandchildren and even their grandchildren. I therefore urge the Department to abandon the proposed rescission and retain the 2001 Roadless Area Conservation Rule. If the Department believes specific management needs exist, they should be addressed through targeted, transparent amendments rather than wholesale repeal. I also ask that the Department respond substantively to the issues raised in these comments in the final rule and Final EIS. Thank you for considering my comments and concerns. Sincerely, JLS New York City, NY

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The national forests of Washington State are where I go to connect with friends, family, and nature. Hiking and camping across Washington is, as I think of it, a home for my soul, and the roadless areas that make that possible, places like Eagle Rock in the Mt. Baker-Snoqualmie, and Green Mountain, Jupiter Ridge, Mt. Zion, Quilcene, Jefferson Ridge, and the other inventoried roadless lands of the Olympic National Forest, are the foundation of that experience. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. I am asking this agency to leave them intact and to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. Washington already has a great deal of working forest land, land that grows trees for industry and is accessible by road. We do not need more land converted to that condition by opening roadless country to new construction. The right approach is to maintain and make the best use of the lands with roads that already exist. No need to build more forest roads. The agency's own data makes the maintenance argument for me: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Building new roads into country that currently has none, while that backlog sits unaddressed and the budget to address it has shrunk by so much, is not a coherent plan. I ask that the agency name the specific funding source for any new road construction and maintenance that rescission would enable, and state in the record the projected change in the deferred maintenance backlog that would result. The fire calculus in the agency's own analysis points in the same direction. "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 Eagle Rock area, the Olympic roadless units, and the other places where I hike and camp are safer from human-caused fire precisely because they are roadless. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access in these areas and weigh that increase honestly against any claimed reduction in wildfire hazard before this proposal advances. The economic accounting in the supporting documents does not hold together. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas, and then concedes some of those firms may lose these receipts anyway. That is not a finding of no significant impact; it is an averaging away of a real impact on specific people. The agency should withdraw the small-business certification and conduct a genuine assessment focused on the small entities actually operating in the potentially affected roadless areas. This comment is itself a reliance interest of the kind the agency invited and then declined to weigh. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." I have organized my outdoor life in Washington around the existence of roadless protections. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, and countless people beyond me have made similar choices premised on these protections remaining in place. The agency must identify and weigh the reliance interests described in the comments it receives, including the one expressed here, before it can lawfully change course. These are public lands. The Forest Service held more than 600 public meetings and received 1.6 million comments to write the rule that protects them. It has held none to undo it. Any change of this magnitude requires an expansive public process, not a quiet reversal. The agency should deny this rescission. Arvia Morris Seattle, Wa.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forest stillness that changes my breathing, the movement of a nuthatch working bark, the occasional egret in the water, the owl I am always hoping to see: these are the things I go into roadless areas to find, and to photograph. I am writing about the Woodford roadless area in Green Mountain National Forest in Vermont, 2,456 acres that exist inside a state holding 25,096 acres of inventoried roadless land. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered in Docket FS-2025-0001. I have watched small areas near me get taken over by development and seen what follows. There were foxes living in a nearby area. When that land was converted to housing, the foxes first appeared in parts of the neighborhood, which was wonderful to see, and then they were gone entirely. That is what happens: the wildlife does not simply relocate, it disappears. We are losing the life around us, and it happens incrementally, each loss looking small until the accumulation becomes irreversible. The Woodford area is one of the places where that loss has not yet happened, and this rule is part of the reason why. The agency justifies rescission in part on wildfire and fuels management grounds, but its own record contradicts that justification. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If road construction raises ignition risk by that magnitude, rescinding the rule does not improve fire outcomes, it worsens them. I ask that the agency explain why the proposal departs from these findings and reconcile the rescission with the ignition data in DEIS Table 21, which the agency's own staff prepared. The proposal also invokes administrative and permitting burdens, but the rule as written already accommodates the exceptions the agency describes as necessary. The rule states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the burdens driving this rescission are real and specific, the agency must name them, identify which ones fall outside the exceptions already in the rule, and quantify those burdens. That accounting does not appear in the record and should. Water is where this becomes irreversible. Across the Eastern region, which includes Vermont, 286 municipal water intakes sit in watersheds that contain affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. This is where the water starts. Damage at the source cannot be undone. I ask the agency to account for those 286 intakes in its analysis of this rescission and to explain how watershed integrity is protected once the rule no longer applies. The DEIS cites a finding that the agency chose not to carry forward into any projection: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and stops there. No projection across the 40.1 million acres of potentially affected environment follows. Woodford is 2,456 acres of forest where owls, egrets, woodpeckers and nuthatches still move in ways that are individual to each of them. Fragmentation does not leave those species in place; it removes them, as I have seen happen nearby. The agency must apply the cited fragmentation range to the full 40.1 million acres of potentially affected environment and place that projection in the record. Finally, the DEIS cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." No population-level consequence for big game is projected anywhere in the document. The agency should project the effects of rescission on big game populations and hunter opportunity and place those projections before the public before any final decision is made. The foxes are gone from the place near me. That outcome was also incremental and also seemed manageable at each individual step. I ask the agency to answer each of these points in the record before it proceeds. Sincerely, Lisa Segarra Marlboro, Massachusetts

Dear Joshua White, Acting Director of Ecosystem Management Coordination at the USDA Forest Service, and Members of Congress: The Climate Action Collective (CAC) respectfully writes to oppose the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). We urge the Forest Service to withdraw this proposal or select Alternative 1, No Action. The Climate Action Collective was established in Fall 2023 and consists of students from the University of Vermont, Champlain College, and Saint Michael’s College who engage in grassroots political action on local climate and environmental issues. Our goals are to cultivate a close-knit, welcoming, and engaging community; provide opportunities to connect with others professionally outside the classroom; and make a tangible difference in Burlington. Our work is centered on environmental justice and intergenerational justice. As college students, we recognize the importance of ensuring that younger generations have a voice in the decisions that will greatly impact our future. For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million acres of National Forest System lands, representing about one-third of all lands managed by the USDA Forest Service (Forest Service). The Inventoried Roadless Areas (IRAs) protected by the Roadless Rule represent some of the wildest, healthiest, and most intact landscapes in the United States (https://www.pfpi.net/wp-content/uploads/2026/06/Roadless-Rule-Rescision-Threatens-Preprint-Mildrexler-et-al.-2026.pdf). More than 1.5 million Americans submitted comments in support of the Roadless Rule when it was developed, setting a record for public participation in federal rulemaking that still stands today. In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the combined White Mountain and Green Mountain National Forests. Iconic landscapes protected by the rule include Franconia Notch, Mount Moosilauke, Mount Chocorua, and the Presidential Range in New Hampshire, as well as White Rocks in Vermont. The famous Long Trail and Appalachian Trail also traverse numerous Inventoried Roadless Areas protected by the rule. Equally important, the Roadless Rule safeguards clean drinking water, helps protect against floods and droughts, and supports the region’s native biodiversity, including imperiled species such as the northern long-eared bat, brook trout, Canada lynx, Bicknell’s thrush, and American marten. Only 3.3% of New England is protected from timber harvesting and road construction, yet scientists say we must protect at least 10% of the region to support biodiversity, carbon storage, and the well-being of our communities. Rescinding the Roadless Rule would reverse decades of conservation progress and make New England’s conservation goals even more difficult to achieve. Recognizing the exceptional value of Inventoried Roadless Areas, which account for just 2% of the contiguous United States, as well as the Forest Service’s multibillion-dollar backlog of road maintenance, the agency established the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the rule’s development. A recent study found that, in New England, the Roadless Rule helps protect drinking water sources for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents receive their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest. Importantly, the Roadless Rule is also one of our most valuable tools for addressing wildfire risk. Most wildfires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). By limiting road construction and development in roadless areas, the rule helps protect these landscapes from additional human-caused fire risks. The Roadless Rule also protects culturally significant sites and areas used for subsistence. These spaces are critical to food security for many Indigenous communities and help sustain cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts. For these reasons, we urge the U.S. Forest Service to withdraw its proposal to rescind the Roadless Rule or select Alternative 1, No Action, to preserve these essential protections for future generations. Finally, we call on our members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025 (H.R. 3930 and S. 2042) to codify the Roadless Rule into law. Thank you for your time and consideration. Sincerely, The Climate Action Collective

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million-acres of National Forest System lands, or about a third of all lands managed by the USDA Forest Service (Forest Service). “Inventoried Roadless Areas” (IRAs) protected by the Roadless Rule represent many of the wildest, healthiest, and most intact landscapes in the United States (https://www.pfpi.net/wp-content/uploads/2026/06/Roadless-Rule-Rescision-Threatens-Preprint-Mildrexler-et-al.-2026.pdf). Over 1.5 million Americans submitted comments in support of the Roadless Rule when it was developed, a record for public participation in federal rulemaking that still holds to this day.In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the White and Green Mountain National Forests, combined. Iconic landscapes protected by the Rule include places like New Hampshire’s Franconia Notch, Mt Moosilauke, Mt Chocorua, and the Presidential Range, as well as Vermont’s White Rocks. The famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.It is so important to protect the remaining wild places that we have in this country. This is imperative for the health of humanity because of the aforementioned "ecosystem services" that such places provide. But even more than that -- these places and their inhabitants have rights too: the rights to retain their wellness and sovereignty in a world not merely inhabited by humans, but dominated by us. Can't we draw a line somewhere, and say that we are not going to desecrate the last remaining wild places that there are?Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.MonicaVermont

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This reckless action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the Agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in New York, NY and spend time recreating in upstate New York, along the Appalachian Trail. Vermont’s Green Mountain National Forest has long been a place I've dreamed of visiting. Under the agency’s proposal, protections for nearly 45 million acres of wild, public lands would be eliminated. The economics of these attacks on the Roadless Rule do not add up. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads rarely, if ever, used. According to the DEIS, the Forest Service could build new roads across 18.2 million acres. This would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion according to the DEIS. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access, resulting in a loss of $9 million in annual visitor spending in local communities. Beyond the economic folly, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and serve as critical carbon sinks in the fight against climate change. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. How would the agency ensure these populations and their habitats aren’t further degraded without protection of the Roadless Rule? The DEIS also states that “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” Communities across the country would lose protections to their drinking watersheds. How would the agency ensure that these watersheds remain intact and that water sources are not compromised from increased risk of erosion and sedimentation? Once roads and clearcuts fragment these landscapes, the damage is permanent. In the DEIS, the agency admits that “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. I am concerned that removing Roadless Rule protections would increase fire risk in our nation’s backcountry forests. Lately, I am appalled by the USDA’s decision to pursue this rollback through an abridged and inadequate public comment process. The original Roadless Rule was created after the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. During last fall’s comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with over 99% of comments opposing the proposed rescission of the rule. During the legally required Tribal consultation process, the agency found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission. Its analysis concedes that timber harvest and road construction in these areas “could have long-term negative effects on Tribal rights and interests.” Now, the agency is attempting to dismantle these protections through a rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. Despite the shortened comment periods, the American public has already made their voice clear: keep the Roadless Rule in its full form in place. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Instead of rolling back protections, the agency should strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

am writing to strongly oppose the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule. I urge you to withdraw this proposal and maintain the protections that have been in place for the past 25 years. At a minimum, please select Alternative 1, No Action. I have spent much of my life in the outdoors, and living in New England has made me especially appreciative of how fortunate we are to have access to forests, mountains, rivers, and truly wild places. These are places where people hike, ski, fish, camp, and simply experience the natural world. But they are also much more than recreational spaces. They are essential to clean water, wildlife, biodiversity, carbon storage, and the health of our communities. The Roadless Rule protects approximately 58.5 million acres of National Forest System lands, including some of the wildest and most intact landscapes remaining in the country. When the Rule was created, more than 1.5 million Americans submitted comments in support of it, a remarkable demonstration of how much these lands matter to the American public. That protection is especially meaningful here in New England. The Roadless Rule protects approximately 260,000 acres, or about one-fifth of the White Mountain and Green Mountain National Forests combined. It includes extraordinary places such as Franconia Notch, Mount Moosilauke, Mount Chocorua, the Presidential Range, and Vermont’s White Rocks. The Appalachian Trail and Long Trail pass through many of these roadless areas. Once roads are built and forests are fragmented, we cannot simply undo the damage. These are some of the few places we have left where natural ecosystems can continue to function with relatively little human disturbance. The benefits extend far beyond recreation. Roadless areas help protect drinking water and buffer communities against floods and drought. In New England, the Roadless Rule helps protect drinking water sources for approximately 8.8% of Vermont residents and 7.3% of New Hampshire residents. In Massachusetts, approximately 7% of residents receive water from sources originating in Inventoried Roadless Areas in the White Mountain National Forest. These lands also provide critical habitat for native species, including brook trout, Canada lynx, Bicknell’s thrush, American marten, and the northern long-eared bat. And there is an important irony in proposing to open these areas to additional roads when the Forest Service already faces a multi-billion-dollar backlog in road maintenance. We should be investing in maintaining the roads we already have, not creating new obligations and fragmenting additional public lands. Roadless areas can also help reduce wildfire risk. Most wildfires are started by people, and recent research found that fires are four times more likely to start near roads. Keeping some forests roadless is therefore not only a conservation strategy. It is also a sensible way to limit human-caused wildfire risk and protect intact forests. Finally, these lands have cultural importance that goes far beyond recreation. Inventoried Roadless Areas include places important to Indigenous communities for hunting, fishing, gathering plants, food, medicine, and traditional arts, as well as culturally and spiritually significant sites. We have spent 25 years learning the value of protecting these places. We should not give up those protections now. New England has already lost much of its original forest and continues to face pressure from development, fragmentation, and climate change. Only about 3.3% of the region is protected from timber harvest and road construction, while scientists estimate that at least 10% should be protected to support biodiversity, carbon storage, and healthy communities. Rescinding the Roadless Rule would move us further away from that goal at exactly the wrong time. These are public lands that belong to all of us. Once they are opened to roads and development, we cannot get their wildness back. Please withdraw the proposal to rescind the Roadless Rule and select Alternative 1, No Action. I also urge my Members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R. 3930 and S. 2042, to codify these protections in law.

I believe that the correct ruling is Alternative One -- No Action I spend a great deal of time in the outdoors hiking and camping both in my home state of VT ( green mountain national forest) and in the medicine bow national forest, Laramie district in WY, which I try to visit every year, especially LaBonte canyon and the areas around Wedawoo. I've also traveled extensively in other countries like Switzerland and France, but have not seen undisturbed areas to match what we have here in the US. What we have is special and it belongs to all American citizens, not just the relative few who would profit by degrading these amazing places. In addition to the negatives most people think of, I am concerned about the noise pollution that would be created by road building and the later use of the roads. Millions of people treasure these areas as they are -- and the current uses and protections keep opportunities in place for future generations.