Every public comment on the proposed rescission of the Roadless Rule, sorted by what it talks about. Pick a topic, then narrow by position, by how hard the comment is for the agency to set aside, or by how substantive it is. Each comment is shown in full, as filed. How comments are classified and scored is explained in the Comment Analysis.
10/6/2026
Dear Forest Service,
Please do not rescind the Roadless Rule. As a lifelong Virginian, I believe roadless areas are essential for our state. They supply fish and wildlife habitat we can secure nowhere else, they are sources of drinking water for nearby communities and millions more downstream, and they are loved places for outdoor recreation. All of these values and resources benefit our quality of life and economy in Virginia.
I grew up on a farm in southern Augusta County, in the Shenandoah Valley, and still live in the area. The George Washington National Forest – and roadless areas specifically – is the scenic backdrop to Valley communities and a refuge for locals and visitors alike. Areas like Kelley Mountain on the east side and Elliott Knob, Crawford Mountain, Little River, Oak Knob, Gum Run/Dry River west of the Valley are popular places to get out for a hike or mountain bike ride, run the dog, camp, fish, or just quietly enjoy these beautiful mountain forests. As a fly fisher, I know our Virginia roadless areas have some of the best native brook trout habitat left in the entire Southern Appalachian region. Our communities also benefit from the scenic beauty and outdoor recreation opportunities that roadless areas provide to our area, where drawing visitors for tourism and recreation is critical to the local economy.
Beyond the benefits to Virginia, the national Roadless Rule should remain in place. The rule represents a balanced approach to managing our national forests. All Americans benefit from a consistent approach that sets this strong base level of protection for all roadless areas. Fish and wildlife and water resources often move across state lines. I want to have the opportunity – and all Americans deserve the same opportunity – to visit and enjoy roadless areas in other states, across the public National Forest System.
The rule is also incredibly popular. I would be hard-pressed to identify any single issue on which 99% of Americans agree, but the public comment numbers shows that 99% of those who have expressed an opinion to the Forest Service agree that the Roadless Rule should stand. This support has not wavered since the agency began developing the rule in the 1990s, in fact, support may have grown. The popularity of the rule belies the agency’s claims that local Forest Service officials should make decisions for roadless areas in their bailiwick, informed by input from stakeholders, communities, and local, state, and tribal governments. Many voices have already spoken up strongly for keeping the nationwide Roadless Rule in place. If the Forest Service actually intends to listen to the public, then it should withdraw this misguided proposal to rescind the Roadless Rule.
The Forest Service should retain the Roadless Rule of 2001 in entirety.
Thank you for considering my comment.
Sincerely,
Sarah Francisco
Staunton and Lyndhurst, VA
Opposes rescissionA1 strongSubstance 16/24Owed an answerOct 7, 2026FS-2025-0001-605501
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The George Washington National Forest is where I go to recharge. I hike and camp there, and fall is my favorite season because of the mild temperatures and the colorful leaves. The forest is peaceful because there aren't many roads there. Southern Massanutten, where I live, is part of that beauty. Adding roads would drastically change this environment. I am asking you to keep the Roadless Rule fully intact.
I love watching and listening to birds in the forest. Their calls are calming, and research has shown that listening to birds can reduce stress levels, positively impact mood, and improve cognitive function. The agency's own environmental analysis confirms what I experience: the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I also watch deer in these woods. The DEIS itself cites research finding that roads built for resource extraction may have altered mule deer migration routes and increased their movement speed, with the agency's own analysis identifying disrupted migration and lost unroaded security as the danger. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, including Southern Massanutten, Gum Run, Oak Knob, Dry River, and Skidmore in the George Washington. Every road opened into these areas narrows the habitat birds and deer depend on. I ask the agency to explain, with specificity, how this rescission is compatible with what its own DEIS documents about roads and wildlife.
Nothing is more important than clean drinking water. Rescinding the Roadless Rule would negatively impact the safety and availability of drinking water, and that is unacceptable. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. Opening these roadless areas risks the majority that are still clean. The agency must explain what it intends to do to protect those watersheds if the rule that protects them is gone.
If a road went into Southern Massanutten, I would be devastated. It doesn't make sense to create new roads when current roads aren't able to be maintained well. The agency is already carrying a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain on the record how an action whose own numbers cannot establish a net benefit justifies expanding a road system already collapsing under its maintenance burden.
The proposal also rests on a wildfire justification that the agency's own data contradicts. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from this finding.
Finally, the claim that the 2001 rule exceeded statutory authority is contradicted by the courts that reviewed it. The Tenth Circuit held, exercising jurisdiction under 28 U.S.C. Section 1291: "we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and MUSYA, and found it did not create de facto wilderness. The agency has not explained what legal basis exists for a contrary position, and it should.
Public land must be protected from development. The forest is peaceful because there aren't many roads there. Please don't change this.
Sincerely,
Katie in Massanutten, VA
October 5, 2026
Director, Ecosystem Management Coordination
U.S. Department of Agriculture, Forest Service
201 14th Street SW, Mailstop 1108
Washington, DC 20250-1124
RE: Comments on Proposed Rescission of the 2001 Roadless Area Conservation Rule and Draft Environmental Impact Statement, Docket No. FS-2025-0001; RIN 0596-AD66
Dear Director:
The City of Harrisonburg respectfully submits these comments in opposition to the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). The City requests that the Forest Service select the No Action alternative and retain the Roadless Rule. The Rule provides nationally consistent safeguards that generally prohibit road construction, road reconstruction, and timber harvesting in inventoried roadless areas, subject to limited exceptions. Those safeguards are essential to protecting the water resources, recreation opportunities, and community benefits on which Harrisonburg relies.
Harrisonburg has a longstanding and direct interest in management of the George Washington National Forest (GWNF). In 2008, the Harrisonburg City Council adopted a resolution calling on the Forest Service to provide comprehensive management and protection of drinking-water resources within the GWNF. In 2010, the City reiterated that maintaining protection of its water resources was the most significant issue associated with the Forest Plan. Those concerns remain unchanged.
The GWNF is integral to the protection of Harrisonburg's drinking-water supply. The City provides drinking water to more than 60,000 people and relies on surface-water intakes on the Dry River and North River; as well as constructing a new supply from the South Fork of the Shenandoah River. These supplies are fed by headwaters that flow from nearby roadless areas. The Skidmore Fork, Gum Run, Oak Knob, Little River, Ramseys Draft Addition, Crawford Mountain, and Elliott Knob Roadless Areas all help protect watersheds important to the City.
The City's Dry River source illustrates the public value of maintaining these protections. The City's Comprehensive Plan identifies the source as minimally affected by development, of sufficiently high quality to require relatively little treatment, and positioned to provide gravity flow to the Water Treatment Facility. Protecting this type of high-quality source water avoids or reduces future treatment and energy costs borne by utility customers. Protecting drinking-water watersheds also supports long-term water-supply resilience for Harrisonburg and other Shenandoah Valley communities.
Road construction and associated ground disturbance can increase erosion and sedimentation, adversely affecting streams and downstream water supplies. Rescinding the Roadless Rule would eliminate an important preventive safeguard. Local forest planning and site-specific environmental review should reinforce, not replace, the Rule's clear, nationally applicable protections for inventoried roadless areas.
Roadless areas also provide significant recreation, habitat, and economic benefits to Harrisonburg and the surrounding region. They support hiking, mountain biking, hunting, angling, and backcountry experiences that draw visitors to the Shenandoah Valley and sustain local businesses. Their intact forests and cold, clean streams support wildlife, including native brook trout, while helping preserve the natural character that makes this region a destination for residents and visitors alike.
The City recognizes the Forest Service's need to address wildfire, forest health, and other management needs. The existing Roadless Rule already includes exceptions and does not preclude all management activity. Rescission is neither necessary nor appropriate to preserve the ability to address site-specific risks. Any forest-management approach affecting roadless areas must continue to protect source-water quality and quantity and provide meaningful early coordination with the local governments that depend on those watersheds.
For these reasons, the City of Harrisonburg strongly opposes rescission of the 2001 Roadless Area Conservation Rule and urges the Forest Service to retain the Rule. Maintaining these safeguards is a prudent and cost-effective means of protecting Harrisonburg's drinking-water supplies, supporting the regional recreation economy, and preserving important natural resources for current and future generations.
Sincerely,
Alexander Banks VI
City Manager
City of Harrisonburg
Opposes rescissionA2 moderateSubstance 14/24Owed an answerOct 5, 2026FS-2025-0001-559584
PLACESTANDDOCGAPEVIDASKALTLAW
It was only 500 years ago when the United States had no roads at all. I ask you to reflect on what the forests, the streams, and lands must have looked like then. Imagine cresting a hill to see nothing but wild lands until the far ocean. Imagine watching buffalo and salmon migrating by the millions. Today in 2026, we cannot fathom what the lands and streams once looked like, just like future generations will be shocked that we had the chance to protect what we have and squandered it – our fresh water, our clean air, our game and fishing populations, our recreation spaces, our wild places. To date, we have only managed to protect a fraction of our lands (for example, the Roadless rule protects fewer than 60 million of the nearly 2 billion acres in the US). I am writing in strong support of maintaining the protections of the 2001 Roadless Area Conservation Rule.
This is deeply personal. Many of the regions protected by the Roadless rule are areas that I frequent. I hike, bike, go birding, do photography in Southern Massanutten dozens of times a year. I have also hiked, camped, birded, and explored other Virginia/West Virginia regions including: Dry River, Skidmore, Oak Knob, Gum Run, Little River, Seneca Creek, and Dolly Sods. On the West Coast, I have hiked, camped, birded, and explored Quilcene, Mt. Zion, Alpine Lakes Adj, Thorp Mtn, Teanaway, Eagle, Larch, and San Dimas regions – among many others. As an outdoors enthusiast, I believe the DEIS inadequately addresses the recreation losses from road construction and downstream activities, and I ask that the FEIS provide a thorough analysis of lost visitor spending and local economic multipliers in all impacted regions and specifically the regions named above. Without such analysis, the agency misrepresents the economic impact of rescinding this rule.
The USDA’s argument that rescinding the Roadless rule will prevent large wildfires is not credible. 78% of human-caused wildfires on National Forest start within ½ a mile of a road (based on USDA data). The Roadless rule does not preclude forest management activities that help reduce the risk of wildfire. I ask the agency to quantify the expected increase in human-caused ignitions resulting from new road access and to quantify it against claimed reductions in wildfire hazard. I am specifically interested to see this analysis in the regions mentioned above and also in all impacted regions.
Furthermore, building new roads will fragment ecosystems, which are already fragile as humans continue to develop and build. Fragmentation by roads has been found to reduce biodiversity by 13-75% (Haddad et al. 2015). Once again, healthy ecosystems gives us clean air, clean water to drink, pollinators to keep our crops productive, healthy soils to grow healthy food for healthy children, beautiful lands that people travel from around the world to see, etc. I ask that the agency provide an economic and environmental analysis of the negative impact of ecosystem fragmentation from new roads on these critical environmental benefits and ecosystem services.
Finally, if the agency is looking to create more rural jobs, which I wholeheartedly support, I suggest creating jobs that help preserve these precious ecosystems - it would be a win-win for everyone. Given the agency’s goal of wildfire management and rural job creation, I ask that the FEIS include an analysis of alternative methods to accomplish their goal. I believe that it would be insufficient to consider rescinding the Roadless Rule without a careful economic and environmental analysis of alternative options, including greater funding for job creation around fire fighting, invasive species management, existing road repair, and forest management.
I am writing this as an outdoor enthusiast, an angler, a birder and wildlife lover, an artist whose work is inspired by the natural places that I explore, and a passionate environmentalist. The Roadless rule preserves ecosystems – lands, rivers, flora, and fauna. It provides access to people who love to hike, camp, and fish (like me), and who simply want to breathe clean air, drink clean water, and eat healthy food (also like me).
Let us keep our lands as wild and healthy as possible – for the land, for ourselves, and for our children. Thank you.
Opposes rescissionA1 strongSubstance 14/24Owed an answerOct 1, 2026FS-2025-0001-531552
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The roadless areas in the George Washington National Forest matter to me, and I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The areas I am concerned about include Northern Massanutten, Big Schloss, Southern Massanutten, Gum Run, and Dry River, all within the George Washington National Forest in Virginia and West Virginia. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. What happens to these places is not abstract to me.
The agency's stated rationale rests partly on wildfire and fuels management. But the agency's own record undermines that rationale directly. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding does not appear anywhere in the rescission proposal as something to be reconciled, explained, or distinguished. The agency needs to explain why it is departing from its own prior analysis on fire occurrence and reconcile this proposal with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.
The economic case for rescission is just as weak. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." These are small numbers. 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 spanning -$92 million to +$199 million. That range does not establish a net benefit. The agency should explain how an action whose own analysis cannot demonstrate a clear economic gain justifies expanding a road system already carrying a $6.9 billion maintenance backlog. I want a direct answer to that question on the record.
The proposal also argues that state-specific approaches can replace the national rule. The agency's own record shows where that path led before. The record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed the agency's last attempt to substitute a state-by-state framework for the national rule and found it deficient. The agency has already acknowledged that local decision-making can incrementally reduce nationally significant roadless values. This proposal needs to address how it avoids the same deficiencies the Ninth Circuit identified, and what prevents the same incremental erosion of the roadless values found across the 64 inventoried roadless areas Virginia alone contains.
Finally, the proposal claims the 2001 rule exceeded the agency's statutory authority. The Tenth Circuit addressed that claim directly and held otherwise. The court stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency's current position implies a different legal conclusion. I ask that it state plainly what the basis for that contrary position is, and how it accounts for the Tenth Circuit's holding.
Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The roadless areas in the George Washington National Forest protect that water. The economic analysis cannot establish a net benefit. The agency's own data show roads increase ignition risk. The courts upheld the rule's legal foundation. The agency should withdraw this proposal.
Sincerely,
Jared Foeppel
Reston, VA
Opposes rescissionA2 moderateSubstance 10/24Owed an answerSep 28, 2026FS-2025-0001-485116
PLACESTANDDOCGAPEVIDASKALTLAW
I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, specifically as it affects the George Washington National Forest's North River District in Virginia.
I live in the Shenandoah Valley, where five roadless areas — Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition — together comprise roughly 70,000 acres and represent the largest concentration of roadless areas in the eastern United States. These areas are currently part of the proposed Shenandoah Mountain National Scenic Area (SMNSA), legislation now before the Senate Agriculture Committee that reflects 25 years of community-driven work to secure permanent protection for this landscape.
These roadless areas provide three benefits that rescission would directly threaten:
Clean water: These lands protect the headwaters of streams that supply drinking water and support native brook trout populations in the region.
Outdoor recreation: The undeveloped character of this landscape supports hiking, hunting, and other recreation central to the regional economy and quality of life.
Wildlife habitat: This concentration of roadless acreage provides some of the last large, unfragmented habitat blocks in the eastern national forest system — a resource that, once roaded and logged, cannot be restored on any meaningful timescale.
I have specific concerns about the Draft Environmental Impact Statement:
The DEIS does not adequately analyze the cumulative impacts of road construction and logging on watershed health in areas like the North River District, where roadless status has protected water quality for 25 years.
A blanket, nationwide rescission does not account for regions like the Shenandoah Valley, where roadless areas have been identified through extensive local and congressional review — via the pending SMNSA legislation — as having exceptional conservation value distinct from areas where wildfire risk may be a legitimate management concern.
Rescinding the rule while SMNSA legislation is actively pending before Congress undermines an ongoing legislative process and risks foreclosing options Congress itself is still considering.
I request that the Forest Service withdraw this proposed rescission, or at minimum exempt the roadless areas within the proposed SMNSA boundary from any final rule, pending the outcome of the legislative process already underway in the Senate Agriculture Committee.
Rescinding the Roadless Area Conservation Rule in America's National Forests is not necessary, nor responsible. Especially in the Eastern United States, thoughtless clear cutting and mismanagement of forests resulted in the creation of the National Forest Service, whose purpose includes the following: sustainable management, scientific forestry, and public benefit. The forests are not simply for sustainable management and cutting; science and public benefit are part of the three purposes for the Forest Service. Public benefit includes areas for outdoor recreation, clean water, and wildlife habitat.
In the Shenandoah Valley, where I live, there is a proposed 70,000 acre roadless area which includes the Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition. This would be the largest roadless area in the Eastern United States. It is an incredibly small area considering the George Washington National Forest comprises over 1.8 million acres. Surely, we can spare less than 4% of an immense area for public benefit, scientific discovery, and wildlife habitat of an area undisturbed by roads and all that roads would introduce into such an area. There is simply no need for the rescinding of the Roadless Area Conservation Rule.
In the Bible, we are urged to be stewards of creation, not only exercising dominion, but tending and caring for Creation. Allowing for such a small portion for that Creation to NOT be developed is surely good for our nation as well as for future generations who will benefit from such undisturbed areas.
Opposes rescissionA2 moderateSubstance 12/24Owed an answerSep 2, 2026FS-2025-0001-301773
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
The wild spaces God has given us need to remain wild. I hike and camp to become one with nature, and the roadless areas I am writing to defend, across the George Washington, Jefferson, and Mendocino national forests, the areas called Gum Run, Oak Knob, Three Sisters, Southern Massanutten, and the others, are exactly the kind of places that rule protects. Virginia alone holds 64 inventoried roadless areas totaling 393,682 acres. Rescinding the 2001 Roadless Area Conservation Rule would put every one of them at risk, and I oppose that rescission.
Public land should be managed for the public benefit, not to benefit administration officials with ties to the logging industry. Logging has destroyed our country's forests, and communities across the nation are still recovering from this loss of natural resource. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." That is the sum of what rescission buys. I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog.
I am a taxpayer. There is no reason to be expanding roads that will economically benefit only a select few. I want this land preserved for the sake of my neighbor's grandchildren, my boss's family, Republicans and Democrats 100 years from now. Land is tied to our nation, and we owe it to manifest destiny to preserve what we can. The proposal offers wildfire management as a justification for opening these areas to roads, but the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must explain why this proposal departs from those findings, and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas.
We need to preserve and protect our water sources. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own data show that about 24 million Americans drink water that starts in these watersheds. Roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Treading on those 24 million Americans who rely on this clean water is playing God. I ask the agency to address, specifically, what mitigation it proposes for sediment loading in watersheds like those feeding the intakes across the Southern region, and to explain what legal or scientific basis supports doing so.
The agency argues that state-specific approaches can replace one national rule. But its own record shows "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit already reviewed what happens when this agency replaces a national rule with a state-by-state approach, and it did not end well for the agency. I ask that the agency address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time this path was tried.
The agency also argues the 2001 rule exceeded its statutory authority. That question has already been decided. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we REVERSE the district court’s order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the rule was within the authority Congress granted. The agency must explain on the record the legal basis for any contrary position.
It is un-American and unpatriotic to rob future generations for short-term, oligarchical gain. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. My children should not inherit fewer of these places than I did. Shame on you.
Sincerely,
Michael J.
North Carolina
Exact copy — Byte-identical to another submission. This comment stands for all 2 submissions in its group.
To the United States Department of Agriculture and the United States Forest Service:
I am writing to formally oppose the decision to rescind the Roadless Area Conservation Rule (RACR) as it pertains to the George Washington National Forest (GWNF) and the proposed Shenandoah Mountain National Scenic Area (SMNSA), and more broadly to ALL public lands to which this Rule applies.
My opposition is based on the quantifiable impacts this rule change will have on established conservation benchmarks.
First, the proposed SMNSA contains five designated roadless areas—Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition—totaling 70,000 acres. According to the spatial data regarding the GWNF North River District, this constitutes the largest concentration of roadless acreage in the eastern United States.
Second, the stated purpose of the SMNSA initiative is to secure permanent protection for three primary benefits: clean water, outdoor recreation, and wildlife habitat. The value of roadless land to these specific benefits is well established. Roadless areas serve as natural source-water protection zones; without road construction, there is significantly less sedimentation and runoff, which maintains the high water quality required by downstream communities and aquatic ecosystems. Furthermore, large, unbroken forest blocks provide interior habitat that is critical for species that cannot thrive in fragmented landscapes cut by roads. Finally, the absence of motorized road networks preserves the quiet, backcountry character that supports the hiking, hunting, and dispersed recreation economy of the Shenandoah Valley. Rescinding the RACR directly exposes these specific acres to new road construction, logging, and other development activities, which would degrade all three of these established benefits.
The factual record shows that these 70,000 acres are unique in just my area of eastern landscape due to their size and lack of road incursion. I urge the Department to maintain the Roadless Area Conservation Rule to ensure that the specific characteristics of the Shenandoah Mountain area are not degraded prior to the conclusion of the legislative process regarding the National Scenic Area designation.
While the Shenandoah Mountain area serves as a specific example, my opposition to this action extends to all National Forest roadless areas across the nation that would be affected by a full rescission of the RACR. These lands represent the last remaining undeveloped portions of our National Forest System. Once roads are constructed and development occurs, the wild character of these places is permanently lost; fragmentation cannot be reversed within a human lifetime. To open these areas to new road construction is to forfeit an irreplaceable public asset in exchange for short-term extractive use that will only enrich private interests.
Finally, while the opportunity to comment on the Draft Environmental Impact Statement (DEIS) is provided, the proposed action to rescind the RACR would alter the baseline management standards for these lands before the Senate Agriculture Committee has completed its deliberation on the SMNSA.
The harm of this action would be borne by ALL American citizens. National Forests are public lands held in trust for the benefit of the entire nation, not just for the industries that would profit from their development. Every citizen has a stake in the clean drinking water that originates in roadless watersheds, the carbon storage provided by intact mature forests, and the opportunity to experience true backcountry solitude. Rescinding the RACR would strip current citizens of their benefits and beauty, and would deny future generations of Americans of their right to inherit wild, undeveloped public lands. I urge the Department to recognize that the Roadless Area Conservation Rule protects values that belong to all of us, and to maintain the rule in its entirety.
Sincerely,
A citizen of these great American lands.
I am writing to implore you NOT to rescind the Roadless Area Conservation Rule. This Rule would open our National Forest roadless areas across the nation for new roads, logging, and other development. Why is this important to all of us in the Shenandoah Valley? The proposed Shenandaoh Mountain National Scenic Areas has 5 roadless areas totally 70,000 acres: Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition. Together these comprise the largest concentration of roadless areas in the eastern US. The map shows these and other roadless areas in the GWNF North River District. We have been working for 25 years to gain permanent protection for the SMNSA for three primary benefits: clean water, outdoor recreation and wildlife habitat. This action could undermine all the progress we have made. Don't surrender in this fight or you will be replaced by someone who understands what is at stake & will fight for the environment & us
Opposes rescissionA1 strongSubstance 14/24Owed an answerAug 31, 2026FS-2025-0001-291341
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Cold water is the whole thing. Roads are how you ruin it. I fish spring creeks in Pennsylvania and I see it happening: the subterranean water table shifts, the spring creek issuance changes, and the source is often what you put on the land and how you let water move through it. Road access is a version of that same problem on the exposed side, above ground. That is what I know in my gut, and rescinding the 2001 Roadless Area Conservation Rule does not pass the gut test.
I am writing about inventoried roadless areas I chose because they matter to me: Northern Massanutten, 9,444 acres in the George Washington National Forest in Virginia; Southern Massanutten, 11,985 acres; Gum Run, 12,620 acres; Oak Knob, 10,882 acres; Skidmore, 5,641 acres; Dry River in the same forest; Big Schloss, 8,375 acres in the George Washington in West Virginia; and in the Monongahela National Forest in West Virginia, North Mountain Hopeville, 6,525 acres, and Dolly Sods Roaring Plain, 13,392 acres. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. The Monongahela's 20 inventoried roadless areas total 174,885 acres and protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions.
The agency's own DEIS states that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number appears in the document. No projection of what that sediment load actually reaches the streams below follows it. The spring creeks I watch in Pennsylvania do not recover quickly from sediment pulses. The Monongahela protects headwaters that become drinking water for millions of people. The George Washington's roadless acres protect tributary systems that feed into those same broader watersheds. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas, and put that projection in the record.
The DEIS states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." That sentence is offered as reassurance. It is not one. Less than 12 percent impaired now tells me nothing about what happens after road mileage increases in places like the Dolly Sods Roaring Plain or the Gum Run drainage. The DEIS says forest plans address sources of public drinking water, but identifies no enforceable plan provision by name. I want the agency to identify, forest by forest, which specific plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Name them.
The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. The Monongahela's roadless acres shelter the Cheat Mountain salamander, the West Virginia northern flying squirrel, the northern long-eared bat, snowshoe hare, and red spruce ecosystems described as relics of the last ice age. Dolly Sods carries spruce-bog habitat more reminiscent of northern Canada than West Virginia. These species and places are exactly what fragmentation science describes as vulnerable. But the cited range is never applied to the 40.1 million acres of potentially affected environment. A range of 13 to 75 percent applied to 40.1 million acres produces a projection the agency owes the public. I ask that the agency apply that cited fragmentation range to the full potentially affected acreage and show its work.
Finally, the DEIS states: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." That is the agency telling me that existing roads are already damaging water quality because there is not enough money to maintain them. The same document proposes opening roadless areas to additional road construction. I want the agency to reconcile those two positions in plain language. We can have financial prosperity and conservative conservation practices, and I believe a deal can be negotiated, but not by adding road mileage on top of a maintenance shortfall that the agency's own analysis identifies as a cause of water quality harm. Find a different path forward.
Sincerely,
Sean Eagan
Manchester, MD
Please do not rescind the Roadless Area Conservation Rule. This will open up our National Forest roadless areas across the nation for new roads, logging, and other development. Why is this important to all of us? The proposed Shenandaoh Mountain National Scenic Area, now before the Senate Agriculture Committee, has 5 roadless areas totally 70,000 acres: Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition. Together these comprise the largest concentration of roadless areas in the eastern US. Citizens have been working for 25 years to gain permanent protection for the SMNSA for three primary benefits: clean water, outdoor recreation and wildlife habitat. This action could undermine all the progress we have made.
PLEASE WE ARE THE STEWARDS OF THIS BEAUTIFUL LAND.
FUTURE GENERATIONS DESERVE MORE!
Cathy Rogers
Florence, KY
Exact copy — Byte-identical to another submission. This comment stands for all 2 submissions in its group.
Please do not rescind the Roadless Area Conservation Rule. Our National Forests are treasures for all Americans, and not assets for developers. The proposed Shenandaoh Mountain National Scenic Area, now before the Senate Agriculture Committee, has 5 roadless areas totally 70,000 acres: Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition. Together these comprise the largest concentration of roadless areas in the eastern US. We have been working for 25 years to gain permanent protection for the SMNSA for three primary benefits: clean water, outdoor recreation and wildlife habitat. Please protect our natural and cultural resources.
Do not rescind the Roadless Area Conservation Rule in Virginia. This will open up our National Forest roadless areas across the nation for new roads, logging, and other development. Why is this important to all of us in the Shenandoah Valley? The proposed Shenandaoh Mountain National Scenic Area, now before the Senate Agriculture Committee, has 5 roadless areas totally 70,000 acres: Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition. Together these comprise the largest concentration of roadless areas in the eastern US. Vote NO to logging and development!
I do not concur with opening up these areas to new roads and logging. Please keep the Roadless Area Conservation Rule for the Shenandoah Mountain National Scenic Area. and keep these 5 areas roadless. These are 70,000 acre, Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition which should remain without logging or access roads.
I am writing to strongly oppose rescinding the 2001 Roadless Area Conservation Rule.
As a resident of the Charlottesville area and a parent raising a young child here, I deeply value the National Forest lands that surround our community. These forests are not simply undeveloped land waiting for another use. They protect clean water, provide critical wildlife habitat, preserve biodiversity, store carbon, and give our families and future generations access to wild places that are increasingly rare.
I am particularly concerned about the impact this change could have on roadless areas of the George Washington National Forest and Shenandoah Mountain, including Little River, Gum Run, Oak Knob, Skidmore Fork, and the Ramseys Draft Addition. These are extraordinary resources in our own backyard, and once intact forests are fragmented by roads and development, many of their ecological benefits cannot simply be restored.
The bipartisan Shenandoah Mountain Act demonstrates the value our region places on protecting this landscape for the long term. The fact that legislation to permanently protect these lands has received bipartisan support makes it especially troubling to remove existing safeguards in the meantime.
The Roadless Rule has provided protection for these public lands for more than two decades. I urge the USDA to retain the Roadless Area Conservation Rule and prioritize the long-term health of our National Forests, watersheds, wildlife, and communities over short-term development.
I want my children — and generations after them — to inherit these forests as healthy, connected, wild places. Please keep the Roadless Rule in place.
I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the USDA and U.S. Forest Service to select the No Action Alternative and retain the Roadless Rule.
I live in Virginia, near the George Washington National Forest, and these protections are not an abstract national policy to me. Roadless areas in the Shenandoah Valley and surrounding mountains protect the places where we hike and recreate, the watersheds that provide clean water to our communities, and large, intact areas of habitat that wildlife depend upon.
Of particular concern to me are the roadless areas within the proposed Shenandoah Mountain National Scenic Area, including Oak Knob, Gum Run, Skidmore Fork, Little River, and the Ramseys Draft Addition. These lands represent an extraordinary natural resource for Virginia and should receive greater protection, not less.
Road construction does much more than create a path through a forest. It fragments wildlife habitat, increases erosion and sedimentation, affects streams and watersheds, and can permanently alter the character of places that have remained largely undeveloped. Once an intact roadless landscape is fragmented, restoring what has been lost can be extraordinarily difficult, if not impossible.
I also strongly value these lands for outdoor recreation. The wild and undeveloped character of our national forests is one of the things that makes the Shenandoah Valley such a special place to live and visit. Hiking, camping, wildlife viewing, hunting, fishing, and simply having access to quiet natural places are important to our quality of life and to the economies of communities surrounding our public lands.
I understand the need for responsible forest management and wildfire prevention. However, I do not believe eliminating nationwide protections for millions of acres of roadless National Forest lands is necessary to accomplish those goals. The Roadless Rule already contains exceptions that allow certain activities when needed to protect public health and safety and address other legitimate management needs.
These public lands belong to all Americans, including future generations. Decisions affecting them should reflect their tremendous long-term value for clean water, wildlife habitat, recreation, climate resilience, and intact ecosystems, rather than the short-term benefits that may come from additional road construction, logging, or development.
Please retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. In particular, please protect the remaining roadless lands of the George Washington National Forest and the proposed Shenandoah Mountain National Scenic Area so that these remarkable places remain intact for generations to come.
I am TOTALLY against destruction of the Shenandoah Valley. How much more greed is to be dispensed? Protect Our Roadless National Forests—Do Not Open Them to Development
I strongly oppose the U.S. Department of Agriculture’s decision to rescind the Roadless Area Conservation Rule.
Our national forests belong to all of us. They should be protected for clean water, wildlife, recreation, quiet solitude, and for future generations—not opened up to roads, logging, and development that could permanently alter some of our most treasured wild places.
This issue is especially important here in the Shenandoah Valley. The proposed Shenandoah Mountain National Scenic Area includes five extraordinary roadless areas—Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition—together encompassing approximately 70,000 acres. These areas represent the largest concentration of roadless lands in the eastern United States.
For 25 years, citizens and conservationists have worked to secure permanent protection for the Shenandoah Mountain landscape. That effort has never been about keeping people out. It has been about protecting the things that make these public lands so valuable to everyone: clean drinking water, exceptional outdoor recreation, and critical wildlife habitat.
Once roads are constructed and forests are fragmented, we cannot simply undo the damage. A road is not merely a line on a map. It can bring logging, increased traffic, erosion, invasive species, habitat fragmentation, and permanent changes to the character of a wild landscape.
We should be moving forward—not backward.
The Shenandoah Mountain National Scenic Area deserves permanent protection, and the roadless areas within it deserve to remain intact. After 25 years of work toward that goal, it would be incredibly short-sighted to weaken the protections that have helped preserve these lands.
I urge the U.S. Department of Agriculture and our elected representatives to reject the rescission of the Roadless Area Conservation Rule and protect our remaining roadless national forest lands. I also urge the Senate Agriculture Committee to move forward with permanent protection for the Shenandoah Mountain National Scenic Area.
These lands are not ours to consume. They are ours to safeguard.
We owe it to the people who worked for 25 years to protect them, to the communities that depend upon their clean water and natural resources, and most importantly, to the generations who will inherit what we choose to protect—or what we choose to destroy.
Please protect the roadless lands of the George Washington National Forest and support permanent protection for the Shenandoah Mountain National Scenic Area.
I strongly oppose rescinding the 2001 Roadless Area Conservation Rule and urge the USDA and U.S. Forest Service to choose the No Action Alternative and keep the Roadless Rule in place.
As a Virginia resident, I am especially concerned about the impact this could have on the George Washington National Forest and the roadless areas surrounding Shenandoah Mountain, including Oak Knob, Gum Run, Skidmore Fork, Little River, and the Ramseys Draft Addition.
These areas are valuable for far more than their scenery. They protect clean water, wildlife habitat, mature forests, and recreational opportunities such as hiking, hunting, fishing, camping, and wildlife viewing. Once roads are built and intact forest is fragmented, those impacts can be difficult or impossible to reverse.
I understand the need for responsible forest management and wildfire prevention, but removing nationwide Roadless Rule protections is far broader than necessary to accomplish those goals. Forest management should be targeted and science-based without opening millions of acres of currently protected National Forest land to expanded road construction, logging, and development.
The Shenandoah Valley and surrounding National Forest lands are resources that belong to current and future generations. Short-term development should not come at the expense of long-term water quality, wildlife habitat, recreation, and intact public lands.
Please retain the Roadless Area Conservation Rule and preserve these protections for our National Forests.
I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket [insert number from Federal Register notice]), specifically as it affects the George Washington National Forest's North River District in Virginia.
I live in the Shenandoah Valley, where five roadless areas — Oak Knob, Gum Run, Skidmore Fork, Little River, and Ramseys Draft Addition — together comprise roughly 70,000 acres and represent the largest concentration of roadless areas in the eastern United States. These areas are currently part of the proposed Shenandoah Mountain National Scenic Area (SMNSA), legislation now before the Senate Agriculture Committee that reflects 25 years of community-driven work to secure permanent protection for this landscape.
These roadless areas provide three benefits that rescission would directly threaten:
Clean water: These lands protect the headwaters of streams that supply drinking water and support native brook trout populations in the region.
Outdoor recreation: The undeveloped character of this landscape supports hiking, hunting, and other recreation that is central to the regional economy and quality of life.
Wildlife habitat: This concentration of roadless acreage provides some of the last large, unfragmented habitat blocks in the eastern national forest system — a resource that, once roaded and logged, cannot be restored on any meaningful timescale.
I have specific concerns about the Draft Environmental Impact Statement:
The DEIS does not adequately analyze the cumulative impacts of road construction and logging on watershed health in areas like the North River District, where roadless status has protected water quality for 25 years.
A blanket, nationwide rescission does not account for regions like the Shenandoah Valley, where roadless areas have been identified through extensive local and congressional review (via the pending SMNSA legislation) as having exceptional conservation value distinct from areas where wildfire risk or overgrown stands may be a legitimate management concern.
Rescinding the rule while SMNSA legislation is actively pending before Congress undermines an ongoing legislative process and risks foreclosing options Congress itself is still considering.
I request that the Forest Service withdraw this proposed rescission, or at minimum exempt the roadless areas within the proposed SMNSA boundary from any final rule, pending the outcome of the legislative process already underway in the Senate Agriculture Committee.
Exact copy — Byte-identical to another submission. This comment stands for all 2 submissions in its group.
Exact copy — Byte-identical to another submission. This comment stands for all 2 submissions in its group.