Read the comments.

Please, do not rescind or alter the roadless area conservation rule in any way. I recently had the opportunity to visit three amazing roadless areas in Oregon. They were not the first I had visited, as I love exploring outside and have been doing so as often as possible — usually with my kids — for more than 20 years. In fact, I moved to Oregon to explore the outdoors that I had heard so much about having grown up in the midwest. The places I visited and so many more like them within Oregon’s more than 2 million acres of roadless forests — and the nation's more than 45 million acres — are absolutely amazing. I cannot believe that you would even consider building roads into some of these areas, or opening them to logging, mining or other industrial activity. These are a legacy that should be left for future generations to enjoy and for the benefit of all the other species we share this world with. Tamawanas Falls, Mt. Hood Additions Roadless Area, Mt. National Forest Part of a 7,000 acre roadless area, this amazing, short hike to an epic waterfall was breathtaking. It was not remote or tranquil, but amazing to be able to share this experience with so many other people out there enjoying the natural world on a beautiful Sunday afternoon. Mt. June, Hardesty Mountain Roadless Area, Willamette and Umpqua National Forests A spectacular climb through this 6,300 acre roadless area spanning two of Oregon’s national forests. Spending a morning in this area to catch post-sunrise at the summit. To spot a deer on my way up through the lush woods. To feel like I had the mountain to myself, not seeing another hiker that morning — but hearing the echo of owls and birds ring through the understory. Niagara Falls, Hebo 1a Roadless Area, Siuslaw National Forest A nearly 14,000 acre area in the coast range. An easy hike through a lush forest to a waterfall, which I am sure is much more prominent in the spring (I can't wait to return). Full of a variety of mosses, lichen, fungi, slugs, frogs, birds and one of my favorite things to see on a hike — nurse logs. I have attached a photo from each of the places I visited most recently, so that you can —and indeed have to — see just a few examples of what you would be spoiling just here in Oregon. To make sure that you open your eyes to the natural world that is not just here for exploitation and profit. Upon leaving these places recently, I was also confronted by spray paint on numerous trees marked to be cut and also an active logging operation before I exited those national forests. I just can’t imagine seeing either of those sights in the areas I spent the day hiking in. When will enough be enough? There are so few of these places left. Please do not rescind or alter the roadless area conservation rule. Thank you for considering my voice. Justin Boyles Portland, OR

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to eliminate or weaken the Roadless Rule. This reckless action would devastate public lands, waste taxpayer resources, and undermine the water, wildlife habitat, and recreation opportunities on which millions of Americans depend. I personally have camped, fished, boated and rafted in some of the areas currently protected by the Roadless Rule including many times at gorgeous Sparks Lake, Oregon Dunes in the Siuslaw Forest, the PCT near the incomparable Waldo Lake and Hardesty Mountain. To build roads in any of these pristine areas would open them to irreparable damage. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean drinking water, provide refuge for vulnerable species, and serve as critical carbon sinks critical to mitigating the worsening impacts of climate change. People hike, forage, bike, fish, camp, ski, climb, and find solace in these remote places. Roads spread invasive species, fragment wildlife habitat, and erode the very ecological resilience we need in the face of a warming climate. More roads in the backcountry also mean more fires: research shows wildfires are more likely to ignite near roads. Once roads and clearcuts fragment these landscapes, the damage is permanent. Weakening or repealing the Roadless Rule would be a grave mistake. I do not support any of the proposed action alternatives that roll back the Roadless Rule. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule intact to protect these precious resources for future generations. Sincerely, Janice Bohman Eugene, OR 97405-5824 janbohman@comcast.net

Dear Secretary Rollins, I am writing to you as a young person who, like many others in the Western US, has experienced the fear and loss that wildfire can bring to a community. Repealing the roadless rule is reckless and dangerous as roads increase the number and frequency of wildfires. Building new roads or increasing the length or density of existing roads in roadless areas will increase human-caused ignitions (Brown et al. 2004; Swetnam 1990). 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 (Cardille et al. 2001). Roads permanently damage and further fracture the already fragile ecosystems that I, and my community, rely on for clean water, clean air and recreation. I often visit the Hardesty Mountain Roadless area in Oregon. This area is so special to me, providing a spot to hike, bike, swim, eat thimble berries, forage chanterelles and smell the vanilla leaf. This spot is near and dear to my heart, please make the right choice and maintain the current protection that the roadless rule provides. I do not support any of the proposed action alternatives that roll back the Roadless Rule. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule in place. Thank you for taking my comment to heart, please do the right thing to protect my safety and the health of these ecosystems.

I am submitting my comment to vehemently oppose partially or fully rescinding the Roadless Rule. To reverse this rule would throw decades of peer-reviewed research in the trash, to favor short term financial gain for very few and without benefit to the American public. To allow such a change would be a dereliction of the Agriculture Department's duties to protect public health, conserve natural resources, and responsibly manage agricultural production. In 2025, approximately 99% of public comments opposed changing the Roadless Rule. Despite this, the federal administration is once again attempting to force this through without appropriately addressing the public's substantial opposition to partially or fully rescinding this rule. Roadless areas are some of the last intact landscapes in America, providing clean water, critical wildlife habitat, and world-class recreation opportunities. As a resident of Oregon, my health, safety, and enjoyment of public lands include Roadless areas like Larch Mountain, Lost Lake, and the Salmon River Trail (Mount Hood National Forest), Iron Mountain and Hardesty Mountain (Willamette National Forest), Oregon Dunes (Siuslaw National Forest), Lookout Mountain (Ochoco National Forest), Joseph Canyon (Wallowa-Whitman National Forest), and Tumalo Mountain (Deschutes National Forest). In the summer of 2026, Oregon saw some of the worst wildfires in our country's history, and unsustainable forestry, deforestation, fragmented habitat, and irresponsible recreation were largely to blame. Not a lack of roads. The proposed changes to the Roadless Rule fail to consider the overwhelming body of scientific evidence that habitat fragmentation increases wildfire risk and negatively impacts protected species. Alternatives 2 and 3 of the Draft EIS are wholly unacceptable. Therefore, I support Alternative 1 - No Action.

Comment on FR Doc # 2026-16965 I write to strongly oppose the weakening or repeal of the Roadless Rule. This Rule has protected critical water resources, has enhanced air and water quality, and has protected essential wildlife habitat. Allowing the building of roads in protected areas will inevitably lead to logging, mining and development that will greatly diminish all of these benefits. The heart of our public lands is our system of National Forests. These Forests contain some of the. most mature and wild forest habitats remaining in the United States, which represent a tiny fraction of the mature forests that once blessed this country. These forests provide multiple environmental benefits to communities and wildlife. Notably, they provide high quality drinking water for millions of citizens, water that is now critically scarce and will be impossible to replace. In my home state of Oregon, roadless areas protect nearly 2 million acres of Oregon’s forests, including beloved places like the Metolius River, Lost Lake, the Oregon Dunes, Mount Hebo, Hardesty Mountain, Tumalo Mountain, and the Upper Hood River Valley. These are some of the most intact landscapes we have left. I personally have spent many years enjoying the beauty of these special places. In addition to providing life-enhancing recreation, they provide clean drinking water for communities like Bend, Eugene, and Salem. They shelter fish and wildlife and preserve sacred sites and traditional foods. Carving roads into these wild places will fragment wildlife habitat, pollute drinking water sources, spread invasive species, increase fire risk, and make it possible for industrial logging and mining activities to degrade the landscape. Among other harms, it will undo generations of work to restore Northwest native salmon populations. Management of or national forests must protect the many benefits that only healthy forests can provide: clean air and water, carbon storage, fish and wildlife habitat and recreation. The “greatest permanent value” of our forests (if their permanence is assured) is in these multiple environmental benefits, and most critically, in their carbon sequestration at a time when the climate crisis is overtaking ecosystems and destroying life and property on an ever-widening scale. We now know that Northwest coastal and Cascade Range forests have some of the world’s highest capacity to store carbon. Indeed, current science supports large forest reserves to sequester carbon, provide wildlife habitat and foster biodiversity. The catastrophic effects of climate change on forests are all around us, and more and more species are becoming threatened or endangered. The value of extractive industries must not be allowed to outweigh the invaluable and irreplaceable ecosystem services provided by our small remaining areas of mature and old-growth forest. Last year over 600,000 citizens (including myself) expressed their strong support for the current Roadless rule by submitting comments to the U.S. Forest Service. U.S. citizens also overwhelming support the protection of our National Forests for future generations. Public sentiment on this issue is clear. The Roadless Rule preserves the last of our intact public lands as a source of clean water, a home for wildlife, a haven for recreation, and a heritage for future generations. It must be maintained and protected.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless means quiet. That is not a small thing. In places like Hardesty Mountain, in the Umpqua National Forest in Oregon, that quiet is the point. It is what makes it possible to actually hear the birds and other wildlife. I love all waters, rivers and mountain lakes included, and I believe our public lands should be managed for true multi-purpose: certain areas for sustainable tree harvest, certain areas for ecologically safe extraction, but large areas left for recreation, for clean water and air, and for all the non-human inhabitants. The 2001 Roadless Area Conservation Rule is one of the few tools we have that holds that line. I oppose its rescission. The agency's own draft environmental impact statement acknowledges what anyone who goes looking for birds already knows. The DEIS cites the finding that "road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely." Bird richness declines with road presence in forested habitat. These are the agency's own cited findings, from Kroeger et al. 2022, McClure et al. 2013, and Ware et al. If the agency rescinds this rule and roads follow, the habitat that makes quiet possible at Hardesty Mountain and across Oregon's 211 inventoried roadless areas totaling 1,937,741 acres is not recoverable on any human timescale. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and yet no projection of that range across the 40.1 million acres of potentially affected environment appears in the record. I ask the agency to apply that cited fragmentation range to the full 40.1 million acres before it takes any final action. The proposal invokes wildfire as a justification for rescission. 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." That is the agency's language, not mine. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain why the proposal departs from its own prior findings and reconcile the rescission with that ignition data. The economic case for rescission is not made. The agency's own 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. A cost-benefit analysis that cannot establish a net benefit does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. Moreover, the record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." How does an action with those projected stakes, and that degree of economic uncertainty, justify permanent loss across millions of acres? The agency has not answered that question, and it must do so in this proceeding. The permitting burden argument fares no better. The rule as written 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)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection already exist inside the rule. The agency has not identified which specific burdens fall outside those existing exceptions, nor has it quantified them. It should do both before the record closes. Oregon has 1,522 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Northwest region. Clean water is one of the necessities of life I named, and it is not separable from the lands that filter and protect it. Rescission puts those watersheds at risk. The record must reflect that cost. Sincerely, John Mullen Dexter, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 When I moved to Oregon, the ~8,000 acre Hardesty Mountain roadless area became one of my most frequented and meaningful places, and I bring my loved ones there to geek out over the old growth trees, the threatened plant and lichen species, and the unique birds in the area. The agency's own record, drawing on Kroeger et al. 2022, McClure et al. 2013, and Ware et al., acknowledges 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. Rescinding the Roadless Area Conservation Rule would expose Hardesty Mountain and the other inventoried roadless areas across Oregon, 211 of them totaling 1,937,741 acres, to the very road-building pressures the science documents as harmful. I ask the agency to explain, specifically, how that documented harm to bird communities is weighed in its proposal. Public lands should be managed for ecological health for all of us, human, animal, plant, fungi. This is where the water, air, and soils that we all depend on reside. My ecologist background informs me just how vital it is that this foundation for life be taken care of. Logging and road-building bring pollutants into waterways that are essential for all life, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Opening those watersheds to road-building is not a neutral administrative act. I want the agency to address, plainly and on the record, what it concludes happens to those intakes and the communities they serve when that sediment burden arrives. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own 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 this rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why its own prior findings on fire occurrence are being set aside. On the administrative burden rationale: the rule as written already provides 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 existing exceptions for public health and safety, mineral leases, and community wildfire protection already address the agency's stated concerns, then what specific, quantified burdens remain that only full rescission can relieve? The agency has not answered that question, and it should. The regulatory flexibility analysis accompanying this proposal 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. Spreading an aggregate expenditure loss across every small firm in the sector nationally is not an assessment of the outfitters and guides actually holding permits in these areas. The certification should be withdrawn and replaced with an analysis of the small entities actually operating in the potentially affected roadless areas. Finally, the proposal itself 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. This comment is one such interest. I commented in the 2025 round of public comments for the roadless rule, and I am exhausted that we must come back again and again in efforts to protect the health of our human and more-than-human communities. That exhaustion is itself a reliance interest: the rule has structured how people like me invest time, attention, and trust in these places. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Sincerely, Flora Eugene, OR

As a senior taxpayer and director of Progressive Voices, I state our strong opposition to any removal of roadless areas designation. These are valuable public resources whose forests serve as invaluable "carbon sinks" to counter the climate changes our planet is facing. We have enjoyed hiking in local roadless areas such as McGowan Creek old growth grove near Marcola and Eagles Rest. The latter is a wonderful, unfragmented, old-growth backcountry forest located within the Hardesty Mountain Inventoried Roadless Area of the Willamette National Forest. Located roughly 20 miles southeast of Eugene, its dense Douglas-fir canopies provide municipal watershed protection and excellent outdoor recreation options enjoyed by so many citizens who also pay taxes for the benefits of such roadless areas. Because of these reasons and the fact that they are irreplaceable, such roadless areas should be protected with the current law and their forests allowed to remain uncut so that future generations can also benefit from their existence.

I am appalled at the Trump administration's attack on our forests and I am writing to oppose the rescission of the Roadless Area Conservation Rule. I live in Oregon and the forests around Smith Umpqua, Hardesty Mountain, and Fairview are the places I visit on a regular basis to camp, hike, and bird watch. Rescinding the 2001 Roadless Area Conservation Rule would open them, and the 211 inventoried roadless areas totaling 1,937,741 acres across Oregon, to road construction and the harms that follow. Opening up this land would cut down and destroy more of our forests and habitat for wildlife. Not only that, building roads into our forests will increase the risk of human-caused wildfires. The agency's own record undermines the wildfire rationale offered for rescission. 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 is the agency's, not mine. If roads into areas like Smith Umpqua on the Siuslaw NF and Fairview on the Umpqua NF increase the likelihood of human-caused ignitions, the agency must explain why it now treats road access as a wildfire remedy. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and reconcile the rescission with the ignition data in its own DEIS. That data is specific. The DEIS reports: "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." Hardesty Mountain at 2,597 acres sits alongside Fairview at 7,417 acres and Smith Umpqua at 7,622 acres. These are not abstract numbers. Opening such areas to roads would, by the agency's own data, sharply increase ignition risk within them. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this proposal can proceed. The recreation and small-business analysis is internally inconsistent. The agency's own materials state: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification is reached by spreading the $9 million annual expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The Pacific Northwest, which includes Oregon, has 1,522 municipal water intakes in watersheds containing affected roadless areas, meaning the downstream consequences extend well beyond recreation. The agency should withdraw the small-business certification and assess the impact on the specific firms operating in the potentially affected roadless areas, not the national average firm. Finally, the agency has solicited comment on reliance while declining to weigh any of it. The proposal requests "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. This comment is precisely such an interest. The forests at Smith Umpqua, Hardesty Mountain, and Fairview on the Umpqua NF are places whose protection under the current rule I have counted on. Under the legal standards governing agency change of course, that kind of reliance must be identified and weighed, not solicited and then set aside. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Leave our forests alone! Sincerely, Stephanie Wolpers Eugene, OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Siuslaw National Forest (52,000 acres), Siuslaw National Forest, Oregon - Deschutes National Forest (136,000 acres), Deschutes National Forest, Oregon - Hardesty Mountain (2,597 acres), Umpqua NF, Oregon As a resident and taxpayer in Oregon I benefit from the ecosystem support of roadless areas. The flora and fauna that exist across my own property does so because these areas are unharmed and interacting with the ecosystem as a whole. Opening more of these spaces to roads, logging, and other exploitation is against national interest to the benefit of corporations. Personally, I take several vacations a year which involve hiking, camping, fishing (including salmon fishing) and other outdoor activities along the Oregon coast and mountainous regions of Oregon. My personal enjoyment of the vistas and recreation areas would be vastly diminished if roads and logging were allowed in currently protected areas, but that feels like a small complaint next to the horror I feel at the idea of damaging old growth rainforests and key watersheds for monetary gain. Shame on all of you. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Sincerely, Amber Willett Eugene, Oregon

To the USDA Forest Service: I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Department to withdraw the proposal and keep the rule's national protections in place. I am Eugene, Oregon, and I regularly use the Hardesty Mountain roadless area. These lands belong to all Americans, and I do not believe a single administration should strip protections from them without a thorough, deliberate process. 1. The rule protects a national inheritance. The 2001 rule provides protection for roughly 58.5 million acres of inventoried roadless areas across the National Forest System. These are among the last large, intact landscapes in our national forests. Once a road is built, the area's roadless character is effectively lost for good. federalregister 2. Forest-by-forest management invites incremental loss. The proposal would return these decisions to individual forest planning. A national rule exists so these places do not face piecemeal road building, one plan amendment at a time, under shifting local pressures. Rescission would also leave protections dependent on the priorities of whoever holds office. 3. Roadless areas protect water, wildlife, and recreation. Intact watersheds supply clean drinking water to downstream communities. Roadless areas also provide refuge for fish and wildlife, including sensitive and endangered species, and they support hunting, fishing, hiking, and quiet recreation. 4. The Forest Service cannot maintain the roads it already has. The agency already faces a large backlog of road maintenance. Building or reconstructing roads in remote, steep, undeveloped terrain would add liabilities that taxpayers would have to carry. 5. Wildfire is not a sound justification. Wildfire risk is a real concern, but the Roadless Rule already allows fuels treatments, and research indicates wildfire risk is comparable inside and outside roadless areas. Rescinding the rule is not a targeted wildfire strategy. 6. The public process has been inadequate. The agency initially allowed only 32 days for comment, far less than the 129 days it provided when the rule was adopted in 2001. The 2001 rule drew 1.6 million public comments, roughly 95 percent in support. A decision of this scale deserves a longer comment period and public meetings in the regions affected. earthjustice senate I respectfully ask the Forest Service to abandon the proposed rescission and retain the 2001 Roadless Rule as written. I also ask that this comment be included in the administrative record.

Roadless Rule Protects Drinking Water for Up to 2 Million People in Oregon By various counts, up to 2 million people in Oregon get their drinking water from federally inventoried roadless areas in municipal watersheds. Cities like Salem, Eugene, Bend, Ashland, Baker City, Lake Oswego, Oregon City, Pendleton, and Portland all rely on roadless areas of forestland to filter and purify their drinking water before it’s treated for consumption. Most of these cities have found ways to legally shelter their watershed from logging or other extraction. Portland’s Bull Run Creek reservoir is a model in municipal watershed protection, and Bend and Salem watersheds are sheltered by protective covenants, although not to the same extent as Portland. Eugene, population 172,000, is unique among Oregon’s largest cities in that so much of the McKenzie River watershed relies on informal partnerships with private landowners and the various REIT’s and TIMO’s that manage industrial forestlands there. The limits of this model have been made apparent, recently, by the discovery that timber heiress Katherine Jones-McCann had constructed a sizeable compound directly adjacent to the McKenzie River without securing county permits. Luckily, most of the Eugene water supply comes from federally Inventoried Roadless Areas in the Willamette National Forest, notably the Hardesty Mountain Roadless Area some 25 miles southeast of the city. The recission of the Roadless Rule, however, could mean that Eugene’s luck has run out. The experience of a several mall Oregon towns with watershed degradation from private lands logging—Rockaway Beach, Wheeler, Yachats and others--portends an uncertain future for Eugene. The problem with recission is that, contrary to popular belief, there are already tens of thousands of miles of road on National Forest Land already. An estimated 370,000 miles of NF Roads already exist. This massive network of national forest roads is already too expensive for the U.S. Forest Service to maintain. Chris Wood, a former USFS senior policy advisor, recently told Outdoor Life that the service can only maintain about 20% of existing roads, with a current maintenance backlog of $10.8 billion. This was among the original considerations when the Roadless Rule was put into effect 25 years ago; there were just too many roads already. Anyone who hikes, forages for mushrooms or hunts on public land in Oregon has seen how often logging roads can erode and even collapse into creek bottoms, inevitably clouding the rivers they feed. The gated roads I hike and forage in Lane County often require new maintenance annually. Shoulders erode every winter, sometimes dangerously. Culverts can be blocked, causing washouts, just as a matter of course. If USFS opens roadless areas to new roads and logging, municipal watersheds will suffer over the whole state. As I said, my hometown of Eugene is in this exact situation. It is downstream from inventoried roadless areas that naturally filter surface water feeding the McKenzie River, Eugene’s sole water supply. And Eugene is not unique. A 2025 University of Washington study found that some 25,000,000 Americans depend on roadless areas to help filter their drinking water. Absent this natural filtration, many communities will struggle to purify public water. For more than 30 years, Big Timber and Wall Street have hungered for old trees on public land. By feigning concern about wildfire and rural jobs, they’ve not only found a way to get at those trees, but to have the taxpayers pay the price. Please don’t let them get away with it! Uphold the Roadless Rule.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I support Alternative 1, the No Action alternative. I am 34 years old, I live in Eugene, Oregon, and I work at a local watershed council protecting the rivers that supply our drinking water and sustain our salmon. I plan to raise a family here, and this decision will shape the Oregon my children inherit. I want them to drink clean water from our rivers, to hike and fish in places like Hardesty Mountain, and to grow up among old trees that are still standing and still pulling carbon out of the air. Roadless areas are one of the few climate solutions we already own, and they cost nothing to keep. I am asking the Forest Service not to trade away my generation's future for short-term timber volume. I submit this comment as an individual, and the views are my own. Roadless areas protect some of the largest intact forests in the National Forest System, including old-growth stands that hold carbon for centuries and keep sequestering as they age. Alternatives 2 and 3 would allow new roads and commercial logging across up to 18.2 million acres in the short term. Logging releases stored carbon, and replacement stands take decades to recover it, which is time the climate does not give us. The draft EIS also acknowledges that higher road density increases human-caused wildfire ignitions, and research finds fires are about four times more likely to start near a road than in roadless forest. More ignitions mean more emissions and more stored carbon lost. The Rule already allows roads and cutting for emergencies, restoration, and wildfire risk reduction, so rescission is not needed for fire safety. The final EIS should quantify the greenhouse gas emissions and lost sequestration from road construction, harvest, and added ignitions, apply the social cost of carbon, and explain how rescission is consistent with climate goals through 2050. As snowpack declines and summers dry, intact forest watersheds matter more. The draft EIS acknowledges that roadless areas "typically have good water quality due to limited disturbance," and that road construction and native-surface roads are the largest source of sediment from timber harvest. Forest Service data show more than 7,000 municipal water intakes within inventoried roadless areas, and Oregon communities including Eugene draw from watersheds that include them. The agency's own analysis finds Alternative 2 would "adversely affect" 327 listed species and 71 critical habitats, including Oregon's Chinook, coho, and steelhead. The final EIS should quantify the added treatment costs for downstream utilities and ratepayers and the effect on salmon recovery. The agency already reports a $6.9 billion road maintenance backlog, yet Alternative 2 would open 18.2 million acres to new roads. Meanwhile, visitors to the affected forests spent $8.5 billion in local communities in 2024, and the agency itself estimates Alternative 2 would reduce visitor spending by about $9 million per year. The final EIS should compare lifecycle road costs with expected timber receipts. The draft EIS reports that most consulted Tribal governments oppose rescission and concedes long-term negative effects on Tribal rights and interests. Alternative 3 is no compromise: it would remove protections from about 1.4 million acres, 75% of Oregon's roadless areas, including Hardesty Mountain near Eugene, and would degrade the intact forest left beside every stripped acre. About 95% of 1.6 million comments supported the Rule when it was adopted, and over 99% of more than 600,000 comments in 2025 urged retaining it. A 300-page draft EIS also cannot be meaningfully reviewed in this short a comment period. For these reasons, I urge the Forest Service to select Alternative 1 and retain the Roadless Rule in full. Alex Renirie, Eugene, OR

Dear Secretary Rollins, I am writing to oppose rescinding the Roadless Rule (RR). I live in Lane County, Oregon and 2 of my favorite hiking spots in Willamette National Forest are protected by the RR---Hardesty Mountain and Iron Mountain. I go to these spots for the beauty, the peacefulness and to look for wildflowers and wildlife, especially birds. Once roads are cut into an area, logging, mining and other development will eventually take place. Meanwhile, the roads themselves cause erosion which adds sediments to the streams and rivers that provide drinking water to thousands of Oregon residents. Healthy, clean drinking should be a right, not a privilege. Additionally, building more roads into pristine forest lands would significantly increase human access. Data from several sources indicates that the vast majority of wildfires are caused by human activity. This includes use of equipment; power lines; negligence with campfires and cigarettes; and arson. Nationwide the RR protects nearly 45 million acres of remaining intact forest ecosystems. Once lost these ecosystems are irreplaceable on a human timeline. For the above reasons and in fairness to futures generations, I urge you to retain the RR. Thank you for considering my input on this topic Carolyn Partridge

I am writing regarding the current administration proposal to rescind the 2001 Roadless Area Conservation Rule that restricts road construction, reconstruction and timber harvest on almost 45 million roadless acres on National Forest Service land across the country. My name is Gail Gredler. I moved to Oregon 52 years ago specifically for its beautiful forests, rivers, mountains and coastline. I have visited many of the almost 2 million acres of roadless land in Oregon that is currently protected from development by the rule in question. I have taken an active role in trying to preserve a number of these roadless areas through the years. The Hardesty Mountain Roadless Area is particularly near and dear to me. I have reviewed the three alternatives presented in the proposed recission of the rule, and the only one that is acceptable to me is Alternative 1, fully retaining the roadless rule for almost 45 million acres. These are our last wild lands that have not been developed. They are an irreplaceable resource. We owe it to future generations to set these areas aside for them. These lands belong to all Americans, and I believe that retaining them in their current state will provide far more benefits to the American public than developing them for resource extraction. Some of these benefits include: *Protecting watersheds – Many of these acres are on steep and fragile terrain that is not appropriate for roadbuilding and logging. In the Pacific Northwest, there has been a concerted effort to preserve and restore salmon habitat. That requires that water remains free of the detritus that roadbuilding and logging send into streams and rivers. Development activities also degrade drinking water quality in forested watersheds. *Providing intact wildlife habitat – Wildlife needs adequate food, water and space to live and reproduce. Roadless lands provide all of these in abundance compared to areas that have been impacted by human activities. Species that are threatened or endangered rely on large tracts of undeveloped land to survive. In western Oregon, salmon, steelhead, marbled murrelet, western snowy plover, Pacific marten, red tree vole, and more make their homes in roadless areas. *Providing abundant recreational opportunities – The number of people seeking to get out into nature and away from development has ballooned in recent years. Whether hiking, skiing, biking, canoeing, kayaking or just enjoying the peace and quiet of wild areas, people use our remaining roadless areas to recharge from their busy lives. The roadless areas that remain are invaluable in this regard. In addition, businesses that offer equipment and recreational opportunities thrive as a result. I also want to comment on one of the rationales for rescinding the roadless area rule. The idea that doing so would result in improved forest health is misleading. Recent research concludes that building roads into roadless areas is likely to result in more fires, not less. Access roads are often the conduit for fires caused by humans. In addition, it is unlikely that the US Forest Service will have the funds and personnel available to maintain new roads, as there is already a tremendous backlog of maintenance on current roads. I feel strongly that rescinding the Roadless Area Rule is a bad idea, amounts to an assault on our public lands and is an unnecessary land grab. Please choose Alternative 1 and keep the roadless areas roadless in perpetuity.

I am writing to support maintaining the Roadless Area Conservation Rule and urge you to choose Alternative 1 of the proposal. The Rule provides vital protections for public lands that are meaningful to me and my community. Roadless areas like Mount Hagen and McLennon Mountain in the Willamette National Forest safeguard my drinking water supply in the McKenzie River. I share roadless areas such as Echo Mountain, Gordon Meadows, Mount Washington West, Hardesty Mountain, Waldo-Fuji, Maiden Peak, Calf-Copeland, Mount Hebo, and the Oregon Dunes (in the Willamette, Siuslaw, Deschutes, and Umpqua National Forests) with colleagues and members of the public through educational hikes. The hiking guide I published in 2019 through Mountaineers Books includes trails in 26 different roadless areas, including Lost Lake in the Mt. Hood National Forest, the North Fork Malheur River in the Malheur National Forest, and Brown Mountain in the Rogue River-Siskiyou National Forest. I’ve enjoyed countless experiences with wildlife within roadless areas - places where birds, elk, wolves, and salmon find refuge and essential habitat. All of these values will be harmed by repealing the Roadless Rule. Such a decision will compromise clean water, fish and wildlife habitat, low-impact recreation and so much more. Rather than opening up new opportunities for exploitation of our roadless wild lands, I urge you to maintain the 2001 Roadless Rule for the many benefits they provide to the American people.

I strongly oppose the USDA’s proposal to eliminate, weaken, or alter the Roadless Rule. I live very near the Hardesty Mountain Roadless area and visit it frequently to hike and botanize. My wife is a professional botanist who often advises the local Forest Service botanists about populations of rare plants and invasive weeds. There is no question that roadbuilding facilitates the proliferation of dangerous invasive plants. Please take the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Sincerely, James Babson OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wildlife in the Hardesty Mountain wilderness area currently has room to live as it should. That is not a small thing to me, and it is exactly what rescinding the 2001 Roadless Area Conservation Rule would put at risk. I hike in Hardesty Mountain, a 2,597-acre roadless area in the Umpqua National Forest in Oregon, and I am filing this comment in opposition to the proposed rescission under Docket FS-2025-0001. The agency's own numbers undercut the economic rationale for this action before the argument is even made. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that backdrop, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a range so wide it cannot establish whether this action produces any net benefit at all. This is before accounting for a road maintenance backlog already standing at $6.9 billion. I ask that the agency reconcile the proposal with those figures and explain how an action whose own economic analysis cannot demonstrate a net benefit justifies expanding a road system already carrying that debt. The water I drink every day begins in these affected watersheds. I do not want water treatment costs to rise, and I do not want to drink unclean water. The wildlife that depend on these watersheds for their lives matter too, and roads are precisely the threat the rule was designed to hold back. Across the Pacific Northwest region, which includes Oregon and encompasses the Siuslaw and Umpqua national forests where the Smith Umpqua, Hardesty Mountain, and Williams Creek roadless areas sit, 1,522 municipal water intakes lie in watersheds containing affected roadless areas. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Opening these areas to road construction is not an abstraction; it is a direct threat to the watershed quality that municipal intakes and aquatic species depend on. The agency must explain, with specificity, how it proposes to protect those intakes and that wildlife if the national rule is removed. The proposal argues that state-by-state approaches can substitute for a uniform national rule. The agency has tried that before and the record reflects what followed: "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 found that prior state-by-state substitution inadequate. The agency should explain how this proposal avoids the same deficiencies, and address its own prior finding that local decision-making can incrementally erode roadless values that are nationally significant. On the question of statutory authority, the Tenth Circuit has already spoken: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the 2001 rule fell 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 must state on the record what legal basis it believes supports a contrary reading after that holding. Finally, the administrative burden argument does not survive contact with the rule's own text. The rule "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)." Exceptions already exist for public health and safety, existing mineral leases, and community wildfire protection. The agency should identify by name which specific burdens fall outside those existing exceptions and quantify them, because a vague appeal to permitting friction is not a record basis for eliminating protections that took years to establish and that serve the 1,937,741 acres of Oregon roadless land and the communities downstream from them. Our public lands must be managed with environmental integrity and with future generations in mind. The agency has not met that standard here. Sincerely, Lila Moore Eugene, Oregon

I wholeheartedly reject the rolling back of the Roadless rule for conservation. I am an Oregonian, and like all of us, we both love and recreate in these areas. This plan puts at risk beloved wild places in Oregon like Larch Mountain in the Gorge, Lost Lake and the Salmon River Trail in the Mount Hood National Forest, Hardesty Mountain outside Eugene, Tumalo Mountain outside Bend, Lookout Mountain in the Ochocos, the rugged canyonlands of Joseph Canyon in northeast Oregon, and the Oregon Dunes on the coast, among others. These are public lands and some of the last intact landscapes in America, providing clean water, critical wildlife habitat, and world-class recreation opportunities. And without the Roadless Rule, they could all be opened up to roadbuilding, commercial logging, and development.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Over fifty-five years of fishing Oregon's rivers, I have watched streams in the Siuslaw, Willamette, Umpqua, and Deschutes National Forests degrade under pressure from excessive logging. I have backpacked in almost all of Oregon's National Forests. I have birded roadless areas for decades because the birds there are more uncommon, and I have now seen over 600 species. I saw my first wolf in the Kalmiopsis. These places are not abstractions to me, and I am filing this comment to oppose rescission of the 2001 Roadless Area Conservation Rule. The agency's own draft environmental impact statement records that "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 proposal nonetheless invokes wildfire management as a justification for rescission. The agency must reconcile that ignition data, found in DEIS Table 21, with its claimed rationale, and explain in plain terms why its own findings on fire density do not cut against the action it is now proposing. The economic case fares no better on its own terms. The agency's record states plainly that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those figures, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. It also cannot justify expanding a road system already carrying a $6.9 billion maintenance backlog. The agency should explain directly how this action passes any reasonable cost-benefit threshold. I have fished the Umpqua and the Deschutes long enough to know what road sediment does to a stream. The DEIS acknowledges 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 and then nothing follows it. No projection of sediment delivery to downstream intakes is offered. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency should quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before finalizing any action. The Deschutes roadless areas, including the 26,432-acre Maiden Peak area, sit in a watershed that supplies roughly 60 percent of Bend's municipal drinking water, and the Deschutes also supports one of only two national strongholds for federally threatened bull trout. The DEIS states that "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." The document then asserts that forest plans address municipal water sources, without identifying a single enforceable provision equivalent to 36 CFR 294.12 or 294.13. That assertion does no protective work. The agency should identify, forest by forest, which plan provisions would carry that load. The DEIS also records that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Birding roadless areas is how I practice my craft. The Hardesty Mountain area in the Umpqua, where I have hiked for decades and which is exceptional for spring wildflowers, and the Kalmiopsis areas in the Siskiyou, which I consider the wildest and most climate-vulnerable landscape in Oregon, exemplify what the rule protects. Public land should be managed for resilience to climate change, to maintain clean water and protect the species that depend on it. This proposal moves in precisely the opposite direction, and the agency has not shown otherwise. Sincerely, David Funk Eugene, Oregon