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Roadless Areas contain some of the wild spaces that have shaped my experience with outdoor recreation, and I continue to recreate in these landscapes frequently today. For example, Liberty Bell in the Okanogan-Wenatchee National Forest is where I led my first multi-pitch trad climb, Hidden Creek in the Mount Baker-Snoqualmie National Forest was one of the first canyons I explored and helped inspire my love of public lands, and Mineral Creek in the Okanogan-Wenatchee National Forest is where I take new canyoners to experience the waterfalls and wild landscapes of Washington. These are only three examples of the dozens of ways I recreate in Roadless Areas. I am deeply concerned that rescinding the Roadless Rule could eventually result in the loss of access, or increased costs and barriers to access, as logging, road construction, and other extractive activities expand into currently Roadless Areas. I have already seen some of these impacts in canyons where logging leases have affected access and the surrounding landscape, and I worry that opening roads in Roadless Areas could lead to similar outcomes in other places where I recreate. I am also concerned about the effects of increased roads and human access on the condition of these areas. In canyons that are currently accessible by roads, canyoners already encounter excessive garbage dumping and invasive species. I worry that opening currently Roadless Areas to additional roads and development would expose more of these relatively untouched places to the same problems. Road construction also has the potential to alter the natural processes that make these canyons unique. In my experience, canyons near roads have experienced problems including extreme seasonal flooding, unstable log jams, and destruction of anchors used for technical canyon access. I am concerned that increasing road density could exacerbate these impacts and degrade both the natural character and recreational value of these areas. Wildfire risk is another significant concern for me. Multiple members of my family lost their homes in human-caused fires during the past fire season, making this issue particularly personal. I understand that the existing Roadless Rule allows for wildfire management within Roadless Areas. I would ask the Forest Service to fully explore and utilize those existing wildfire-management options rather than opening additional wild areas to roads and the increased human access and potential for human-caused ignitions that roads can bring. I also have a significant fiscal concern. The Forest Service is already responsible for maintaining approximately 380,000 miles of National Forest System roads, and the agency faces substantial challenges maintaining its existing road network. Many existing roads are aging or inadequately maintained because of limited resources. Given these constraints, I believe it would be fiscally irresponsible to expand the active road network into currently Roadless Areas when there are already so many existing roads that the Forest Service does not have the resources to adequately maintain. I urge the Forest Service to retain protections for Roadless Areas and not rescind the 2001 Roadless Rule. These landscapes provide irreplaceable opportunities for recreation, solitude, and connection with wild places. I fear that rescinding the Roadless Rule will lead to irreversible damage to the places where I recreate, permanently altering the landscapes that I feel incredibly fortunate to enjoy today. I hope future generations will have the same opportunity to experience these wild places as I have.

Winter Wildlands Alliance (WWA) is a national non-profit conservation organization representing the interests of human-powered winter recreationists. We work to inspire and empower people to protect America’s wild snowscapes. Our alliance includes 38 grassroots groups across 16 states. Our community values roadless areas for the opportunities they provide for backcountry winter recreation, including skiing, snowboarding, and snowshoeing. Additionally, while these areas are protected from new road construction and timbering, their management is less restrictive than Wilderness, allowing for more flexible land management in these important places. Roadless areas exist across the country and are home to beloved winter backcountry recreation spots like Montana’s Hayalite Canyon, a world-renowned ice climbing destination; backcountry skiing at Washington Pass and Liberty Bell at the Headwaters of Washington’s Methow Valley; backcountry skiing, Nordic skiing, and snowshoeing in Utah’s Central Wasatch, a region which draws thousands of visitors each winter; backcountry skiing around Lake Tahoe and in the Sherwins next to the town of Mammoth California; and backcountry skiing and snowshoeing around Wyoming's scenic Teton Pass; and so many more special areas. Without the protections of the 2001 Roadless Rule, all of these areas are subject to new road construction, timber harvesting and commercial development which could fundamentally impact landscapes that provide critical ecosystem services and meaningful outdoor experiences. We write here to submit comments on behalf of 1,134Winter Wildlands Alliance members and supporters. Thank you for considering these comments from across our network.

I urge USDA to reject full rescission of the 2001 Roadless Rule and select Alternative 1, the No Action alternative. I am a resident of Corvallis, Oregon and regularly visit these nine Roadless Areas in Oregon and Washington: Marsh, Tahkenitch, Echo Mountain, Maiden Peak, Waldo-Fuji, West-South Bachelor, Sawtooth, Pasayten Rim and Liberty Bell. I visit these Roadless Areas to hike, observe and photograph wildlife, and enjoy the solitude of an area without vehicle noise. Besides all the benefits they provide humans, Roadless Areas provide critical, undisturbed habitat for wildlife feeding and reproduction as well as vehicle-free corridors for safe movement. I saw my first bald eagle nest and pacific fisher in the Marsh Roadless Area along Upper Klamath Lake in Oregon. I have seen meadows of spring wildflowers and hundreds of butterflies at Iron Mountain in the Echo Mountain Roadless Area. I have hiked many times through the quiet dunes at Tahkenitch Roadless Area to the vehicle-free beach at the end of the trail. I have watched American dippers singing at a snow-covered creek in the Maiden Peak Roadless Are. I have waded into the crystal clear waters of Betty Lake in the Waldo-Fuji Roadless Area. I have enjoyed spectacular views of the Methow Valley from the Liberty Bell Roadless Area. I have watched hawks migrating through the spectacular Pasayten Rim Roadless Area in the fall. Please do not make any changes to the 2001 Roadless Rule. Roadless Areas make America great!

I am writing to oppose the repeal of the 2001 Roadless Area Conservation Rule. I am an avid user of America’s public lands and have thru-hiked more than 3,000 miles of our national trails, including the Pacific Crest Trail (PCT, 2021), Vermont Long Trail (2023), and Arizona Trail (2025). These experiences have given me a deep appreciation for undeveloped forests, mountains, and wild places—not simply as scenery, but as places where people can challenge themselves, find solitude, and experience landscapes and wildlife that cannot be recreated once roads and development change them. This issue is especially personal because approximately 288 miles of the Pacific Crest Trail (~11% of the trail) pass through 63 roadless areas in California, Oregon, and Washington. For example, Liberty Bell, in my home state of Washington, incorporates just one of numerous sections of hiking trails that stand to be impacted if the Roadless Areas Conservation Rule is repealed. In 2021, as I was hiking the PCT, the Northern Terminus of the trail was almost closed due to wildfires in the area. I remember sitting at Rainy Pass, knowing a fire was within just a few miles of the trail, and deciding to continue with the final 60 miles of my trip. The days that followed, hiking through Liberty Bell, were among the most peaceful and memorable of my entire journey. I have attached a photograph from my approach to Grasshopper Pass as a reminder of what is at stake. Liberty Bell is much more than a beautiful backdrop for recreation. Its approximately 108,495 acres of continuous, unroaded subalpine forest provide important habitat and movement corridors for wildlife, including gray wolves, Canada lynx, wolverines, and other species that depend on large, connected landscapes. Keeping these areas roadless also helps protect watersheds, fish habitat, soils, and native plant communities from the erosion, sedimentation, fragmentation, and invasive species that roads and logging can bring. I understand that the Forest Service faces legitimate challenges, including wildfires, forest health, and the need to manage public lands effectively. But those challenges should not lead us to permanently sacrifice some of the country's remaining intact landscapes. The Forest Service already has hundreds of thousands of miles of roads to maintain, and once a road is built into a previously roadless landscape, its ecological and recreational character may be permanently altered. One of our nation's greatest strengths is its natural beauty. Our public lands provide something remarkably rare: places where Americans of every age, race, gender, political affiliation, and background can share the same experience. Whether hiking, climbing, hunting, fishing, camping, or simply standing quietly in a forest, these lands belong to all of us. I respectfully urge the U.S. Forest Service and Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and protect Liberty Bell and the many other roadless landscapes that future generations deserve to experience as we do today. Please preserve these irreplaceable places. Sincerely, Alder Colleen Strange

I am writing to oppose proposed changes to the Roadless Rule. I am a Washington state avid climber, hiker and cross country skier. I am particularly concerned about how he negative impacts the rule change will have on the Quilicene on the Olympic Peninsula and Liberty Bell in the North Cascades, Preservation of these wildernes areas is critical to their enjoyment by future generations.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Baker River and its tributaries, the alpine lakes throughout the region, the Liberty Bell area: these are not abstractions to me. I work in restoration, and I have watched what road creation does to water. Sedimentation, degradation of habitat, increased water temperature. I have seen these things. Rescinding the 2001 Roadless Area Conservation Rule will produce more of them, and the agency's own analysis makes that plain while declining to follow the logic through. 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 is stated and then left hanging. No projection of sediment delivery follows it. Across the Pacific Northwest region alone, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. People downstream of those intakes are drinking that water. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas and explain in the final record how that delivery is controlled under the proposed rescission. The drinking water problem runs deeper than sediment. 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." The document then asserts that forest plans address public drinking water, but it does not identify a single enforceable provision in any of those plans equivalent to what the rule currently requires. We have a responsibility to manage our public lands for people, water quality, and habitat. That responsibility cannot be discharged by a general reference to forest plans that are never examined. The agency must identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. I hike and ski in the Liberty Bell area frequently. It is a gorgeous zone that would be completely changed if roads were allowed. Liberty Bell sits within the Okanogan National Forest and covers 108,495 acres. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and what happens to the rule happens to all of them. On the biology The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is wide enough to span catastrophe, yet no projection across the 40.1 million acres of potentially affected environment follows it. The Liberty Bell area has a character that comes precisely from its freedom from roads and the development roads enable. The agency should apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what outcome it considers acceptable. On the economics, The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The guides and outfitters who work in areas like Liberty Bell are not a national average. Spreading an expenditure loss across every small firm in the sector to reach a no-impact conclusion does not assess the firms actually holding permits in the affected areas. The certification should be withdrawn and the impact assessed for the small entities actually operating in the potentially affected roadless areas. One further point: I don't think it makes sense to build more roads when the agency can't keep up with maintenance of the roads it already has. The agency is aware of its maintenance backlog. Building new roads into country that currently has none, while that backlog grows, transfers a long-term liability to the public and to the watersheds those roads will drain into. The final record should address this directly. Sincerely, Walker Brown Bellingham, WA 98225

As a PCT'19 alumni and wildands advocate, I oppose the repeal of the Roadless Area Conservation Rule. There are 63 roadless areas along 288 miles of the PCT in California, Oregon and Washington. These miles represent roughly 11% of the trail. Roadless areas provide clean drinking water to 60 million Americans. This also provides connected wildlife corridors and undisturbed natural connected ecosytems. These undeveloped lands are critical to our nation’s ecological health.  These areas store 20% of all carbon in U.S. national forests. Roadless areas offer abundant outdoor recreation opportunities such as hiking hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. The outdoor recreation economy generates $730 billion annually, far more than timber sales. Roadless areas are crucial habitat for 1,600+ threatened species. We already have 370,000 miles of forest roads with a multi-billion dollar maintenance backlog. Studies show wildfire ignitions are 4x more likely near roads than in roadless areas Please keep these roadless areas roadless! Deep Creek IRA—San Bernardino National Forest: On the north slope of the San Bernardino Mountains about 60 miles east of Los Angeles. Starting at 6,200 feet above sea level, the stream through the IRA drops about 3,000 ft through dramatic canyons in its 22-mile course before flowing into the East Fork of the Mojave River. It includes deep pools and hot springs and is a popular spot for day hikers. South Sierra IRA—Inyo National Forest: On the PCT and near the South Fork of the Kern River. San Joaquin IRA—Inyo National Forest: Red’s Meadow is a beloved respite along the PCT and a starting point for horse packers at the Agnew Meadows Pack Station. Dardanelles IRA—Lake Tahoe Basin Management Unit: Nearly the entire PCT from Carson Pass to Echo Summit is in this roadless area. Granite Chief IRA—Lake Tahoe Basin Management Unit: Heading north from Barker Pass, the PCT, and the contiguous Tahoe Rim Trail climb to dramatic ridgelines, yielding dreamlike views of Lake Tahoe amidst red fir and hemlock forests. Further north, the trail enters Granite Chief Wilderness and intersects the Western States Trail. Areas between Granite Chief Wilderness and Donner Pass are within this IRA, jeopardizing views enjoyed by thru-hikers, day hikers, and even skiers who use Olympic Valley, Lake Tahoe’s largest ski park. Mount Eddy IRA—Shasta-Trinity National Forest: Just across the valley from Mount Shasta, Mount Eddy is the tallest peak along the Trinity Divide, and the tallest peak in CA west of I-5. This subrange of the Klamath Mountains features a unique landscape of towering granite spires, lush evergreen forests, and alpine lakes deep in glacier-carved cirques. The area is under the jurisdiction of the U.S. Forest Service and was established as a Research Natural Area (RNA) to study its ecological significance, serving as the headwaters for the North Fork Sacramento River. Grider IRA—Klamath National Forest: This is a popular area for campers and day hikers along the creek, which feeds the Klamath River. Severely burned in the 2014 Happy Camp Complex, the regrowing brush gives way to large stands of surviving trees, and the sound of rushing water is a constant along the trail. The area has already been the subject of a legal fight over logging. Norse Peak IRA—Okanogan-Wenatchee National Forest: Next to Mount Ranier National Park, Sheep Lake is a picturesque alpine lake and a welcome destination for families for swimming, backpacking and camping. The hike to the lake is a gentle, 1.8-mile climb past summer wildflowers and red huckleberry plants in the fall, with great views of the Rainier fork of the American River, Mount Rainier, and Naches Peak. Liberty Bell IRA—Okanogan-Wenatchee National Forest: Some 30 miles of the PCT from Rainy Pass to Harts Pass, including the popular day hike to Cutthroat Pass, are within this large IRA. Situated in the heart of the North Cascades, this area is home to the mighty Methow River, many alpine passes, and some of the highest elevation stretches of the PCT in Washington.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Methow Valley and the Liberty Bell Inventoried Roadless Area are what brought me to this docket. I go there for solitude. Liberty Bell is a legendary gem of Washington's North Cascades that deserves the protections it has, and the Okanogan-Wenatchee National Forest surrounding it is one of the broadest, most diverse assemblages of habitat, recreation opportunities, and a deep source of economic stability for local communities. The proposal to rescind the 2001 Roadless Area Conservation Rule would strip those protections from Liberty Bell's 108,495 acres and from the 1,006,000 acres of the Okanogan-Wenatchee as a whole. I oppose it. The agency's own findings on fire undermine its primary justification for rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless invokes wildfire and fuels management as grounds for opening roadless areas to new road construction. That rationale contradicts the agency's own ignition data, which DEIS Table 21 reports as showing far higher fire density on roaded land than inside the affected roadless areas. The agency must explain, with specificity, why its current proposal departs from those prior findings, and must reconcile the rescission with the data it gathered and published in its own environmental review. The economic case for rescission is no stronger. The agency acknowledges: "The agency receives less than 20% of the funds needed annually to maintain the existing road infrastructure. As funding needs remain unmet, the cost of fixing deteriorating roads increases exponentially every year." Against that admission, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The existing road system already carries a $6.9 billion maintenance backlog. An action whose own analysis cannot establish a net benefit, and whose implementing agency cannot fund the roads it already has, cannot be justified by economic grounds. I ask the agency to reconcile the proposal with those numbers before it proceeds. On statutory authority, a court has already resolved the question the proposal reopens. The Tenth Circuit held: "In sum, we conclude that the Roadless Rule did not designate de facto administrative wilderness areas in contravention of the procedures set out in the Wilderness Act." That court further held the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act. The proposal argues the rule exceeded the agency's authority. What is the legal basis for that position in light of the circuit court holding? The agency must address this directly. Finally, the regulatory flexibility analysis that certifies no significant impact on small entities cannot survive contact with the rest of the record. The 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. The certification is reached by spreading expenditure losses across every small firm in the sector nationally rather than examining the outfitters, guides and permit holders actually operating in the affected areas. The analysis itself concedes some of those firms may lose those receipts entirely. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The economic reach of this rescission is not abstract or evenly distributed. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually holding permits and operating in these places, not a national average that obscures the local harm. Liberty Bell and the Okanogan-Wenatchee are worth protecting because of what they are. The agency has not made the case, by its own numbers or by law, that rescission improves on that. Sincerely, Tony Cannistra, Ph.D. Winthrop, Washington

Re: Proposed Rescission of the Roadless Area Conservation Rule To Whom it May Concern: The Center for Responsible Forestry, a Washington conservation organization working to protect the state's legacy forests, urges the Forest Service to withdraw this proposal and keep the Roadless Rule in place. Washington has over nine million acres of national forest, including over two million acres of inventoried roadless areas. They lie across the Olympic, Mount Baker-Snoqualmie, Gifford Pinchot, Wenatchee, Okanogan, Colville, and Umatilla National Forests, in the Cascades, Kettles, Selkirks, Olympics, and Blues. In northeast Washington, the Kettle Range and the forests around the Salmo-Priest Wilderness hold critical habitat for grizzly bears and a reestablishing lynx population, and backcountry destinations like Liberty Bell and Maple Pass would become vulnerable. Areas such as Mount Baker and Lake Quinault also offer popular backcountry recreation that depends on roadless protection. Much of what remains of Washington's older, intact forest sits in or beside these roadless areas. Once a road is cut into such a forest, the damage cannot be undone. SENATE BILL REPORT +4 The Department calls the rule a barrier to wildfire risk reduction, and protecting communities from fire is a legitimate goal. But the rule already limits logging in roadless areas to smaller-diameter trees for restoration and fire resilience. Opening remote backcountry to roads does not protect towns. It brings more human presence and more fire danger, and it adds to a road system that already has too many decaying roads that are too expensive to maintain. conservationnw conservationnw Timber industry representatives have argued that other laws, such as the Endangered Species Act and NEPA, would still limit timber production and protect the environment. Those laws apply project by project, after roads and timber sales are already proposed. The Roadless Rule is the only protection that applies everywhere in advance. Without it, every roadless area would have to be defended again in a separate fight. yahoo Washington has been through this before. When the rule was first developed, 45 public meetings were held in Washington and more than 140,000 comments came from Washington residents, the overwhelming majority in support. After the 2005 repeal, the state was left petitioning the federal government to keep its protections. In this rulemaking, the agency received more than 600,000 comments in the first round and now admits that 99 percent opposed rescission. The proposed rule and draft environmental impact statement then received 32 days of comment, compared with 129 days in 2001 and 182 days in 2005. Washington's communities, tribes, hunters, anglers, and forest users deserve real public meetings in this state before any decision is made. skip to navigation | skip to content +2 For 25 years the Roadless Rule has kept Washington's headwaters cold, its wildlife corridors connected, and its backcountry open to everyone. Please do not rescind it. Sincerely, Brel Froebe Center for Responsible Forestry

Re: Proposed Rescission of the Roadless Area Conservation Rule To Whom it May Concern: The Center for Responsible Forestry, a Washington conservation organization working to protect the state's legacy forests, urges the Forest Service to withdraw this proposal and keep the Roadless Rule in place. Washington has over nine million acres of national forest, including over two million acres of inventoried roadless areas. They lie across the Olympic, Mount Baker-Snoqualmie, Gifford Pinchot, Wenatchee, Okanogan, Colville, and Umatilla National Forests, in the Cascades, Kettles, Selkirks, Olympics, and Blues. In northeast Washington, the Kettle Range and the forests around the Salmo-Priest Wilderness hold critical habitat for grizzly bears and a reestablishing lynx population, and backcountry destinations like Liberty Bell and Maple Pass would become vulnerable. Areas such as Mount Baker and Lake Quinault also offer popular backcountry recreation that depends on roadless protection. Much of what remains of Washington's older, intact forest sits in or beside these roadless areas. Once a road is cut into such a forest, the damage cannot be undone. SENATE BILL REPORT +4 The Department calls the rule a barrier to wildfire risk reduction, and protecting communities from fire is a legitimate goal. But the rule already limits logging in roadless areas to smaller-diameter trees for restoration and fire resilience. Opening remote backcountry to roads does not protect towns. It brings more human presence and more fire danger, and it adds to a road system that already has too many decaying roads that are too expensive to maintain. conservationnw conservationnw Timber industry representatives have argued that other laws, such as the Endangered Species Act and NEPA, would still limit timber production and protect the environment. Those laws apply project by project, after roads and timber sales are already proposed. The Roadless Rule is the only protection that applies everywhere in advance. Without it, every roadless area would have to be defended again in a separate fight. yahoo Washington has been through this before. When the rule was first developed, 45 public meetings were held in Washington and more than 140,000 comments came from Washington residents, the overwhelming majority in support. After the 2005 repeal, the state was left petitioning the federal government to keep its protections. In this rulemaking, the agency received more than 600,000 comments in the first round and now admits that 99 percent opposed rescission. The proposed rule and draft environmental impact statement then received 32 days of comment, compared with 129 days in 2001 and 182 days in 2005. Washington's communities, tribes, hunters, anglers, and forest users deserve real public meetings in this state before any decision is made. skip to navigation | skip to content +2 For 25 years the Roadless Rule has kept Washington's headwaters cold, its wildlife corridors connected, and its backcountry open to everyone. Please do not rescind it. Sincerely, Center for Responsible Forestry

I'm a Washingtonian and passionate outdoorsman. I am a climber, mountaineer, hiker, & forager. I urge you to keep the Roadless Rule in place, defend public land over short-term profit, and pursue other forest management and fire-mitigation tactics. Per Access Fund, "The USFS asserts that rescinding the Roadless Rule is necessary to improve forest health and reduce wildfire risk, but it has not demonstrated that the Rule is a significant obstacle to effective fire or forest management." The Trump Administration is escalating development of public land and this is an example of that. Think downstream: once wild spaces are developed, it's done. Industry brings pollution & spreads invasive species; roads and logging destabilize the forest and are "the largest single source of sediment pollution in national forest streams" per Sierra Club; they do irreparable harm to biodiversity. We need to keep our few remaining roadless areas protected for the sake of our future generations. Per Sierra Club, outdoor recreation in Mt. Baker-Snoqualamie NF (MBSNF) is magnitudes more fiscally impactful than the proposed timber and mining extraction - $13.5b/year or 45x vs. $300m/year in timber sales inventory, and at risk if the roadless rule is rescinded. My home woods are MBSNF, one of the most intact wild spaces in the lower-48 states spanning the I-90 cooridor north up to the border with Canada, inclusive of many areas impacted by the proposal. MBSNF has brilliant stands of mature and old growth temperate rain forest, rich with biodiversity. Re: The USDoD's Project BioShield, mycologist Paul Stamets said, "We should save old growth forests as a matter of national defense," as they have irreplaceable biodiversity; these do not come back with tree farms and secondary timber stands. Much of the Cascades old growth has been logged; the rule has helped keep it unprofitable for the timber industry to log what remains. To create roads in these spaces changes that. Eg, Heather Lake, impacted by the proposal. Heather is an accessible alpine lake with stands of old growth, a gateway to Cascades hiking from Seattle. There is a palpable difference between the health of lower, secondary growth trail and upper old growth. Lower has huge cedar stumps, deep erosion, & lacks ground cover; upper has lushness and biodiversity, rich with mushrooms and big trees, protected by the roadless rule. See attached pic from a hike with my sister, admiring an old cedar. To drive an hour from the city and immerse myself into the alpine lakes is amazing - the air is clean. It's away from road noise, light pollution, run off. There are few invasives, like the rampant Himalayan Blackberry brambles tracked in by forestry trucks that choke out natives in the PNW. I can drink the melt water; there's no industry upstream. South in MBSNF is the headwater of Seattle's drinking supply, put ask risk by roads given the reality of industrial pollution from timber and mining. It's humbling, awe-inspiring, and spiritually moving for me to be immersed in these spaces. The woods has measurable therapeutic effects. I was in the Allegheny NF in PA recently, an area already logged, mined, and parceled, which is filled with invasive species choking out natives, like Japanese Knotweed. FS roads have oil derricks alongside streams. Camping has traffic sounds. This is not what WA needs! WA's roadless forests are a recreation hotspot - folks travel the world to climb our world-class alpine terrain, and to train for larger objectives like the Himalayas, or to backpack, like The Enchantments, adjacent to impacted Chelan NF; part of what makes this place special is it's wildness. Liberty Bell in Chelan NF just outside of N. Casc. NP, another area protected by the rule, is among the 50 Classic Climbs in North America, and the surrounding wilds impacted by the rule are home to some of the best climbing in WA, e.g., Early Winter and Kangaroo Spires. Last time I was there saw wildfires in N. Casc. NP - the road through the middle of the park didn't stop the spread of the fires; per Access Fund, "fuels reduction and fire management can occur in roadless areas, while, research indicates, expanding road networks increase human-caused ignition risks." I was married in Mt. Baker North, an area protected by the rule. 20 people flew in from around the world. We did day trips to a huge stand of old-growth douglas firs, to admire the volcanoes, to see pink salmon spawning. This is a special place that needs more environmental protection not less! Creative management, not expanded industry. Bottom line: WA's roadless forest are special, rich with biodiversity, ripe for recreation, and deserving of protection by the roadless rule. Think longer-term - keep the roadless rule. Allow future generations to cherish these spaces. Keep public land public and help slow industrialization. Listen to the people! Protecting public land has bipartisan support! Preserve the roadless rule.

I feel strongly that the Roadless Area Conservation Rule should be strengthened to eliminate logging and roadbuilding loopholes and provide better protection to roadless areas and adjacent Wilderness areas. I may not ever hike there but, in the same sense, I would hope that someone was preserving the Liberty Bell and not selling it for scrap.

I am asking that we preserve the roadless area protections for the Norse Peak IRA and Liberty Bell IRA. Norse Peak Inventoried Roadless Area (IRA)—Okanogan-Wenatchee National Forest: Next to Mount Ranier National Park, Sheep Lake is a picturesque alpine lake and a welcome destination for families for swimming, backpacking and camping. The hike to the lake is a gentle, 1.8-mile climb past summer wildflowers and red huckleberry plants in the fall, with great views of the Rainier fork of the American River, Mount Rainier, and Naches Peak. Liberty Bell Inventoried Roadless Area (IRA)—Okanogan-Wenatchee National Forest: Some 30 miles of the PCT from Rainy Pass to Harts Pass, including the popular day hike to Cutthroat Pass, are within this large IRA. Situated in the heart of the North Cascades, this area is home to the mighty Methow River, many alpine passes, and some of the highest elevation stretches of the PCT in Washington These areas are valuable public lands that provide opportunities for hiking, camping, backpacking, wildlife life viewing and experiencing Washington’s remarkable natural landscapes. Protecting these areas ensure the same opportunities for future generations. Maintaining roadless protections will help preserve the ecological integrity, scenic character, wildlife habitat, clean water, and recreational opportunities these areas provide. Once roads and associated development are introduced into these landscapes, the character and ecosystems can be permanently changed or completely lost for future generations.

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

SUBMITTED VIA REGULATIONS.GOV Date: Sep 3, 2026 U.S. Department of Agriculture – Forest Service Attn: Public Comments Processing / Proposed Rule Rescission Docket No. FS-2025-0001 (Document: FS-2025-0001-223869) Subject: Formal Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Forest Service Leadership and Rulemaking Committee, I am writing in strong opposition to the U.S. Department of Agriculture and Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001). For nearly a quarter-century, the Roadless Rule has provided a balanced, durable framework that safeguards 44.7 million acres of inventoried roadless lands nationwide, including approximately 2 million acres across Washington State. Rescinding this rule to open fragile, backcountry lands to industrial road construction and commercial timber extraction is ecologically harmful, fiscally irresponsible, and fundamentally unnecessary for active forest restoration. I urge the agency to withdraw this proposal and maintain full Roadless Rule protections based on the following substantive grounds: 1. Expanding the Road Network Exacerbates Wildfire Ignition Risks The proposal suggests that road-building is required for wildfire mitigation. However, peer-reviewed fire science and regional data demonstrate that forest roads serve as primary vectors for human-caused wildfire ignitions. In Washington State, approximately 85% of all wildfires are caused by human activity. Expanding road access into remote backcountry dramatically increases ignition vectors in steep, dry, and fire-prone terrain where containment is most difficult. 2. Forest Health and Fuels Reduction Are Already Permitted Under the 2001 Rule The premise that the 2001 Roadless Rule prevents necessary forest health management mischaracterizes existing regulatory flexibilities. The current rule explicitly permits ecological restoration thinning, small-diameter hazardous fuels reduction, and prescribed fire within roadless areas. What the rule restricts is industrial commercial timber harvest and road construction. Hauling heavy commercial timber out of steep, rugged backcountry is constrained by topography and market economics—not forest health regulations. 3. Deepening an Existing $10.8 Billion Road Maintenance Backlog Is Fiscally Irresponsible The Forest Service currently manages an expansive infrastructure network of over 380,000 miles of existing roads, while facing a documented, persistent deferred maintenance backlog exceeding $10.8 billion. The agency receives annual appropriations sufficient to maintain only a small fraction of its existing road inventory. Constructing new roads across steep, erosion-prone terrain will generate long-term liabilities, increase culvert blowouts, accelerate sedimentation into fish-bearing streams, and drain vital resources away from existing road maintenance priorities. 4. Severe Impacts on Habitat Connectivity, Fisheries, and Municipal Headwaters Roadless areas are vital reservoirs of biodiversity and ecological connectivity. In Washington, areas such as the Dark Divide (Gifford Pinchot National Forest), Liberty Bell (Okanogan-Wenatchee National Forest), and Abercrombie-Hooknose (Colville National Forest), along with roadless landscapes across the Cascades, Kettles, Selkirks, Olympics, and Blue Mountains, provide crucial contiguous corridors for wide-ranging species including the Canada lynx and wolverine. Furthermore, these untouched watersheds provide clean, cold, naturally filtered drinking water to downstream municipal communities and protect essential spawning beds for threatened salmon, steelhead, and bull trout from damaging road runoff and sedimentation. 5. Cultural, Subsistence, and Backcountry Economic Values Roadless national forests sustain essential cultural and traditional subsistence practices, while anchoring a vibrant backcountry recreation economy. Hunters, anglers, hikers, and local outfitters depend directly on undisturbed, intact wildlands. Industrial development in these areas degrades the very qualities that draw visitors and sustain rural economies. Conclusion The 2001 Roadless Area Conservation Rule is one of the most successful, widely supported conservation policies in American history. Rescinding it would cause generational ecological degradation while compounding the Forest Service's infrastructure deficit. I respectfully request that the Forest Service cancel this proposed rulemaking and retain the 2001 Roadless Rule in its entirety. Sincerely, M. David Conrad Angler, Outdoorsman, Voter Burien, WA

Roadless areas are some of the last places on public lands free from industrial development. In Washington, that means country like the Dark Divide in the Gifford Pinchot National Forest, Liberty Bell in the Okanogan-Wenatchee National Forest, and Abercrombie-Hooknose in the Colville National Forest. They provide landscape connectivity for wide-ranging species like wolverine and Canada lynx, and clean, cold water for downstream communities. Much of the wildlife we work to protect lives in these areas and depends on habitat free from human development. They also support cultural and subsistence practices and some of the best backcountry recreation in the state. There are already more roads on national forests than can be affordably maintained. The Forest Service manages a 380,000-mile road system with a growing $10.8 billion maintenance backlog that has persisted for decades, and it receives funding to maintain only a fraction of that system. The proposal also misstates what the rule already allows. Restoration thinning and prescribed burning are both permitted in roadless areas. The rule limits commercial timber harvest, but hauling logs out of steep backcountry terrain was never going to pencil out for mills in the first place. The constraint here is economics and topography, not regulation. Roads fragment and degrade wildlife habitat, act as vectors for human fire ignitions, and dump sediment into fish habitat and spawning beds each year. In Washington, about 85% of fires are caused by people each year. We need our wild country more than we need new forest roads.

Growing up in the mountains of the Pacific Northwest, we love to hike, camp, and hunt. Roadless areas are some of the last places on public lands free from industrial development. In Washington, that means country like the Dark Divide in the Gifford Pinchot National Forest, Liberty Bell in the Okanogan-Wenatchee National Forest, and Abercrombie-Hooknose in the Colville National Forest. Growing up in the Pacific northwest, our family loves to hike, camp and hunt. We also visit lands in So. Carolina and GA. We love forested land. Forested land provides for species like wolverine and lynx, and clean, cold water for downstream communities. Much of the wildlife we work to protect lives in these areas and depends on habitat free from human development. They also support cultural and subsistence practices and some of the best backcountry recreation in the state of WA. We want to keep our forests for the animals, for the fish and the cold waters that we love to swim in. Destroying the US FORESTS with clear cuts is wrong, it will enhance the effects of climate change. We must protect our forests............no extra forest roads!

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The trails of the Okanogan-Wenatchee National Forest shaped who I am. I grew up running, biking, and hiking on the numerous trails there, and the forest continues to be one of my favorite places to visit and recreate. Liberty Bell, within the Okanogan, is one of the most special places I have ever been and is deeply important to my personal growth and experiences. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I want my children to have the same opportunities for exploration and solitude as I did. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and these are not abstract statistics to me. The 108,495-acre Liberty Bell area and the broader 1,006,000-acre Okanogan-Wenatchee landscape are places I have moved through on foot and by bike, places I expect to bring the next generation to. These places should remain roadless for future generations. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule. It has held none to undo it. I ask the agency to explain how that asymmetry is consistent with its obligations to the public. Fire is not abstract to me either. The fire seasons of my childhood form some of my earliest and most visceral memories. Most recently, the 2021 fire season sticks in my mind for being able to watch flames expand across the valley from my bedroom. The agency's justification for rescission leans on wildfire and fuels management, yet the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence, and to reconcile the rescission with that ignition data. The Pacific Northwest, which includes Washington, holds 1,522 municipal water intakes in watersheds containing affected roadless areas. The communities downstream from the Okanogan and Wenatchee forests depend on what roadless protection keeps intact. The supporting regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading losses across every small firm in the sector nationally, rather than assessing the outfitters, guides and tour operators actually holding permits in the areas at issue. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That is not a national abstraction; it is the economy of places like the ones I grew up in. The agency should withdraw the small-business certification and assess the impact on the specific small entities operating in the potentially affected roadless areas, not the national average firm. The proposed rule solicits reliance interests and then declines to weigh them. This comment is one such interest. I have planned and continue to plan my life, my children's upbringing, and my connection to the Okanogan-Wenatchee around the expectation that these roadless areas remain protected. Under the legal standards that govern agency change of course, reliance interests created by a prior policy must be identified and assessed, not merely solicited and ignored. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency declares foreseeable plan amendments, including expanded timber harvest and road construction, beyond the scope of this proposal, and then in the same document invites public comment on them. That posture is not defensible. The agency is asking commenters to perform an analysis it has refused to conduct itself. The foreseeable scenario in which plan amendments follow rescission and open additional areas to harvest and roading must be analyzed as part of this action, not deferred to proceedings the public cannot yet see or participate in. The Okanogan-Wenatchee shaped my upbringing. I expect the agency to answer each of these points in the record before it acts. Sincerely, Ella Hall Missoula, MT

Subject: Strongly Oppose the Rescission of the 2001 Roadless Area Conservation Rule (Docket ID: FS-2025-0001 / RIN 0596-AD66) To the U.S. Department of Agriculture Forest Service: I am writing to express my strong opposition to the U.S. Department of Agriculture and Forest Service’s proposal to fully rescind the 2001 Roadless Area Conservation Rule. For the last 25 years, the Roadless Rule has protected almost 60 million acres of our nation's wildest, undeveloped national forest lands from destructive road building and commercial logging. These remote backcountry areas are critical for preserving clean drinking water for millions of Americans, maintaining unfragmented wildlife habitats, supporting climate resilience, and offering world-class outdoor recreation that holds up our economy. One such area that has been afforded protection by the Roadless Rule is Washington Pass, just East of the North Cascades National Park. As a hiker, climber, biker, and skier, I have ventured to the Pass in all four seasons to enjoy the beauty of the wild space. Whether scaling the rock faces of the Liberty Bell spire group, or feeling the soaring elation of a ski descent from Silver Star Mountain, the pristine beauty of this place brings joy and fulfillment to my life. Our protection of it for future generations is an embodiment of our values - to recognize, appreciate, and protect the land that imbues our lives with vitality and meaning. Dismantling these nationwide protections and shifting management to local, fragmented plans will put fragile ecosystems at risk, increase the agency's existing multibillion-dollar road maintenance backlog, and fail to address the root causes of severe wildfires. Rather than moving forward with this deregulatory repeal, the Forest Service must select the "No Action Alternative" and preserve existing national roadless protections intact. Thank you for considering my comments. Sincerely, Jake Mutter

I oppose the repeal of the Roadless Area Conservation Rule (Alternative 2 of the Draft Environmental Impact Statement). The Roadless Rule should remain in place. As a recreational user of the National Forests in Washington, Oregon, California, Idaho, Montana, Wyoming, and Colorado, I can say that the value of forests and undisturbed land for the millions of recreational users is beyond measure. The outdoor industry generates $730 billion annually. This is far more than any timber sales would generate. The US Forest Service already has 370,000 miles of roads and is increasingly unable to manage and maintain the existing roads. The maintenance backlog continues to grow. Wildfires are increasingly common in the West as drought continues and climate change impacts forests. Roadless areas are NOT more prone to fire. 88% of wildfires occur within .5 miles of a road. Additional roads will lead to more fires. These roads would accelerate climate change in that 20% of all carbon in the U.S. national forests is in the roadless areas. As an avid hiker, I know well many of the areas that would be impacted by this senseless change. Earlier this spring, I took three separate day hikes in the Teanaway Roadless Area northeast of Cle Elum, Washington. Earl Peak and Bean Creek Basin were closed because of fires from the year before. How can we bear more damage to this valley. As a frequent user of the Pacific Crest National Scenic Trail, I know that Grasshopper Meadows and Tatie Peak in the North Cascades/Pasayten Liberty Bell Roadless Area would be ruined by further roadbuilding. The Norse Peak Roadless Area near Crystal Mountain and Mount Rainier is another area we frequent-- these are beautiful places close to a major metropolitan area-- American citizens, forests, and wildlife deserve to have areas free of roads. These areas provide critical habitat for many species of plants and animals, and are critical to our nation’s ecological health, not to mention watersheds of drinking water for over 60 million people. Rescinding the Roadless Rule would affect 11% of the Pacific Crest National Scenic Trail in areas adjacent to it. Roadless areas offer abundant outdoor recreation opportunities such as hiking, hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. Rescinding the Roadless Rule is wrong in every possible way.