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I am writing to oppose the proposed partial or full recission of the Roadless Area Conservation Rule, which has protected our wild, roadless areas for a quarter of a century. As a resident of Oregon, I hike, camp, bird, and find immeasurable refreshment in roadless areas that could be adversely affected by such a recission. These areas include Larch Mountain in the Columbia Gorge (where I have seen many Great Horned Owls and Common Nighthawks), the Salmon River Trail in the Mt. Hood National Forest (which I hike with friends at least half a dozen times a year), and Lookout Mountain (the highest peak in the Ochoco Mountains of central Oregon and a thrilling, wild hike. But while I am concerned about the future of roadless areas I know and love, that concern extends to the almost 45 million acres of public land nationwide that could be affected. The actions proposed under this recission would, according to the Administration's DEIS, "adversely afffect" 327 endangered or threatened species and 71 critical habitats. But these wild areas are not just crucial habitat for the wildlife that is facing stressful conditions across the board. They also help to purify our water and air, and they provide first-class opportunities for recreation and relaxation in nature. Opening them to road-building, logging, and other forms of commercial development would damage them in ways that could not be repaired. Opening these roadless areas to road-building does not make environmental sense. Nor does it make economic sense. Road-building is costly and would add to the backlog of deferred maintenance, which is already nearly $7 billion. The public is being told that road-building is needed to combat the risk of wildfires. Not true. The Administation itself has said, "“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.” An article on fire ecology published in January 2026 examined three decades of data and found that fires are four times more likely to start near roads than in roadless areas. The Administration's DEIS also stated that road-building and increased logging will “introduce and spread invasive plant species due to ground disturbance.” Invasive plants are another factor that contributes to wildfires. “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations," says the Administration's DEIS, "and sediment delivered to surface waters is a major source of water quality degradation.” In addition to costing communities near roadless areas millions of dollars in lost revenue as recreational areas are degraded, rescinding the Roadless Area Conservation Rule would imperil the clean drinking water of communities such as LaGrande and Ashland here in my home state, and many other communities elsewhere. I urge the Forest Service to keep the Roadless Area Conservation Rule in full force. Thank you for your time and attention. Rebecca Stefoff, Portland, Oregon

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.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Lookout Mountain area of the Ochoco National Forest is the kind of place that stays with you. I have been going there for years, riding the Lookout Mountain trails, searching for elk, raptors, and songbirds in contiguous habitat like the Deschutes and Paulina Roadless Areas, and finding in all of it what I can rarely find elsewhere: a chance to unwind and slow down. The raw nature of the landscape and trails is what draws me back. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) because the roadless character of these places is not incidental to what they offer. It is the whole point. The elk I look for in the Deschutes and Paulina Roadless Areas depend on conditions that roads destroy. The agency's own analysis acknowledges that elk survival rates rose during a road closure and fell again when the gates were removed, and that unroaded land with cover and forage constitutes ideal summer elk habitat. The bird richness I seek in this contiguous habitat is equally at stake. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. These are not projections about distant forests. They describe the conditions I go to the Ochoco and Deschutes to find. I ask the agency to explain what analysis supports the conclusion that opening these areas to road construction would leave wildlife-dependent recreation intact. The agency defends this rescission partly on wildfire grounds, but its 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. The agency must reconcile the rescission with those findings and explain why the proposal departs from its own prior analysis of fire occurrence and fuel treatment in the areas the rule currently protects. On economics: the agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Its own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. The agency has not shown how expanding that system, at marginal commodity gains its own numbers cannot confirm as net positive, serves the public interest. It should answer that question plainly before moving forward. Finally, the small-business certification in the supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading estimated losses across every small firm in the affected sector nationally, rather than examining the outfitters, guides, and tour operators actually holding permits in the affected areas. The DEIS names those operators as affected, and the agency's own Cost Benefit Analysis books their recreation losses at a minimum of $6.1 million a year. A methodology that dissolves real, localized harm into a national average does not satisfy the purpose of the certification requirement. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas, including those on the Ochoco and Deschutes National Forests where I ride and watch for wildlife. The Deschutes holds 11 inventoried roadless areas totaling 136,446 acres. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. These are not abstract figures. They represent the contiguous, unroaded habitat that makes the wildlife and the experience I described possible. The agency should protect them. Sincerely, Mike Schmeiske Bend, OR

The Roadless Rule as pertains to our public lands among our USFS territories needs to remain in force. Please read and think about my family's reasons to keep this understanding of our watersheds, open spaces for wildlife and so much more. East Cascades Bird Alliance works to educate us about birdlife in our Central Oregon area. And protect it. This June I and others spent a day traipsing around acres and acres of USFS lands with Bird Alliance, leader, Chuck Gates. He is a retired Crook County public school biology teacher. This day is a prime example of how hiking way beyond parking lots (there were none; just roadsides stretching into roadless areas or within close viewing range of No Roads. This Roadless Rule elimination plan would basically eliminate our beloved tradition being passed on to grandkids who are already your Admin voters… 4 generations of Hensons who feel commited to many parts of our state's public lands. Here are the main geographic areas: The Rogue River/ Siskiyou NF and The Umptqua NF when we previously lived in Roseburg Boundaries of Crater Lake NP and the Park itself. Entire coastal area not protected by our State Parks that often border NForests. We visit the coast often. And there is the Strawberry Lakes region in E. Oregon and surrounding forests! And the Wallowas...! Just in Central Oregon, we highlight some truly beautiful and ecologically necessary places, in the areas around: Steelhead Falls, the Metolius River, Three Creeks Lake, Tam McArthur Rim, Paulina Lake, Kwolh Butte, Maiden Peak, Green Mountain, Lookout Mountain and more. There are close to 200,000 acres in Central Oregon of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland. These areas have protected wildlife habitat, boosted the economies through both outdoor recreation and high quality of life, and ensured clean drinking water for nearly 25 years. Pushing roads into these unspoiled places would change Central Oregon forever. Let’s do everything we can to ensure our forests remain wild, healthy, and resilient—for people, wildlife, and future generations. Despite hearing from over 600,000 Americans opposed to the rollback—99% of all comments received—the USDA released details as to how it plans to axe the Roadless Rule. I urge you to choose the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Sincerely, with watchful diligent eyes, Annis Henson 2399 NW Hosmer Lake Dr. Bend OR 97703 Annis Henson Bend, OR

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This reckless action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in Bend, Oregon and spend time recreating in nearby Roadless Areas like Tumalo Mountain, the Cascade Lakes, Lookout Mountain in the Ochoco National Forest, and North and South Paulina in the Newberry Caldera. I also visit other Roadless Areas across Oregon to hike, camp, fish, forage, and enjoy nature. The Tumalo Mountain Roadless Area is especially important to me because it protects my community’s drinking watershed at Bridge Creek. Under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections, including the ones I listed above. The economics of these attacks on the Roadless Rule simply do not add up. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely, if ever, used. According to the DEIS, the Forest Service could build new roads across 18.2 million acres (44.5% of current IRAs) in the short term. This would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion according to the DEIS. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. Beyond the economic folly, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and serve as critical carbon sinks in the fight against climate change. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In Oregon, this includes listed species such as Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet, Northern spotted owl, Oregon silverspot butterfly, Oregon spotted frog, Sierra Nevada red fox, and steelhead, among others. How would the agency ensure these populations and their habitats aren’t further degraded without protection of the Roadless Rule? The DEIS also states that “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” Bend, Oregon has exceptional water quality, largely due to the protections of the surrounding Tumalo Mountain - Bend Watershed Roadless Area. This Roadless Area would lose protections under both Alternatives 2 and 3. Other communities in Oregon like Eugene, Ashland, and La Grande would also lose protections to their drinking watersheds. How would the agency ensure that these watersheds remain intact and that water sources are not compromised from increased risk of erosion and sedimentation? Once roads and clearcuts fragment these landscapes, the damage is permanent.

Why are you ignoring 99% of the comments on this proposed rule weakening protection for roadless areas? I write to you once again to protest this proposed rule change. At risk are some truly beautiful and ecologically vital places in Central Oregon, for example: Steelhead Falls, the Metolius River, Three Creeks Lake, Tam McArthur Rim, Paulina Lake, Maiden Peak and Lookout Mountain. Stop ignoring those of us who live here. Lee Lucas

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My family explores the Cascade corridor from Mount Baker to the Sierra. We paddle lakes, rivers and streams. We photograph everything we encounter on our adventures. We visit for the beauty, peacefulness, uninterrupted landscapes, and the flora and fauna. A road is noise and sight pollution to ALL! I oppose rescinding the 2001 Roadless Area Conservation Rule. We have visited Rock Creek in the Ochoco National Forest and its beautiful watershed. We explore South Paulina in the Deschutes National Forest for the beauty. We have hiked Lookout Mountain, since the early 2000s. North Paulina is beautiful, and our family has enjoyed exploring it for years. The birding at Green Mountain is phenomenal, and would be devastating to lose those creatures. Silver Creek is good therapy near a heavier population, and that matters too. These places shelter bears, elk, and deer. On elk, the agency's own cited research found that elk survival rates rose during a road closure and fell again when the gates were removed. Elk avoid areas near roads and the agency's own analysis says ideal summer elk habitat is unroaded land with cover and forage. On deer, the agency's own record cites research finding that roads built for extraction may have altered mule deer migration routes and increased their movement speed. Roads disrupt migration and eliminate the unroaded security deer depend on. On bears, the agency's own citation from the federal grizzly recovery plan states that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. I ask that the agency explain in this docket how rescinding the rule can be squared with each of those specific findings in its own record. The agency's own record states 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 invokes wildfire and fuels management as a reason to rescind. That reasoning contradicts the agency's own ignition data. The agency must explain why it departs from those findings and reconcile this proposal with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I am also not persuaded that the economics favor this action. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency should reconcile the proposal with its own cost-benefit analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog makes sense when the existing roads already need fixing. Why not pay to fix the current roads and avoid more debt? Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Preserving these fragile ecosystems is necessary for clean water in our future. The agency must answer, directly and specifically, how rescission protects drinking water downstream from the roadless areas we have walked and paddled. The agency has already tried replacing this national rule with a state-by-state approach. Its own record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected that approach. The agency must explain how this proposal avoids the same deficiencies. On the question of statutory authority, the Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that holding and state the basis for any contrary position it now takes. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Future generations should not inherit fewer of these places than we did. Public land should be a safe and sheltered place from human exploitation. These places should be kept whole.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Growing up on the East Coast, I had no real sense of what public lands could be until I lived in Oregon for a year. Hiking and camping in roadless areas of the Deschutes and Ochoco National Forests, places like Lookout Mountain, Tumalo Mountain, Green Mountain, and Cascade Lakes, showed me what it means to have natural spaces where dispersed recreation is inevitable and prevents the overburdening of human activity. Beyond hiking and camping, Roadless Areas help protect the availability and quality of places I love to paddle too, including many alpine lakes and Wild and Scenic Rivers, like the Rogue, the Crooked, and the Deschutes. I want to return to these places someday with my children, so they can experience the reward of navigating into the wilderness without the convenience of destructive roads. Repealing the Roadless Rule will take us multiple steps back from my vision of natural spaces and world with more wildlife and biodiversity, improved water and air quality, and a more stable climate for future generations. I oppose rescission for the reasons that follow. The agency's small-business analysis cannot be squared with its own cost figures. "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 conclusion is reached by spreading the 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 Deschutes alone holds 11 inventoried roadless areas totaling 136,446 acres, and Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The operators whose livelihoods depend on those specific landscapes are the ones the analysis should assess. I ask that the agency withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency has also invited comment on reliance interests and then declined to weigh them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. I built expectations around these places, and around the idea of returning to them with my children, on the reasonable assumption that the protections the rule provides would hold. An agency changing course is obliged to identify and weigh the reliance interests its prior policy created. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire data argues against the proposal. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The Deschutes supports federally threatened bull trout, Oregon spotted frog, northern spotted owl, white-headed woodpecker, redband trout, and elk, all species whose habitat a surge in human-caused fire could degrade. The effects analysis concedes that road access could increase the number and frequency of wildfires, yet projects no numbers from that concession. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against whatever wildfire hazard reduction it claims to offer. Water is the issue that closes this letter, because Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The document the agency relies upon 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 record. No projection of what it means for downstream intakes follows it. The agency has not told the public what sediment load those intakes should expect if roadless protections are lifted. That omission is not a minor gap. The agency must quantify projected sediment delivery to the municipal intakes downstream of these areas before this proposal advances any further. Sincerely, Taylor Wilkie Warsaw, NY

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 Hiking and paddling through the forests of central Oregon, watching for bald eagles and foxes, has shaped how I think about what public land is for. I hike at Lookout Mountain in the Ochoco National Forest, which covers 14,115 acres of some of my favorite terrain in the state. I hike and backpack at Rock Creek, another 11,396 acres in the Ochoco. I love hiking at South Paulina and North Paulina in the Deschutes National Forest, 9,074 and 19,670 acres respectively, and I regard Silver Creek and Green Mountain in the Ochoco as areas we simply cannot lose. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to respond to the points below. The agency's own record undermines the wildfire rationale for this proposal. The draft environmental impact statement 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 forests where I hike, including the Ochoco and the Deschutes, contain inventoried roadless areas whose lower fire density is consistent with that finding. The Deschutes alone holds 11 inventoried roadless areas totaling 136,446 acres, and Oregon statewide holds 211 inventoried roadless areas totaling 1,937,741 acres. Opening these landscapes to roads in the name of fuels management contradicts the agency's own data. I ask the agency to explain why this proposal departs from its prior findings on fire occurrence and to reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally unsupported by the record. The agency's own analysis states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Balanced against that marginal supply contribution, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, a range so wide it cannot establish a net benefit. The road system already carries a $6.9 billion maintenance backlog. Across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, and the Deschutes is among them. I paddle and backpack in these forests because they are intact. Degrading the watersheds that supply them does not pencil out. The agency must reconcile this proposal with an economic record that fails to demonstrate net public benefit before adding further infrastructure liability. The proposal argues that state-by-state approaches can substitute for a national rule, but the agency has tried that before and a federal court rejected it. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit nonetheless reinstated the national rule, having found that local and incremental decision-making could erode nationally significant roadless values in ways a patchwork approach could not prevent. This proposal follows the same structural logic the circuit already examined. The agency must address how this rescission avoids the deficiencies the Ninth Circuit identified the last time it tried replacing the national rule with a state-by-state framework. Finally, the statutory authority argument does not hold. The Tenth Circuit resolved this question directly: "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 that the 2001 rule fell within authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The proposal does not adequately engage that holding. The agency must explain the legal basis for any position contrary to the Tenth Circuit's reasoning, and it must do so with specificity sufficient for meaningful public review. Silver Creek is crucial to protect. Green Mountain is wilderness we cannot afford to lose. I ask this agency to keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Sydney Livingston

I am writing to oppose the proposed rescission of the Roadless Rule. I am a senior who has hiked all over the PNW, including roadless areas, and a mother who raised a son who hikes and backpacks in roadless areas. Most importantly, I am a public lands owner, a taxpayer who believes it is my responsibility to protect public lands. I live in the PNW, surrounded by thousands of acres of roadless areas. I have hiked into some, but enjoyed many from a distance. Each summer, I hike the trail on Lookout Mountain in Oregon and eat lunch while looking over the Badger Creek roadless area: forested mountain foothills dotted with occasional lakes. I regularly hike trails in the Gifford Pinchot National Forest that offer views of roadless areas. I live in a rural community, and many of the parcels around my five acres are privately owned by forest products companies and have been clear-cut. I have witnessed the complete destruction of forests multiple times. After timber corporations remove the dead trees from the razed forest, they spray the entire parcel with a toxic herbicide before planting Douglas Fir seedlings (the preferred species for commercial harvesting in the PNW) in rows, creating a tree plantation where a forest once stood. Twelve years later, those trees are growing, along with a few native species (elderberry, Oregon grape, gooseberry, yarrow). No shrub understory, no wildflowers, no orchids, no visible fungi, and no birds or animals. Aside from the trees, it is a dead zone; a tree plantation. The timber corporation will return in four decades to cut the trees, poison the land, and replant the plantation. Every day I walk a road bordered by clear-cuts, and the lack of other species weighs on my soul. Millions of birds have already disappeared because of habitat loss; insects, butterflies, and bees lose habitat and are poisoned by toxic herbicides. I lost two beehives because of the herbicides used on nearby clear-cuts. Forests are critical to our planet's health and the survival of its many species. I have created a list of why roadless areas matter. 1) Trees serve humanity every day: they regulate the atmosphere and oceans, hold ancient medicines for healing, inspire awe and wonder, teach us new things about life and living, model collaboration and connection, and stabilize and cool the planet. 2) Forests are major carbon sinks: they sequester carbon dioxide from the atmosphere, absorbing greenhouse gas emissions from the burning of fossil fuels. Deforestation is a major contributor to climate change and increases the risk and intensity of natural disasters. 3) When sustainably managed, forests provide food, medicine, shelter, jobs, and fuel for billions of people. Most importantly, we live because they provide oxygen. 4) Forests help build and nourish soil and prevent erosion. 5) Forests slow down the movement of water, preventing landslides & floods. 6) Forests play a major role in the water cycle and help maintain water quality by filtering out toxic pollution. 7) Forests are living systems that provide habitats for 80% of land-based species. Roads fragment habitats, which impacts wildlife. 8) Habitat loss is a major cause of biodiversity loss. 9) Recreational tourism dollars sustain rural communities; extractive dollars are a boom-and-bust economy. Once the trees are cut, the corporations move on. 10) Road building will increase wildfire risk (even the feds acknowledge this) and invasive species. National forests already have a huge maintenance backlog for Forest Service roads. The most important issue is the lack of concern for the inherent biodiversity of wild forests. Our God-given purpose is to steward life on this planet, ensuring that animal and plant species have a habitat to live in. Public lands belong to the public, not private corporations that rape the land and move on to the next parcel, caring little about ecosystems and rural communities. Don't sell out our forests and grasslands to international corporations that couldn't care less about life. Their entire business model is based on destruction and death.

Several times a week I am out hiking on public lands, and many times I am also backpacking or camping. I ride trails in the Ochoco National Forest and the Deschutes National Forest, and I have been backcountry skiing in both forests for decades. The quiet covering of snow, the contrast it brings to the trees and rocks and vistas, the physical oneness and spiritual peace that come from wild nature: these are things I can only experience by walking away from the disturbance that roads bring to the landscape. The solitude I find near Lookout Mountain and throughout the Ochoco National Forest is not incidental to these visits. It is the point. This proposed rescission of the 2001 Roadless Area Conservation Rule would place that directly at risk, and the agency's own documents reveal serious analytical gaps it must address before proceeding. The Recreation and Scenery section of the environmental review documents that, as stated in Table 41, "The majority (90 percent) of the potentially affected IRAs are either primitive, semi-primitive non-motorized, or semi-primitive motorized recreation settings." The document also shows that national forests containing inventoried roadless areas receive the large majority of total annual National Forest System visits and that substantial visitor expenditures flow to surrounding communities. Yet the purpose and need statement does not weigh any reduced regulatory burden against the risk of degrading precisely the primitive and semi-primitive character that draws those visitors and supports that economy. The agency eliminated from detailed study any alternative that retains roadless protections to preserve recreation values, calling such alternatives non-responsive to the stated purpose. That reasoning is circular. The agency must explain in the final environmental impact statement how many primitive and semi-primitive acres are projected to shift to roaded or developed recreation opportunity spectrum classes under each action alternative over time, and what economic effect that shift carries for recreation-dependent communities adjacent to these forests. The agency uses wildfire risk as a central rationale for rescission, but its own fire data, set out at Table 26, states: "Nationally, 23.5 percent of NFS road length that interacted with wildfires was associated with successful containment." The agency further acknowledges that most new road construction under the action alternatives would consist of temporary spur roads built for timber harvest rather than strategically located, maintenance-ready roads designed for fire suppression. The gap between those two facts is never closed. The agency has not quantified how many lane-miles of permanent, higher-standard roads would realistically be built or funded specifically for fire control under each alternative, nor what those roads would cost. Without that analysis, the fire-control rationale rests on an assumption the document itself does not support. The agency should provide a site-specific or regional breakdown showing projected permanent road construction for fire suppression purposes under each alternative, with associated costs. The Roads section and Figure 6 disclose that appropriated funding for the National Forest System road network "has declined by almost 70 percent over the last twenty years," falling to $73 million in 2024 against an estimated $1.6 billion annual need, with a deferred maintenance backlog of $6.9 billion already accumulated on existing roads. The action alternatives would increase permanent road mileage and expand that deferred maintenance liability further. The document does not quantify the additional annual maintenance obligation that new roads under alternatives 2 and 3 would create, and it does not identify any specific funding stream, whether appropriated or derived from timber receipts, sufficient to cover those costs. Building roads the agency cannot afford to maintain does not serve the public lands I use or the watershed values I depend on. Before any final rule is issued, the agency must provide a fiscal analysis projecting the annual maintenance cost of new roads under each alternative and demonstrate how those costs would be funded.

Public Comment: In Support of Retaining the 2001 Roadless Area Conservation Rule To: U.S. Department of Agriculture / U.S. Forest Service Re: Proposed rescission of the 2001 Roadless Area Conservation Rule From: Scott Emry, Oregon resident I am writing as an Oregonian to urge the Forest Service to withdraw its proposal to rescind the 2001 Roadless Area Conservation Rule and to keep this rule fully in place. Why this matters to Oregon specifically: The Roadless Rule protects nearly 2 million acres of national forest land in Oregon — places like Iron Mountain in the Willamette National Forest, Joseph Canyon in Wallowa County, Tumalo Mountain in Central Oregon, and Lookout Mountain in the Ochoco National Forest. In Central Oregon alone, roughly 200,000 acres would be affected, including about 137,000 acres in the Deschutes National Forest and 61,000 acres in the Ochoco National Forest and Crooked River National Grasslands. These are the backcountry areas around the Cascade Lakes Scenic Byway, Mt. Bachelor, and Mt. Hood that Oregonians hunt, fish, hike, and draw drinking water from. The facts supporting the rule: 1. Scale and process: The rule protects 58.5 million acres of national forest nationwide — roughly a third of the entire National Forest System — and was the product of one of the most extensive public rulemaking processes in U.S. history: 600 public hearings and over 1.6 million public comments were submitted before it was finalized in January 2001. 2. Legal durability: The rule survived over a decade of litigation. In October 2012, the U.S. Supreme Court declined to hear a mining industry appeal after lower courts upheld the rule, cementing it as settled law. 3. Drinking water protection: Undeveloped, unroaded forest headwaters supply drinking water to tens of millions of Americans downstream. Roads and logging in these areas increase sedimentation and erosion that degrade water quality; keeping these areas roadless protects that water at the source. 4. Wildfire and road-maintenance costs: The Forest Service already carries a multi-billion-dollar backlog of deferred maintenance on its existing road system. Building new roads into currently intact forest adds long-term maintenance liabilities and, contrary to some claims, new roads are also a documented vector for human-caused ignitions, since most wildfires start near roads and points of human access. 5. Recreation access is preserved, not reduced: The rule does not close any existing road or trail. Hunting, fishing, hiking, camping, and other dispersed recreation remain fully allowed. Oregon's outdoor recreation economy — a significant contributor to the state's GDP and rural employment — depends on the continued existence of large, intact backcountry areas rather than roaded, developed landscapes. 6. Broad, sustained public and political support: In 2025–2026, more than 600,000 public comments were submitted in response to the current proposal to rescind the rule, with the large majority opposed to weakening it. In Congress, Oregon's own delegation has been active on this issue — Rep. Andrea Salinas introduced the Roadless Area Conservation Act to codify the rule into permanent law, and Sen. Ron Wyden has pushed to preserve it in committee votes. My request: Please withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule in full, without state-by-state carve-outs or weakening amendments. Oregon's roadless forests are irreplaceable sources of clean water, wildlife habitat, and recreation opportunity, and the rule protecting them has already withstood the most rigorous public and legal scrutiny of any forest policy in modern history. Thank you for considering my comment. Scott Emry Salem, Oregon September, 16, 2026

Secretary Rollins: In Central Oregon, we have almost 200,000 acres of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland have protected wildlife habitat, boosted local economies, and ensured clean drinking water for 25 years. From protecting recreational opportunities in Newberry Caldera, to safeguarding sweeping views atop Lookout Mountain in the Ochocos, to maintaining mule deer and elk migration corridors in the Metolius Basin, the Roadless Rule is vital to our local communities. I STRONGLY OPPOSE THE USDA’S PROPOSAL to eliminate, alter, or weaken the Roadless Rule, which would reduce protections across 44.7 million acres of public lands managed by the US Forest Service nationwide. The agency should select Alternative 1, the No Action alternative, and leave current roadless protections in place. Rescinding the Roadless Rule is not practical. The USFS already has billions of dollars in deferred maintenance on its existing 370,000+ miles of roads, and this rule rescission will only compound the problem by adding expensive, infrequently used backcountry roads on the taxpayers’ dime. Worse still, in areas like Central Oregon, where the timber industry has been in decline for decades, opening roadless areas to logging will not yield a meaningful economic return. Instead, increasing roads will damage recreation areas, scenic views, and wildlife habitat, and eliminate the core reasons people choose to live, work, and play in Central Oregon. I am very opposed to the the elimination of the roadless rule, which protects so much important land in our area Laurel Francis Bend, Oregon

Hello, I am very concerned about the possible repeal of the Roadless Rule. The Roadless Rule was adopted in 2001. It preserves many of the last undeveloped areas of public lands as a home for wildlife, havens for quiet recreation, drinking water sources, and permanent protection of these sensitive areas for current and future generations of our children. It is a critical part of our country's legacy of protecting open space, protecting nearly two million acres of Oregon’s public forests and nearly 45 million acres nationwide from logging, road building, and destructive extractive practices. Opening up protected areas seems to me to be a direct "gift" to corporations that are only concerned about profits. We need to stop putting a monetary value on everything in this country. The value of many things cannot be quantified monetarily. Some things should be allowed to just exist. God created this world and it is wrong to just extract profit from resources such as our land, water, trees, and wildlife. Some things should be left alone. Humans cannot survive in a world that no longer has open space, clean water, trees to balance the carbon cycle in ecosystems, and wildlife. Remember this. Humans cannot exist without nature. Rolling back the Roadless Rule puts some of Oregon’s most iconic places at risk: Larch Mountain in the Columbia River Gorge, Tumalo Mountain outside of Bend, Lookout Mountain in the heart of Oregon, the forests around Lost Lake on Mount Hood, Hardesty Mountain east of Eugene, sections of the Pacific Crest Trail near Waldo Lake, the Oregon Dunes, and many more special places throughout the Cascadia bioregion and beyond. When roads are carved into these areas, they fragment wildlife habitat, spread invasive species, increase wildfire risk, hinder recreation opportunities, introduce noise, and literally pave the way for industrial logging and mining activities to degrade these last wild public forests. We need to be mindful of protecting this earth. God wants us to steward our natural resources in a balanced manner. We already have all of the resources we need. We need to recycle what we have extracted already. We need to protect at least half of the world from development (we are nearing this at the moment.) We cannot continue to take and take - we need to balance what we have already taken and extracted with preserving what is left untouched by humans. If we do not do this, we are hastening the end of life on earth. There is no such thing as unlimited growth. We need to now start recycling and protecting. Do not forget this. These are important decisions. What is more important - money or life? Please protect these areas, as they have been protected since 2001. This is what our citizens want. Listen to citizens over corporate demands. Thank you.

This is horrifying! In Central Oregon, we have almost 200,000 acres of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland have protected wildlife habitat, boosted local economies, and ensured clean drinking water for 25 years. From protecting recreational opportunities in Newberry Caldera, to safeguarding sweeping views atop Lookout Mountain in the Ochocos, to maintaining mule deer and elk migration corridors in the Metolius Basin, the Roadless Rule is vital to our local communities. I STRONGLY OPPOSE THE USDA’S PROPOSAL to eliminate, alter, or weaken the Roadless Rule, which would reduce protections across 44.7 million acres of public lands managed by the US Forest Service nationwide. The agency should select Alternative 1, the No Action alternative, and leave current roadless protections in place. Rescinding the Roadless Rule is not practical. The USFS already has billions of dollars in deferred maintenance on its existing 370,000+ miles of roads, and this rule rescission will only compound the problem by adding expensive, infrequently used backcountry roads on the taxpayers’ dime. Worse still, in areas like Central Oregon, where the timber industry has been in decline for decades, opening roadless areas to logging will not yield a meaningful economic return. Instead, increasing roads will damage recreation areas, scenic views, and wildlife habitat, and eliminate the core reasons people choose to live, work, and play in Central Oregon. Rescinding the Roadless Rule is also dangerous. More roads also mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas is dangerous, costly, and diverts resources from protecting communities. More roads will also degrade drinking watersheds. National Forests and Grasslands are the single most important source of municipal water supply in the United States, and Roadless Areas filter drinking water for over 2 million Oregonians. In Central Oregon, the Bend Municipal Watershed begins in the headwaters of Bridge Creek and Tumalo Creek in the Deschutes National Forest. Losing Roadless protections will threaten water quality for fish species and the drinking water supply for more than 100,000 people in Bend, and tens of millions of people across the country. And, rescinding the Roadless Rule makes our forests less resilient. Roads spread invasive species, disrupt wildlife corridors, and erode forest resilience in the face of rapidly shifting wildfire regimes. Logging these roadless forests would also directly eliminate overstory and understory habitats, harm First Foods, and reduce the carbon storage we need to combat climate change.

Secretary Rollins: In Central Oregon, we have almost 200,000 acres of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland have protected wildlife habitat, boosted local economies, and ensured clean drinking water for 25 years. From protecting recreational opportunities in Newberry Caldera, to safeguarding sweeping views atop Lookout Mountain in the Ochocos, to maintaining mule deer and elk migration corridors in the Metolius Basin, the Roadless Rule is vital to our local communities. I STRONGLY OPPOSE THE USDA’S PROPOSAL to eliminate, alter, or weaken the Roadless Rule, which would reduce protections across 44.7 million acres of public lands managed by the US Forest Service nationwide. The agency should select Alternative 1, the No Action alternative, and leave current roadless protections in place. Rescinding the Roadless Rule is not practical. The USFS already has billions of dollars in deferred maintenance on its existing 370,000+ miles of roads, and this rule rescission will only compound the problem by adding expensive, infrequently used backcountry roads on the taxpayers’ dime. Worse still, in areas like Central Oregon, where the timber industry has been in decline for decades, opening roadless areas to logging will not yield a meaningful economic return. Instead, increasing roads will damage recreation areas, scenic views, and wildlife habitat, and eliminate the core reasons people choose to live, work, and play in Central Oregon. Rescinding the Roadless Rule is also dangerous. More roads also mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas is dangerous, costly, and diverts resources from protecting communities. More roads will also degrade drinking watersheds. National Forests and Grasslands are the single most important source of municipal water supply in the United States, and Roadless Areas filter drinking water for over 2 million Oregonians. In Central Oregon, the Bend Municipal Watershed begins in the headwaters of Bridge Creek and Tumalo Creek in the Deschutes National Forest. Losing Roadless protections will threaten water quality for fish species and the drinking water supply for more than 100,000 people in Bend, and tens of millions of people across the country. And, rescinding the Roadless Rule makes our forests less resilient. Roads spread invasive species, disrupt wildlife corridors, and erode forest resilience in the face of rapidly shifting wildfire regimes. Logging these roadless forests would also directly eliminate overstory and understory habitats, harm First Foods, and reduce the carbon storage we need to combat climate change. This rescission would not, as the DEIS claims, restore the decision-making power of our local forest managers. Instead, as the DEIS expressly admits, it would further the misguided goal of ramping up timber production on public lands while disempowering the Forest Service staff and Central Oregonians who care for these roadless areas. Sacrificing our local values for short-term logging profits is not sound policy; it is a net loss for communities, economies, and future generations. Roadless forests represent some of the most intact, resilient ecosystems left in our country, but once roads and clearcuts fragment our landscapes, the damage is permanent. Despite the clear consequences of rescission and the vocal majority opposing the Proposed Rule, the USDA continues this rollback through an abridged and inadequate public comment process. The original Roadless Rule resulted from the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. Now, the agency is attempting to dismantle these protections with zero public meetings, shortened comment periods, and a disregard for the public input received during scoping. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Weakening or repealing it would be a grave mistake. Both Alternatives 2 and 3 will have severe consequences for wildlife, biodiversity, clean water sources, climate resilience, cultural resources, local economies, outdoor recreation, and the health of our nation's wildest forests. The USDA should abandon this damaging effort and instead strengthen its commitment to protecting the clean water, climate resilience, recreation, and biodiversity that roadless forests provide. I urge the agency to take the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Sincerely, Matt Kelly

Secretary Rollins: Please take all the letters and comments you have received as a message for what we want to see as far as this initiate you are trying to push through. Regardless of all these responses you have received, it seems you're going ahead with your own agenda and not what the people want. It isn't your wilderness to do with as you want. It is OURS. Please do what we ask!!!!!!!!! In Central Oregon, we have almost 200,000 acres of Inventoried Roadless Areas in the Deschutes National Forest, Ochoco National Forest, and Crooked River National Grassland have protected wildlife habitat, boosted local economies, and ensured clean drinking water for 25 years. From protecting recreational opportunities in Newberry Caldera, to safeguarding sweeping views atop Lookout Mountain in the Ochocos, to maintaining mule deer and elk migration corridors in the Metolius Basin, the Roadless Rule is vital to our local communities. I STRONGLY OPPOSE THE USDA’S PROPOSAL to eliminate, alter, or weaken the Roadless Rule, which would reduce protections across 44.7 million acres of public lands managed by the US Forest Service nationwide. The agency should select Alternative 1, the No Action alternative, and leave current roadless protections in place. Rescinding the Roadless Rule is not practical. The USFS already has billions of dollars in deferred maintenance on its existing 370,000+ miles of roads, and this rule rescission will only compound the problem by adding expensive, infrequently used backcountry roads on the taxpayers’ dime. Worse still, in areas like Central Oregon, where the timber industry has been in decline for decades, opening roadless areas to logging will not yield a meaningful economic return. Instead, increasing roads will damage recreation areas, scenic views, and wildlife habitat, and eliminate the core reasons people choose to live, work, and play in Central Oregon. Rescinding the Roadless Rule is also dangerous. More roads also mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas is dangerous, costly, and diverts resources from protecting communities. More roads will also degrade drinking watersheds. National Forests and Grasslands are the single most important source of municipal water supply in the United States, and Roadless Areas filter drinking water for over 2 million Oregonians. In Central Oregon, the Bend Municipal Watershed begins in the headwaters of Bridge Creek and Tumalo Creek in the Deschutes National Forest. Losing Roadless protections will threaten water quality for fish species and the drinking water supply for more than 100,000 people in Bend, and tens of millions of people across the country. And, rescinding the Roadless Rule makes our forests less resilient. Roads spread invasive species, disrupt wildlife corridors, and erode forest resilience in the face of rapidly shifting wildfire regimes. Logging these roadless forests would also directly eliminate overstory and understory habitats, harm First Foods, and reduce the carbon storage we need to combat climate change. This rescission would not, as the DEIS claims, restore the decision-making power of our local forest managers. Instead, as the DEIS expressly admits, it would further the misguided goal of ramping up timber production on public lands while disempowering the Forest Service staff and Central Oregonians who care for these roadless areas. Sacrificing our local values for short-term logging profits is not sound policy; it is a net loss for communities, economies, and future generations. Roadless forests represent some of the most intact, resilient ecosystems left in our country, but once roads and clearcuts fragment our landscapes, the damage is permanent. Despite the clear consequences of rescission and the vocal majority opposing the Proposed Rule, the USDA continues this rollback through an abridged and inadequate public comment process. The original Roadless Rule resulted from the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. Now, the agency is attempting to dismantle these protections with zero public meetings, shortened comment periods, and a disregard for the public input received during scoping. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Weakening or repealing it would be a grave mistake. Sincerely, Mary Becker Bend resident for over 35 years

**Position:** Oppose. Select the no-action alternative and retain the 2001 Roadless Area Conservation Rule. --- I ski, hike, and recreate in the National Forest Service around the Deschutes and Ochoco year-round. I oppose the USDA's proposal to rescind the 2001 Roadless Rule, and I urge the agency to select the No Action alternative and keep these protections fully in place. Nearly 200,000 acres of Inventoried Roadless Areas sit in the Deschutes National Forest, the Ochoco National Forest, and the Crooked River National Grassland. For years they have held wildlife habitat, clean water, and the recreation that Central Oregon's economy actually runs on. Rescinding the Roadless Rule is unnecessary. The 2001 rule already permits timber cutting in roadless areas to reduce uncharacteristic wildfire risk and restore forest structure. The agency's own figure — that only about 5% of roadless acres have been treated since 2014 — points to a funding and staffing shortfall, not a regulatory barrier. Removing the rule does not put a single additional dollar or crew on the ground. Rescinding the Roadless Rule is impractical. These are steep, remote, high-elevation stands a long way from any mill. Logging them will not produce a meaningful return, but the roads will stay on the books forever. The Forest Service already carries a road maintenance backlog near $5 billion and more than 8,500 miles of road on the Deschutes alone, much of it washing out for lack of funding. Adding mileage to a system the agency cannot maintain is not management. Rescinding the Roadless Rule is dangerous. Most wildfires in the West are human-caused, and ignitions cluster along roads — more access means more starts, in the exact fuels this rule is being blamed for. Roads also degrade drinking water. Bend's municipal supply begins in the Bridge Creek and Tumalo Creek headwaters on the Deschutes National Forest, inside protected roadless country. Road-related sediment there threatens water quality for fish and for roughly 100,000 people downstream. Rescinding the Roadless Rule is permanent. Once a road is cut, the backcountry is gone. The quiet, unfragmented ground that people hunt, ski, ride, and fish — Tumalo Mountain, Tam McArthur Rim, Kwolh Butte, Waldo Lake, Lookout Mountain — does not come back. Roadless areas are elk and mule deer security habitat and the buffer that keeps our wilderness areas functional. Open road density pushes game out; it does not improve hunting. Please withdraw this proposal, select the No Action alternative, and keep the Roadless Rule intact. Respectfully, M

The Ochoco draws me in every season. I camp at the Ochoco Forest Campground and hike Lookout Mountain. Out there I photograph birds, horses, trees, and views. I watch old growth Ponderosas, birds and squirrels, wild horses, and magnificent vistas. I oppose rescinding the 2001 Roadless Area Conservation Rule, and I want my reasons on the record. Water is the first reason. The Crooked River and the Deschutes River, along with groundwater, are the primary water sources for all of Central Oregon. Old growth forests and undamaged riparian areas are the primary sources of clean water and must be left untouched for centuries. Roads are a prelude to logging the forests, which I adamantly oppose. The scale of what is at stake is stated plainly in Table 35 of the DEIS: "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas." Despite documenting that exposure, the water quality analysis is entirely qualitative. There is no quantitative modeling of sediment loads, pathogen risk, or treatment cost increases that road construction and timber harvest would produce. Saying that Best Management Practices reduce but do not eliminate impacts is not an analysis. The agency must explain, before finalizing this rule, how it intends to protect the drinking water that flows from these watersheds to millions of people, and it must do so with specifics, not programmatic language. Fire is the second reason. I live across the Deschutes River from forest that has had four fires in the last two years, three of them human caused. The more access roads open into forest lands, the more human-caused fires will follow. Hikers and bikers rarely cause fires, but humans in vehicles do. Rescinding roadless protections is not a fire management strategy. It is an invitation to the very ignition sources already burning the land I can see from where I live. The agency should address directly how expanded road access interacts with human-caused fire risk, and put a real answer to that question in this record. Cumulative timber pressure is the third reason. The DEIS frames the possibility that certain alternatives could increase sawtimber harvest by some margin as a benefit, while Table 4 of the same document acknowledges an ongoing reasonably foreseeable action: the One Big Beautiful Bill Act, which "Directs the Forest Service to annually, beginning in FY2026 and through FY2034, sell a quantity of timber on National Forest System land that is at least 250 million board feet greater than the quantity that was sold in the previous fiscal year." That statutory mandate runs independently of this rulemaking, yet nowhere in the document does a cumulative analysis combine both pressures and measure their joint effect on inventoried roadless area resources. The agency cannot treat a decade-long escalating harvest obligation as background noise. It must integrate that mandate with IRA-specific projections before this rule is finalized. The national forests must be reserved for recreation, wildlife, and environmental management. Roadless areas must be maximized, not removed. I oppose logging in the federal forests anywhere except the Wildland Urban Interface, and I urge the agency to withdraw this proposal.