Read the comments.

I oppose the proposed repeal of the Roadless Area Conservation Rule. I urge you to maintain the existing Rule as is. The Roadless Rule protects the watersheds of many of our National Wild and Scenic Rivers in California, as well as many rivers and streams deemed eligible for national protection by the Forest Service. The roadless areas through which these wild rivers flow are an important refuge for threatened and endangered fish, wildlife, and plants. They provide outstanding opportunities for outdoor recreation in a primitive setting, such as hiking, backpacking, whitewater boating, mountain biking, and even motorized recreation on existing legal trails. Roadless areas provide clean water for wildlife and recreation and the rivers that flow from the roadless areas into reservoirs are an important source of high-quality water for downstream communities and farms. Many rivers to consider include but are not limited to the North Fork American, Rubicon, Mokelumne, Tuolumne, South Fork Kings, Middle Fork Feather, and North Fork Kern. The Roadless Rule does not limit public access. Most roadless areas are legally available for public recreation under the Rule – they are simply closed to new road building, commercial logging, and other development that requires new roads. It is not true that roadless areas increase wildfire threats. Roads – not roadless areas – are a primary source of wildfire starts. With 30+ years as a career wildland firefighter I have direct knowledge of how many fires are cause by humans, especially when they have easy access to forested areas by vehicle. Please go into the Dept of Agriculture (Forest Service) and Dept of Interior’s “wildfire cause” GIS data and plot it on maps. It is a quick & easy visual of human caused fire with a direct correlation to roads. I have direct knowledge that it is still possible to reduce hazardous fuels (in order to reduce wildfire risk) in Roadless Areas, without repealing the Rule. I have been an author, editor, and fire/fuels specialist on several hazardous fuels reduction environmental analysis projects and implementation of those NEPA projects within Roadless Areas. So please do NOT spin this repeal as a way to reduce wildfire risk when there are other tools (besides logging) to complete this work that already exists. Which brings me to my next comment. Heavy equipment also causes wildfires and bring risk to the roadless areas if used for logging operations. I have responded to many equipment caused fires outside of roadless areas both as a fire fighter and as a fire investigator. All you have to do is pull the “wildfire cause” GIS data to see this fact. I urge that Roadless Rule be retained to protect our wild places for recreation, fish and wildlife habitat, and as important sources of clean water for our communities and farms. Sincerely, Teresa Riesenhuber Sincerely, Teresa Riesenhuber Somerset, CA 95684

Here's your comment, ready to copy: As an Idaho hunter and angler, I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66). My special place is the Frank Church–River of No Return Wilderness and the roadless country surrounding it in central Idaho. I have hunted and fished that country — the high basins, the cold clear tributaries of the Salmon and Middle Fork — and what makes it extraordinary is precisely that you reach it on foot, not by road. The elk, mule deer, bighorn sheep, and native cutthroat trout there depend on large, intact, unfragmented habitat, and the solitude of the experience depends on the absence of roads. The inventoried roadless areas bordering the Frank Church are what buffer and connect that wilderness. They are not empty acres waiting for development — they are functioning wildlife habitat, clean headwater streams, and some of the finest backcountry hunting and angling opportunity left in the Lower 48. Once roads are punched in and the timber cut, that character cannot be restored, not in our lifetimes. There is also a fiscal case against rescission. Opening tens of millions of acres to new road construction adds to an already enormous Forest Service road maintenance backlog rather than reducing it. Taxpayers would foot the bill for roads into country that is currently providing habitat, clean water, and recreation at no cost. The Roadless Rule exists because 1.6 million Americans asked for it through the most extensive public process in Forest Service history. Rescinding it from the top down, against that record, would trade a permanent public inheritance for short-term extraction. I urge the Forest Service to retain the 2001 Roadless Rule in full. Sincerely, Jared Mattravers Nampa, Idaho

Dear Director White, I am writing to state my opposition to the rescission of the 2001 Roadless Area Conservation Rule. I am a Wyomingite from Riverton, Wyoming, and I have spent many of the summers and falls of my adult life in part working in and next to roadless areas guiding pack trips, hunts and helping to run a cowcamp. I likewise recreate, hike, hunt and ride in Wyoming’s roadless areas frequently. What I value most from these areas includes both their solitude, wildlife and also their relative accessibility compared to wilderness. These are the places I, and other friends and colleagues, use as day trips that still allow for a backcountry experience. With the dramatic growth in populations in the rural west and increasing outdoor recreation, I believe roadless areas are worthy of increased protection, not weakening of existing protective frameworks. I urge the Forest Service to maintain the Roadless Rule and consider working with local communities, conservation organizations and other stakeholders in improving the Rule if necessary rather than scrapping or gutting it via Alternatives 2 or 3. Out of the three alternatives identified in the DEIS, I support the “no action,” Alternative 1. The proposed rule–analyzed as Alternative 2 in the DEIS -- would remove the Roadless Rule’s protections against commercial logging and road building from nearly 45 million acres of intact public forests, including over 3.2 million here in Wyoming. Alternative 3 is far from offering a meaningful alternative to a full rescission in that it removes roughly three fourths of lands currently listed as IRAs from protection via excessive and arbitrary methods. The Supplementary Information in the NOI stated “About 23 percent (10.2 million acres) of inventoried roadless areas managed under the 2001 Roadless Rule are within the Wildland-Urban Interface (WUI) areas … an additional 4.8 million acres are within one mile of the WUI, totaling about 35 percent of these inventoried roadless area acres.” Findings by The Wilderness Society, using the Forest Service’s own data, suggest that only 2.8 million acres of IRAs are located within one mile of the WUI, not 24.5 million. An additional analysis by the Property and Environment Research Center found that only roughly 74,000 roadless acres are within direct-exposure zones near developed areas, further suggesting that the 31.7 million acres removed from Roadless Rule protection under Alternative 3, and even more so the full rescission under Alternative 2, grossly exaggerate the geographic scope of benefit to community-wildfire protection. Wyoming’s roadless areas provide some of the best fish and wildlife habitat in the country, help supply one of five Wyomingites with clean water, and offer world class recreational opportunities. The loss of the Roadless Rule would put many of these values at risk, including in IRAs that I personally value. The Castle Rock Inventoried Roadless Area and Telephone Draw Inventoried Roadless Area are both IRAs facing incredible pressure from motorized vehicle use on their edges (much of the public land to the south is already incredibly accessible and well-roaded. This poses an issue to wildlife especially during hunting season when big game (elk, mule deer, bighorn sheep) species and other wildlife are heavily pressured and stressed. Telephone Draw has existing tribal and ancient Indigenous resources. Castle Rock IRA is likewise composed mostly of incredibly steep terrain that is incompatible with roadbuilding. The Middle Fork Inventoried Roadless Area is a prized recreational area for locals and visitors alike. The area is facing increased recreation pressure. The loss of the Roadless Rule protections would be damaging for wildlife, cultural resources and recreational experience in each of these IRAs as in other roadless areas across Wyoming and the nation. Thank you for your consideration of these comments, I urge the Forest Service to choose the “no action” Alternative. Thank you, Gabby Yates

I oppose the proposed repeal of the Roadless Area Conservation Rule. I urge you to maintain the existing Rule as is. The Roadless Rule was intentionally enacted for good reason. It protects the watersheds of many of our National Wild and Scenic Rivers in California, as well as many rivers and streams deemed eligible for national protection by the Forest Service. The roadless areas through which these wild rivers flow are an important refuge for threatened and endangered fish, wildlife, and plants. The Roadless Rule provides greater continuity of habitats to increase local biodiversity and minimize risks of invasive species by limiting the edge effect for habitats and habitat alteration due to resource extraction. Roadless Areas provide outstanding opportunities for outdoor recreation in a primitive setting, such as hiking, backpacking, whitewater boating, mountain biking, and even motorized recreation on existing legal trails. Roadless areas provide clean water for wildlife and recreation. The rivers and the headwaters and tributaries of those rivers that flow from and through the roadless areas into reservoirs are critical to maintaining high-quality water for downstream communities and family farms and agriculture. Many rivers to consider include but are not limited to the Klamath, South Fork Trinity, North Fork American, Tuolumne, South Fork Kings, Middle Fork Feather, Merced, and North Fork Kern. The Roadless Rule does not limit public access. Most roadless areas are legally available for public recreation under the Rule – they are simply closed to new road building, commercial logging, and other development that requires new roads. Roadless areas do not increase wildfire threats. In fact, it is quite the opposite because roads, not roadless areas, are a primary source of wildfire starts. The Forest Service has current techniques, tools, and existing access to address any fire concerns within the roadless aresa. Natural areas with less disturbance, such as Roadless Areas, are better equipped to deal with normal fire occurrence with more resiliency and allow fire to return nutrients to the land instead of burning catastrophically. I urge that Roadless Rule be retained to protect our wild places for recreation, fish and wildlife habitat, to protect our wild and scenic rivers, and be retained in their current status as important sources of clean water for our communities and farms. Sincerely, W. Y.

I am asking you to please uphold the Roadless Rule . It is important to the protection of healthy intact natural systems for wildlife and provides important wilderness experience recreation opportunities. I have spent my career and live working and recreating in roadless area. From 8 seasons working on the Middle Fork of the Salmon River I. The Frank Church Wilderness to other area through out OR, ID, MT, and WY. These are vital to preserving large roadless areas. We need to foster a land ethic not just punch more roads in and open more acces for side by sides and other mechanized vehicles. These places are vital. The propaganda to open the. Are false. Only 3% of wildifres start in roadless( by the way j also work in wildland fire…). To say roadless fires are larger and more destructive would do more toward policy of let it burn than the fires themselves. If fires out of roadless areas where managed similarly they would and already do get large. We have back log of roads on public lands that already need maintenexd and to add more that we can take care of is foolish. A lot of roadless areas and wilderness study areas do not have marktetae timber at all. They include canyons and deserts. Much of WY has little marketable timber to begin with. There is a reason roadless areas exist in that the terrain is not suitable or economically feasible to log in the first place. There is no need to open roadless areas other than this administrations desire to squeeze every penny out of resources with no regard to conservation, stewardship or protection of these places for future generations. In light of urban sprawl, urban wildland interface and lose of connected habitat for animals that require large intact habitat it is more important than ever. As technology and the I ability to get away from technology creeps in at an alarming rate we need to protect wild places to recreate. Please do NOT rescind this. The people pushing for do not spend time in these places. roadless and wilderness and protecting OUR public lands has huge public bipartisan. Support. Listen to the public and not just representative with no wildlife management background like Harriet Hageman or a Mike Lee. Thanks you for your time.

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. The remaining intact forests and headwaters on our national forests are natural water infrastructure. Removing their protections would put watershed resilience and downstream water security at risk. I live near the confluence of the North, Middle, and South Forks of the Nooksack River in Whatcom County, Washington. My work centers on watershed restoration and ecological forestry. I have spent approximately thirty years climbing and twenty years mountaineering. The Mt. Baker–Snoqualmie National Forest is a place I love and know intimately through years of returning to its mountains, forests, and headwaters. On visits to Deming Glacier, at the headwaters of the Middle Fork Nooksack, I have watched a substantial part of its lower portion disappear. Its meaning is immediate: the sources of stored water sustaining our watershed are changing. We need to protect the watershed functions we can protect. Forest management is water management. Water security depends on when water arrives, how quickly it moves, its temperature and quality, and how much remains during the driest months. More runoff during a winter storm does not resolve a shortage of cold water in August. Older, native, structurally complex forests have a living architecture that develops over centuries: layered canopies, diverse vegetation, large wood, roots, and intact soils. A plantation does not immediately replace those functions. Forest condition influences interception, evapotranspiration, soil water storage, snow processes, and the pathways connecting hillslopes to streams. Treating all tree cover as hydrologically interchangeable obscures these differences. Long-term research makes the summer-flow concern especially clear. Perry and Jones (2017, Ecohydrology) analyzed sixty-year records from eight paired-basin experiments in Oregon. Average July–September streamflow in basins with 34–43-year-old Douglas-fir plantations was approximately 50 percent lower than in reference basins with 150–500-year-old forests. That number should not be applied mechanically to every Washington watershed. It does demonstrate that converting older forests to plantations can produce substantial summer-flow deficits decades after cutting. The Forest Service must evaluate these long-term effects, including regrowth and repeated harvest, rather than emphasize initial runoff increases. The 2022 South Fork Nooksack forest-management and August-streamflow modeling report prepared for the Nooksack Indian Tribe also deserves consideration. Roads introduce another set of risks. Road surfaces, cut slopes, ditches, and culverts can intercept and reroute water, connect runoff to channels, and deliver sediment. Their hydrologic footprint extends beyond the driving surface. Closing a road to traffic is different from restoring its hydrologic function. Forest effects on flood peaks vary with storm magnitude, basin characteristics, and management. Intact forests cannot prevent every flood. Nevertheless, avoidable changes to runoff pathways, erosion, and sediment delivery deserve serious assessment. Uncertainty about a precise downstream effect is not a reason to ignore the mechanism or the cumulative pressure. These headwaters are connected to watersheds already affected by roads, development, and timber management across public and private lands. Private industrial timberlands must be included in the cumulative assessment. Remaining intact federal lands should strengthen watershed resilience. Opening them to additional disturbance risks undermining investments in salmon recovery and watershed restoration downstream. I ask the Forest Service to retain the Roadless Rule and evaluate an alternative that strengthens intact-watershed protection while prioritizing maintenance and restoration of existing roads. The analysis must address peak flows, summer low flows, baseflows, evapotranspiration, seasonal water yield, snow dynamics, sediment, temperature, and relevant groundwater pathways over decades. Wildfire concerns require evidence specific to forest type, treatment, and location. The agency must explain why existing exceptions are insufficient and compare claimed safety benefits with road-related ignition risks and watershed costs. Broad claims about management flexibility do not justify removing a national conservation safeguard. Our full balance sheet must include the ecological capital these forests already provide. Protecting their living architecture is an investment in public infrastructure and water security. I love these mountains, and I live downstream of them. Please protect the intact headwaters that sustain the rivers, salmon, and communities below.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Decades spent living next to roadless areas in central Idaho, working as a whitewater guide on the Main Salmon and as a wilderness guard and river ranger on the Middle Fork Salmon, shaped who I am in ways I cannot fully account for. I hunted, fished, camped, hiked, and skied those drainages and carried the same habits into Colorado and Wyoming. Those experiences have been a huge positive influence on my life, and I want the same opportunity to exist for my son and grandchildren. The 2001 Roadless Area Conservation Rule is part of what keeps that opportunity intact. I oppose its rescission. I have commented on this matter before and received no response. I file this comment expecting the agency to engage with the specific points it raises and to answer them in the record it builds. The rule I guided on and worked in protects water that salmon need. Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, and the affected area includes Essential Fish Habitat and critical habitats managed by NMFS. I have watched salmon in those rivers. I have worked that water. I have yet to see a plausible explanation of what we will do once the fisheries have been diminished. Beyond temperature, the DEIS itself 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," yet no projection of sediment delivery to downstream waters follows that finding. There are more than 7,000 municipal intakes sitting in watersheds that contain affected roadless areas. I ask that the agency calculate the projected sediment load reaching those intakes and place that calculation in the record before any final decision is made. One contamination pathway the DEIS does not appear to address at all is tire-derived pollutants. Compounds including 6PPD and 6PPD-quinone are shed from truck and car tires and migrate into waterways near roads. The resulting water toxicity has severe effects on fish and everything that depends on them. New roads built following rescission would extend the zone of exposure for salmon runs that are already under pressure. I ask the agency to address tire-derived contaminant loading as a distinct water quality effect in any final environmental review. The agency's own fire data undermines a central justification for 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 same analysis concedes that road access could increase the number and frequency of wildfires. Despite that, the agency claims the rescission reduces wildfire hazard without quantifying the fires new road access would add. I ask that the agency project the expected increase in human-caused ignitions from new access and weigh it openly against whatever hazard-reduction claim it is advancing. The economic certification is also defective. 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. I was one of those outfitters operating on those rivers. The flexibility analysis reaches its no-impact conclusion by averaging a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the guides and outfitters who actually hold permits in the affected areas. That method is not analysis; it is concealment. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the agency has affirmatively invited public comment but has not committed to weighing what it receives. 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 such a reliance interest. Decades of work, recreation, and expectation built on the rule's protections are real and they belong on the scale. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before it reaches a final conclusion. Sincerely, Steve Moore Captain Cook, HI

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (FS-2025-0001 / RIN 0596-AD66) and urge the Forest Service to retain the rule in full. I am a rock climber and Mountaineers volunteer living in Snoqualmie, Washington. My climbing and backcountry travel take me through the national forests of the Cascades, including the Middle Fork and the I-90 corridor — areas whose character depends directly on roadless protections. The quiet, undeveloped backcountry experience I seek is only possible because these landscapes are not laced with roads. I am skeptical of the wildfire rationale for this rescission. The agency's own Draft Environmental Impact Statement acknowledges that as road density increases, so do the probability, number, and frequency of wildfire ignitions — and recent research (Aplet et al., 2026) finds fires are four times as likely to start near roads. If the goal is reducing fire risk, building more roads into roadless areas works against it. The rule's exceptions already allow hazardous-fuel treatments where genuinely needed; the claim that local managers are blocked is not a case for eliminating protections across 44.7 million acres. Roads are effectively permanent. Once built, the habitat connectivity, watershed integrity, and recreational values the 2001 rule was created to protect are lost for generations — and the agency's deferred maintenance backlog shows it cannot manage the roads it already has, let alone tens of thousands of new miles. The burden of proof is on rescission, and it has not been met. Please retain the Roadless Rule in full.

The herons and egrets I watch near the American River, and the pictures I take of the river, shore, and greenery behind it, depend on the North Fork and North Fork Middle Fork regions of the American river staying intact under the 2001 Roadless Rule. I don’t want the quality of my drinking water to be compromised. Wild spaces are important in keeping water naturally clean. I would rather have that, than constantly boil and filter drinking water. California has 1,034 municipal watersheds in the 4,389,760 acres of roadless areas. Potential timber production can leak sediment into the watersheds. I ask the agency to explain how rescinding the Roadless Rule would leave watersheds unharmed. Sincerely, Raina Bahadur

I urge you to rescind the proposal discussed in FS-2025-0001-223869, Special Areas: Roadless Area Conservation, because of the irrevocable devastation it would cause. Once roads are built, there is no way to undo the damage. According to the analysis in the DEIS, elimination of the Roadless Rule across 45 million acres nationwide would result in a loss of up to $9 million a year from lowered visitor spending, especially hurting local communities, 327 ESA-listed species and 71 critical habitats would be negatively impacted, threaten Tribal sacred and archeological sites, exacerbate the Forest Service’s estimated maintenance backlog of over $8.6 billion covering the existing 370,000 miles of roads, and could actually increase fire risk. When it was adopted in 2021, the Roadless Rule applied to forests containing habitat for approximately 25 percent of animal species and 13 percent of plant species listed as Endangered in the U.S. Roadless areas are critical habitat for 1,600+ threatened species. Many roadless areas are mature or old-growth forests—irreplaceable ecosystems that protect plant and animal diversity. Roadless areas also provide important migration corridors that are critical for numerous migrating species. Additionally, rivers flowing through roadless areas provide vital refuges for declining fish and wildlife species. A study conducted in the Sierras found that the biologically healthiest waters were in roadless areas including many existing Wild and Scenic Rivers such as the Middle Fork Feather, North Fork American, Tuolumne, Kings, and North Fork Kern and many recommended by the Forest Service for Wild and Scenic protection, including Deer and Mill Creeks and the Clavey River. A spectacular example of what we have to lose without the Roadless Rule is the Tongass National Forest (9 of 17 million acres). It is the largest national forest in the country, spanning Southeast Alaska's islands, fjords, waterways, and mountains, the largest intact temperate rainforest in the world, and is the only public land in the U.S., if not the world, that still has intact water sheds. The Tongass provides critical habitat for more than 400 species of fish and wildlife and for birds from across the globe, supporting approximately 350 bird species, including about 40% of all bird species found in North America. The forest contains the world's highest density of nesting Marbled Murrelets and Bald Eagles, and hundreds of thousands of migrating shorebirds stop here each spring before continuing north to Arctic breeding grounds. Unique subspecies—including the Queen Charlotte Goshawk and Prince of Wales Spruce Grouse—depend on the mature and old-growth forests that make the Tongass special. Roads threaten high-quality streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers with mounds of mud. Roads result in other long-lasting harms such as fragmenting wildlife habitat, degrading habitat, increasing pollution, spreading invasive species, and are the single largest threat to bird species and the greatest driver of population declines. It is imperative that at least 30% of all species and their habitats be preserved to have a livable future. Given the widespread multifaceted harms repealing the Roadless Rule would cause it is imperative that it be improved by: Eliminating the logging loopholes. Logging does not improve anything - it only causes degradation. Instead of the 2000 EIS estimated ~ 1,400 acres of logging in roadless areas across the nation annually, on average from 2008-2018, there has been 3,200 acres of inventoried roadless logging annually in Montana alone. The majority of which was from using Roadless Rule loopholes. Eliminating livestock grazing in our inventoried roadless areas. Livestock grazing spreads invasive grasses that exacerbate wildfires, displaces wildlife, destroys habitat, and pollutes clean water. Despite being only four percent of livestock production in this nation, livestock grazing is pervasive on nearly 250 million acres of our public lands. The Forest Service is clandestinely restocking vacant grazing allotments with cattle, including in roadless areas and Wilderness, without public knowledge or participation. Restricting motorized and mechanized use in our inventoried roadless areas. Research shows that motorized and mechanized access (on roads, trails, or over the snow) harm wildlife, from elk to grizzly bears. Extend the provisions of this strengthened national rule to Idaho and Colorado, which currently have less protective rules. Thank you

I urge the Forest Service to retain Roadless Rule protections in the Flathead watershed and to support the proposed provision allowing Class 1 e-bikes on National Forest System trails where conventional bicycle use is already permitted. One of the keys to successfully protecting the Flathead River system is the network of overlapping protections that safeguard its rivers, watersheds, lands, wildlife, and natural resources. These include federal laws and regulations governing the National Forest System and National Park Service, the Wilderness Act, the Endangered Species Act, and, most importantly, the Wild and Scenic Rivers Act and the Flathead’s Wild and Scenic River designations. The Roadless Rule is another important part of that protective network. In the Flathead watershed, Inventoried Roadless Areas protect important lands in the Trail Creek, Whale Creek, Logging Creek, and Big Creek drainages of the North Fork; the Morrison Creek, Granite Creek, Bear Creek, and other tributary drainages along the Middle Fork; and the Spotted Bear River, Bunker Creek, Twin Creek, and other drainages of the South Fork. These protections also extend to numerous tributaries flowing into Hungry Horse Reservoir. These roadless lands are not separate from the Flathead River system—they are an integral part of it. The condition of the surrounding watersheds directly affects the river’s water quality, sediment levels, fisheries, wildlife habitat, scenic character, and recreational values. Maintaining intact, largely undeveloped watersheds provides an important measure of protection for the river itself. I recognize that rescinding the Roadless Rule would not automatically authorize a particular road, timber sale, or development project. However, the Forest Service acknowledges that rescission could increase opportunities for road construction, vegetation management, fuels treatments, and other activities in areas where existing forest plans allow them. The Roadless Rule therefore serves as an important national safeguard against incremental development of some of the most intact watersheds associated with the Flathead River. For a river system as nationally significant as the Flathead, I believe it is prudent to maintain that additional layer of protection. Once roads and associated development penetrate intact watersheds, their effects can extend well beyond the immediate footprint of the road. Protecting the surrounding lands is therefore an important part of protecting the river. At the same time, I support sensible modernization of recreational access where it does not compromise the fundamental roadless character of these lands. In particular, I support the Forest Service’s separate proposal to exempt Class 1 electric bicycles from motor vehicle designation requirements when they are used on National Forest System trails where conventional bicycle use is already permitted. Class 1 e-bikes provide pedal assistance only while the rider is pedaling and are limited to 20 mph. Allowing them on trails already open to bicycles would provide additional recreational opportunities without requiring roads or other infrastructure, while retaining the ability of Forest Service officials to impose seasonal, land-management, and site\-specific restrictions. I believe these positions are compatible. We can preserve the essential roadless character and watershed protections of the Flathead while allowing carefully defined, low-impact recreational uses that reflect modern technology. For these reasons, I support retaining the Roadless Rule protections applicable to the Flathead watershed and supporting the proposed Class 1 e-bike provision for National Forest trails where bicycle use is already permitted. Thank you for considering my comments. Bob Jordan

I respectfully oppose nationwide rescission of the 2001 Roadless Area Conservation Rule because of the consequences for clean water, trout fisheries, and the undeveloped headwater watersheds that support them. I say take Alternative 1 – No Action, and maintain the roadless rule in place. Ever since I was a child, I have camped, fished, hunted, and backpacked across some of the designated roadless areas in particularly in Middle Fork Roadless Area in Wyoming and Price Mountain in Virginia. I grew up as a Boy Scout and as the son of a U.S. Fish and Wildlife Service biologist, my favorite memories in the are hiking through the most beautiful stands of pine trees and catching the most beautiful brook trout. Nowhere have I experienced this more clearly than in Middle Fork Roadless Area . In my experience, it contains some of the finest trout fishing anywhere. On one trip to two lakes known as the Twin Lakes, I caught roughly 60 brook trout in only a few hours. What made that experience extraordinary was not simply the number of fish. It was fishing in a remote mountain watershed surrounded by an essentially undeveloped landscape. These fisheries are a treasure! My experience as an angler illustrates an important principle of watershed science: a trout stream or lake cannot be separated from the landscape draining into it. Forest roads can disturb soils, alter drainage, increase erosion and sediment delivery, and create barriers at stream crossings. Forest Service research has long identified increased sedimentation and obstruction of fish migration as important potential effects of forest roads on salmonid habitat (Yee & Roelofs, USDA Forest Service, 1980). USFS Research & Development The Forest Service's own environmental analysis has also found that road sediment can increase fine material in streambeds and reduce preferred fish-spawning substrates. Culverts can fragment aquatic habitat, while roads and stream crossings can alter channel form, substrate, pool depth, and other characteristics important to fish. US Forest Service This matters far beyond the physical footprint of a road. Roadless areas occur within hundreds of major American watersheds. US Forest Service Protecting relatively intact headwaters helps protect water quality and fisheries downstream. Sediment and altered runoff do not stop at an administrative boundary. I also question whether nationwide rescission is justified as a wildfire and forest-health measure. Forest Service researcher Sean Healey analyzed nearly 20 years of monitoring data and found that forests with and without roads burned at similar rates after the Roadless Rule took effect. Fuel-management activities still occurred in roadless areas and were actually more numerous per square kilometer, although treatments outside roadless areas covered larger areas. His analysis of more than 15,000 forest inventory plots also found non-native plants were twice as common within 500 feet of roads. He concluded that the monitoring evidence did not support speculation that eliminating road prohibitions would improve forest health (Healey, 2020, Environmental Research Letters 15:104023). USFS Research & Development I am not arguing that roads should never be built or that forests should never be actively managed. As a hunter, fisherman, camper, and backpacker, I recognize the need for wildfire mitigation, ecological restoration, responsible timber management, and access. Roads can be valuable management tools where there is a demonstrated need. But restraint is also a form of management. Some watersheds provide their greatest public benefit precisely because they remain relatively intact. Once a remote watershed is fragmented by permanent roads, restoring its hydrology, aquatic habitat, and undeveloped character can be difficult and expensive. The scientific response should therefore be targeted management based on local conditions, not elimination of a national conservation framework covering tens of millions of acres. I ask USDA to retain the 2001 Roadless Rule. Where legitimate wildfire, restoration, or public-safety needs cannot reasonably be addressed under the existing framework, USDA should use narrowly tailored, science-based exceptions rather than nationwide rescission. At minimum, strong protections should remain for important headwater watersheds, native and wild trout habitat, spawning tributaries, and watersheds supporting sensitive aquatic species. Future generations of Americans deserve the opportunity I had as a kid: to shoulder a backpack, hike beyond the end of a road, and find cold, clean water full of trout. These places provide clean water, wildlife habitat, hunting and fishing opportunities, and experiences that become increasingly valuable as truly undeveloped landscapes become harder to find. Please retain the 2001 Roadless Area Conservation Rule and protect the clean, cold headwaters upon which America's trout fisheries and downstream communities depend.

I am writing to urge you to keep the Roadless Area Conservation Rule by supporting Alternative 1: No Action. I have lived in Pierce, Kamiah, Kooskia, within the Wild & Scenic Middle Fork Clearwater River corridor, and, currently live in Moscow. As a long-time resident, recreationist and conservationist who highly values the great historical and wilderness character of our nearby Bitterroot National Forest (NF) and Nez-Perce-Clearwater NF, Frank Church River of No Return Wilderness Area (WA), and Selway-Bitterroot WA. Enjoying and valuing these wild public places is my life-style; it’s part of who I am, and I’m not by a long-shot alone. Thousands of people – Idaho, Wyoming and Montana family, neighbors, townsfolk, as well as tourists and recreationists from all over the country and the world enter these wild places to hike, camp, swim, raft, kayak, ski, bike, horse ride, berry pick, scout wildflowers, practice photography, hunt, fish, bird, and learn and experience Lewis & Clark Expedition and Native American history … or to simply find peace and joy in nature. And they are able to do it all without despoiling the land, the rivers and lakes, nor the plant and animal life. While Idaho operates under its own state-specific roadless rule, the proposed rescission of the Roadless Area Conservation Rule would directly affect the immediate and neighboring national forests and wilderness areas I know and use. These landscapes don't stop at state lines, nor at wilderness and national forest boundaries. Essential wildlife migration corridors, shared watersheds, old growth tree clusters, the trails and legends of Native and non-Native history, and regional recreation economies connect them directly to where I live. The Roadless Rule has proven itself vitally protective. It continues to be supported broadly by millions of Americans. Even right here in logging country, not even the timber industry is asking for its rollback. If there is any agreement between the rural ‘left’ and the rural ‘right,’ the Roadless Rule would be the nexus! In terms of wildfire frequency, rolling back the Roadless Rule will lead to more, not fewer. Research covering 1992–2024 found wildfires were four times as likely to start in areas with roads than in roadless forest tracts, and a separate study found more than 90 percent of wildfires nationwide occurred within half a mile of a road. The Roadless Rule as written already allows the flexibility land managers need. It permits road construction to address fires, floods, or other catastrophic events, and to connect communities. Forest managers routinely conduct stewardship work in roadless areas — prescribed burning, wildlife habitat improvement — under the current rule. These lands are the source of drinking water for downstream communities, home to iconic wildlife including the Yellowstone-area grizzly and elk populations and salmon species for whom Roadless Areas provide crucial sanctuary. These lands are also the backbone of regional outdoor recreation economies. Since 2001, protected roadless areas in Wyoming, Montana and Idaho have supported world-class hunting, fishing, and camping. Millions of Americans use these public lands every year, powering billion-dollar recreation economies across the West. I urge you to reject rescission of the Rule and to keep the 2001 Roadless Rule intact by supporting Alternative 1: No-Action.

Dear Forest Service Leadership: I write as a Mental Health Counselor who has seen the impact the decimation of natural spaces has on mental health--impact that costs a lot of money elsewhere. I also write as a person dedicated to spirit, shaped by traditions that know the earth as inextricable from our safety and belonging. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Roadless areas anchor the highest-integrity watersheds. Within the National Forest System, watersheds with the highest ecological integrity scores tend to be dominated by wilderness and roadless areas — over 50 percent roadless or wilderness cover in 81 percent of the highest-integrity subbasins. Watersheds with the lowest integrity scores show the opposite pattern: little roadless cover and moderate to high road density (USDA Forest Service 2000). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf) Rescinding the Roadless Rule would open the Mt. Baker West, Mt Baker-Snoqualmie National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. We're at a time where many corporate and elected officials act like they've given up on accountability to the living earth and our reciprocity within these complex systems of life. Preserving these spaces aligns with so much that we know about holistic health. Moreover, I think stewardship and protections like that encompassed with the roadless rule aligns with all the mystery of what we don't yet know, but still pay a cost for our ignorance. Short sighted cash grabs need to end. Please be a part of saying no to this tide. I love Mt. Baker West. The Nooksack River in her different forks has been a source of some of the most profound healing and connection I've had. Protecting this lifespring from the run off and damage logging causes isn't just a general logical and moral imperative, it is personally meaningful. I remember sitting by the banks of the middle fork of the Nooksack and being reparented over a many month long process. These big healthy centers of power can help revision and recontextualize human and other than human challenges . My spiritual center feels linked with this land. Logging this land injures me and so many others. The Department is respectfully urged to allow the Rule to stand and to decline the rescission action now proposed. Most respectfully,

I support preserving intact watersheds for clean drinking and agricultural water, safeguards to wildlife habitats, Backcountry recreation, avoiding the up to 4x higher increase in potential wildfire opportunities, in areas of cultural significance to native tribes including the black feet. I want us to continue to protect the badger to medicine area, the national forest land along the two, and the middle fork, the jewel and the swN. What makes this area of Montana unique is exactly all of these things.

Dear Secretary Rollins, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the Forest Service to adopt Alternative 1, the No Action alternative, and keep full Roadless Rule protections in place. I live in the Flathead Valley of northwest Montana, and my family owns a outdoor recreation company. Wild country is a big part of why people live here, visit here, and spend money here. About 6.4 million acres of Montana's national forests, roughly 37%, are Inventoried Roadless Areas. Alternative 2 would strip protections from all of it, and Alternative 3 would still open much of it to new roads and logging. Near my home that includes the northern Swan Range and the Jewel Basin Hiking Area, the Whitefish Range west of the North Fork Flathead, the Middle Fork Flathead, the Badger-Two Medicine, and the roadless country bordering the Cabinet Mountains Wilderness on the Kootenai. Wildlife. The DEIS says rescission would "adversely affect" 327 threatened and endangered species and 71 designated critical habitats. In northwest Montana that means grizzly bears, Canada lynx, wolverine, and bull trout, all federally listed and all dependent on large, unfragmented landscapes and cold, clean water. The Swan and Whitefish ranges link Glacier National Park to the Bob Marshall Wilderness complex. How will the agency keep secure grizzly habitat and that connectivity intact once new roads go in? Water. The DEIS states that roadless areas "typically have good water quality due to limited disturbance" and that "road construction and native surface forest roads are the largest source of sediment related to timber harvest operations." These headwaters feed the Flathead River and Flathead Lake, and Wild Montana estimates about a third of Montanans get drinking water from roadless watersheds. Sediment is especially damaging to bull trout spawning streams. How will the agency prevent erosion and sedimentation in these watersheds without the Rule? Fire. The DEIS admits that "road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions." Studies have found fires are four times more likely to start near a road than in a roadless area. Northwest Montana already lives with long smoke seasons. Adding roads to remote country adds ignition points. Cost. The Flathead National Forest already has about 3,500 miles of road and maintains only about half of them. The national deferred maintenance backlog is over $6.9 billion, and the DEIS says new roads could be built across 18.2 million acres in the short term. Much of Montana's roadless land is steep, high-elevation ground with little commercial timber value. Building roads there leaves taxpayers with a bill and little to show for it. The DEIS also projects a $9 million annual loss in visitor spending in local communities, and Montana towns like ours depend on that spending. Process. More than 600,000 people commented last fall, and over 99% opposed rescission. The DEIS notes that "the majority sentiment among Tribal governments consulted is opposition to the proposed rescission," which matters here given the Badger-Two Medicine's importance to the Blackfeet Nation. A decision this large should not be rushed through shortened comment periods. For these reasons, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a serious mistake. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, C Quinn Kalispell area, Montana

My name is Peggy McCrackin and I live in Laramie, WY, just 30 minutes from my beloved, pristine, and largely roadless Snowy Range Mountains in the Medicine Bow National Forest. I access the roadless of portions of these mountains on nearly a daily basis in the summer for hiking and often in the winter for snow shoeing and sking. Areas that I love include: the Snowy Range Mountains, French Creek, Libby flats, north fork, middle fork, and even Sheep Mountain. This is a true respite from the noisy world of vehicles, masses of people, exhaust, pollution left behind by visitors, and the constant barrage of man-made stimuli that impacts my mental and physical health. A stroll through the forest, wildflowers, snow, rocks, sounds and sights of nature and wildlife, and beautiful landscapes restores my soul like nothing else can. I strongly support the "NO Action" Alternative 1 that would maintain protections for our Roadless Forests. I strongly oppose Alternatives 2 and 3 which would strip their protections. As you well know, roadless areas are critical for fresh drinking water, wildlife habitat, and the many opportunities for recreational access that I and so many others enjoy. And as you undoubtedly know, most wildfires are started within a quarter of a mile of a road where most of the people are typically gathered. Roadless areas are actually a deterrent to wildfires. So the claim that this action is needed to better respond to wildfires is inaccurate at best and most likely deceptive. There are already so many roads in our national forests that are falling into disrepair because the forest service cant afford to maintain them. Why build more?? As I am sure you know by reviewing documentation that led to the roadless rule becoming law, this is what the American people want! They want roadless areas. The American people understand the value of roadless areas. Do you? Are you going to trample all over the will of the American people? Please do the right thing and keep the Roadless Rule intact.

Dear Special Areas: Roadless Area Conservation, Dear Public lands are deeply important to me, especially our remaining roadless lands. I have been fortunate to visit many roadless areas throughout my life, and the more disconnected we become from the natural world, the more important it is to me that these places remain intact. Simply knowing that wild, healthy ecosystems still exist—and that future generations can experience them—is profoundly valuable. I urge the U.S. Forest Service to retain the Roadless Rule and its protections. The United States has long been a leader in wildland conservation. For decades, the U.S. Forest Service has been entrusted with caring for these lands on behalf of all Americans. Roadless areas protect drinking-water sources for millions of people, provide habitat for threatened and endangered species, sustain healthy forests, and support opportunities for hunting, fishing, hiking, camping, and other forms of recreation. They also contribute to local economies through the billions of dollars generated by outdoor recreation. But the value of roadless lands cannot be measured in dollars alone. There is an immeasurable public benefit in being able to experience places that remain wild, quiet, and whole. These landscapes provide opportunities for people to develop a lasting connection to nature and a deeper appreciation for the natural heritage we hold in common. I am concerned that eliminating the Roadless Rule would put these irreplaceable places at greater risk of development and resource extraction. Once roads are built and intact ecosystems are fragmented or degraded, we cannot simply restore them to what they were. The loss is effectively permanent. The Forest Service has a responsibility to manage these lands for the long-term benefit of the American public, not only for immediate or short-term uses. And not for a few powerful interests. Maintaining the Roadless Rule preserves options for future generations while safeguarding clean water, wildlife habitat, recreation, and the ecological integrity of our national forests today. I respectfully urge the U.S. Forest Service to retain the Roadless Rule and continue protecting our nation's remaining roadless lands. These places belong to all of us, and we have a responsibility to pass them on intact to those who come after us. Sincerely, Elise McLaughlin 701 Middle Fork Road Blowing Rock, NC 28605 elise@skyloom.com Sincerely, Elise McLaughlin

I am a Montana resident living on the Blackfeet Reservation, near the Lewis and Clark National Forest, Flathead National Forest and the Wild & Scenic Middle Fork of the Flathead River. I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. I value our roadless lands because they protect wildlife habitat, clean drinking water, and the intact landscapes that make our nation special. These places are not simply undeveloped land—they are important ecosystems that support communities, wildlife, and future generations. I am particularly concerned about the potential impacts on the Badger-Two Medicine. The Badger-Two Medicine is a place of profound cultural and spiritual importance to the Blackfeet people. It contains traditional cultural resources, sacred places, and areas connected to Blackfeet cultural practices and gathering. Management decisions affecting these lands should recognize that their significance extends far beyond their potential value for timber, roads, or other extractive uses. I am also concerned about the effects of additional roads and development on wildlife habitat and water resources. Roadless landscapes can provide large, relatively intact areas for wildlife and can help maintain connected habitat. Roads can fragment habitat, increase human access and disturbance, and affect soils and waterways. Clean drinking water is a public resource that Montana communities depend upon, and protecting intact watersheds should be a fundamental consideration in federal land management. I understand that the Forest Service is considering wildfire risk reduction, forest management, and local decision-making as reasons for rescinding the Roadless Rule. Those concerns deserve consideration, but rescinding a nationwide protection is a much broader action than addressing specific forest-health or wildfire-management needs. The Forest Service should evaluate whether those objectives can be achieved through carefully targeted management while retaining protections for the ecological, cultural, and water-resource values of roadless areas. Please retain the 2001 Roadless Rule and protect these irreplaceable Montana landscapes for present and future generations. Thank you for considering my comment.

Docket ID: RIN 0596-AD66 Title: Keep the 2001 Roadless Rule Intact! I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I urge the U.S. Forest Service to maintain the 2001 Rule. I have lived in the West since I was four years old, surrounded by our public lands. They have shaped my identity, interests, and professional pursuits for over 50 years. Now, in my retirement, I am dedicating much of my time to defending the wild places around where I currently live in Meadow Valley, California, in the heart of the Plumas National Forest. Over the last 20-plus years, catastrophic wildfires have affected me and my neighbors more intensely and frequently. The Plumas National Forest is already heavily roaded due to its extensive logging and mining history. At least 4,500 miles of system roads are on the Plumas NF, leaving only 6% of the forest as designated Inventoried Roadless Areas (IRA’s). Rescinding protections on these remaining mostly unroaded 65,000 acres will not solve our wildfire crisis. Instead, bringing roads into these steep, backcountry zones will dramatically increase the risks of human-caused ignition right in my backyard. More roads and more motorized human access increases wildfire ignition risks. Data consistently shows that humans are the source of roughly 90% of all wildfires in California. Introducing roads into currently IRAs significantly elevates the risk of accidental or intentional fires from vehicle use, equipment, and public access, endangering human and natural communities. The 2001 Roadless Rule already allows for fire suppression and public safety emergency responses. Rescinding this rule will degrade critical watersheds, and the Upper Feather River Watershed is the primary headwaters for the California State Water Project, supplying clean drinking water to over 27 million Californians and agricultural irrigation to 750,000 acres of farmland. Rescinding this rule would increase habitat fragmentation and impact wildlife. Roads cut through critical wildlife corridors, fragmenting the continuous habitat that wildlife needs to migrate, reproduce, and forage. Preserving large, contiguous blocks of forest is essential for maintaining biodiversity and ecosystem resilience, especially under changing climate conditions. The Inventoried Roadless Areas that I know best on the Plumas National Forest are: •Middle Fork & Bald Rock IRAs (29,278 acres) – the steep, rugged canyons that flank the Middle Fork of the Feather River, one of America’s original Wild and Scenic Rivers, is just a few short miles from my home. I regularly hike and backpack into this IRA. Keeping heavy machinery out of the canyon is so important to protect the plant and wildlife communities and recreational experiences like the ones I cherish. I have taken students to Bald Rock IRA for an overnight field course over a dozen times. We hiked in to spend the night in this sacred place, and learned about plant communities, geology, and myth. Allowing roads would ruin the unique character of Bald Rock IRA. •Adams Peak IRA (5,283 acres) – I have hiked Adams Peak, reveling in the challenge of route-finding, bushwacking, and breathless views of the Great Basin, Southern Cascades, and Northern Sierra Nevada received as a reward for the effort. The plant diversity is exceptional due to the junction of these ecoregions. •Grizzly Peak (6,222 acres) – The soaring views and opportunities for bird watching, hiking, swimming, and botanizing are what make this IRA special for me. There are so many places where vehicles are able to get on the Plumas National Forest. I urge you to maintain a few that are relatively roadless in order prioritize clean water, community safety and wellness, and ecosystem integrity. Please maintain the nationwide protections of the 2001 Roadless Rule. Sincerely, Darla S. DeRuiter