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The Wasatch and Uinta mountains are where I hike and camp, and protecting those places is exactly why I am filing this comment. Mill Creek Canyon in the Uinta National Forest, White Pine and Twin Peaks in the Wasatch-Cache National Forest, these are the wild, unroaded landscapes I want my children and their children to be able to experience. The proposal before the agency would put all of that at risk, and the agency's own record makes clear it should not proceed. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. These are not abstract acres. They are the backcountry I depend on, the places that are still genuinely wild precisely because roads have not reached them. More and more land is developed and destroyed, increasing fire risk, increasing watershed contamination, decreasing wildlife and plant populations. Rescinding the 2001 rule accelerates every one of those trends, and the agency's own analysis says so. On wildfire, the agency's record states plainly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless justifies rescission on fuels management grounds, which inverts what the agency's own findings show. I ask that the agency explain why the proposal departs from those prior findings and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Watersheds need to be kept pure. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. By the agency's own data, roads and their facilities contribute directly to contamination. The agency has acknowledged that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. How can that be justified when everyone needs access to clean water now more than ever? I want the agency to explain, specifically and on the record, how opening these watersheds to road construction serves the public interest in clean drinking water. The economic case for rescission is just as weak. The agency's own record acknowledges: "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's 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, with a net present value spanning -$92 million to +$199 million, and the road system already carries a $6.9 billion maintenance backlog. The agency cannot establish a net benefit from this action by its own numbers. It must reconcile the proposal with that analysis and explain what economic rationale remains. On the question of statutory authority, a court already answered it. 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 argues the 2001 rule exceeded its authority, but the Tenth Circuit found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state, plainly and with legal support, the basis for any position contrary to that holding. Finally, the proposal itself acknowledges that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them. The agency cannot ask the public to comment on consequences it has simultaneously placed outside the scope of its own analysis. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred. We do not want more roads, development, mining, or logging on our public lands. These lands should be left as wild spaces and backcountry. The agency held more than 600 public meetings and received 1.6 million comments before it put the 2001 rule in place. It has held none to undo it. That process debt alone warrants withdrawal of this proposal. Sincerely, Michelle Richardson Sandy, Utah

To the U.S. Forest Service / USDA Re: Proposed rescission of the Roadless Area Conservation Rule (RIN 0596-AD66) I am writing to ask the Forest Service to keep the 2001 Roadless Area Conservation Rule in place and not rescind it. My husband and I regularly camp and travel in Oregon's national forests, including the Ochoco National Forest, in a Jeep with a small trailer. We fish, read, and camp along the Crooked River and in the Mill Creek area. The quiet, undeveloped character of these inventoried roadless areas — clean headwater streams, intact habitat, and places you can still experience on foot or on a forest road without new road construction cutting through them — is exactly why we go. Roadless protections do not close these forests to the public. They keep the existing road system in place while preventing new permanent roads and most commercial timber harvest in the wildest remaining backcountry. That balance has worked for 25 years: it protects drinking-water headwaters and fish and wildlife habitat while leaving recreation, existing access, and forest management tools available. Please retain the Roadless Rule as it stands. At minimum, I ask that the agency fully analyze, in the final environmental impact statement, the effects of rescission on recreation access and experience, water quality in headwater streams like the Crooked River, and wildlife habitat connectivity in Oregon's national forests before making any change. Thank you for considering my comment. Anna Streano Lake Oswego, Oregon

I live in Mill Creek, WA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking and wildlife watching. It is important to me to spend as much time as I can in nature, free from roads and developments, to revive and refresh from a demanding job. I am concerned about wildlife habitat and landscape connectivity. Roadless areas ensure wildlife habits remain intact and protected. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

"I am writing as a public lands user to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). As a community member, I am concerned about the claim that the proposed rescission emphasizes greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning processes to maintain ecological, cultural, and public values of roadless areas to an adequate level across the National Forest System. Political partisanship and corruption is being factored into the current push to dismantle this rule, which is not reflective of the opinions of the people they represent. The Roadless rule is supported by the VAST majority of voters across the political spectrum— 76% according to recent Pew polling. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protection measures. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. As a community member, I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk. 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). It is clear that more roads mean more fires. As a sister in-law of a CA firefighter. We’ve seen and have intimate knowledge of wildfires. They will tell you that the majority of fires are due to human activities. Roads invite more people and vehicles deeper into the woods. Those roads that are built “in case of wildfires” are also pushing potential fires deeper into the landscape. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. I am particularly concerned about climate resilience. The claim that putting these forests under local control would have little adverse impact on land managers' ability to protect undeveloped wildlands puts these values at risk. I have an intimate knowledge of the Lassen National Forest: Mill Creek Inventoried Roadless Area roadless area(s). I am particularly concerned about Climate resilience affects all of us. It affects all animals and plants, and that affects you. The Roadless Rule keeps old growth forests intact, protects multitudes of species and biodiversity, protects the air and drinking water, increases wildfire resilience, protects from land erosion, and is critical infrastructure as the effects of climate change intensify and create unstable and unpredictable changes to our everyday lives. All of these changes affect you, your loved ones, and all future generations of your family. This area - Supports large old growth forest, California spotted owl and other old growth dependent species. - Supports one of the few wild runs of threatened spring chinook salmon and winter steelhead flowing into the Central Valley. - Homeland of the Yahi Indians and the story of Ishi. - Important migration corridor for the Tehama black tailed deer herd - The Mill Creek Inventoried Roadless Area is recommended for wilderness protection by the USFS. - The USFS recommended wilderness protection for the Mill Creek Inventoried Roadless Area and National Wild and Scenic River protection for Mill Creek. Not only is the change proposed to the Roadless Rule terrible on it’s face for animals, the environment, and the people these biomes support in different ways (often unnoticed but absolutely crucial to our health), it’s also a cynical bid to disregard the will of the vast majority of The People in order to make a few people richer. It steals an asset that is explicitly under the stewardship of the People of the United States. Our tax dollars are what supports these areas. We do not consent to this change. And the corrupt few who are in power and pushing for this rule are not doing their job of representing the will of The People. Keep the roadless rule by choosing the no action alternative."

We lost over 300000 acres of timberland in Crook County this year. Our family lost timber that we have owned for over 50 years. When the fire was in the Mill Creek Wilderness and other area off NFR27, firefighters could not get to it fast enough to prevent spotting fires Freon developing into major areas of burn. National Forest and wilderness areas require roa access to prevent fire spread and to manage undergrowth.

I am a resident of Park County, Montana, where more than half of public land outside of designated wilderness is protected by the Roadless Rule. My family, friends and I have spent countless hours hiking, fishing, and camping along Suce Creek, Mill Creek and Deep Creek in the Absaroka Range, Tom Miner Basin and Big Creek in the Gallatin Range, and Big Timber Creek, the Twin lakes, and the Porcupine-Ibex Trail in the Crazy Mountains. I am not alone in my appreciation for these quiet, undeveloped lands. Every year thousands of Montanans, as well as people from around the country and the world, come here to enjoy the hiking, fishing, hunting and wildlife watching available in these roadless areas. These activities are essential to are local economy which relies heavily on tourism and recreation. Rescinding the Roadless Rule will reduce these opportunities and destroy the quiet, undeveloped characteristics of the land that motivates people to come here for recreation. In addition, rescinding the Roadless Rule will especially effect those of us who live in an area prone to wildfires. Building new roads deeper into our forests will increase the chances of fires being started in these areas. 85% of wildfires are human caused and research shows that between 80 and 90% of wildfires start within ½ mile of a road. I urge you to select Alternative 1 (No Action) to keep the 2001 Roadless Rule intact.

Dear Forest Service Leadership: As an outdoor enthusiast, I know the value of what this rule protects — and it's not replaceable. I live here in the mountains only 10 miles from Big Butt, Hicky Fork and Mill Creek. I hike these areas several times every year. In 1972 three friends and I hiked up Big Butt, camped and gloried in the sunset. I moved here to continue that experience. My community depends on that unroaded watershed for drinking water, trout fishing, and clean air. Regarding the Bald Mountain in the Pisgah National Forest, North Carolina: The Bald Mountain IRA, Pisgah National Forest, supplies water to downstream users who depend on its current quality. National forests provide drinking water to over 60 million Americans. The headwaters in this roadless area contribute to that supply precisely because road-generated sediment, the dominant non-point source pollution in national forests, is absent. The Bald Mountain IRA, Pisgah National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently. The DEIS must evaluate the cumulative effects of road construction in the Bald Mountain IRA, Pisgah National Forest, on downstream water users, including changes to turbidity, temperature, and flow regime. The analysis must include the cost of increased water treatment required by downstream municipalities and the economic impact on downstream fisheries and recreation. "Riparian shade restoration (2000s climate) could decrease mean August stream temperatures by 0.62°C across the study network. Removing the current riparian shade resulted in a nearly 50% loss of habitat meeting the numeric temperature water quality criteria (12°C 7DADM) for char spawning and rearing, while restoring vegetation only increased the proportion of fish habitat meeting the criteria by ~10%. The linear relationship established in our models between reach shade and stream temperature indicates an increase of ~40% reach shade should cool a stream reach by ~1°C." — Restoration Ecology (PMC/Wiley), 2022 The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. This comment constitutes a formal objection to rescission of the Roadless Area Conservation Rule and a request for its retention. In earnest, CommentID: RLC-20261006-3PKHM7

I'm a hiker, trail runner and mountain biker. I appreciate the presence of Wilderness and understand and accept and applaud that mountain biking is not allowed in Wilderness. Because of that, the closest thing to a wilderness experience on a mountain bike are roadless areas. Some I've ridden and appreciate include the Warm Springs complex of trails off of Lost Trail Pass, Mill Creek and Carlton Ridge outside of Lolo, Alpine 7 in the Swans. I have treasured and loved these experiences to get into the backcountry and have a sense of a landscape (relatively) untouched by man. Having just returned from 3 weeks hiking and biking in the European Alps, I can personally attest that while the huts and restaurants along the trails are cute and convenient and a must-do, you definitely don't get the sense of being out in it. And the biggest difference was the utter lack of wildlife. We have lots of roads that lead to lots of places and to plenty of harvestable timber. Lets keep the roadless areas - roadless. And give us mechanized folks a place to have the next closest thing to a Wilderness experience. Our public lands truly are the envy of the world and rightly so.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Sierra Nevada is where I go to remember what the world is supposed to look like. I hike, backpack, and camp across its National Forests, Wilderness Areas, and National Parks, moving through places like Black Mtn., Lion Ridge, Greenhorn Creek, Slate Mtn., Chico, Mill Creek, and the Kings River country in Sequoia and Sierra National Forests. I have stood in those places and watched bears move through timber, tracked deer across open ground, and looked up at elk on ridgelines. I have heard grouse and wild turkeys and birds of so many varieties because I was somewhere far from mass human noise, somewhere animals still live their lives. It breaks my heart to imagine how those places will look if they are opened to roads. All for "better, easier access." That is the phrase that keeps coming back to me, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency's stated rationale for rescission includes wildfire and fuels management. But the agency's own record says something different. Its 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." I have walked through the burned-out corridors in these forests. I know what fire does to bear habitat, to the cover elk depend on, to the granite drainages that deer migrate through. The agency must reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land, and explain why the proposal departs from these findings rather than following them. The economic case for rescission is just as hard to square with the agency's own numbers. Its record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against gains that small, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion road maintenance backlog. I want to know how an action whose own analysis cannot establish a net benefit justifies expanding a road system that the agency cannot currently afford to maintain. The agency argues that state-by-state approaches can do what one national rule does. But the record contains the agency's own acknowledgment of what happened the last time it tried 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." Local and incremental decision-making, the agency's own prior analysis found, can reduce nationally significant roadless values one project at a time, in ways that no single review catches. The bears and elk I have encountered in the Kings River drainage at 52,999 acres and the contiguous Greenhorn Creek country at 28,226 acres do not observe administrative boundaries. The agency must explain how this proposal avoids the specific deficiencies the Ninth Circuit identified the last time a state-by-state scheme replaced the national rule. On statutory authority, the agency contends the 2001 rule exceeded what Congress granted. The court record says otherwise. 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." That court found the 2001 rule was within the authority Congress provided under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes a direct, on-the-record explanation of its legal basis for any position contrary to that holding. We shouldn't interfere with what still exists in these places. The agency should leave the 2001 rule in place. Sincerely, Kenna Watkins Visalia, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I backpack in many areas of the national forest. My first backpacking trip was in the national forest, and I now backpack with my children in places like Mill Creek, Rincon, Channell, and Greenhorn Creek in the Sequoia National Forest. I want these wild places available for their children and their grandchildren. The memories we create in nature are lasting and build resilience. We need a resilient generation now and later. That is why I oppose rescinding the 2001 Roadless Area Conservation Rule. The agency's own record on fire makes the case against this proposal better than I can. The rule's own supporting analysis 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." If the agency now proposes to open areas like Moses, Slate Mtn., and Dennison Peak to new roads in the name of wildfire management, it owes the public a full explanation of how that position squares with what its own DEIS Table 21 found about fire density on roaded versus unroaded land. I ask that the agency reconcile this proposal with those numbers before it proceeds. I am not interested in allowing more roads for logging, and the agency's own economic record does not make a compelling case that anyone should be. The rule's analysis concedes 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 projects timber revenue to itself of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value that its own Cost Benefit Analysis cannot pin above zero. When we don't have funding to maintain what is already there, how can we afford to build more roads? The Forest Service carries a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. The agency must explain how opening areas like Chico, Lion Ridge, and Black Mtn. to new roads serves the public interest when its own numbers cannot establish a net benefit. The proposal argues that state-by-state approaches can substitute for a national rule. The record shows that argument was tried before. The agency's own prior rulemaking process acknowledged "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." California alone holds 381 inventoried roadless areas covering 4,389,760 acres, and 1,034 municipal water intakes in the Pacific Southwest region sit in watersheds containing affected roadless areas. Piecemeal state decisions cannot protect values of that scale. The Ninth Circuit already found that local decision-making can incrementally erode nationally significant roadless values, and the court rejected the state-by-state substitute. How does this proposal avoid those same deficiencies? The proposal also suggests the 2001 rule exceeded the agency's authority. That question was litigated. The Tenth Circuit held, exercising jurisdiction under 28 U.S.C. Section 1291, that it would "REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must state plainly, on the record, what legal basis it believes supports a contrary position now. My daughter once attended a camp for diabetic children where campers hiked into the national forest, showing them their condition does not define who they are or what they are able to do. I want that available to others. These are the places that do that work. Nature is healing, and I want to keep our public land clean, cared for, and free of further development. I urge the agency to withdraw this proposal. Sincerely, Carrie Kears Visalia, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Dispersed camping in the national forests is what I go to these areas for, and I want to be plain about what I stand to lose. The roadless areas of Sequoia National Forest, including Black Mtn. at 15,102 acres, Lion Ridge at 5,265 acres, Greenhorn Creek at 28,226 acres, Slate Mtn. at 12,299 acres, Chico at 39,836 acres, and Mill Creek at 27,643 acres, are places I go to escape. They are also places I photograph, and the wildlife that makes them worth photographing depends on the quiet that roads would end. Roads bring traffic, trash, and people in volumes that these areas were never built to absorb. They scatter wildlife and disrupt the natural ecosystems that give these landscapes their value. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record for Docket FS-2025-0001. The agency frames this proposal partly as a wildfire and fuels management measure. Its own analysis does not support that framing. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency now proposes to build roads into inventoried roadless areas as a fire-management tool, it must explain how that squares with its own finding that roaded lands carry a dramatically higher ignition rate, and it must reconcile that departure with the fire-density data in DEIS Table 21. The economic case for rescission is just as weak. The agency's record already acknowledges 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's own Cost Benefit Analysis projects timber revenues to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. It cannot establish that this action produces a net benefit. Meanwhile, the Forest Service is already carrying a $6.9 billion road maintenance backlog. Rescinding the rule to add roads to a system the agency cannot currently maintain, in pursuit of commodity outputs that represent a fraction of a percent of national production, is what I mean when I say this opens opportunities for unsustainable corporate greed to take over our public lands. The agency must explain on the record how a proposal whose own analysis fails to demonstrate a net benefit justifies expanding that backlog further. The agency argues that state-by-state approaches can replace a single national rule. That argument has already been tested. The agency's 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 rejected the state-petition approach that followed. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and the Pacific Southwest region, which includes California, has 1,034 municipal water intakes sitting in watersheds containing affected roadless areas. Piecemeal state processes have already proven inadequate to protect values at that scale. The agency must explain how this proposal avoids the legal deficiencies the Ninth Circuit identified when the agency last walked this path. Finally, the agency questions whether the 2001 rule exceeded its statutory authority. A federal appellate court already answered that question. 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." That court found the rule within the authority Congress granted under the Organic Act and MUSYA and held that it did not create de facto wilderness. The agency owes a direct explanation of what legal basis it believes supports a contrary position today. The roadless rule already accounts for management of these forests. Rescinding it does not improve management. It removes a protection that courts have upheld, that the agency's own data shows reduces fire ignition, and that stands between the remote places I value and the damage that roads reliably bring. Sincerely, J Fry Visalia, CA

I'm writing to express my strong opposition to the proposal to rescind the 2001 Roadless Area Conservation Rule across our National Forest System lands. The Roadless rule is vital to both the preservation of ecosystems, as well as to ensuring future generations can enjoy these lands as I have over the years. I urge you to maintain these critical protections. Inventoried roadless areas represent some of the last remaining intact ecosystems in our country. They provide irreplaceable habitats for wildlife, safeguard critical migration corridors, protect old-growth forests, and secure pristine watersheds that supply clean drinking water. Allowing road construction and commercial timber harvesting in these areas risks fracturing these fragile habitats beyond repair at a time when ecological resilience is more critical than ever, and for what? So that a handful of people can profit while citizens lose access? These wild undeveloped areas belong to all Americans. They provide unique opportunities for quiet recreation, backcountry hiking, hunting, fishing, and outdoor heritage that disappear once roads are cut and industrial activities begin. I live near the gateway to the southern Sierra Nevada and deeply value having access to untamed landscapes like the Kings River and Mill Creek roadless areas in the Sequoia National Forest. Further, it is my belief that the generations that come after me should get to enjoy that access as well. We are but stewards of this land. While I understand the critical importance of wildfire mitigation and forest health, rolling back a foundational, nationwide conservation rule is a disproportionate measure. Prohibiting new road construction does not prevent fire management; rather, it ensures that management is done sustainably without permanently damaging the wild character of our public forests. Please protect the integrity of our shared natural heritage, respect the decades of public support for these protections, and reject this proposed rollback. Sincerely, Cyntia Medrano Visalia, CA

Subject: Public Comment opposing the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) To the U.S. Forest Service and the Department of Agriculture, I am writing to express my strong opposition to the proposal to rescind the 2001 Roadless Area Conservation Rule. As a resident of Park County, Montana, I urge the USDA to select Alternative 1 (No Action) to leave the 2001 Roadless Rule fully intact and protect our public lands. As someone who cares deeply about the future of Park County, Montana and surrounding public lands, I am concerned about how a rollback would impact the Custer Gallatin National Forest. Protecting these unfragmented landscapes is essential to me for the following reasons: Crucial Wildlife Migration Corridors: The roadless wild lands north of Yellowstone National Park serve as a primary corridor for wildlife moving through the Greater Yellowstone Ecosystem. Our wildlife species are already under threat from ongoing development in this region, maintaining these roadless areas is critical to allowing them to migrate safely through a connected landscape. Vital Habitat for Vulnerable and Iconic Species: Roadless areas hold low-elevation forests, wetlands, canyons and other undeveloped lands critical to overall ecological health. With no roads to divide them, these Roadless areas provide unbroken safety for many threatened and iconic species like grizzly bears, wolves and elk. Our local roadless areas and wildlife populations are deeply important. I regularly spend time in Roadless Areas in Park County and the Custer Gallatin National Forest. On a weekly basis I can be found hiking, skiing and observing wildlife in nearby drainages such as Suce Creek, South Fork of Deep Creek, George Lake, Mill Creek (including Wicked Creek, JoMaHa Creek) as well as the Jardine and Eagle Creek areas north of Gardiner Montana. Maintaining these sanctuaries as roadless is important to me and critical to the wildlife populations that reside and move through these areas. The Roadless Rule is a proven, forward-thinking policy that protects the fundamental resources of our local communities—our clean water, our economy, and our wildlife. Please abandon the proposal to rescind these protections and uphold Alternative 1 (No Action). Sincerely, Melissa Stringham Frady Livingston, Montana

I am opposed to the proposed changes to roadless areas. As a mountain biker, I value opportunities to recreate on trails that are not used by motorists. Motorcycles and dirt bikes quickly deteriorate the quality of the trail, disrupt wildlife, and cause noise pollution, prohibiting me from seeing wildlife of my own. It also disrupts the hunting I do in these areas. Some of my favorite trails that fall into this category in Northwest Montana include the following: - Warm Springs Complex at Lost Trail Pass: Warm Springs Ridge, Colter Creek, Porcupine, Fire Creek, Warm Springs Creek - Palisades/Willow Creek - All of Rock Creek outside of Welcome Cr W - Carlton Ridge and Mill Creek - Petty Mountain and Albert Creek Rescinding the roadless rule in place would ruin the experience of the thousands of people currently accessing and maintaining these areas. Thank you for your consideration.

I am writing to express my opposition to the proposal to rescind the Roadless Area Conservation Rule (the Roadless Rule) which was enacted in 2001 to protect National Forest lands from new road construction as well as from new extractive efforts. I am an avid mountain biker, backcountry skier, angler, and general adventurer who loves spending time exploring the wild and accessible public lands on the National Forests that are available to me near my home in Missoula, Montana. As an avid mountain biker, I am wholly opposed to the idea of allowing road-building, extractive industries, and selling off of public land from Roadless Areas. Because bikes are not permitted in congressionally designated Wilderness, the wild and remote backcountry trails in Roadless Areas have become the mountain bike community's version of Wilderness. Many areas close to Missoula would be negatively affected if the Roadless Rule were rescinded - like the Warm Spring complex of trails off of Lost Trail Pass, Palisades and Willow Creek trails in the Sapphire Mountains, Carlton Ridge and Mill Creek trails in the Northern Bitterroot Range, and the amazing Alpine 7 Trail in the Swan Mountain Range. These places are where mountain bikers seek a wilderness experience on a bike and it's where I go to connect with myself and with nature in a way that is not accessible in developed areas and areas filled with roads for logging and other extractive industries. Taking away the rule that protects the wild and remote character of these areas is unacceptable and will negatively impact the trails, the people who recreate on these trails, and the gateway communities who rely on recreation in these Roadless Areas as part of their economy. I'd like the USDA to maintain the Roadless Area Conservation Rule. Please consider actively maintaining the undeveloped, backcountry character of Roadless Areas, recognizing that their value is rooted in a sense of remoteness, quietude, and connection to nature. Please also prioritize high-quality trail access and recreation experiences that sustain local economies and provide meaningful, low-impact outdoor adventure opportunities. Ensure balance rather than dominance in future resource development; so infrastructure or extractive uses don't interfere with or overwhelm the recreational and ecological values that define the Roadless Area landscapes.

I'm very concerned that a huge amount of mountain biking trails inlcuding the following at the bottom of this comment will be ruined or destroyed by this potential roadless change for these ares. Please keep the rule in place to not allow new roads, extraction or anything else that could destory these wonderful outdoor recreation areas. They offer solace to so many locals and also drive tourism dollars in each of these surrounding communities. If roads are allowed to run through these areas, it will be a big loss to all of us that enjoy them and economically to each of these small communities that depend on the tourism dollars. Warm Springs Complex at Lost Trail Pass: Warm Springs Ridge, Colter Creek, Porcupine, Fire Creek, Warm Springs Creek Palisades/Willow Creek All of Rock Creek outside of Welcome Cr W Carlton Ridge and Mill Creek Petty Mountain and Albert Creek Alpine 7 Thank you for listening,

Please don’t rescind the roadless rule. These last tracts of old growth forest need to be protected for our children and their children's children. If they are destroyed, they are gone forever. These trees, this wilderness are part of the lungs of the planet. Along with protected areas in Canada, Patagonia, and other countries, they breathe in carbon dioxide and breathe out oxygen. They create a home for countless wild creatures: birds, bears, wolves, snakes, otters, marmots, bats, deer, cougar, fox, coyote, turtle, and badger. As many as 414 animals and plants listed as endangered, threatened or proposed for listing under the Endangered Species Act have ranges that overlap with roadless areas. Sierra Nevada Red Fox (Vulpes vulpes necator) The Sierra Nevada red fox is one of North America’s most endangered mammals, enduring in the high, snowy mountains of Oregon and California. Most often, this rare fox quietly pads through the snow-covered highlands undetected. However, without proper habitat protection, it could quietly disappear altogether. The numbers are dire: fewer than 40 individuals remain in the Sierra Nevada portion of its range, with the total population likely to number in the hundreds at most. Because Sierra Nevada red foxes are now so rare, direct sightings are incredibly unusual. Instead, biologists document their presence indirectly through game cameras and scat detection . Such “sightings” are often on remote, mountainous federal lands, including the Lassen, Stanislaus, Deschutes, and Mt. Hood National Forests. Relictual Slender Salamander (Batrachoseps relictus) No bigger than a crayon, the relictual slender salamander is considered a “microendemic” species—one that only exists in an extremely small range. Its habitat occurs on a single mountaintop in the southern Sierra Nevada of California. Over half its suitable habitat is protected by the Mill Creek Inventoried Roadless Area within the Sequoia National Forest. The U.S. Fish and Wildlife Service identified habitat degradation associated with road construction as a primary threat to the species’ continued persistence. Given this precariousness, it is unsurprising that the relictual slender salamander is proposed for listing as federally endangered. Rescission of the Roadless Rule could obliterate the little remaining intact habitat it has left. Grizzly Bears Ultimately, the recovery of grizzly bears depends on connectivity. Roadless areas function as “stepping stones,” allowing individuals to move between isolated recovery zones and recolonize historic habitats. Without the protection of the Roadless Rule, the natural expansion of the grizzly bear will become considerably more challenging. Jaguar (Panthera onca) The Chiricahua Roadless Area, located within the Coronado National Forest in southeast Arizona, is a hot spot for biodiversity. It contains suitable habitat for 57 at-risk wildlife, including the endangered jaguar. The Chiricahua Mountains, spanning roughly 700 square miles, serve as the home range for a specific male jaguar known to researchers as “ Jaguar #3 .” Students in Tucson have nicknamed the cat “Sombra,” Spanish for “shadow.” This individual was first detected in 2016 and has been photographed about 50 times since. The Chiricahua Mountains serve as an important dispersal corridor for jaguars like Sombra, moving north from core breeding populations in Mexico into the United States. Recovering the endangered jaguar requires conservation of its remaining habitat. Roadless areas in the borderlands are essential for facilitating safe wildlife movement across the landscape and for supporting the re-establishment of jaguars in the American Southwest.  Canada Lynx (Lynx canadensis) Over two million acres of lynx critical habitat are currently protected by the Roadless Rule. Thanks to protected lands like these, the U.S. Fish and Wildlife Service found that “current regional effects of timber harvest and thinning appear to occur at levels that are not likely threatening western lynx populations.” Removing roadless protections will increase threats to lynx, allowing more logging and development in their habitat. Southern Appalachian Brook Trout (Salvelinus fontinalis) There are currently more than 600,000 acres of roadless areas in the South.These areas provide prime fish habitat free from logging, roads and culvert barriers. For example, most brook trout streams left in Georgia and South Carolina are in the Chattahoochee and Sumter National Forests. There, roadless areas overlap 2,500 acres of intact brook trout habitat. Protecting these roadless forests, along with other actions, can help conserve native brook trout.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The steep trails inside Chico, Lion Ridge, and Mill Creek in Sequoia National Forest are where my wife and I go to get away from the hustle and bustle of the city. The intensity of those climbs is the point. We love the workout the forests provide, and in those same hours my wife photographs lakes, ponds, and trees while I look for birds. We want our kids to inherit that same experience, and this proposal puts it at risk without a credible justification for doing so. The agency's own record undermines its stated rationale on wildfire. The DEIS states plainly: "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." If the proposal is justified in part on fuels management grounds, the agency must explain why it departs from that finding, and it must 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. I photograph birds in these forests, and the DEIS cites findings that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely, and that bird richness declines with road presence in forested habitat. Chico alone covers 39,836 acres, Lion Ridge 5,265, and Mill Creek 27,643 acres of Sequoia National Forest. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The birds I go looking for, the water those forests protect, and the recreation my family depends on are all implicated here. I ask the agency to address in its final record what it intends to do about the documented relationship between road presence and the decline of forested bird communities in the areas this rule currently protects. The economics of this proposal do not hold together. The DEIS itself 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." The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit, and the road system this proposal would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile those numbers publicly before this proposal advances. The regulatory flexibility certification compounds the problem. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than assessing the businesses actually holding permits in the affected areas. The agency should withdraw that certification and replace it with one grounded in the actual permit holders operating in these roadless areas. Finally, 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. My family has built our expectations around these places remaining intact. The Forest Service held more than 600 public meetings and received 1.6 million comments before establishing this rule. It has held none to undo it. Under binding administrative law, an agency changing course must assess the reliance interests its prior policy created. This comment is one such interest, and the agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. Sincerely, Rob Michaelis Los Angeles, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The outdoors is worth protecting for its own sake. I go to places like Mill Creek in Sequoia National Forest in California to experience the landscape, get exercise, and connect with the natural world. I photograph wildlife, sunsets, and rivers. What I find there is not a commodity to be extracted but a common good to be kept whole. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens that, and this letter explains why the agency has not made an adequate case for it. The fire argument the agency offers cuts directly against the proposal. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The DEIS makes this precise: "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." I photograph and hike in these places. The wildlife I go looking for, the rivers I frame in a viewfinder, the landscape I move through for exercise, all of it is subject to fire risk that the agency's own numbers show increases with road access. The agency must explain, in quantitative terms, how it weighs an expected increase in human-caused ignitions against whatever hazard reduction it claims road access would produce, and it must do so before any final rule issues. The economic certification does not hold up. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The businesses tied to clean water, wildlife habitat, and undeveloped scenery in places like Mill Creek are not a national average. The agency must withdraw the small-business certification and replace it with an analysis of the specific firms operating under permit in the potentially affected roadless areas. On reliance, the agency's own notice makes the problem plain. 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 exactly the kind of reliance interest the notice invites. I plan my recreation, my photography, and my connection to public land around the expectation that inventoried roadless areas remain protected. An agency changing course is required to identify and weigh the reliance interests its prior policy created, not simply collect them and set them aside. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, and must explain what weight they received in the final decision. Public land exists for the common good and to protect nature. That is not a sentimental position. It is reflected in the agency's own data, which show dramatically lower fire ignition rates inside roadless areas, recreation benefits the Cost Benefit Analysis itself quantifies, and water supply values touching more than a thousand municipal intakes in this region alone. The case for rescission rests on fire management rationale that the agency's own DEIS contradicts, a small-business finding that examines the wrong population, and a reliance inquiry the Cost Benefit Analysis never completes. None of that meets the standard required for a reasoned change of course. Sincerely, Sarah Timberman Los Angeles, CA

I am a fisherman who regularly fishes streams flowing through roadless areas, including the Middle and North Forks of the Feather River, Deer Creek, Mill Creek, Nelson Creek, and Chipps Creek on Plumas and Lassen National Forests. Trout have survived in these waters because they are relatively clean and cold, unpolluted by sediment from roads. I am concerned about the potential damage to these fisheries and increased fire risk that will result from new road construction if the roadless rule is repealed. The Plumas National Forest (PNF), near where I live, already has a huge network of 3854 miles of roads. This comes out to approximately 2 miles of road per every square mile of national forest land. Over 380,000 miles of roads have already been built on national forests land across the country. The Forest Service has not been able to maintain this existing road network due to inadequate appropriations (Forest Service appropriations cover less than 10% of annual road maintenance needs). The problem has only gotten worse with recent staff cuts. The maintenance backlog for the existing Forest Service road network is estimated at over $6 billion. More road construction will swell this backlog. The Forest Service does not have the staff and funding to maintain the current road network; the idea that they will be able to maintain an even larger network is ridiculous. Over 80 percent of wildfires are human-caused, and Forest Service research shows that human-caused fires are three times more likely adjacent to roads than in roadless lands. So increasing human access by road would increase, not reduce, fires. The Roadless Rule allows hazardous fuel reduction projects, which have been conducted on millions of acres in roadless areas, so repealing the rule would not improve fuel management. The rule also does not prevent wildfire suppression. So the claim that rescinding the rule would improve fuel hazard management and fire suppression is a fabrication. The roadless rule as written already provides the necessary management flexibility for these areas, while reducing the risk of severe wildfires that increases with the presence of roads. Roads have numerous other negative effects. One of the most important is sedimentation of streams, which smothers fish and eggs, warms water which deprives trout and salmon of oxygen, and pollutes drinking water. This problem gets worse when roads can’t be maintained. This will increase if even more roads are built and added to the maintenance backlog. Maintaining areas as roadless means less worry for forest managers about fires in these areas, so that they can concentrate their efforts on the wildland-urban interface, where fuel reduction is most important. Elimination of the Roadless Rule would worsen forest, stream and watershed management. Please retain the existing rule.