Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking takes me away from road noise and into a wilderness that is blissful and magical, and I need it to stay that way. Washington holds 139 inventoried roadless areas covering 2,014,832 acres, and I have lived here my whole life with so much still left to see. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to enter this letter into the record for Docket FS-2025-0001. The strongest argument against this rescission is drinking water, and the agency's own numbers make it. The DEIS states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Across the Pacific Northwest region alone, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Water is an increasingly precious commodity. Drinking water is a necessity of life. Yet the agency offers no enforceable replacement for 36 CFR 294.12 and 294.13, pointing instead to forest plans without naming a single provision that does equivalent work. I ask the agency to identify, forest by forest, which plan provisions stand in for those protections in municipal watersheds. The agency also quantifies the sediment threat and then walks away from it. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number is in the document. What follows it is silence: no projection of how much of that sediment reaches the intakes downstream. The agency owes the public a quantified estimate of projected sediment delivery to the more than 7,000 municipal intakes below these areas. I want that projection before any final rule issues. The road maintenance problem makes this worse, not better. The DEIS concedes: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." The agency proposes to add road mileage in the same document where it admits it cannot maintain the roads it already has. I ask the agency to explain, with specifics, how it reconciles that contradiction. Mountain goats, brown bears, and deer are treats to see, but their homeland is being disrupted, and I notice them appearing in places they should not be before we start seeing less of them altogether. The area I care about includes Mt. Baker West, 25,390 acres inside Mt. Baker-Snoqualmie National Forest. The DEIS built Alternative 3 specifically because commenters asked the agency to retain protections for big game habitat, wildlife connectivity, and fisheries. The agency considered that alternative and chose the one that protects none of it. For bears especially, the DEIS draws on the federal grizzly recovery plan, which warns that the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Why did the agency reject Alternative 3, and what does it tell the public about how it weighed that evidence against its chosen course? The record needs an answer. The beauty of nature is something learned and honored in my life. I want my children to hear the sound of the woods without cars running through it, to see glaciers and wild places in all their undiluted glory. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It held none to undo it. Meanwhile, 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 expenditure loss across every small firm in the sector nationally, not the guides and outfitters actually permitted in these areas. The agency should withdraw that certification and assess the impact on the businesses that actually operate in the potentially affected roadless areas. A logged grove grows back. A road does not. I ask the agency to keep the Roadless Area Conservation Rule in place. Sincerely, Maddy Seattle, WA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas around Mt. Baker are where I go. Mt. Baker West, Mt. Baker South, Mt. Baker Noisy-Diobsud, Boulder River, Higgins Mountain, Pressentin: these are the places inside Mt. Baker-Snoqualmie National Forest that I care about, that I want protected, and that this rescission would put at risk. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask the agency to take my comments seriously. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The areas I named above account for portions of that inventory that have remained intact because the 2001 rule held. Rescission would expose them to road construction and the cumulative harm that follows. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The forests around Mt. Baker feed those watersheds. Any degradation of the roadless character of areas like Boulder River or Noisy-Diobsud does not stay in the forest; it moves downstream. The agency has not explained adequately how that burden is acceptable. The proposal invokes wildfire and fuels management as a rationale for opening roadless areas to new roads. The agency's own prior analysis says the opposite. Its record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's finding, not mine. The DEIS Table 21 data on fire density reinforce the same conclusion: roaded lands carry higher ignition rates than the roadless areas the rule protects. The agency must explain, with specificity, why this proposal departs from those prior findings, and it must reconcile the rescission with the ignition data already in its own record. The economic case for rescission is similarly weak on its face. The agency's own record 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 revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year, and a net present value range spanning -$92 million to +$199 million. A range that wide cannot establish a net benefit. Expanding a road system already carrying a $6.9 billion maintenance backlog in pursuit of revenue that, by the agency's own accounting, may not materialize is not a defensible economic rationale. I ask the agency to square that arithmetic with the proposal, in plain terms, in the record. The proposal argues that state-specific rulemaking can replace a single national standard. That argument has a history the agency seems unwilling to confront directly. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency has been down this road before, and the Ninth Circuit found the state-by-state replacement deficient. The agency has never adequately answered its own prior finding that local, incremental decision-making erodes nationally significant roadless values in ways a patchwork of state rules cannot prevent. How does this proposal avoid repeating those same deficiencies? Finally, the proposal suggests the 2001 rule exceeded the agency's statutory authority. Courts that examined that question reached a different conclusion. The Tenth Circuit held, reversing the district court and remanding to vacate a permanent injunction: "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 within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and found it did not create de facto wilderness. The agency must identify, with legal precision, the basis for any contrary position it now holds, given that a federal appellate court already resolved this question in the rule's favor. The places I named at the outset are not abstractions. They are specific, inventoried, irreplaceable. The agency should keep the 2001 rule in place. Sincerely, Aimee Ott Bellingham, WA

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,

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The glaciers on Mount Baker feed the water I drink. I live at the base of that mountain, and the roadless areas surrounding it, including Mt. Baker Noisy - Diobsud at 56,039 acres, Mt. Baker West at 25,390 acres, Boulder River at 32,563 acres, and Mt. Baker North at 16,873 acres, along with Pressentin, Higgins Mountain, Mt. Baker South, Prairie Mountain, Glacier Peak I, and White Chuck Mountain, are the landscape I move through to take photographs, to ride, to camp, to breathe fresh air. My ethic for all of it is simple: take only photographs and leave only footprints. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. What I see in the places I described above is that pristine forests disrupted by clear cutting and deforestation drive all wildlife away. When I go out to photograph wildlife, what I want to see is trees, plants, and the full natural habitat that all animals depend on. Gaping areas where all vegetation has been cleared do not make nature more beautiful, and making more roads does not change that. The agency should explain on the record why it believes the opposite. The proposal invokes wildfire management as a reason to rescind this rule. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding directly contradicts the premise that road-building serves fire safety. I ask that the agency reconcile the rescission with its own ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain what justification remains for departing from its own prior findings. The proposal also rests on an economic argument for timber access. The agency's own record 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 to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The road system already carries a $6.9 billion maintenance backlog. Clear cutting, in my view, is simply stupid when the numbers do not support it. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding that backlog further. My water comes directly from a glacier on Mount Baker. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. More roads mean more pollution, more sediment, and more degradation of the clean fresh water that people here depend on. This is not abstract to me. The agency must address why this hydrological risk, documented in its own analyses, is being discounted in favor of an action whose economic case is, at best, uncertain. The agency argues that state-by-state approaches can replace a national rule. The record before the agency includes its own prior statement 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." But the agency's own record also acknowledged that local decision-making can incrementally reduce nationally significant roadless values, and the Ninth Circuit identified deficiencies the last time the agency tried replacing the national rule with a state-by-state approach. The agency should explain how this proposal avoids those same deficiencies. Finally, on the question of statutory authority, the agency's own appellate record contains this holding: "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 Tenth Circuit found the 2001 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 owes a specific explanation, grounded in law, for any position that departs from that holding. Our forests do not need more roads. We need more people cleaning up. I ask the agency to deny this rescission. Sincerely, Christina Danielson Deming Washington

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The long-term effects of increased development on the places we are asking our children to inherit will outweigh, substantially and eternally in magnitude and duration, whatever short-term gains rescinding this rule might offer. That calculus applies directly to the 25,390 acres of Mt. Baker West in the Mt. Baker-Snoqualmie National Forest, and to the 2,014,832 acres across Washington's 139 inventoried roadless areas that stand behind it. I oppose rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer the following. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own record cuts the other way. 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 roads increase ignition risk rather than reduce it, the agency must explain why that finding supports rescission rather than the opposite conclusion. The agency should reconcile this proposal with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why those findings have been set aside. The agency also suggests the rule creates unworkable permitting and administrative burdens, but its own legal summary of the rule contradicts that framing. The rule, as the agency itself describes it, "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." These exceptions were written to accommodate precisely the circumstances the agency now cites as grounds for rescission. The agency should identify, with specificity, which burdens are not already addressed by the existing exceptions for public health and safety, existing mineral leases, and community wildfire protection, and should quantify those burdens in the record rather than assert them in general terms. The regulatory flexibility certification reaches a no-significant-impact conclusion by distributing the projected loss across every small firm in the relevant sector nationally, rather than examining the outfitters, guides, and tour operators who actually hold permits and operate inside the affected areas. The DEIS names those businesses as affected parties, and the agency's own Cost Benefit Analysis records a minimum of $6.1 million a year in lost recreation benefit. Washington alone has 1,522 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Northwest region, and the communities and small operators whose businesses depend on the character of places like Mt. Baker West are not a national average. The agency should withdraw the small-business certification and conduct a genuine assessment of the firms actually operating in these 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. This comment is one such interest. People who have understood these areas to be protected, and who value them for what they are precisely because roads and industrial development are absent, have built real expectations around the rule's protections. An agency changing course is obligated to identify and weigh the reliance interests its prior policy created. The agency should account for the reliance interests described in the comments it receives, including this one, before any final decision is made. A logged stand grows back. A road does not. For our planet, for our children, this rule must be upheld. Sincerely, Troy McFarland Bellingham, WA

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless forests of Washington state, including the stretches I named in the Olympic National Forest, the Gifford Pinchot, the Wenatchee, and the Mt. Baker-Snoqualmie, are the reason I am filing this comment against the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The areas I listed, among them the 86,000-acre Olympic block, the 74,650-acre Chelan unit in the Wenatchee, and the combined Mt. Baker-Snoqualmie areas running from the 6,335-acre Wobbly unit to the 415,000-acre broader forest inventory, represent exactly what the 2001 rule was written to protect. I oppose the rescission in full. The agency frames this proposal partly as a wildfire and fuels management measure, implying that opening roadless areas to road construction will reduce fire risk. The agency's own record says the opposite. Its prior 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." The roadless blocks in the Mt. Baker-Snoqualmie, including the Glacier Peak K unit at 47,269 acres, the Glacier Peak L unit at 14,084 acres, and the Glacier Peak B unit at 19,328 acres, sit in landscapes where that ignition differential is directly relevant. The agency must explain, with reference to DEIS Table 21, why this proposal departs from its own prior finding that road access raises rather than lowers human ignition rates, and must reconcile that departure with the ignition density data already in its own environmental record. The proposal also rests on timber and energy economics. The agency's own record 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." Against that baseline, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, offset by recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, a span so wide it cannot establish a net benefit. The Forest Service road system already carries a $6.9 billion maintenance backlog. The units I named, including the 25,390-acre Mt. Baker West and the 24,847-acre Mt. Baker Ma, sit within a forest system that cannot maintain what it already has. How does the agency justify expanding that system when its own analysis cannot demonstrate the action produces a net economic gain? On the question of permitting and administrative burden, the agency contends the rule imposes constraints that prevent necessary management. But the rule as written already accommodates that management. The agency's own summary states it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The 8,676-acre Tumwater unit and the 6,570-acre Mt. Baker South unit are the kind of areas the existing exceptions were written to address. The agency must identify, with specificity, which management needs fall outside those existing exceptions, including those covering public health and safety, existing mineral leases, and community wildfire protection, and must quantify those burdens in the record rather than assert them. Finally, the alternatives analysis underlying this proposal is built on a purpose statement written as deregulation, which eliminated every protective option before comparison could occur. The agency dismissed alternatives with more protection as not responsive to the deregulatory executive orders, and eliminated the keep-boundaries option because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose and need framed entirely around reducing regulatory requirements cannot satisfy NEPA's requirement to consider a genuine range of alternatives. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule without honestly analysing a protective alternative treats that water supply, and every other roadless value, as outside the scope of review by design. The agency must restate the purpose and need in terms of actual forest and watershed conditions and carry at least one protective alternative through full analysis before this rulemaking proceeds further. Best, Sophia Simpson-Khan Olympia, WA

I moved to Bellingham, Washington specifically for the outdoor access to undeveloped forests and protected land. That choice was deliberate, and the places I am writing about are not abstractions to me. I backcountry ski, hike, and camp in Mt. Baker-Snoqualmie National Forest most weekends. I backcountry ski in Mt. Baker West, a 25,390-acre inventoried roadless area, and in Mt. Baker South, which covers 6,570 acres. In the Mt. Baker Noisy - Diobsud area, I backcountry ski, hike, and bike. I also ride mountain bikes on the east side of the Cascades, and those backcountry trips are always some of my favorite memories from each year. These places are special to me and to my partner. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The agency's stated justification that rescission serves wildfire and fuels management cannot survive its own record. The agency's own prior findings state: "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 noticed an increase in poor air quality from fire seasons, and I know that even when fires burn in remote areas, they affect the air that millions breathe in major cities like Seattle. Expanding road access into the roadless areas where I ski and hike does not reduce that risk. It compounds it. The agency must explain in this proceeding why the proposal departs from that prior finding and 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. The economic case for rescission is just as difficult to square with the agency's own numbers. The record before the agency 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 to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency should explain how expanding a road system with a known billion-dollar maintenance deficit, for commodity yields the record itself describes as marginal, constitutes sound stewardship of these landscapes. The regulatory flexibility certification compounds that problem. The proposed rule certifies no significant impact on small entities while, as the record itself shows, the DEIS names outfitters, guides and tour operators as affected and the Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting analysis reaches its no-impact conclusion by spreading expenditure losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas, and it concedes that some firms may lose those receipts entirely. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not a national average firm that has no permit at stake. Finally, the agency has invited comments on reliance interests. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I moved to Bellingham because the rule existed and because it meant the forests where I ski and ride and camp would remain intact. That is a reliance interest the agency created and has not assessed. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Nils Kingston Bow, WA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The creeks I fish off-trail and the roadless country I hike across more than a dozen times a year are the reason I am filing this comment. The areas I am writing about, Pressentin, Mt. Baker West, Boulder River, Mt. Baker South, Mt. Baker Noisy-Diobsud, and Higgins Mountain, all within Mt. Baker-Snoqualmie National Forest in Washington, are places where I can be in the presence of wildlife without having other humans around. That matters to me. It brings perspective to my world, and no amount of timber or gas revenue restores it once a road goes in. The agency's own record on fire contradicts the case it is now making. 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." The proposal nonetheless invokes wildfire and fuels management as a justification for opening these areas to roads. The agency must explain the departure, reconcile the rescission with DEIS Table 21's ignition data showing far higher fire density on roaded land, and address specifically why that finding does not apply to the roadless units I fish and hike on the Mt. Baker-Snoqualmie. The economics are also poorly supported. The record before the agency 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." Against that, the agency's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. It cannot establish a net benefit. Washington already holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas, including the creek drainages where I fish. The agency needs to explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when its own analysis cannot confirm the action produces a net gain. The proposal also argues that state-by-state approaches can substitute for a national rule. The record shows the agency has been down that road. The DEIS states 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." That prior state-specific approach was challenged and failed in court. The agency must address its own finding that local decision-making can incrementally erode nationally significant roadless values and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the national rule was replaced with a patchwork of state petitions. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. The Tenth Circuit addressed that question directly. Reviewing the challenge to the rule, it 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 was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency should state plainly, with legal reasoning, why it believes any contrary position is supportable given that holding. I fish creeks I reach by going off-trail. I hike these forests to find quiet country. What I am asking is straightforward: before this agency removes the protection that keeps these places intact, it must answer the questions its own record raises and has not resolved. Sincerely, JUSTIN GERARDY GLACIER, WA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The places I love most are ones where roads have not yet followed. I camp with my family near national parks, hike into forests where running water moves through old growth, and photograph rivers, waterfalls, creeks, and lakes. There is a sense of peace and quiet out there that it is impossible to get elsewhere, even in a rural agricultural area. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule filed under Docket FS-2025-0001, and I ask this agency to answer the specific points below before it acts. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. I have a personal connection to several of them. Olympic National Forest holds 86,000 roadless acres and was one of the first national forests I visited on my own. I have hiked there, and I believe the number of roads it currently has is enough to sustain the area. The roadless areas of Mt. Baker-Snoqualmie National Forest, including Pressentin at 14,545 acres, Higgins Mountain at 13,185 acres, Mt. Baker West at 25,390 acres, Boulder River at 32,563 acres, Mt. Baker South at 6,570 acres, and Mt. Baker Noisy-Diobsud at 56,039 acres, together represent the kind of country where I go to find running water and towering trees. Gifford Pinchot National Forest contributes another 213,000 acres. The beauty of the roadless areas should be preserved. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Opening these forests to roads risks water quality through pollutants, plant life through greater exposure to invasive species, wildlife through noise and light, and air quality. I ask that the agency address how those 1,522 intakes will be protected if roadless protections are lifted. The agency's own findings on fire contradict its stated justification for this rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I agree that fire season is a serious problem, but it is serious in large part because controlled burns were suppressed for hundreds of years, allowing fuels to accumulate. Managing that fuel load does not require building roads for the general public to drive through. I ask that the agency explain why this proposal departs from its own prior findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is not made. The agency's own record 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 $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 negative $92 million to positive $199 million. Meanwhile, the Forest Service is already $6.9 billion behind on maintaining the roads it has, on a road budget of about $73 million a year. Maintain the roads we have, connecting the neighborhoods and communities we already have. That will do more good for the country than adding roads. The agency must reconcile this proposal with a Cost Benefit Analysis that cannot establish a net benefit while expanding a road system already carrying that backlog. 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. This comment is such a reliance interest. My family plans trips around the existence of these protected places. The rule was built on more than 600 public meetings and 1.6 million public comments; it has shaped how people like me understand and use these forests for more than two decades. Not just our children, but our children's children down to seven generations from now deserve to inherit these spaces. The agency must identify and weigh the reliance interests expressed in the comments it receives, including this one. Sincerely, Julie Clark Coupeville, WA

Dear Mr. Schultz: As someone on public land most weekends, the Rule does what it says. Don't touch it. I hike in and commune with this and surrounding 'roadless areas' many weeks throughout the years over the past 30 years. I am committed to it's complete preservation. My first hike up Riddley Creek trail as a young wanderer opened my eyes to the shocking beauty that untouched (non-roaded) wilderness areas let us experience. I built a strong desire to stay close to and work to preserve that beauty with the whole of my efforts. I have seen over the years that no new roads being made here have helped to preserve what precious wilds we still have. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: Oregon Spotted Frog (Rana pretiosa, G2, T) — an imperiled species — is documented present in the Mt. Baker West IRA and ecologically associated with Pacific Northwest Dry Silver Fir Forest (North Pacific Dry-Mesic Silver Fir-Western Hemlock-Douglas-fir Forest) (GNR, 5.2% of the area, ~1,313 acres). A species ranked G2 by NatureServe cannot absorb the habitat degradation that road construction inflicts on its ecosystem in Mt Baker-Snoqualmie National Forest. "Roads dissect previously large patches into smaller ones and create forest edge habitat along both sides of the road. This can lead to a change in community composition because species that depend on particular interior habitat conditions would be removed. Three variables changed significantly with increasing distance from the road to the forest interior along wide roads: tree biomass, herbaceous plant biomass, and soil pH." — Springer Nature / Landscape Ecology, 2020 NatureServe documents Oregon Spotted Frog (Rana pretiosa, G2) as ecologically associated with Pacific Northwest Dry Silver Fir Forest (North Pacific Dry-Mesic Silver Fir-Western Hemlock-Douglas-fir Forest). Species presence data independently confirms the species occupies the Mt. Baker West IRA. Road construction breaks the link between these two documented facts by degrading the ecosystem the species depends on — fragmenting habitat, altering hydrology, and introducing disturbance into previously intact forest. The DEIS must use NatureServe's ecological association data linking Oregon Spotted Frog (Rana pretiosa, G2, T) to Pacific Northwest Dry Silver Fir Forest (North Pacific Dry-Mesic Silver Fir-Western Hemlock-Douglas-fir Forest) (GNR) when analyzing road construction impacts in the Mt. Baker West IRA. This peer-reviewed, publicly available evidence is part of the best available science the agency is obligated to consider. Rescinding the roaless rule would absolutely increase the possibilities of extractive entities to raze through our sacred forests, destroying the vital habitat that protects and connects us all. best, CommentID: RLC-20260926-GF9FVW

As someone who has spent considerable time accessing national forests specifically in areas the 2001 Rule has kept outside the road system, I am in a position to observe that the qualities those areas retain — watershed function, interior acoustic character, landscape continuity — are not incidental but are direct products of the Rule's regulatory prohibition. Your statement1 Roadless areas in our national forests are absolutely mandatory for the preservation, health, and continuation of these invaluable treasures. They contribute to offset carbon, protect large areas from invasive species and the risk of fires that follow road incursions into pristine forests. Regarding fire, for example, most ignitions near roads are human-caused. One study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Roadless areas also protect wildlife and threatened plant and animal species. The wildlife communities reflect the vertical zonation of forest and alpine habitats. In the dense hemlock-fir forests, the federally threatened Northern spotted owl hunts small mammals under cover of old-growth canopy, while the federally threatened Marbled Murrelet nests in the largest trees. The federally endangered gray wolf moves through these forests as an apex predator, and the federally threatened North American wolverine ranges across high-elevation terrain. In streams and cold-water tributaries, the federally threatened Bull Trout and the proposed Similarity of Appearance (Threatened) Dolly Varden occupy distinct niches in the aquatic food web, with Chinook salmon moving through larger channels during spawning seasons. Above the forest, the federally threatened Mt. Rainier white-tailed ptarmigan inhabits alpine heather communities, where Suckley's cuckoo bumble bee, proposed for federal endangered status, pollinates alpine flowers. The proposed threatened Monarch butterfly passes through the area during migration, while the federally threatened Yellow-billed Cuckoo uses riparian corridors in lower elevations. Roadless areas protect water availability and water quality, increasingly critical as our planet undergoes wide fluctuations between drought and flood. Mt. Baker West spans 25,390 acres across the subalpine terrain of the Mt. Baker-Snoqualmie National Forest in Washington. The landscape rises from Bell Pass at 3,900 feet through a series of prominent ridges and peaks—Grouse Ridge, George Peterson Butte, Park Butte, and the Twin Sisters peaks reaching 7,000 feet—that form the South Fork Divide. Water originates in the highest elevations and flows downslope through a network of named streams: the Upper Middle Fork Nooksack River headwaters drain northward through Clearwater Creek, Rocky Creek, and Ridley Creek, while Skookum Creek, Bell Creek, Gallop Creek, Wallace Creek, Green Creek, Rankin Creek, and Cornell Creek carry water through the western and southern portions of the area. The Middle Fork Nooksack River integrates these tributaries into a major watershed system that defines the hydrology of this region. Finally, the Roadless Area Conservation Rule of 2001 established protections for the Mt. Baker West area, a 25,390-acre Inventoried Roadless Area, prohibiting new road construction and timber harvesting. In February 2023, the Nooksack Tribe signed a Memorandum of Understanding with the U.S. Forest Service to co-manage sections of the Mt. Baker-Snoqualmie National Forest, formalizing their ongoing role in the stewardship of these ancestral lands. The Roadless Rule for these national forests must be kept intact. Otherwise the dangers are incalculable - to flora, fauna, waters, agreement with the Nooksack Indian tribe, and with all the American people who actually hold these lands. PLEASE do not rescind the Roadless Rule. I have addressed some of the specific gaps in the Forest Service's EIS, and demand that the Roadless Rule not go into effect. Please listen to the forests. Thank you, Dana Jack

I am a mental health counselor in private practice in Bellingham, Washington. I train clinicians in the neurobiology of nature connection and am the author of a forthcoming book on the subject, Somatic Nature. I live and work downstream of the Mt. Baker-Snoqualmie National Forest. I support Alternative 1 (No Action) and oppose Alternatives 2 and 3. I ask the Forest Service to address each issue below individually in the Final EIS. For over a decade I have done therapeutic work in and around the roadless areas of the North Fork Nooksack and Baker Lake, and I helped develop Wild Whatcom, a Bellingham nonprofit that brought youth groups into these areas. It now serves over 3,000 participants a year, including 1,200+ public school students in Title 1 classrooms and students with disabilities. A Stanford study interviewing former participants five to ten years later found they credited the program with a lasting connection to nature, gains in self- and social esteem, and shaping major life choices (Clark, 2020). In my clinical observation, these benefits extend from participants to their families and community. 1.The wildfire rationale is contradicted by the DEIS's own data. The DEIS claims the rule limited management and so contributed to wildfire and forest-health problems. Yet its fire analysis (Table 21) reports ignition density in roadless areas of about 12 fires per million acres per year, under a third of the 42 on other National Forest System lands, and acknowledges human-caused ignitions increase near roads. The Economic Analysis concedes more road access could increase wildfires. And 1.8 million acres of hazardous fuels reduction occurred inside roadless areas under the rule. I ask the Final EIS to reconcile these findings with the purpose and need, and to quantify any net fire-risk benefit of new roads rather than assert one. 2.National rankings hide effects in steep, wet, unstable Western Cascades terrain. Whatcom County's portion of this forest holds roughly 91,000 roadless acres, including North Fork Nooksack headwaters, and the Mt. Baker West roadless area includes part of Bellingham's municipal watershed. Harvest and road-building in the Canyon Creek drainage in the 1950s-70s contributed to debris floods that destroyed homes west of Glacier in the 1990s. The forest already has roughly 2,000 miles of road, and the DEIS reports road maintenance funding below 20 percent of need. Yet the DEIS describes road effects only as "more likely" or "less likely," with no projected road miles, sediment, or landslide risk by region, though it quantified roads for the Tongass. I ask the Final EIS to provide regional projections of road construction and their effects on sediment, slope stability, drinking water, and salmon habitat, including rain-on-snow and unstable-slope terrain in the North Cascades. 3.The analysis should account for the health value of unroaded settings. Primitive and semi-primitive recreation settings are among the rule's nine roadless characteristics. Clinically, their therapeutic value depends on sustained quiet, absence of engine noise, and an intact landscape, conditions that help clients, especially young people, settle out of a stress response. Research agrees: a study of nearly 20,000 people found about two hours a week in nature was associated with better health and wellbeing (White et al., 2019, Scientific Reports), and weekly awe walks increased positive emotion and reduced daily distress in older adults (Sturm et al., 2020, Emotion). Roads and logging remove exactly these qualities; a roaded forest is not a substitute. I ask the Final EIS to analyze effects on primitive settings specifically and address their public health benefits in the Cost Benefit Analysis. 4.Forest plans are not a substitute for a binding rule. The DEIS relies on plans as the remaining protection, yet states plans "do not compel action or authorize projects" and future decisions depend on local interpretation. Its plan-restriction figures also merge binding standards with non-binding guidelines. I ask the Final EIS to separate the two and disclose, by forest, including the Mt. Baker-Snoqualmie, how many roadless acres would retain binding prohibitions on roads and timber harvest. By the DEIS's own count, about 99 percent of comments on the Notice of Intent opposed rescission. I urge the Forest Service to adopt Alternative 1 and keep the 2001 Roadless Rule. Matthew Fogarty, Bellingham, WA

My future and my health depend on Roadless Rule protection. I am in graduate school, getting my master's degree in Clinical Mental Health Counseling. I dedicate my life to helping others, so I have a tremendous amount of work to do. It is threatened by the climate crisis and by people who are supposed to uphold environmental protections instead of destroying them. On behalf of humanity, especially the next generation, the Roadless Rule must remain as is. As the future generation and a human. Regarding the Mt. Baker West in the Mt. Baker-Snoqualmie National Forest, Washington: Roadless areas store carbon, buffer temperature extremes, and provide intact refugia where species can shift in response to a warming climate. Cold-water fish habitat is shrinking. Climate warming has reduced cold-water habitat in western U.S. streams, and modest additional warming would shrink it further. (Isaak & Young 2023; Mejia et al. 2023). — Isaak & Young, 2023 (https://doi.org/10.1139/cjfas-2022-0302); Mejia et al., 2023 (https://doi.org/10.1111/gcb.16844) 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. Building more roads in national forests would be a drain on taxpayers. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide, and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” I can not fathom losing the forests I've hiked in throughout my life, and that should be enjoyed by future generations. The Forest Service should know how essential complex forests are to our climate, aka our future. This impacts everyone who breathes air, drinks water, and eats food. These roadless areas are what save us from the worst of these 4 disasters: fires, flooding, droughts, and landslides. As the Forest Service should know, trees sequester a significant amount of carbon, with young trees absorbing 22 lbs of CO₂ annually and mature trees absorbing an average of 48 to 55 lbs of CO₂ per year, sequestering more as they grow. This cools our environment, which is crucial, and prevents devastating wildfires. The cooler environment aids more precipitation, allowing more water to settle deep in the ground where trees store the water in their roots. When it's overly dry due to the heat from global warming, and it hasn't rained substantially for prolonged periods of time, the water, when it does rain, runs off the dirt's dry surface (instead of absorbing in like a sponge when the dirt is properly watered), causing flooding. Again, we need more trees to sequester more carbon so there is less heat, causing more fires. These complex forests also help prevent landslides by holding dirt in place with their roots. Areas with roads experience all these issues in high severity. Countless studies prove this. The Forest Service should know that these roadless areas are priceless and irreplaceable. No amount of money is worth the amount of harm and life-threatening devastation it would cause. Not even close. The forests these rules protect aren't hypothetical. They're real places with real ecological function. Don't open them up to road construction. In earnest, Shira Williamson - Age 27

Dear Ms. Rollins, The direct experience of national forest that remains outside the road system has shown me, as an outdoor enthusiast, that what the 2001 Rule protects is not wilderness designation but something distinct — a category of managed national forest that has been maintained in a condition broadly accessible to the public yet free of road infrastructure, and that condition would not survive rescission intact. I live within 20 miles of Mt Baker West and love the healing environment that it provides for me and multiple friends and endless community members. We cannot afford to lose these wild places that help everyone to connect to nature and improve mental, physical and spiritual health. Please consider all of the life forms of these magnificent places. The concept of "human exceptionalism" is a dead theory as we know that we CANNOT survive without a healthy natural environment that regenerates us I have experienced multiple encounters with natural beauty and wildlife peacefully coexisting on wilderness trips in Washington and Alaska that would not have been possible had they been accessible via roads. I would personally lose the calm feeling of knowing that there are protected places for all of life. Places that have clean air, water and soil that benefits us all, whether we are in direct contact with the place or not. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: The threat mechanism classified as 7.1 - Fire & fire suppression (IUCN-CMP 7.1) is actively degrading habitat for Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) in the Mt. Baker West Inventoried Roadless Area, Mt Baker-Snoqualmie National Forest, at Negligible or <1% pop. decline severity across Pervasive - large scope. The physical footprint of road construction — grading, drainage installation, stream crossings — destabilizes slopes and generates chronic sediment inputs that intensify 7.1 - Fire & fire suppression in the Mt. Baker West IRA. Failure to analyze 7.1 - Fire & fire suppression impacts to Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2, PE) in the Mt. Baker West IRA renders the DEIS inadequate under NEPA. The administrative record must address this species-threat-area interaction or the analysis is arbitrary. "Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term." — Conservation Biology (Wiley), 2013 My ask is simple: keep the 2001 Rule. Thank you for your consideration of ALL of life of which we are a small part. Please listen with heart and act with wisdom. Yours sincerely, CommentID: RLC-20260920-X4SSS0

Dear Chief Tom Schultz, My husband's grandfather was a guide on Mt. Rainier, and our extended family visits the areas he loved every summer. We camp at White River and Ohanapecosh, and walk his favorite hikes in rememberance of him. We've encountered many bears and marmots, and we've noted the change in the alpine meadows flowers. The Nisqually glacier is drastically diminished from what it was 30 years ago. I live near Mount Baker-Snoqualmie Forest in Whatcom County, Washington. 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. Headwater Cold-Water Refuge for Threatened Salmonids — The Upper Middle Fork Nooksack River and its tributaries (Clearwater Creek, Rocky Creek, Ridley Creek, and others) originate in Mt. Baker West's subalpine terrain, where glacial meltwater and high elevation maintain the cold water temperatures essential for bull trout (*Salvelinus confluentus*, federally threatened) and Dolly Varden (*Salvelinus malma*, proposed threatened under similarity of appearance). The Nooksack system currently experiences 27% lower August streamflow than natural conditions due to historical timber harvesting and glacial retreat. This roadless area's intact forest canopy and undisturbed riparian zones preserve the remaining cold-water pulse that these species depend on for spawning and rearing—a function that becomes increasingly critical as climate-driven warming reduces glacial contribution to late-summer flows. “Comprehensive assessment of the conservation value of all 240,000 km&sup2; of Inventoried Roadless Areas. The study finds IRAs would expand the U.S. protected-area system by 27% while disproportionately buffering its largest cores: adjacent IRAs add +29% to Greater Yellowstone, +38% to Central Idaho, +32% to the Bob Marshall, and +31% to the North Cascades. 96% of IRAs are wilder than the median of the contiguous U.S.; 93% lie within 10 km of an existing protected area, providing critical connectivity for climate-driven range shifts. 58% of the watersheds intersecting National Forest System lands supply drinking water to over 48 million people, and adding IRAs to the protected network would increase well-protected drinking-water watersheds by 60%. 74% of all Forest Service wilderness designated since 2000 was first an IRA — the rule is the proven pipeline for permanent congressional protection. The authors warn that because IRAs are an administrative designation, they remain vulnerable to degazettement. — Talty et al., 2020 (https://doi.org/10.1111/csp2.288)” These are public lands and making a radical change should include a serious public process should be sure to include the public. USFS's disclosures on roads and fire undermines the argument that building roads will protect forests. Very truly yours, CommentID: RLC-20260910-N4ESJF

Dear Secretary Rollins and Chief Schultz, As someone who has spent a substantial portion of recreational time on public land specifically because of the conditions roadless designation maintains, I am submitting these comments to urge the Department to conduct a more rigorous accounting of public value before rescinding the 2001 Roadless Area Conservation Rule. While I know the Mt. Baker Snoqualmie National Forest best, I have also spent significant time in some of the last wild places on Earth - including the salmon runs of Alaska, wonderfully intact and protected by the Roadless Rule. I continue to explore the Mount Baker Snoqualmie National Forest, and find it beloved and respected by others who frequent it. Time in the protected forest and proximity to it is one of the reasons I live and enjoy living in the Skagit Valley. I have made my life and livelihood here, and without it I would no longer feel at home. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Trombulak et al., 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) 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. Recission of the roadless rule would be devastating for me personally and for my community who love and respect the outdoors. Unquantified Roadless-Specific Forest Health Data Supporting Causal Rationale The DEIS asserts that the 2001 Roadless Rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns" (Rationale for the Proposed Rule, pp. 18-19), yet this three-step causal chain is offered with no acreage figures, no roadless-specific fire, insect, or disease incidence statistics, and no comparison of forest health outcomes between roaded and roadless lands. An agency asserting materially changed conditions must articulate a rational connection between facts found and the choice made, not a bare assertion, under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983), Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), and unsupported factual premises violate APA 5 U.S.C. § 706(2)(A). I request quantified, roadless-specific data on acres affected, fire risk indices, and treatment backlogs, with a direct roaded-versus-roadless comparison, before this rationale is relied upon to justify rescission. Failure to Provide Sensitivity Analysis for Acreage-Derived Percentages The Draft EIS's own acknowledged 0.4-million-acre discrepancy between the 44.7-million-acre IRA figure and the 44.3-million-acre National Forest System land figure is never carried forward into any of the derivative percentages presented in the Affected Environment section, including the 56 percent Tongass figure, the 66.5 percent timber-harvest restriction figure, the 54.5 percent road-construction restriction figure, and the 2.8 percent NWPS overlap figure (pp. 20-36). Having conceded uncertainty in the base acreage, the agency cannot present percentages calculated from it as precise without disclosing how that uncertainty propagates. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), an agency that identifies a data-quality problem must grapple with its implications for downstream conclusions rather than disclose it in passing. Presenting these figures without error bars is also arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request that the agency provide sensitivity ranges or error bars for every acreage-derived percentage in this section before finalizing the rescission. I oppose this rescission, clearly and without qualification. I'm asking the Department to withdraw the proposal. With respect, E Burnham CommentID: RLC-20260908-0HAQRV

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Mount Baker forest area in the North Cascades is one of the most special and beautiful places I know. I have spent years backpacking and camping there, watching deer, marmots, woodpeckers, eagles, hawks, and the occasional black bear. There are so few of these animals left in this world, and I cannot understand why we cannot learn to protect the little wildlife we have remaining. I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001), which would put at risk the inventoried roadless areas I care about most, including the 56,039-acre Mt. Baker Noisy-Diobsud, the 32,563-acre Boulder River, the 25,390-acre Mt. Baker West, and the many other roadless areas across Mt. Baker-Snoqualmie National Forest in Washington that together form the wild country I return to again and again. My strongest concern is wildfire, because the agency's own record is unambiguous and the rescission ignores it. I have watched wildfire become a more serious issue with every passing season, and I know that putting more roads, vehicles, and people into these forests will make that worse. The agency's own 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." When the proposal justifies rescission on fuels management grounds while the agency's own draft environmental impact statement reports far higher fire density on roaded land than inside roadless areas, that is a contradiction that demands a straight answer. I ask the agency to explain why the proposal departs from these prior findings and to reconcile its ignition data in DEIS Table 21 with the decision to open these areas to roads. The economics do not support this rescission either. The agency's own record 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." Against those marginal extraction figures, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million per year against recreation losses of at least $6.1 million per year, with a net present value ranging from -$92 million to +$199 million. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres, and 1,522 municipal water intakes across the Pacific Northwest sit in watersheds containing roadless areas affected by this rule. The agency cannot establish a net benefit from this action while also defending a road maintenance backlog already carrying a $6.9 billion deficit. I expect the agency to reconcile these numbers publicly. The agency has also argued that state-by-state approaches can replace a national rule, but the record reflects the agency's own prior acknowledgment that the previous administration "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." That state-specific approach was reviewed and rejected in federal court. Similarly, the Tenth Circuit already addressed the statutory authority question the agency now raises, holding that the 2001 rule was within the authority Congress granted and did not create de facto wilderness: "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 owes a clear explanation of how this rescission avoids the same legal deficiencies the courts previously identified, and a direct statement of whatever basis it claims for a contrary reading of agency authority. We should be spending our time, energy, and resources protecting these lands and the wildlife that depend on them. That is what I believe, and that is what the agency's own evidence supports. I ask that each of the specific concerns raised in this comment receive a substantive written response in the final record. Sincerely, Sandra Towne Freeland, Washington

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Access to quiet, healthy, remote forests is directly connected to my health and well-being, and the opportunity to hike and camp in the Mt. Baker-Snoqualmie National Forest matters to me in ways that are not abstract. The roadless areas I use, including Mt. Baker Noisy-Diobsud at 56,039 acres, Boulder River at 32,563 acres, Mt. Baker West at 25,390 acres, Pressentin at 14,545 acres, Higgins Mountain at 13,185 acres, and Mt. Baker South at 6,570 acres, are places people can go to connect with nature and natural beauty, away from roads and other forms of civilization and urbanization. Destroying these places with roads would have negative effects not only on the ecosystems but also on my personal mental health and well-being as someone who frequently recreates there. I oppose the rescission of the 2001 Roadless Area Conservation Rule. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The proposal would expose all of them to road construction, including the areas I have named. The agency defends rescission in part on wildfire and fuels management grounds, but its own 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." That finding sits in the same record as the proposal to eliminate the protections that kept roads out. I ask that the agency explain why the proposal departs from this finding, and reconcile the rescission with the ignition data in its own DEIS Table 21. The same ignition data makes the contradiction 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." The forests I hike in are part of the Pacific Northwest region where I depend on these landscapes remaining unroaded and intact. The agency has not quantified the expected increase in human-caused ignitions from new road access or weighed that increase against the claimed reduction in wildfire hazard. It must do so. Access to clean water is a basic human right and one the government should be striving to protect. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Roads lead to increased pollution and threaten public health and wellness. As drought conditions become more common in the American West, we cannot thoughtlessly contaminate more of our precious drinking water by building roads through important watersheds. The agency's own analysis states that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must address, specifically and on the record, what the rescission means for the 1,522 intakes in the Pacific Northwest region and the communities downstream of the roadless areas in Washington. The proposal's regulatory flexibility analysis reaches a no-significant-impact conclusion by spreading an estimated $9 million annual expenditure loss across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and the analysis concedes some firms may lose these receipts entirely. That certification cannot stand alongside the analysis that produced it. I ask that the agency withdraw the certification and assess impacts on the small entities actually operating in the potentially affected roadless areas, not the national average firm. 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. This comment is precisely such an interest. My use of the Mt. Baker-Snoqualmie roadless areas, and my expectation that public lands will be managed for the preservation of native plants and animals and for the conservation of valuable ecosystem services, developed in reliance on the protections the 2001 rule established. An agency changing course must assess the reliance interests its prior policy created. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. Sincerely, Autumn Maust Clinton, Washington

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The waterfalls tumbling over the ridges of the Boulder River area, the wildflowers in spring, the burning fall colors, the peace of the North Cascades trails I have maintained year after year at Noisy-Diobsud Creek: these places are the reason I am filing this comment opposing the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I hike in and near North Cascades National Park and surrounding areas, I have paddled the Nooksack and Skagit Rivers and their tributaries, and I oppose this proposal on grounds that the agency's own analysis cannot sustain it. The economics here do not add up, and the agency owes the public a clear answer on that. The record before the agency already 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 those figures, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency must reconcile the proposal with that range, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when the agency's own numbers cannot establish a net benefit. The fire question is one I think about directly, because I have seen how the trees and vegetation along these streams hold water in the ground and moderate temperature. Roads let in not only machinery but ignition. The agency's own data is stark: "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 effects analysis concedes that road access could increase the number and frequency of wildfires. The agency must quantify the expected increase in human-caused ignitions that would follow new road access and weigh that increase against any claimed reduction in wildfire hazard before it finalizes this rule. When I paddle the Nooksack and Skagit and see the wildlife that inhabits these waters, I think about what feeds those rivers. It is heartbreaking to consider roads placed near these waters: sediment washed in, logging runoff filling streams, the trees and vegetation removed that keep water cool and in the ground. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The Mt. Baker-Snoqualmie roadless areas I care about, including Boulder River at 32,563 acres, Mt. Baker Noisy-Diobsud at 56,039 acres, Mt. Baker West at 25,390 acres, and Mt. Baker South at 6,570 acres, feed those downstream systems. The agency must explain on the record how it weighs the sediment and runoff consequences of new road construction in these specific watersheds against the interests of the communities and ecosystems they supply. The regulatory flexibility finding cannot stand alongside the analysis the agency itself produced. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting analysis reaches that no-impact conclusion by averaging the loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in these areas, and it concedes that some firms may lose those receipts entirely. The agency should withdraw that certification and conduct an honest assessment of the businesses actually operating in the potentially affected roadless areas. Finally, I have done yearly trail maintenance at Noisy-Diobsud Creek for over 10 years. Boulder River, which I have visited every year, is a photographer's and nature lover's dream. These are not abstract commitments. "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 precisely such a reliance interest, offered in direct response to that solicitation. The agency must identify and genuinely weigh the reliance interests described in the comments it receives, including this one, before it proceeds. Judith Akins Bellingham,WA

Dear Chief Schultz, As an outdoor enthusiast, I've seen what roads do to a landscape I'd been walking into for years. The areas within the Mount Baker Snoqualmie National Forest are truly some of the most spectacular places I have seen. They are a place where I can feel more at home than my own home. They are sacred to me, and to so many forms of life. I visit them regularly with my partner, it is a cradle for our love and the love of our Earth. Seeing them threatened, along with so many other treasured landscapes that are nationally protected by the roadless rule, fills my heart with anxiety and my eyes full of tears. One occasion in particular illustrates what that relationship means in practice. The first time I went swimming in the Nooksack, though the Snoqualmie was no less immaculate. These Rivers have cleansed my soul with their waters every time I have visited. Whether I submerge myself or not they have never failed to heal and rejuvenate my heart. It’s not just for the pristine nature of their waters, to which additional road construction would in fact be detrimental, but also for the complex ecosystems they nourish, which simply cannot survive the way they are now if the roadless rule would be rescinded. Everything is connected and all of it can be felt on the banks of each stream, or even just underneath any one of the trees in the forest. The experience recounted and the connection it reflects are offered as evidence that the Rule's continuation serves identifiable, concrete public interests that the present proposal fails adequately to weigh. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: Interior Forest Habitat for Spotted Owls and Marbled Murrelets — The North Pacific Maritime Silver Fir-Western Hemlock and Subalpine Parkland forests provide interior forest conditions required by northern spotted owl (*Strix occidentalis caurina*, federally threatened with critical habitat designation)… “At intermediate scales, roads disrupt soil structures and hydrological pathways and alter plant and animal communities. Chemical pollution from vehicle exhaust (primarily NOX) enriches roadside soil and changes plant composition, favoring a few dominant flowering plants at the expense of more sensitive plant species (for example, ferns, mosses, and lichens). The extent of this effect can range up to 200 m from multilane highways and up to 35 m from two-lane highways. — National Academies Press / Transportation Research Board, 2005 (https://doi.org/10.17226/11535)” “Two centuries of road building, logging, and aggregate mining have contributed to a ~82% (6200 km2) reduction in unlogged, roadless (>1 km from roads) habitat in Algonquin Park at a mean decline rate of 32 km2/yr. There are at least ~5500 km of roads that fragment Algonquin Park into 732 roadless habitats covering 18% of the Park's area. Decline of roadless habitat has contributed to the impairment of ecological integrity and decline of at least 34 species across all trophic levels, including at least 17 species-at-risk. — MDPI / Biosphere, 2026 (https://doi.org/10.3390/biosphere2010001)” “70% of remaining forest is within 1 km of the forest's edge, subject to the degrading effects of fragmentation. A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time, with average species loss >20% after 1 year and >50% after 10 years. — PMC / Science Advances, 2015 (https://doi.org/10.1126/sciadv.1500052)” “Road construction increases soil compaction up to 200 times relative to undisturbed sites, likely decreasing the survival of soil biota. A road transforms the physical conditions on and adjacent to it, creating edge effects with consequences that extend beyond the time of the road's construction. At least eight physical characteristics of the environment are altered by roads: soil density, temperature, soil water content, light, dust, surface-water flow, pattern of runoff, and sedimentation. Long-term use of roads leads to soil compaction that persists even after use is discontinued; the consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated. — Conservation Biology / Wiley Online Library, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “)” The Rule should remain in full force; the Department is urged to decline the proposed rescission action. Respectfully submitted, CommentID: RLC-20260823-F7M9J8