Read the comments.

Please do NOT rescind the Roadless Rule on our protected public lands. I live in rural Colorado. Our tourism industry in Pagosa Springs depends upon our keeping our wilderness areas pristine. It will be devastating to all the outfitters and back country adventurers who enjoy the largest wilderness area in the lower 48 states. Also, putting roads into our dense Ponderosa pine forests increases the chances for forest fires, and we are just coming out of a devastating fire season.

I oppose the proposed action and any other measures to repeal or weaken the Roadless Area Conservation Rule. Please choose Alternative 1 and retain the current roadless rule. Roadless forests are some of our most valuable public lands, providing clean water, wildlife habitat, recreation opportunities, carbon storage, and places where people can experience the beauty of undeveloped forest. I am particularly concerned about the potential loss of protections for roadless areas in the Methow Valley and throughout Washington. These lands are important to our communities and should remain protected from new roads and commercial timber harvesting. I urge the Forest Service to keep the Roadless Rule in place and protect these remaining wild forests for future generations. Opening up roadless areas to new roads will degrade these important values. Road building also increases the likelihood of uncharacteristic wildfire: the vast majority of wildfires are sparked by human ignitions in proximity to roads. Most importantly, the US Forest Service (USFS) already has 371,000 miles of roads and an enormous backlog of needed road repairs and maintenance. In 2024 the USFS estimated that it has a road maintenance backlog of $10.8 Billion on its current road network. I urge the agency to take this backlog seriously and invest in needed road maintenance, repair and decommissioning. We should take care of our current roads before building new ones. Some of our most beloved lands in Washington are protected as roadless areas – the vast stretches of old growth forest above Lake Quinault, the ponderosa pine forests of the Teanaway Valley and the scenic forests near Washington Pass in the North Cascades. All these areas deserve protection. Please choose Alternative 1 and retain the current roadless rule.

I am a conservationist, multi-state, multi-generational landowner, Master Naturalist, and former Georgia Native Plant Society President and wish to present my objection to the consideration of removing the 2001 Roadless Area Conservation Rule that has stood firm across multiple circuits and implemented by both parties. Protecting the biodiversity of these pristine areas is paramount to me as a voting citizen whose parents taught me to love, respect, respect science, and cherish our land and wild places and the value in education. I strongly oppose rescinding the Roadless Rule in its entirety based as wildfire protection. I am well aware that fire suppression has degraded fire-dependent ecosystems. A century of aggressive fire suppression — made possible by road access — has transformed fire-adapted forests like longleaf and ponderosa pine. This is why we are planting long leaf and potentially Montane Long Leaf on our farms once we have completed our controlled burns and invasive removals. We understand that without periodic low-intensity fire, fuels will accumulate as they have most recently with Helene and forest structure shifts toward conditions that support catastrophic, stand-replacing fires (USDA Forest Service 2001). — USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf) We are well aware that fire suppression has degraded fire-dependent ecosystems. A century of aggressive fire suppression — made possible by road access — has transformed fire-adapted forests like longleaf and ponderosa pine. This is why we are planting long leaf and potentially Montane Long Leaf on our farms once we have completed our controlled burns and invasive removals. We understand that without periodic low-intensity fire, fuels will accumulate as they have most recently with Helene and forest structure shifts toward conditions that support catastrophic, stand-replacing fires (USDA Forest Service 2001). — USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf). We have personally experienced that roads are where most wildfires start. A 2026 study covering 30 years of wildfire data across the entire National Forest System found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied (Aplet et al. 2026). — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2). Most ignitions near roads are also human-caused. The same 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). Best practices we personally witnessed in the Sequoia National Forest is done by workers using manual tools to collect and create burn pyramids to be left in tack until winter when conditions are right for controlled burns. We do not need to introduce roads which are proven to result in soil quality reduction to forest edges; introduction of invasive species and diseases to all areas through use of skid steers and other logging equipment; increased sedimentation in streams and rivers polluting water quality and impacting all aquatic lifeforms but also natural aquifers from which humans draw their drinking water; they create barriers to aquatic and terrestrial movement, increase potential for landslides and disturbances to forest roots and slope stability; introduction of cattle and other agricultural animals will lead to soil erosion, disease, invasive plant expansion and much more I can expand upon. Road construction in roadless areas is the primary cause of ecosystem destruction and endangering wildlife. For these reasons, in addition to the aesthetic loss of our national treasures, we vehemently oppose rescinding the Roadless Rule. Facilitating energy, mineral, and timber production “to the maximum possible extent” on public lands will cost our nation far more in ecological desecration than will be compensated by short-term revenues they generate. Now that the Endangered Species Act no longer defines what is "harmful", we absolutely must protect the habitats of our biodiverse habitats in our public spaces. Wildfires are without doubt attributed to roads and public interaction with our wilderness spaces. I urge you to support H.R. 3930, the Roadless Area Conservation Act, to provide lasting protection for inventoried roadless areas within our treasured National Forest System. With hope, Melanie Pollard

As I look at pictures from the late 1800's, I am shocked that such destruction and devastation to our forests and rivers was ever allowed, and that it was perceived as progress and advancement. The Homestead Act of 1862 and subsequent land laws, like the Timber Culture Act of 1873, drove massive logging and deforestation across the American West. While the laws were intended to encourage settlement and agricultural development, they also created opportunities for lumber companies and speculators to exploit forested lands and cut down some of the most incredible and majestic forests on our planet. Giant Sequoias along with soft wood conifers like White pine, Douglas fir, Long leaf pine and Ponderosa pine were lost to this destruction and logging. These forests have never recovered from this horrific mass deforestation. The Roadless rule was implemented in 2001 to protect 58.5 million acres of national forest land by prohibiting road construction, reconstruction, and timber harvesting. This rule is one of the most important and most valued in the history of the USDA. With more than 1.6 million public comments, this is a historic landmark for any rule in the U.S. Of all the comments received, 95% of the comments were in support of keeping roadless protections in place. The Forest Service's FY26 budget slashes agency funding by more than 60%, and it zeroes out funding for Wildland Fire Management. This is basically stating that wildfire risk management is not their top priority and that they plan to give more power to individual states to decide on logging and land use. Wildfire management has been proven to be more effective in areas with less or no roads. One major reason for this is human access: roads have been linked with most forest fires because they enable human access and the majority of wildfires are human-caused. They also increase ladder fuel with the greater amount of dry, flammable vegetation near the road, and alter micro-climates to be hotter and windier, which also facilitates fire ignition and spread. The importance of having pristine and untouched forests, rivers and streams is beyond what humans can imagine. The value of life itself lies in these places. There is a plethora of wildlife and organisms that depend on these forests, streams and clean rivers. We cannot keep appeasing logging, timber and electric companies to destroy our only habitat for profit and margins. We need to protect and value our ecosystem and stop corporations from destroying our forests and watersheds through ruthless exploitation and extraction of natural resources. I strongly oppose rescinding the 2001 Roadless Rule. We need to keep strong protections in place and the agency needs to respect public opinion. The agency also needs to conduct a complete and thorough environmental analysis and secure that no watersheds will be damaged. The public wants to keep our public lands protected and untouched. Our future generations depend on your duty to protect our forests and rivers! Important links attached to my comments: Science on roads fragmenting the landscape: https://conbio.onlinelibrary.wiley.com/doi/epdf/10.1046/j.1523-1739.1996.10041098.x Current rule in place: https://www.federalregister.gov/d/01-726/p-395 Forest Service FY26 budget: https://www.fs.usda.gov/sites/default/files/fs-fy26-congressional-budget-justification.pdf

As I look at pictures from the late 1800's, I am shocked that such destruction and devastation to our forests and rivers was ever allowed, and that it was perceived as progress and advancement. The Homestead Act of 1862 and subsequent land laws, like the Timber Culture Act of 1873, drove massive logging and deforestation across the American West. While the laws were intended to encourage settlement and agricultural development, they also created opportunities for lumber companies and speculators to exploit forested lands and cut down some of the most incredible and majestic forests on our planet. Giant Sequoias along with soft wood conifers like White pine, Douglas fir, Long leaf pine and Ponderosa pine were lost to this destruction and logging. These forests have never recovered from this horrific mass deforestation. The Roadless rule was implemented in 2001 to protect 58.5 million acres of national forest land by prohibiting road construction, reconstruction, and timber harvesting. This rule is one of the most important and most valued in the history of the USDA. With more than 1.6 million public comments, this is a historic landmark for any rule in the U.S. Of all the comments received, 95% of the comments were in support of keeping roadless protections in place. The Forest Service's FY26 budget slashes agency funding by more than 60%, and it zeroes out funding for Wildland Fire Management. This is basically stating that wildfire risk management is not their top priority and that they plan to give more power to individual states to decide on logging and land use. Wildfire management has been proven to be more effective in areas with less or no roads. One major reason for this is human access: roads have been linked with most forest fires because they enable human access and the majority of wildfires are human-caused. They also increase ladder fuel with the greater amount of dry, flammable vegetation near the road, and alter micro-climates to be hotter and windier, which also facilitates fire ignition and spread. The importance of having pristine and untouched forests, rivers and streams is beyond what humans can imagine. The value of life itself lies in these places. There is a plethora of wildlife and organisms that depend on these forests, streams and clean rivers. We cannot keep appeasing logging, timber and electric companies to destroy our only habitat for profit and margins. We need to protect and value our ecosystem and stop corporations from destroying our forests and watersheds through ruthless exploitation and extraction of natural resources. I strongly oppose rescinding the 2001 Roadless Rule. We need to keep strong protections in place and the agency needs to respect public opinion. The agency also needs to conduct a complete and thorough environmental analysis and secure that no watersheds will be damaged. The public wants to keep our public lands protected and untouched. Our future generations depend on your duty to protect our forests and rivers! Important links attached to my comments: Science on roads fragmenting the landscape: https://conbio.onlinelibrary.wiley.com/doi/epdf/10.1046/j.1523-1739.1996.10041098.x Current rule in place: https://www.federalregister.gov/d/01-726/p-395 Forest Service FY26 budget: https://www.fs.usda.gov/sites/default/files/fs-fy26-congressional-budget-justification.pdf

I live in Coconino County, AZ, which hosts part of the largest contiguous Ponderosa Pine forest in the world. The vast majority of national forest land in Arizona is already open to road construction. Only 5% is designated as roadless. That is a TINY fragment of available forest land. The roadless rule areas were selected specifically to preserve sensitive ecosystems and prevent the proliferation of vehicles into these areas. It is already often difficult to find somewhere to just be outside without the rumble of vehicles. Let's keep our 5%.

The Wallowas, Joseph Canyon, the upper John Day, the deep river country draining toward the Snake. Old ponderosa pine, Douglas fir and western larch that survived generations of logging and now stand in some of the last remaining old-growth forest east of the Cascades. These are some of Oregon's great forests, and I hike and camp in them. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens what makes them worth entering. The agency's stated rationale for rescission includes forest health, but its own document undercuts that rationale. The notice claims 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," as stated in the Rationale for the Proposed Rule. Yet the same document cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land, and notes that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency cannot have it both ways: either the rule was a meaningful barrier to addressing forest health or it was not. The agency must reconcile the forest health rationale with those internal findings before this rule proceeds. The economic case for rescission is also thinner than presented. The document estimates, in the section on Economic Benefits from Recreation in Roadless Area Forests, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That single-year ceiling is set against roadless recreation benefits of upwards of $1.5 billion, and the document itself concedes that the magnitude of losses is unknown. Roads and changed recreation settings accumulate and persist across decades, not just a single year, and the Recreation section acknowledges that roughly 52 percent of three setting classes are more likely to be affected. The place I hike and camp in is exactly the kind of dispersed, roadless country this analysis inadequately captures. The agency should estimate cumulative recreation losses over 20 years as roads and settings change permanently, and compare them with projected timber revenue, rather than relying on a one-year 1 percent ceiling as though roads can be unbuilt. Most pressing is what the document discloses about the land that would actually be opened to harvest. In the section on Implications for Forest Vegetation, Health, and Carbon, the agency's own data state that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest" within the operable areas most likely to be logged under the proposed action. Old and mature stands together make up the overwhelming majority of that timberland. The document identifies no old-growth-specific safeguards beyond general land management plan compliance before these stands could be harvested. The forests I walk through east of the Cascades, the ones that survived previous logging rounds, are precisely this kind of old and mature timber. The Forest Service must separately analyze and publicly disclose what protections, if any, would apply specifically to old-growth and mature stands before any harvest is authorized in this land base. The document as written does not do that.

I strongly oppose the repeal of the Roadless Area Conservation Rule. This rule should be strengthened, not gutted. More than 730,000 acres of the first declared wilderness area in the world -- the Gila Wilderness -- stand to be gutted under the rule. The devastation this would cause to the local economy is unthinkable. Ecologically, rescinding the rule would devastate one of the most pristine areas in the world; giving up what is truly American about America. Roadless areas provide clean drinking water to 60 million Americans. I don't want exhaust in my water. Do you? These undeveloped lands are critical to our nation’s ecological health. They provide homes to the flora and fauna that define America. These areas store 20% of all carbon in U.S. national forests, providing a cushion against a rapidly changing climate. Roadless areas offer abundant outdoor recreation opportunities such as hiking hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. The outdoor recreation economy generates $730 billion annually, far more than timber sales. My community relies entirely on outdoor recreation for its economic stability. Visitors to the Gila Wilderness sustain local businesses, providing food, lodging, retail sales, and more. Outfitters depend on roadless areas to take people out on hunts, horsepacking trips, and other wilderness excursions. Recission of the Roadless Rule would devastate these businesses. Roadless areas are crucial habitat for 1,600+ threatened species, including the Mexican Grey Wolf, Gila Trout, and many others. We don't need more roads. We need to maintain the ones we have. We already have 370,000 miles of forest roads with a multi-billion dollar maintenance backlog. The argument that roads would make it easier to fight wildfires is specious. Studies show wildfire ignitions are 4x more likely near roads than in roadless areas. In addition, wildfire is an essential part of forest health. Many species, such as the Lodgepole Pine, Manzanita, Giant Sequoia, and the Sandplain Lupine, depend on fire to reproduce and thrive. The heat and smoke generated by frequent first trigger germination and rejuvenation of these species. In my own back yard, the ponderosa pine ecosystem has had a long and inseparable relationship with fire, depending on frequent low-intensity fires to thrive. I can only close with a quote from Aldo Leopold, close friend of Theodore Roosevelt and the father of the Wilderness Act: “Cease being intimidated by the argument that a right action is impossible because it does not yield maximum profits, or that a wrong action is to be condoned because it pays.” ― Aldo Leopold, A Sand County Almanac Rescinding the Roadless Rule would be a very, very wrong action.

1. The Rule used administrative rulemaking to do what the Wilderness Act reserves to Congress Section 2(a) of the Wilderness Act of 1964 provides that wilderness is designated by Act of Congress. Congress then built a durable process around that principle. The Forest Service inventoried roadless lands in RARE I and RARE II, the National Forest Management Act of 1976 directed forest-level planning with public participation, and Congress took up state-by-state wilderness legislation, area by area, with local debate and local compromise. The 2001 Rule applied to inventoried roadless areas nationwide the central management constraint of wilderness, a prohibition on road construction and most timber harvest, without a designation by Congress and without the area-by-area record that legislation requires. I do not argue that the Rule created legal wilderness. It did not, and recreation uses differ. My point concerns function and process. A category of land that operates in practice as wilderness for roads and timber was created by a single agency rule, and the legislative path that Congress established for that purpose was bypassed. If a roadless area merits permanent protection of that kind, the Wilderness Act supplies the means to secure it, and rescission leaves that means fully intact. 2. The Rule overrode more than two decades of forest planning When the Rule was adopted, the national forests had spent more than twenty years developing land management plans under the National Forest Management Act. Those plans allocated roadless acreage among competing uses, and the allocations reflected negotiation among local governments, industry, recreation interests, conservation organizations, and agency specialists. Some plans recommended wilderness. Others provided for active management. Many produced compromises that no single party preferred and all could accept. The Rule replaced those plan-level allocations with one uniform national prohibition. The documented fact is the Rule's text and its effect on existing plan decisions. My inference, drawn from participating in that planning era, is that the participants in those processes had good reason to see the Rule as discarding the product of their work. Rescission restores the standing of the plans and the public processes that produced them. 3. The Rule's effect on management went beyond its text The Rule contains exceptions, including provisions for certain small-diameter cutting and for fuel reduction near communities. A reader of the text alone might conclude that management in roadless areas remained workable. In my experience it did not. Added approval requirements, the cost of building a defensible record, and exposure to litigation led managers to stop proposing even the activities the Rule allowed. The practical result was that roadless areas were treated as places where management does not occur, regardless of what the regulation said. 4. Decisions belong in public, site-specific planning I am aware that the 2025 scoping period drew a large volume of comments, and that many commenters oppose rescission. I take that seriously. But the question before the agency concerns the proper process for making these decisions, and a count of comments does not settle it. A national prohibition written in Washington cannot distinguish a dry ponderosa pine slope with a century of fire exclusion from a high-elevation spruce basin that burns on a long return interval. Those differences decide whether management is warranted, and they can be seen only on the ground. You have to touch the land to know the land. Forest plan revisions and project-level review under NEPA provide notice, comment, objection, and judicial review, applied to specific acres and specific proposals. The Idaho Roadless Rule and the Colorado Roadless Rule, both developed through state-specific processes, show that locally tailored approaches can be built when decisions are brought closer to the land and the people who live with it. 5. Requests I ask the Forest Service and the Department to finalize rescission of the 2001 Rule. I further ask that the final rule and record of decision commit the agency to address roadless areas through forest plan revision and amendment, with full public participation, so that rescission is followed by open planning and not by project decisions made without it. I ask that the final environmental impact statement present the management-outcome data described above, including results unfavorable to rescission. And I ask that areas for which broad local support exists for permanent protection be advanced to Congress under the Wilderness Act, where that decision belongs. Thank you for considering these comments. I am available to discuss them or to provide supporting material on request. Respectfully submitted, Franklin O. Carroll Managing Partner, Professional Forest Management, LLC (PFMc) Licensed Professional Forester Pueblo, Colorado

I oppose the proposed action and any other measures to repeal or weaken the Roadless Area Conservation Rule. Please choose Alternative 1 and retain the current roadless rule. In Washington state, we have 2 million acres of inventoried roadless areas containing 3,900 miles of recreational trails. These areas are hugely popular for hiking, biking, hunting, fishing and other forms of recreation. Outdoor recreation is a critical economic driver supporting local businesses and communities across Washington. Roadless areas also provide important habitat for endangered salmon and wildlife, and protect treaty rights and cultural values. Opening up roadless areas to new roads will degrade these important values. Road building also increases the likelihood of uncharacteristic wildfire: the vast majority of wildfires are sparked by human ignitions in proximity to roads. Most importantly, the US Forest Service (USFS) already has 371,000 miles of roads and an enormous backlog of needed road repairs and maintenance. In 2024 the USFS estimated that it has a road maintenance backlog of $10.8 Billion on its current road network. I urge the agency to take this backlog seriously and invest in needed road maintenance, repair and decommissioning. We should take care of our current roads before building new ones. As an avid recreational user of our forest lands in Washington state, I frequently encounter USFS roads in deep disrepair. I also encounter roads that have been closed because of storm damage and USFS doesn’t have the funding or the staff to fix these problems. Please turn your attention to taking care of the current road network - and don’t add to the problem by building new roads that are not wanted or needed. Some of our most beloved lands in Washington are protected as roadless areas – the vast stretches of old growth forest above Lake Quinault, the ponderosa pine forests of the Teanaway Valley and the scenic forests near Washington Pass in the North Cascades. All these areas deserve protection. Please choose Alternative 1 and retain the current roadless rule.

I write today in strong support for the no action alternative and the 2001 Roadless Area Conservation Rule. The Roadless Area Conservation Rule is popular, its conservative, its responsive to local and national needs, and its working. Our National Forests have only remained intact because of this 25-year-old commitment not to build roads in these areas. The Forest Service contends that more roads means improved wildfire suppression effectiveness, and therefore rescinding the roadless rule would be a beneficial action for these roadless areas. Yet, rescinding the roadless rule wont prevent wildfire. Just the opposite, in fact. More roads mean more human-caused wildfires. 90 percent of all wildfires start within one mile of a road, and wildfires are four times as likely to ignite in areas with roads than roadless areas. It is highly likely that, on balance, more roads would increase -- not decrease -- the negative fire impacts on wildlands and wildlife in national forests. For decades I have been fortunate enough to traverse roadless areas in national forests around the West -- on foot, on skis, on snowshoes, and in rafts -- from Arizona to New Mexico to Utah to Oregon to Idaho. I've seen wildlife in these places that I've never seen anywhere else. I've experienced solitude and profound quiet in roadless areas that can't be quantified or monetized. Roadless areas not only contain the best intact habitat for countless fish and wildlife species, they are also important to me as a place to recreate, relax, recharge, and recommit to taking care of this gift of a planet we live on. Without these places and the water, plants, animals and other essential elements that they provide humankind, we would certainly perish as a species. I urge you not to erase protections for our roadless areas, which are home to most of our last remaining old-growth forests in America. Protecting them is more important than ever in light of hotter and drier weather. I live in Flagstaff, Arizona, where my property abuts the Coconino National Forest and I walk my dogs every morning on trails in the largest ponderosa pine forest in the world. I watch the forest get drier every year, and fear for the future of our beautiful ponderosa pines. More roads in the Coconino would inevitably mean more catastrophic fires, and threaten my home and habitats for many species who are already struggling to make it in a drier climate. And as a resident of Flagstaff, I have a vested interest in protecting the roadless areas of the San Francisco Peaks within the Coconino, which provide us with three-quarters of our drinking water (which is the best tasting water I've ever consumed). Without the water that falls as rain and snow on these mountains making its way unpolluted through the volcanic rock of the Peaks and into our homes, Flagstaff would be in serious trouble. Across Arizona, roadless forests are oases for a remarkable concentration of threatened and endangered species such as Mexican gray wolves, Mexican spotted owls, Gila trout, jaguars, Chiricahua leopard frogs, and Mount Graham red squirrels. We need to protect these species and a myriad of other endemic and migratory species -- here in Arizona, and across the country -- that count on unspoiled habitats, migration corridors and resources of the national forests for their survival. Opening up the national forests to more roads means more logging, more wildfires, more mining, more drilling, less solitude, less quality recreation opportunities, and more money out of the pockets of taxpayers like me to build and maintain additional roads. I'm not in favor of all that just for "increased local management flexibility." Properly managing our national forests means protecting many of their key resources and values, not degrading them. Roadless areas and the protections afforded to them by the Roadless Area Conservation Rule are critical to our high quality of life. The rule itself is enormously popular. It is supported by millions of Americans, and it has stood the test of time. This attempt to eliminate protections for our public lands is bound to be unpopular, just like Congress failed attempt in 2025 to sell our public lands. Americans are paying attention, and we want our roadless areas left alone. I am one of the millions of Americans who oppose opening roadless areas to road building, commercial logging, mining, and drilling. Its not too late to abandon this unpopular, unscientific, and unwise effort to sacrifice our public forests. I urge you not to rescind the Roadless Area Conservation Rule. Please choose the no action alternative. Sincerely, Pamela Hyde Flagstaff, Arizona

Prior to 2001, several studies had identified road construction and commercial logging activities to be the leading causes of permanent habitat fragmentation. In an effort to preserve remaining wild areas, the Roadless Area Conservation Rule – also known as the Roadless Rule – was proposed by the U.S. Department of Agriculture and eventually passed. The specific goal of the Roadless Rule was to protect drinking water watersheds, preserve wildlife habitat and biodiversity, protect threatened and endangered species, maintain and preserve scenic areas and recreation opportunities, and to reduce recurring controversy over the management of roadless areas, but the primary purpose was to prohibit the construction of new roads while the agency already had a large maintenance backlog. The proposed rescission of the Roadless Rule states “the 2001 Roadless Rule's prohibitions have limited mechanical thinning options and some fire control tactics in inventoried roadless areas. Substantial acreage within potentially affected inventoried roadless areas has a relatively high likelihood of burning under high intensity conditions that are difficult to manage or could pose a risk to communities, infrastructure, or drinking water sources.” If the objective of federal government is to reduce the risk of wildfires in roadless areas of national forests, the only approach that should be entertained is an amendment to the existing Roadless Rule to allow for a wider range of hazardous fuels treatments rather than the construction of more roads. Currently, about 2 million acres (14%) of Inventoried Roadless Areas have received hazardous fuels treatments to reduce fire risk. Since 78% of human-caused wildfires originated within half of a mile of a road, increasing the number of roads in these areas will proportionally increase the number of forest fires. According to the U.S. Geological Survey, “Stormwater and road runoff are increasingly recognized forms of pollution that can contain chemicals harmful to fish and other aquatic animals.” Car tires contain a chemical known as 6 p-phenylenediamine (6PPD) that is integral to the life of car tires; however, 6PPD readily reacts with air to form a variant known as 6 p-phenylenediamine-quinone (6PPDQ) that is released into the environment as tires wear down from driving. Runoff and stormwater carries this compound into nearby bodies of water where fish and other aquatic animals are exposed to it. Two recently published studies have linked the presence of 6PPDQ in waterways to premature deaths in native coho salmon populations. Genome analysis suggests that 6PPDQ may cause arteries, veins, and the barrier between the blood and brain of the fish to be more permeable. Rescinding the Roadless Rule will increase the surface area of watersheds containing this harmful chemical and will further increase the likelihood of negatively impacting native fish populations. As any environmentalist would be quick to point out large-scale logging operations negatively impact forest health in both the near and long-term. During the life of a logging operation, forests are cleared, displacing wildlife and increasing soil erosion. After the operation has concluded, several studies – including a study on Exotic plant responses to large-scale commercial logging in ponderosa pine forests of the Black Hills National Forest – found that the number of noxious weed species drastically increases in the years following large-scale commercial logging operations. Many people remember the predatory and aggressive logging practices of the 1900s that decimated much of the remaining old-growth forests in the contiguous United States. Since its formation, the National Forest System has worked to preserve and protect the habitat for numerous species at have been or would be affected by large-scale commercial logging efforts. The rescission of the roadless rule potentially puts these species and their protected habitats in harm’s way. America is one nation, under God and we have been appointed with the stewardship of His creation. Preserving the natural beauty and resources of these roadless areas is our God-given duty, a duty that should not be left to the whim of corporate lobbying and greed; therefore, a firm, all-encompassing rule must remain in effect to continue to protect these lands from further habitat destruction. Do not rescind the Roadless Area Conservation Rule.

I strongly oppose any effort to repeal or weaken the Roadless Rule. These protections have preserved 58 million acres of undeveloped national forest for more than 20 years and remain vital to the survival of hundreds of wild animal species. These forest areas are some of the last intact habitats left in the United States. They offer refuge for wild animals to raise their young, find food, and migrate safely. The success of this process contributes to the human world more than most of the public realizes. Logging and road-building destroys these critical spaces, displacing animals, and increasing the risk of fire, erosion, and pollution. Once lost, these ecosystems and the animals who rely on them may never recover. These unfragmented backcountry areas serve as critical, low-disturbance habitat and movement corridors for wide-ranging predators, including gray wolves and the Alexander Archipelago wolf, as well as many other species, both prey and predator alike. The roadless area conservation rule protects a vast majority of the unexplored as well as the explored wilderness and wooded areas. Local to me, it protects the alpine wilderness, which is a phenomenally beautiful and majestic area that is full of small lakes, biodiversity, wildlife, hiking/camping, and ultimately a place I personally have enjoyed with family. There are also other areas I have yet to journey to and discover. These roadless areas include numerous wilderness and forest areas in my home state, as well as my close neighbors, Idaho and Montana. I went on my first backpacking trip in the Cabinet mountains in MT. It was memorable in every way, and I fear that reversing the roadless rule, will easily diminish this hard to access and yet pristinely beautiful environment, that is shared by those who dare to hike there along with those who already live there (the animals). While the wilderness areas would remain protected, the inventoried roadless areas that surround them, are vital to maintain these natural habitats. I believe this to be a necessary buffer zone, separating out human impact on these vital areas. There are two ways this roadless rule continues to protect the natural habitats and biodiversity that impact me and have the most meaning to me personally. Maintaining and protecting clean drinking water as well as wild fire management. Based on where I live, I am impacted by both of these risks greatly as the water always flows downstream, and is vital to nourish not just the wild life and the forests themselves, but to deliver downstream to the lakes and the rivers, influencing the habitat of the marine life within. While I am not from California, I did come across some data that speaks to this. California’s roadless areas specifically supply 50% of their drinking water. American Rivers reports that A scientific study done out of the University of Washington (July 15, 2026), has shown that these undisturbed forest lands safeguard clean drinking water for 25 million Americans by naturally filtering contaminants and preventing soil erosion into over 80,000 miles of streams. Also detailed in the study, there are other potential harms from rescinding the roadless rule, including to biodiversity and habitats for species like salmon that spawn in Alaska’s Tongass National Forest and other national forests in the Pacific Northwest. Hunting, fishing and other recreation activities could also be at risk from development of wilderness areas currently protected by the roadless rule. These inventoried roadless areas also act as fire barriers, allowing biodiversity and native plants to thrive. A 2026 study of three decades of National Forest System wildfire data found that wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest. Wilderness and Inventoried Roadless Areas have the lowest ignition densities of any land category studied (Aplet et al. 2026). Most ignitions near roads are human-caused; lightning-caused fires are concentrated away from roads (Narayanaraj & Wimberly 2012). A century of aggressive fire suppression, made possible by road access, has degraded fire-dependent forests by removing the periodic low-intensity fire that longleaf pine, ponderosa pine, and similar systems evolved with (USDA Forest Service 2001). When this rule was formed, it was a slow, thought out process that included public comments and had support by around 90% of those commenting. There are many issues at hand to bring this to the table again, including worsening fires in the west. It is true that climate change and drought are playing a role larger than we think and forests certainly need to be managed. But rescinding this rule should not be industry motivated. The logging and other special interests groups should not have louder or more influential voices than that of the general public. I support the Roadless Rule as it is today and opposed the repeal or rescission of this.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The sounds of nature, the birds in the trees, the smell of the Ponderosa pine, the quiet and the clean fresh air: that is what I go to my nearby National Forest for, and that is what this proposal would put at risk. I am opposing the rescission of the 2001 Roadless Area Conservation Rule. The wildfire argument for rescission collapses against the agency's own findings. I live near the Coconino and Kaibab National Forests, and I watched what the 30,000 acre Pocket Fire did to this landscape. Building roads through National Forests will exacerbate the already-worsening fire seasons dramatically. The agency itself agrees with that concern, writing: "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 agency must explain why this proposal departs from that finding, and must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The birds I listen for in areas like Coconino Rim, East Clear Creek, Padre Canyon, Lower Jacks Canyon, Jacks Canyon, and Leonard Canyon are not incidental to my reason for being there. They are the reason. The agency's own record, citing research on road-noise experiments in roadless areas, found that bird abundance dropped by over a quarter and that 31 percent of species avoided the noise entirely, and that bird richness declines with road presence in forested habitat. Roads do not pass quietly through a forest. They reorganize it. I ask that the agency explain what weight it gave these findings when weighing the costs to bird communities across Arizona's 78 inventoried roadless areas totaling 1,174,256 acres, and whether any mitigation measure in this proposal is designed to address them. The economic case for rescission does not hold up either. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that, 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, with a net present value spanning negative $92 million to positive $199 million. The agency also carries a $6.9 billion road maintenance backlog on the system it already has. The agency must explain on the record how a proposal whose own analysis cannot establish a net benefit justifies expanding that road system further. The rule as written already accommodates urgent needs. Its own text makes clear that 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)." Across the Southwest, 739 municipal water intakes sit in watersheds containing affected roadless areas. Community safety, existing rights, watershed protection: the rule's exceptions already speak to these things. The agency must identify, specifically and by category, which burdens the existing exceptions do not address, and must quantify those burdens in the record before moving forward. We have done enough damage to this country's natural resources. The old growth tree stands in these canyons and on these rims are older than all of us. The roadless protections that have kept them intact reflect a straightforward judgment: some values are worth keeping. Rescinding the rule trades those values for economic projections that the agency's own numbers cannot validate. I urge the agency to withdraw this proposal. Sincerely, Sam Axford Flagstaff, Arizona

I am writing this comment after 2 years in Alaska. In the summer’s I’ve spent here I have witnessed the suffocating effects of wildfires. Wildfires are a natural part of life, and even healthy for our forests. However, effects on communities can be devastating and it is imperative to prevent increase in wildfires beyond what is necessary for normal growth and development. In Alaska, both the Chugach and Tongass National forests would be affected by this policy change. A 2026 study shows that wildfire ignition density within 50 meters of road is four times higher (Aplet et al. 2026). If new roads are allowed to be built, this could ultimately increase overall wildfire ignition density leading to greater fire risk of the entire area. In contrast, wildfires are important for long-term health of our forests. Development of forest roads prior to the roadless rule in 2001, lead to aggressive fire suppression of low-intensity fires fire that longleaf pine, ponderosa pine, and similar systems evolved with (USDA Forest Service 2001). As outlined above, rescinding the roadless rule actually increases risk of wildfire. In addition, it may lead to unnecessary suppression of some needed wildfire. Wildfires can wreak havoc on communities and cause millions of dollars in damage. The cons of using taxpayer money to fund roads far outweigh the pros. Do not rescind the roadless rule.

As a PhD biologist and recreational user of National Forest lands I oppose the rescinding of the Roadless Rule. This proposal is not based on meeting the needs of the regional communities around National Forests, it is a blatant attempt by the timber industry to transfer resources from the American people to private interests for short term gain. The two primary reasons cited for changing the rule are "economic development" and "fire prevention," both are canards. Anyone who lives in Montana can tell you the timber industry is dead in this state, and was dying for decades before the last mills closed - long before the Roadless Rule came into effect. Montana is a terrible place to grow commercial lumber: the average time between harvests is 100+ years, versus around 20 on the Gulf Coastal Plain and 30-40 in coastal Oregon and Washington. Opening Montana's forests to large scale commercial logging will not meaningfully improve the state's economy, there is far more local economic activity utilizing these roadless areas (fishing, hunting, guiding, backpacking etc.) that puts money in local citizens and businesses pockets. Logging and milling operations at their peak employed only a fraction of people now receiving economic benefits from these lands. Reopening our forests to logging won't create jobs, it is going to erase them; taking money and resources out of local pockets and transferring them to out of state corporations. And even that will be a brief hit of revenue before the saleable timber gets logged out and the logging conglomerates pull out again. It is throwing away 100 years of potential revenue from use of the land to get 5-10 years of quick money. As for roads being required for "fire prevention," the increased wildfires our forests in the Northern Rockies now face are the direct result of logging. The timber industry cuts down mature forest that is resilient to fire and leaves early succession regrowth that is far more prone to burning, and when it does burn it burns hotter, faster and is more difficult to control. Logging is a form of disturbance, and in this region most regrowth following such disturbance is Lodgepole Pine (Pinus contorta): a short-lived, weedy species whose life cycle is based on being wiped out by fire every 50 to 100 years. Most of the forest fires we now experience in the Northern Rockies are direct result of logging in the 20th century, which created an expansive monoculture of Lodgepole Pine at mid-elevations that are now reaching the end of their lifecycle and are dying off. These dead and dying Lodgepoles are a low grade timber product, only suitable for fence posts and pulp production. The timber industry is not going to restart logging operations to clear out old Lodgepoles. If they re-enter Montana it will be to go into healthy forest and take mature Ponderosa Pine, Douglas Fir, Western Larch, etc. that have much better fire resistance than the "trash" Lodgepole Pine. These operations will not have any measurable impact on reducing fires, since they aren't going to remove the Lodgepoles and will take the trees most likely to survive fires. There is a growing body of evidence that "thinning" coniferous forests by removing mature trees as a means of fire prevention actually does the opposite, opening the canopy to dry out the understory (making it more vulnerable to fire starts) and keeping a perpetual cohort of juvenile trees that are more likely to burn in a surface fire. The forest fire "problem" in Montana was created by logging, more logging is not going to solve it. There is no need to build new roads to prevent or fight fires. Most of the roadless areas are distant from inhabited districts anyway, with plenty of roaded sections between them that can be used as firebreaks. More economic activity is generated from the forests as they are than by cutting a bunch of roads into them and disrupting the opportunities for outdoor recreational activities like camping, fishing and hunting. Again I affirm: do not repeal the "Roadless Rule."

Hello, I oppose full rescission of the Roadless Rule. As a hiker, backpacker, employee of the outdoor industry, and someone who calls Utah home, pulling back these restrictions would directly affect me, my family, and the environment we love so much. From our zipcode alone, there are over 50 areas that would be affected by the Roadless Rule's end. Each of these areas are home to hundreds of species and make Utah special. Outdoor recreation and tourism is essential to our state's economy and my work as a marketer in the outdoor space. The Roadless Rule protects these spaces from logging and industry development. Research on Western U.S. economies describes a shift from extraction-based growth to amenity-based growth. Counties with substantial protected federal lands have grown faster in population, employment, and per capita income than counties without — with growth concentrated in lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). Wilderness recreation generates an estimated $574 million annually in economic value, and Western wilderness passive-use value is estimated at roughly $168 per acre (Loomis 2000). The Forest Service's own road-management strategy documents an $8.4 billion deferred maintenance backlog across the existing road network — a backlog the agency has acknowledged it cannot resolve. Expanding the road network into roadless areas would compound this maintenance burden (USDA Forest Service 2001 EA). Opening up these spaces will also not help with wildfire suppression. A 2026 study of three decades of National Forest System wildfire data found that wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest. Wilderness and Inventoried Roadless Areas have the lowest ignition densities of any land category studied (Aplet et al. 2026). Most ignitions near roads are human-caused; lightning-caused fires are concentrated away from roads (Narayanaraj & Wimberly 2012). A century of aggressive fire suppression, made possible by road access, has degraded fire-dependent forests by removing the periodic low-intensity fire that longleaf pine, ponderosa pine, and similar systems evolved with (USDA Forest Service 2001). Please leave these spaces wild for those who enjoy them and those who live there. Thank you

To the U.S. Forest Service, I am writing as a California resident to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, which would strip protections from nearly 45 million acres of National Forest System land nationwide — including roughly 4 million acres across California's 21 national forests, from the Angeles and Los Padres in the south to the Shasta-Trinity and Modoc in the north. I urge the agency to withdraw this proposal. This issue is personal to me. Hiking is one of my greatest joys, and California's roadless national forest land is exactly the kind of place I go to experience it — quiet, undeveloped, and largely untouched by industrial activity. Opening these areas to road-building and logging would permanently change the character of trails and wild landscapes that I and countless other Californians rely on for recreation. Once roads and logging infrastructure move into these areas, that sense of remoteness is gone for good. Beyond my own interest in hiking, the ecological stakes are significant. Roadless areas make up just 2% of land in the lower 48 states yet provide habitat for 57% of the country's vulnerable terrestrial species. In California specifically, protected roadless land includes ponderosa pine forests in the Modoc, giant sequoia groves, and undeveloped stretches of the central Sierra Nevada near Yosemite. The agency's stated rationale — that repeal is necessary to reduce wildfire risk — is not well supported by the evidence. Research has found that the highest wildfire-ignition density occurs in lands within 50 meters of roads, and fewer than 1% of wildfires in the lower 48 states since 2010 started in roadless areas of national forests. More roads generally mean more human activity and more opportunities for human-caused ignitions, not fewer. These forests also protect drinking water supplies that Californians depend on, including watersheds near the Lake Tahoe Basin, and they support the hunting, fishing, and outdoor recreation economies of rural communities throughout the state. Finally, I have serious concerns about the process behind this proposal. The majority of Tribal governments consulted have opposed the rescission, viewing it as a threat to inherent rights, tribal sovereignty, cultural survival, and the ecological health of ancestral homelands. A decision of this magnitude should not move forward without genuine, good-faith consultation and consent from the Tribes whose lands and rights are most directly affected. For these reasons — the loss of irreplaceable hiking and recreation land, habitat fragmentation, increased wildfire ignition risk from new roads, threats to clean water, and inadequate Tribal consultation — I ask that the Forest Service withdraw the proposed rescission and retain the 2001 Roadless Rule in full for California's national forests and nationwide. Sincerely, Carrissa Rogers

I am in opposition to the repeal of the 2001 Roadless Rule. It should be retained for many reasons, including forest health. I am a retired physician and a life-long resident of Washington State, with more than 60 years of recreating in the Cascade mountain range, and beyond. I can attest to the values of keeping roadless areas protected, for both recreation and for improving forest health. In our area (Chelan County) we currently have a huge number of non-functional forest roads, dating back to the era when timber interests were vigorously building roads for industrial logging. These roads, built for out-dated concepts of timber extraction, are often a liability, as they were otherwise unplanned and currently unsupervised. Many of these existing roads have since deteriorated to the point where in many cases they are un-usable, even to hikers as well as equestrians, and mountain- and motor-bikers. They require extensive work to keep the sun-seeking shrubbery from overgrowing the tread, and to keep washouts from occurring during rain and snow events. This maintenance is generally not done, unless a wildfire emergency (such as the Little Giant Fire) requires emergent and dangerous work, followed by expensive rehabilitation to avoid mudflows. Rather than opening current roadless areas up to more roads built willy-nilly and solely for timber extraction, it would make much more sense to focus on an intelligent system of using and maintaining our existing National Forest roads, designing a system which makes sense for communities and stakeholders. Wildfire mitigation efforts, using our many existing roads, can include forest health measures which leave large-diameter Ponderosa pine and Douglas-fir trees intact, still harvesting small-diameter and flammable trees for modern products such as mass timber. Using and maintaining our existing roads can also enhance recreation, dispersing our use away from relying solely on recently over-used areas, such as the Enchantments. Our currently road-free areas are a precious source of biodiversity, water quality, wildlife habitat, and recreational opportunities for us and for the future. They deserve to retain their current protected status. Thank you for considering our Comments.

Subject: Roadless Rule Recission Draft EIS Introduction I had almost a 40 career with the Forest Service working on the Nez Perce, Clearwater, Deerlodge, Bighorn, Beaverhead-Deerlodge National Forests and the Pawnee National Grassland. I retired in 2010 but remained on a type 2 fire team until the fall of 2019. The last 20 years of my career were on the Beaverhead-Deerlodge NF. After retirement I continue to use the B-D NF for hunting, fishing. trail hiking and riding. I don't know why the USDA has taken on this additional workload of an EIS when travel plans are not completed for all national forests. Because the Beaverhead-Deerlodge NF does not have a travel plan, resource damage and user conflicts are rampant. I am going to defer my input to the comments provided by the National Association of Retired Forest Service Retirees (NARFSE) letter dated September 3, 2026. The board of NAFSR has recent and extensive experience with managing the Wildland-Urban Interface (WUI) and Roadless Areas (RAs). If the decision maker cannot utilize the recommendations from NAFSR in full then I recommend to the Roadless Rule not be rescinded. Loosing 70% of the RAs as proposed by Alternative 3 is not acceptable. The benefits of RAs for wildlife security and clean water are well documented. I fear that if the miles of open roads are increased on NFs, the big game will be pushed off of the National Forests and on to private land and unavailable for public land hunters to hunt. The Forest Service does not need any more roads. The backlog of unmaintained roads is well documented. This administration has gutted funding for road maintenance. The Beaverhead-Deerlodge has only two people on the road crew when they formerly had 8. The Custer-Gallatin NF doesn't have a road crew. I my area a number of roads are in horrible condition. One of my concerns is the ability of the Forest Service to implement this EIS with the current workforce. It seems like a top-down approach is inevitable, unless not rescinding the Roadless Rule is chosen, When timber harvest is allowed in RAs, I have no problem allowing for harvest of large diameter lodgepole pine. Large diameter Douglas fir and ponderosa pine should be left. Conclusion I cannot overemphasize the need to utilize the comments from the National Association of Retired Forest Service Employees. Thank you for considering my thoughts on this important issue. Introduction