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The Wonalancet Out Door Club was founded in 1898 with the mission to make the natural beauty of the Sandwich Range accessible to a broad public through the maintenance of hiking trails. We now maintain more than fifty miles of trails and provide a variety of other year-round services to thousands of visitors and hikers annually. The Club has a long history of advocacy in protecting our national forests, from supporting the Weeks Act of 1911 to promoting the establishment of the Sandwich Range Wilderness in 1984 and its expansion under the New England Wilderness Act of 2006. The Club also advocated for approval of the Roadless Area Conservation Rule in 2001. The Roadless Rule, established with the input of an amazing 1.6 million letters from citizens, has acted as a safeguard for our pristine National Forests for two and a half decades. In terms of natural resources, the rule protects intact ecosystems that are the habitat for large numbers of endangered species, that serve as vital migration corridors, and that encompass the headwaters of rivers which are crucial to preserving pure drinking water for tens of millions of Americans. The function of these uninterrupted forests to sequester carbon is increasingly appreciated as new scientific studies are published. And as the rule safeguards these forests it ensures that they remain available for recreation and appreciation of natural beauty that is untouched by human interference. These values survive because these large tracts are uninterrupted ecosystems. All these benefits come from protected areas that cover only 2% of the land in the United States. It is therefore hard to fathom that short-term commercial interests that are behind efforts to rescind the Roadless Rule should be given preference over the protection of such a unique and valuable resource. Once the commercial value is taken out of our forests their value as uninterrupted ecosystems is lost forever. The building of new roads and potential increase in commercial logging not only disrupt them irrevocably; they would likely also increase the risk of wildfires, since most forest fires have been shown to be caused by human activity. Respect for our wild lands has been part of our national character for many decades. We honor that tradition and, on behalf of all our members and our partner organizations around the country strongly advocate that the U..S. Forest Service retain the 2001 Roadless Area Conservation Rule. Respectfully submitted, Frumie Selchen and Genevieve Christy Co-Presidents Wonalancet Out Door Club

I am just one of millions of Americans lucky enough to have walked in a wilderness, in land that is part of our National Forest and protected by the 2001 Roadless Area Conservation Act. The wilderness in my back yard is the Sandwich Range where intrepid locals banded together in 1898 to form trails that they made available to everyone. They were followed by others who fought to protect the forest with the Weeks Act in 1911 and still later who assembled mountains of documents and gave testimony to establish it formally -and they hoped finally -as Wilderness in 2006. The Roadless Area Conservation Act itself was a triumph of human cooperation that was achieved with the input of 1.6 million letters and hundreds of meetings over many years. I consider it an act of reverence- an acknowledgement that the natural environment we have been given deserves respect and protection from human interference. The forest itself embues a sense of generosity, at once it belongs to no one and still to everyone. It fills me we awe as it does almost everyone who enters it. So the announcement that the U.S. Forest Service plans to rescind the Act that protects the roadless forest fills me with dred and outrage. The building of roads to facilitate commercial development would destroy the value of these uninterrupted ecosystems as habitat for precious and endangered flora and fauna, eco-systems that function in beneficial ways we have barely begun to understand. Rescinding the Roadless Act to facilitate development is short-sighted, prejudiced to serve narrow commercial interests and simply immoral. Keep the 2001 Roadless Area Conservation Act. Respectfully submitted,

Re: Special Area; Roadless Area Conservation Docket No. FS-2025-0001 RIN 0596-AD66 I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule because its claimed wildfire management benefits do not justify the environmental, recreational, and fiscal costs. I am a native New Hampshirite and hike or backpack in the White Mountain National Forest (WMNF) once or twice a month. Some of its wildest areas - like Lincoln Woods, the Sandwich Range and Mount Chocorua, and areas surrounding the Pemigewasset Wilderness - lie within the 235,000 acres of Inventoried Roadless Areas (IRA) in the WMNF [1]. These landscapes help draw roughly six million people annually [2]. The rescission of the Rule places them at risk from commercial timber harvesting. I argue three points against this proposed rescission: 1. Wildfire Management Benefits are not Proportional to Environmental Risks The Rule already allows substantial wildfire risk management, so the Forest Service’s rationale that a full repeal is needed for wildfire mitigation is flawed. Under 36 C.F.R. § 294.13(b)(1), small-diameter timber may be cut or removed to maintain or restore ecosystems, including to “reduce the risk of uncharacteristic wildfire effects.” The Forest Service also stated that “hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule, so long as road construction or reconstruction is not necessary.” 66 Fed. Reg. 3244, 3258 (Jan. 12, 2001). The Rule separately permits road construction when necessary to protect public health and safety from an imminent threat of fire or another catastrophic event. 36 C.F.R. § 294.12(b)(1). I concede that rescission would provide managers more flexibility, but that does not justify eliminating nationwide protections. New roads fragment habitat, increase erosion and sedimentation, and increase human access; the proposed rule itself acknowledges that “greater public access can increase human-caused ignition potential.” 91 Fed. Reg. 53829 (2026). If additional access is needed in particular high-risk forest, “especially in the Western United States,” the Forest Service should adopt targeted exceptions instead of repealing the Rule nationwide. 2. Harm to Scenic Value and Recreation Beyond environmental significance, the WMNF is the crown jewel among NH’s natural assets that support major tourism and outdoor recreation activity. This activity supports 30,000 jobs and contributes $4 billion to the state’s economy annually [2]. The Forest Service acknowledges that rescission could cause “noise, visible infrastructure, and temporary closures” and reduce opportunities for “quiet, remote and self-reliant recreation.” What’s more, the estimated $6.1 million in annual lost recreation is likely an underestimate because the analysis relies heavily on assumptions and admits substantial uncertainty about what and where development would actually occur. In a heavily visited forest like the WMNF, those losses deserve substantial weight. Commercial access that degrades remote landscapes should not be expanded absent a demonstrated public benefit. 3. New Roads are Difficult to Justify Amid a $6.9 Billion Maintenance Backlog The Forest Service already faces a multi-billion dollar backlog of deferred maintenance for its existing roads. 91 Fed. Reg. 53829. It acknowledges that timber harvest and vegetation management would likely create the greatest demand for new roads, and that expected timber-efficiency gains would be “incremental” and constrained by road costs, maintenance funding gaps, and the $6.9 billion backlog. It is fiscally irresponsible to open areas to taxpayer-funded road expansion for the benefit of private timber harvesters when the agency can’t afford to maintain existing infrastructure. Limited Forest Service resources would be better directed toward maintaining existing infrastructure than opening currently roadless lands to additional development. In sum, I request that USDA withdraw the proposed rescission and retain the 2001 Roadless Rule. If the agency concludes that additional management flexibility is necessary for wildfire risk reduction in particular regions or circumstances, it should pursue narrowly tailored amendments that preserve the Rule's nationwide baseline protection while addressing demonstrated management needs. Stripping all protections is an unnecessary excuse to open these delicate ecosystems to extractive industrial activities. [1] https://newhampshirebulletin.com/2026/09/14/repub/unique-stretch-of-new-england-forest-under-threat-after-proposed-rollback-of-roadless-rule/ [2] https://www.unh.edu/news/whos-visiting-new-hampshires-white-mountains

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The protected areas of the White Mountains are my literal home and my spiritual home as well as being tightly tied with my state’s ability to survive economically. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record of Docket FS-2025-0001. I live in the White Mountains region of New Hampshire and regularly go out into the woods for a hike or camping trip. The Carr Mountain area, at 17,110 acres in the White Mountain National Forest, is one of the few places beginner backpackers can go to learn outdoor skills, an important American legacy. The Carr Mountain area houses wetland and habitat that would be destroyed by logging, flooding a region's water system with difficult to remove pollutants. The Sandwich Range, at 16,797 acres, is one of the most popular areas for people to visit. It has an intrinsic beauty and sheds water directly into the lakes region of the state, one of the main tourist attractions in New Hampshire. These places have already seen a history of ecological damage that ruined the economy's long-term health. That history is not abstract. The Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut. We are being asked to forget that lesson. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. Logging in Carr Mountain and the Sandwich Range does not stay in those units. It enters the water. I ask the agency to explain how it will protect those 286 intakes and the downstream communities that depend on them if this rule is rescinded. 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." Building new roads that the agency has yet to prove it can maintain, in order to facilitate logging that yields fractions of a percent of national production, makes no sense. It would also decimate the thriving outdoor economy that New Hampshire enjoys, tanking our viability as a state. I ask that the agency reconcile the proposal with its own economic analysis, which 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, and that it explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also claims the rule imposes permitting and administrative burdens that justify rescission. But the rule as written states 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)." The rule already accommodates the situations the agency says require relief. The agency must identify which specific burdens are not already addressed by these existing exceptions and quantify those burdens in this proceeding. 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. I have organized my life around these protected areas. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Molly McCahan Plymouth, NH

To whom it may concern: I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Dr. Amber Rock and I am a biologist who lives in Boston, MA. I am an avid recreator and have enjoyed camping, hiking, backpacking, and fishing on public lands since I was a child in southern California. Locally, I find time to to hike in the the Pemigewasset (32,255 acres) and Sandwich Range (16,797 acres) in White Mountain National Forest, New Hampshire in all four seasons. This summer I also had the privilege of hiking the Pacific Crest Trail, 231 miles of which go through 71 roadless areas across California, Oregon, and Washington. Our pristine wilderness in the crown jewel of America and rescinding the Roadless Area Conservation Rule in any capacity would be a grave mistake ecologically and financially; we owe it to ourselves to keep the wilderness wild for generations to come. While hiking the PCT, I had to miss parts of the trail due to fire and smoke. The proposal justifies rescission in part on the ground that new road access is needed for management. But the agency's own document states that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If we cannot maintain the roads we already have, and if those roads themselves drive fire ignition at the rate the agency has documented, the case for opening roadless areas to new construction does not hold. I have seen countless unmaintained FS roads, strewn with blown down trees, potholes, and rockfall, barely passable for a walker, let alone vehicles. 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 DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. After walking hundreds of miles of burn scars, I know first hand how a single fire can devastate an ecosystem for decades to come. The agency also argues administrative burden and permitting friction as grounds for rescission. The rule's own text, as the agency acknowledges, states 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)." Those exceptions are broad. Which specific burdens are not already addressed by them? I ask that the agency identify those burdens by name and quantify them on the record, rather than asserting that the rule as written forecloses management it does not foreclose. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. 286 municipal water intakes sit in watersheds containing affected roadless areas. The DEIS states 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 documented and then, in the agency's own analysis, set aside without a projection of what it means downstream. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before any final action is taken. The drinking water question does not stop there. The agency's own record states that "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." The DEIS then asserts that forest plans address sources of public drinking water without identifying a single enforceable provision equivalent to what 36 CFR 294.12 and 294.13 currently provide. Brook trout, moose, Canada lynx, Bicknell's thrush, the northern long-eared bat: species that depend on the clean, cold, undisturbed water these roadless areas produce in New Hampshire and across the system. I ask that the agency identify, forest by forest, which plan provisions would replace those protections for municipal watersheds. The Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut. We built a federal land protection system from that lesson. Rescinding the Roadless Rule repeats the mistake the Weeks Act was meant to correct. The agency should say plainly why that history does not apply here. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, Amber Rock, PhD Boston, MA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Clean water and quiet forest: those are the two things the roadless areas of the White Mountain National Forest protect, and those are the two things this proposal would put at risk. I am asking the Forest Service to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The White Mountain's 16 inventoried roadless areas total 240,669 acres, including Carr Mountain, Sandwich Range, Pemigewasset Ext, Waterville, Jobildunk, and Mt. Wolf - Gordon Pond, and they are the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911 authorized the federal government to purchase private land for national forests specifically because of what happened when New England's mountains were clearcut. That history is the whole argument for keeping these places intact. The moose, black bear, American marten, Bicknell's thrush, brook trout, Canada lynx, and northern long-eared bat that live here depend on forest that has not been fragmented by roads. Wildlife migration, human recreation, the cooling shade of trees above clean streams: these are not abstractions. Building roads into this forest would be a terrible idea for every living thing, and I want the agency to explain what it believes justifies that consequence. On water, the agency's own analysis 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 Eastern region alone, 286 municipal water intakes sit in watersheds containing affected roadless areas. I would rather drink clean water. Roads bring trucks, petroleum, and sediment, and the agency's own record shows roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The proposal says forest plans will fill the gap left by rescinding 36 CFR 294.12 and 294.13, but the DEIS does not identify a single enforceable plan provision that is equivalent. I ask that the agency identify, forest by forest, which specific plan provisions would provide equivalent protection for municipal watersheds if this rule is rescinded. On wildfire, the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal uses wildfire and fuels management as part of its justification for rescission. Those two things point in opposite directions. The agency needs to reconcile this proposal 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 why the rescission departs from prior findings the agency itself produced. On 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." 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. That range does not establish a net benefit. The road system the agency already maintains carries a $6.9 billion maintenance backlog. The agency must explain on the record how expanding that system is fiscally defensible when its own numbers cannot confirm a positive return. On legal history, the agency's record states: "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 proposal argues that state-by-state approaches can replace national protection. The Ninth Circuit already reviewed that substitution and found it wanting. The agency should address how this proposal avoids the deficiencies identified in that prior litigation, and explain its own finding that local decision-making can incrementally erode nationally significant roadless values. Please leave the land alone. Let the animals and people enjoy the forest. Trees give us clean air and keep the Earth cool, and the rule that protects them should stay in place. Sincerely, Maya Plymouth, NH

I grew up in New Hampshire and a big part of why I chose to live here as an adult is the natural beauty of the wild spaces throughout the state. Some of my fondest memories are from time spent in areas which would be impacted by the rescission of the Roadless Rule. Areas including Mount Chocorua in the Sandwich Range Mountains, Lincoln Woods Trail off the Kancamagus Highway, the Appalachian Trail on Mount Moosilauke, and Liberty Springs Trail from Franconia Notch State Park. If the Roadless Rule is repealed, over 200,000 acres of roadless areas in the White Mountain National Forest of New Hampshire will be impacted. People come from all over the world to visit these special places, which brings billions of dollars to the state. We, in NH, treasure these wild spaces, and feel it is our duty to protect them for future generations to enjoy. One administration, favoring profit over conservation, should not be allowed to disregard the overwhelming public support of the Roadless Rule. I urge the administration to keep the Roadless Rule for the health of the environment, the health of the wild plants and animals that call these places home, for the humans who recreate in these wild spaces, and for local economies that depend on the tourism dollars these wild places attract. The Trump administration is claiming that the roads are needed for wildfire management. But the Forest Service’s own studies show that most wildfires are the result of human activity and that wildfires are much more likely to occur near roads than in roadless areas. Building roads through wild areas leads to soil erosion which then washes down into nearby streams and rivers and negatively impacts the aquatic wildlife, changes the water flow which increases the risk of flooding, and degrades the water quality which impacts all those downstream who depend on clean drinking water. The roads will negatively impact the local wildlife, some of which are endangered, by fragmenting their habitat and disrupting migration routes. These roadless areas are already managed by the Forest Service without the need for roads. The roads are needed for logging and mining equipment, not to fight wildfires. Let’s not trade a short-term profit for a precious gift which should be preserved for future generations to enjoy. We, as American citizens, collectively own these public lands. Listen to us! We want to preserve these wild spaces. Do not rescind the Roadless Rule!

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I love, the places where I go to find peace were shaped by a crisis that Congress chose not to repeat. The Weeks Act of 1911 authorized the federal purchase of private land for national forests specifically because of what had already happened when New England's mountains were clearcut. The Pemigewasset Ext, Sandwich Range, Waterville, Mt. Wolf - Gordon Pond, Jobildunk, and Carr Mountain roadless areas in the White Mountain National Forest exist, in part, because that lesson was taken seriously. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. I recreate in these forests, and I am opposing the rescission of the 2001 Roadless Area Conservation Rule. The agency's own record undermines the economic case for this action. The agency stated 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 baseline, 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 agency must reconcile this proposal with those numbers and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. That question deserves a direct answer in this record. The state-by-state rationale the agency advances now has already been tested. 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." What the record does not reflect is any honest accounting of what followed: the Ninth Circuit found the agency's prior attempt to replace the national rule with a state-by-state approach legally deficient. New Hampshire holds 234,681 acres in 15 inventoried roadless areas. The moose, black bear, American marten, Bicknell's thrush, brook trout, Canada lynx, and northern long-eared bat that depend on the White Mountain's roadless character do not recognize state lines, and neither do the watersheds. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies the Ninth Circuit identified the last time the agency walked this path. The permitting and administrative burden justification fares no better when the rule's actual text is consulted. The rule, as written, "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)." Those exceptions also address existing mineral leases and community wildfire protection. The agency has not identified, with specificity, which burdens remain after those exceptions are applied. I ask that the agency name the particular burdens not already addressed by the rule's existing exceptions and quantify them. The Regulatory Flexibility Act certification deserves the same scrutiny. 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 certification reaches its no-impact conclusion by distributing the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides who actually hold permits in these areas, and it concedes some firms may lose those receipts. The people who run small guiding operations in and around the Carr Mountain and Sandwich Range roadless areas are not a national average. The agency should withdraw the certification and conduct an honest assessment of the small entities actually operating in the potentially affected areas, not a statistical abstraction built to avoid the finding the data supports. I go to these forests to recreate and find peace and quiet. The history encoded in the Weeks Act, the water those acres protect, and the wildlife that depends on undisturbed terrain all argue against rescission. So does the agency's own analysis. Sincerely, Jackie Dean Thornton, NH

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I live in Thornton, New Hampshire near the Welch-Dickey Trailhead. The Smarts Brook trails, the Sandwich Range and the mountains around Welch Dickey are where I spend most of my recreation time hiking, mountain biking, cross-country skiing, snowshoeing and downhill skiing. I volunteer year round with Waterville Valley Adaptive Sports. I coach and support athletes with disabilities, skiing, trail riding, mountain biking and camping in the White Mountain National Forest surrounding Waterville Valley. Waterville Valley Adaptive Sports conducts trail rides on the many rail trail systems throughout Northern New Hampshire. These places matter to me and to the people I bring there. The proposal to rescind the 2001 Roadless Area Conservation Rule would put them at risk, and the agency's own record does not support that choice. The agency's economic case for rescission does not hold together. The record before the agency 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 marginal gain, 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 minimum $6.1 million a year, a net present value spanning -$92 million to +$199 million, and a road maintenance backlog already sitting at $6.9 billion. The agency cannot establish that this action produces a net benefit by its own numbers. I ask that the agency reconcile the proposal with that analysis and explain how expanding a road system already carrying that backlog is justified when the economics are this uncertain. The agency has already walked this road and been stopped. The record notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected the state-by-state approach the last time the agency tried it, precisely because local decision-making can chip away incrementally at roadless values that are nationally significant. The trails where my adaptive sports group rides and camps are part of that national fabric. How does this proposal avoid the legal deficiencies the court identified before, and how does the agency answer its own prior finding that piecemeal local decisions erode values that a national rule exists to protect? The agency also argues administrative burden, but the rule as written already accommodates the things the agency says it cannot do. The record states that the rule "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)." Exceptions also exist for existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside those exceptions. It should do so, and it should put numbers behind that identification, because a vague claim of administrative burden is not a reason to open the Sandwich Range and the forests around Smarts Brook to road construction. The regulatory flexibility certification does not survive contact with the agency's own analysis. 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 certification reaches its no-impact conclusion by spreading that loss across every small firm in the sector nationally rather than looking at the permit holders actually operating in the affected areas, and it concedes that some of those firms may lose these receipts. The outfitters and guides working the trails near Waterville Valley and Smarts Brook are exactly the small entities this analysis is supposed to protect. The agency should withdraw the certification and conduct an honest assessment of the businesses actually holding permits in roadless areas, not a national average that obscures the real harm. I oppose this rescission. The places I hike, the trails my adaptive group rides, and the campsites where we bring adaptive athletes belong in a category of protection the agency's own numbers cannot justify abandoning. Sincerely, Diane Siegart Thornton

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The White Mountain National Forest has been part of my life since I was a child, over 30 years of camping, hiking, and watching the world slow down the moment the cars and phones fall away. Streams, rivers, birds, and other critters replace all of it. That is unlike anything I can explain. It is pure bliss. I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001), and I am asking the agency to answer specific questions this proposal raises. I hike and camp every year in the White Mountain National Forest, including the Pemigewasset, the Sandwich Range, the Pemigewasset Ext, and the Kearsarge areas. These are real places I know on foot. Standing on a summit and seeing miles of unbroken forest in every direction is something I photograph and carry home. Watching loons on the lakes, eagles and songbirds overhead, and bears on the trails is not a coincidence of luck: it is what intact forest does. The White Mountain's 16 inventoried roadless areas total 240,669 acres and include verified habitat for Bicknell's thrush, black bear, Canada lynx, American marten, moose, brook trout, and the northern long-eared bat. These are the species that share the trails I hike. Rescinding the rule that protects their habitat is not a management adjustment. It is a decision with permanent consequences for the wildlife and the wild character that makes these places worth going to. The agency's own draft environmental impact statement found that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I watch birds everywhere I hike in the National Forest. I ask the agency to explain in this docket what it intends to do with those findings, and why opening these areas to roads is compatible with them. Part of the justification offered for rescission is wildfire and fuels management. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal does not reconcile this finding with its stated rationale. I ask that the agency explain why it is departing from its own prior findings on fire occurrence, and that it square this proposal with the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is not made by the agency's own numbers. The 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, with a net present value spanning -$92 million to +$199 million, while the road system already carries a $6.9 billion maintenance backlog. An action whose own analysis cannot establish a net benefit, measured against those numbers, demands a direct answer: how does the agency justify expanding that road system under these conditions? The Sandwich Range and the Kearsarge area are less traveled. That is exactly the point. Part of the fun of hiking is the effort and planning it takes to get to these areas. We do not need more roads. It has all the access it needs. The agency has proposed a regulatory flexibility certification finding no significant impact on small entities, while its own DEIS names outfitters, guides, and tour operators as affected and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. I ask that the agency withdraw that certification and assess the impact on the small entities actually operating permits in these areas, not a national average figure that obscures local harm. Finally, the proposal solicits reliance interests and its Cost Benefit Analysis weighs none. This comment is one. My family has relied on these areas being protected for over 30 years. My brother takes his family there every year. I think about my nieces and whether they will ever get to experience what real nature is and have an appreciation for it. The agency must identify and weigh the reliance interests that comments like this one describe, not invite them and then set them aside. Sincerely, Tina Campbell

To Whom It May Concern, I am writing to express my strong opposition to the U.S. Forest Service’s proposed rule to rescind the 2001 Roadless Area Conservation Rule. While the administration frames this rollback as a move toward localized flexibility, eliminating these baseline federal protections poses a severe and irreversible threat to approximately 235,000 acres of pristine, inventoried roadless backcountry within the White Mountain National Forest (WMNF) in New Hampshire. The unique topography, ecology, and outdoor economy of New England make a "one-size-fits-all" removal of roadless protections highly damaging to the region for several key reasons: • Fragmentation of Wilderness Buffers: In the rugged terrain of the White Mountains, inventoried roadless areas serve as crucial ecological buffers for designated federal wilderness areas. Allowing road construction and commercial timber harvesting in areas adjacent to places like the Sandwich Range or Franconia Notch will fragment contiguous wildlife habitats, accelerate edge-effect degradation, and permanently alter the wild character of these lands. • Degradation of High-Value Recreation Infrastructure: The White Mountains are the crown jewel of Northeastern outdoor recreation. Pristine backcountry landscapes surrounding iconic routes—including the Appalachian Trail on Mount Moosilauke, and trails like Liberty Springs, Falling Waters, and Nancy Pond—rely on the Roadless Rule to preserve their backcountry solitude. Introducing industrial access roads, traffic, and noise pollution will directly degrade the experience that draws millions of visitors annually. • Economic Harm to New Hampshire's Outdoor Economy: The untouched nature of WMNF's roadless areas is not merely an aesthetic asset; it is vital economic infrastructure. As noted by regional business coalitions like the Granite Outdoor Alliance, New Hampshire's multi-million dollar tourism and outdoor recreation economies depend entirely on the wild, unmarred character of our peaks and valleys. Diminishing these landscapes directly threatens local guiding services, gear outfitters, and hospitality businesses in nearby gateway communities. • Fiscal and Environmental Irresponsibility of New Roads: Building and maintaining roads in the steep, rugged, and weather-threatened terrain of the White Mountains is environmentally disruptive and fiscally reckless. The U.S. Forest Service already faces a massive, multi-billion dollar national road maintenance backlog. Allocating resources toward new road construction in previously protected wildlands—which also statistically elevates the risk of human-caused wildfires—is a step backward for responsible forest stewardship. • Threats to Critical Forest Research: The White Mountains host invaluable long-term ecological research sites, such as the Hubbard Brook Experimental Forest. Opening adjacent roadless areas to commercial exploitation risks disrupting decades of foundational scientific data on northern hardwood forests, water quality, and carbon sequestration. As a frequent visitor to the White Mountains, I have personally hiked many of the trails in these areas. I know firsthand that once these wild spaces are roaded and logged, they can never be truly restored. The 2001 Roadless Rule has successfully protected the ecological integrity and economic value of the White Mountain National Forest for a quarter of a century. I urge the U.S. Forest Service to withdraw this proposal and maintain the nationwide protections that keep New Hampshire’s rarest backcountry wild and intact. Thank you for your time and consideration of these substantive comments. Sincerely, Jean

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The ravens riding thermals above Franconia Ridge have kept me alive. That is not a metaphor. I hike on trails throughout the White Mountain National Forest every week, including in the Pemigewasset Wilderness, the Sandwich Range Wilderness, and the Presidential Range Dry River and Great Gulf Wilderness areas. I work for a locally-owned retail store that equips people to recreate safely in these mountains and helps build community through running, biking, and skiing outings. My partner owns a gas station and deli just south of the Presidential Range. These places are my livelihood and my life, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. I have dealt with bouts of depression for most of my life. Over the last decade I have seen multiple therapists and spent months in outpatient treatment facilities, spending more than $20,000 before insurance on medical care. No pharmacist or therapist has rivaled what the wilderness of the Pemigewasset does for me. The vastness of Franconia Ridge triggers all five senses. I gaze at the ravens riding thermals above the summit. I feel winds that raise the hair on my arms. I taste mountain water clarified by running over the granite landscape. The aroma of balsam firs triggers a nostalgia for the white Christmases of my youth. I pet the underside of Labrador Tea leaves, a softness akin to the bumble bees I left behind below tree line. If making America healthy is a priority of this administration, preserving our wilderness and sharing resources for responsible recreation within them needs also to be prioritized. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911 authorizing federal purchase of private land for national forests was passed specifically because of what happened when New England's mountains were clearcut. The agency is now proposing to undo the protection those lessons produced. I ask that it explain how rescission squares with that history and with its obligations to the 286 municipal water intakes across the Eastern region that sit in watersheds containing affected roadless areas. The economic case for rescission does not hold. 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 marginal gain, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million, all while the road system this proposal would expand already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile those numbers and explain how an action whose own analysis cannot establish a net benefit justifies that expansion. The small-business certification has the same problem. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The store I work for and the one my husband owns are exactly the small entities the certification ignores. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than assessing the businesses permitted in the affected areas. It should withdraw that certification and assess the entities who would actually bear the cost. Finally, the agency's own fire data argues against the proposal. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The streams and waterfalls I drink from, the balsam firs whose smell keeps me grounded, the moose, black bear, Canada lynx, and Bicknell's thrush that share these 240,669 acres with me: all of it is more exposed to fire under this proposal than protected. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire hazard before this rule goes any further. Sincerely, Kelsey O'Connell North Conway, New Hampshire

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Mad River runs from Waterville Valley past Welch and Dickey mountains to the Pemigewasset, and I have fished those waters and hiked those trails for over 20 years. I also fish Upper Hall Pond. Our home sits at the base of Welch and Dickey mountains, with a direct view of those peaks and of the Sandwich Range extending toward us. I volunteer to maintain two of the local trails and to assess the condition of heritage sites within the White Mountain National Forest. I also volunteer on a local search and rescue team. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule as proposed under Docket FS-2025-0001. The four inventoried roadless areas I know best, Waterville (4,312 acres), the Sandwich Range (16,797 acres), Pemigewasset Ext (15,840 acres), and Pemigewasset (32,255 acres), all lie within the White Mountain National Forest in New Hampshire. The White Mountain's 16 inventoried roadless areas total 240,669 acres and form the headwaters for rivers draining to the Connecticut, the Merrimack, and the Saco, providing drinking water to communities across New Hampshire, Vermont, and Massachusetts. Before these lands were protected, New England's mountains were clearcut, which is the condition that led directly to the Weeks Act of 1911 authorizing federal purchase of private land for national forests. I have already seen firsthand the destruction of heritage sites by early road development that preceded the roadless rule. Those sites will be under direct threat if this proposal proceeds. The agency must explain on the record why the history that created these protections is not addressed in its justification for removing them. The proposal invokes wildfire management as a rationale for rescission. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The Sandwich Range and Pemigewasset wilderness are places I enter regularly on foot. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and that it reconcile the rescission with the ignition data in its own draft environmental impact statement. On economic grounds, 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." I have witnessed the thousands of people drawn to these wilderness areas bringing economic activity to local communities. That activity will wane if these forests are opened to road construction and logging operations. There is no demonstrated economic need for such operations; abundant sources of wood and pulp exist throughout the United States and beyond. The agency must reconcile the proposal with its own economic analysis projecting timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year, explain how an action whose own cost-benefit analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog, and do so on this record. The agency must identify which specific administrative burdens are not already addressed by the rule's existing exceptions and quantify those burdens with specificity. The proposal's treatment of sedimentation is not adequate. The agency's own document states 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.'" Excessive sedimentation of the Mad River and the local streams and ponds I fish is a direct consequence I expect from any expansion of road construction into the Waterville, Sandwich Range, and Pemigewasset areas. Across the Eastern region, which includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. The figure stating that skid roads and landings can contribute up to 90 percent of sediment generated by timber activity appears in the agency's document and then no projection of actual sediment delivery to those intakes follows. The agency must provide that projection before this rulemaking proceeds further. Sincerely, [Your Name] [Your City, State]

Subject: Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule – Support for Alternative 1 (No Action Alternative) I am writing as a New Hampshire resident and hiker who has summited all 48 of New Hampshire’s 4,000-foot peaks to strongly oppose the USDA Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule, and to register my firm support for Alternative 1 (the No Action Alternative) in the Draft Environmental Impact Statement (DEIS). For a quarter-century, the 2001 Roadless Rule has provided a balanced, essential safeguard for undeveloped National Forest lands. In the White Mountain National Forest, inventoried roadless areas (IRAs) buffer federally designated Wilderness areas—including the Pemigewasset, Sandwich Range, and Presidential Range-Dry River Wildernesses—creating the continuous, intact habitat and backcountry solitude that define northern New England. Rescinding the rule would jeopardize these remaining unfragmented blocks across the country, including approximately 45 million acres of public land. Having hiked every 4,000-footer in the state, I know firsthand that the value of these peaks lies not only in the trails themselves, but in the unbroken ridgelines, pristine headwaters, and quiet expanses that surround them. Road construction and commercial encroachment in adjacent roadless tracts would permanently alter the character of these historic routes, accelerate soil erosion along fragile alpine and subalpine zones, disrupt vital wildlife corridors for species like the American marten and Canada lynx, and introduce noise and visual fragmentation. Future generations deserve the opportunity to experience the White Mountains with the same wild character and scenic integrity that hikers have cherished for decades. Furthermore, New Hampshire’s tourism and outdoor recreation economy depends directly on the preservation of these lands. Communities across Grafton, Coos, and Carroll counties rely on visitors drawn by high-quality backcountry recreation. Dismantling the Roadless Rule risks degrading the primary asset supporting our regional economy and high quality of life. The 2001 Rule already provides practical flexibility for emergency wildfire response, public safety, and authorized forest management. Rolling back these protections is unnecessary and short-sighted. I urge the Forest Service to maintain intact protections for our public lands by selecting Alternative 1.

Dear Chief Tom Schultz, As a parent, I respectfully submit that the Department should treat the proposed rescission of the 2001 Roadless Area Conservation Rule as the consequential, irreversible administrative action that it is — and apply a standard of justification commensurate with that consequence and that irreversibility. Regarding the Sandwich Range in the White Mountain National Forest, New Hampshire: Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Roadless areas maintain more natural fire regimes. Because roadless areas lack the access that enables intensive suppression and the traffic that brings human ignitions, they retain fire patterns closer to what their ecosystems evolved with. Adding roads changes both ends of the equation at once (Aplet et al. 2026; USDA Forest Service 2001). — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2); USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf) Rescinding the Roadless Rule would open the Sandwich Range, White Mountain 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. This is our legacy and what we leave behind for all living things. Nothing here justifies throwing out two decades of protection. Best regards, CommentID: RLC-20261002-AI4YAS

My name is William Meserve and I’m a resident of Falmouth, Maine. I am writing to oppose the proposed recission of the 2001 Roadless Area Conservation Rule. I am now in my eighties, but for the past seventy years or so, I’ve spent an incredible number of hours hiking, backpacking and camping in the roadless areas of northern New England — sometimes solo and often with my wife, children, grandchildren and brothers. I’ve carried each of my three children and most of my grandchildren over beautiful trails to fabulous summits before they were even two years old, and ever since this early introduction, they all have continued to hike and enjoy their time in the outdoors. These excursions in various roadless areas from Caribou - Speckled in Maine to the Sandwich Range, Pemigewasset, Presidential-Dry River, and the Great Gulf Wilderness in New Hampshire have been memorable for all of us and helped strengthen family bonds. We have all enjoyed immensely the scenic beauty and tranquility of these magical places. They should not be destroyed. Please reconsider your proposed recission of the roadless area conservation rule and preserve or, if anything, enlarge these protected areas so that my children and grandchildren, among millions of others, can continue to enjoy them. Over one hundred years ago much of the forest in New Hampshire, in particular, was heavily logged. Fabulous scenery was destroyed, fires became rampant because of the resulting slash, and erosion clogged many of the rivers that originate in mountainous terrain. Then the Weeks Act was adopted creating the White Mountain National Forest. The wanton destruction of the forest stopped. It’s taken a hundred years for much of it to regrow, but that revival has created incredible recreational activities for many while providing some peace and tranquility to others who are trying to escape the worries of the everyday world. These roadless areas are a priceless resource, and they have had the added benefit of generating increased economic activity in nearby towns and cities. Many years ago, I worked as a logger for a large timber company on National Forest land in Idaho. I witnessed first-hand the incredible damage that is caused by heavy logging machinery and trucks, the wasteland created when an area is logged too intensively, and the extensive destruction of valuable habitat for both animals and birds. While timber resources are certainly important, indiscriminate cutting and disruption of our forests should not be permitted. A principal mission of the Department of the Interior is to preserve and protect our natural resources, including national parks and monuments as well as the numerous areas that have previously been designated as roadless. Please fulfill your fundamental mission by withdrawing your proposed rule that will, if implemented, cause incredible and long lasting damage to these very special places.

Dear Brooke L. Rollins, I am a lifelong Catholic who heeds Pope Francis' call to respect the sanctity of all of God's creation, including the wilderness. The Roadless Rule is essential for keeping forests intact, showing our appreciation for the gift of wild places. New Hampshire still has substantial areas largely unharmed by human development. These places now serve as the last refuges for species endangered by habitat loss and climate change. To damage these place, and imperil the species that rely upon them, is to show a deep disregard for God's creation, which we are called upon to safeguard. I am thinking in particular of the Sandwich Range in the White Mountain National Forest, New Hampshire, which would be affected by the proposed rule change. The area's subalpine and high-elevation ecosystems support vulnerable plant species including white bog orchid and Cutler's goldenrod (vulnerable, IUCN), which occupy narrow ecological niches in wetland-upland transition zones and alpine meadows. These species have limited dispersal ability and cannot recolonize disturbed sites quickly. Road construction and associated soil disturbance directly destroy these microhabitats and create corridors for invasive species that outcompete native flora in disturbed soils. Furthermore, climate refugia networks lose resilience non-linearly when fragmented. Road construction in either Sandwich Range or Carr Mountain does not halve the network's climate adaptation value — it collapses the corridor function entirely. The 4 shared climate-threatened species lose access to the full 29,879-acre refugia, not merely the portion in the developed area. These lands, now under threat, are our birthright, both as Americans and as part of God's creation. It seems with every generation, we discard more of this birthright in favor of short term gain. The cost is always regretted with the next generation, which becomes embittered to its predecessor and their wastefulness. In this time of accelerated extinction and habitat loss, we should slow down and take account of what we value. When I compare a one-time payout with continuous tourism revenue, safeguarded biodiversity, and preserved heritage, the answer is obvious. Do not degrade these lands in gratuitous haste. Listen to the people to whom these lands matter. You answer to us, and we are telling you no. These lands belong to the people, to God's people, not to the powerful and greedy. We speak with many voices but with one answer: no. No to the perversion of our heritage. No to the loss of vital land to future generations. No to the loss of endangered species, which have their own part in God's creation. No to fantasies of growth without end. There is only so much forest left, and we will not carelessly lose any more of it. Best, Alex Marshall CommentID: RLC-20261003-VSZ7NE

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing to voice my strong opposition to the full or partial rescission of the 2001 Roadless Area Conservation Rule and submit the following points for the record. The White Mountains of New Hampshire are where I hike and camp regularly, and where I go in summer to observe shy birds like warblers, ovenbirds, and other deep forest species. The Sandwich Range, a 16,797-acre inventoried roadless area in White Mountain National Forest, is part of a landscape that is already seeing more and more traffic each year as tourists come to see my state's natural beauty. These are one of only a few pristine forests left in New England. Carving them up with more roads will bring more litter, more vehicles polluting the air, more runoff destroying the creeks and streams, would be a devastating loss to our state’s culture, history, and health. Public lands are an investment in our future. They protect our water, our air, our soil, and our connection to nature. They are a responsibility to be treasured and cared for, not plundered to line the pockets of the wealthy. The birds and wildlife I go to observe in the White Mountains depend on interior forest conditions that roads directly degrade. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) The verified species of the White Mountain include Bicknell's thrush, American marten, Canada lynx, the northern long-eared bat, moose, black bear, and brook trout. Opening roadless areas to new construction would alter the habitat conditions on which all of these species depend. I ask that the agency explain how the proposal accounts for these documented effects on bird abundance and species avoidance inside the affected roadless areas. The proposal justifies rescission in part on wildfire and fuels management grounds, but 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." I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission 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. The economic case for rescission is even worse. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile the proposal with its own Cost Benefit Analysis, which 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 fact that the Trump administration has already wasted countless billions of taxpayer dollars compounds that failure. The agency must explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal argues that the 2001 rule exceeded the agency's statutory authority, but the courts that reviewed that question held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address the Tenth Circuit's holding that 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, and explain the basis for any contrary position. Once again, I firmly opposed to the rescission of the 2001 Roadless Area Conservation Rule and demand that the agency answer to the very clear demands of the American people to leave the rule unchanged. Sincerely, J. K. Nashua, NH

As a New Hampshire resident, I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. Removing it would strip protection from about 235,000 acres of the White Mountain National Forest, roughly a quarter of the forest, and from about 45 million acres nationwide. These lands belong to all Americans, and they should stay as they are. The White Mountains drive our economy. The White Mountain National Forest draws more than 6 million visitors a year, more than Yosemite. New Hampshire's outdoor recreation economy is worth nearly $4 billion a year, and the people who hike, ski, fish, hunt, and paddle here fill our inns, restaurants, gear shops, and guide services. North Country towns depend on that business. Visitors come for unbroken backcountry, not logging roads and clearcuts. Roadless areas protect our water and wildlife. The headwaters of the Pemigewasset, Saco, Androscoggin, and other rivers start in these forests and supply communities downstream. New roads mean erosion, runoff, and sediment in streams that hold native brook trout. Large unfragmented forests are also what moose, black bear, and pine marten need, and they will matter even more as the climate warms. These lands buffer our Wilderness and trails. Roadless areas border the Pemigewasset, Sandwich Range, Presidential Range–Dry River, Great Gulf, and Wild River Wilderness areas, and much of the Appalachian Trail and our 4,000-footers. Roads and logging up to their edges would degrade the experience that defines the White Mountains. The wildfire rationale does not fit New Hampshire. Our wet northern hardwood and spruce-fir forests are not the fire-prone western landscapes cited to justify this change, and the existing rule already allows fuel reduction where it is needed. Nothing here requires removing protections wholesale. The public has already spoken. The original rule drew more supportive public comments than any federal rule before it. New Hampshire's congressional delegation has raised concerns, and the state House recognized the value of outdoor recreation this spring. A short comment period is not enough to undo a protection Americans have supported for 25 years. I urge you to withdraw this proposal and keep the Roadless Rule in place, in New Hampshire and across the country. Sincerely, Kyle Dimick

Dear Secretary Rollins: I am writing to express my strong opposition to the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the agency to take Alternative 1, the No Action alternative, and retain full Roadless Rule protections. I live in Webster, NH, and my family has a camp in Pittsburg, NH. I regularly spend time and recreate in the White Mountain National Forest and deeply value the unfragmented landscape that these 15 roadless areas provide to New Hampshire and the citizens of the United States, including Carr Mountain (17,110 acres), Cherry Mountain (8,766 acres), Dartmouth Range (9,233 acres), Great Gulf Extension (15,110 acres), Jobildunk (3,660 acres), Kearsarge (4,554 acres), Kilkenny (28,766 acres), Kinsman Mountain (8,999 acres), Mt. Wolf - Gordon Pond (11,846 acres), Pemigewasset (32,255 acres), Pemigewasset Extension (15,840 acres), Presidential – Dry River Extension (10,555 acres), Sandwich Range (16,797 acres), Waterville (4,312 acres), and Wild River (46,878 acres). These undisturbed areas are a primary reason NH is such a special place to live. Protecting wildlife is important to me. I am an avid birder and one of my hobbies is monitoring and documenting wildlife. The DEIS states that eliminating the Roadless Rule would "adversely affect" 327 threatened and endangered species and 71 critical habitats for these species. In New Hampshire, these roadless areas protect 16 distinct ecosystems that provide diverse habitat for many species, including 5 federally listed and 19 species of concern. Many of these species need large expanses of unfragmented habitat to survive. The DEIS cites findings that habitat fragmentation reduces biodiversity by 13-75% and that bird richness declines with the presence of roads in forests. And it's not just the listed species; it's the hundreds of other species that contribute to the biodiversity of the White Mountain National Forest and make it such a treasure to the people of NH and those from around the country and world who visit to experience its beauty and solitude. It is critically important that roads do not further fragment what little area remains in New Hampshire, and across the United States. The wild, undisturbed areas of the White Mountain National Forest provide a sense of culture and natural heritage. These areas are part of an expanse of natural spaces where many people, including me, find solace and a way to recreate and recharge from the stress of modern life. The landscape is a part of who we are. According to a study by the Granite Outdoor Alliance, in 2024 outdoor recreation and enjoyment contributed $4.2 billion to the New Hampshire economy and supported over 33,000 jobs. This economic benefit expands beyond recreation to support retail, tourism, hospitality, and manufacturing. Logging will not offset the long-term economic losses we would incur by rescinding the 2001 Roadless Area Conservation Rule. The agency's own activity-tracking data show that timber harvest within potentially affected IRAs has averaged only about 500 acres per year, with volume inconsequential to overall nationwide harvest levels, across the 44.7 million acres covered by the rule. That trivial historical harvest level undercuts the claim that roadless prohibitions are a meaningful driver of the national forest health and timber supply problems the agency describes. The Forest Service should explain, with data, how opening land that has produced inconsequential harvest volume for over two decades will now deliver the promised benefits. For these reasons, I strongly urge the U.S. Forest Service and the U.S. Department of Agriculture to abandon the proposed rescission and instead support Alternative 1, the No Action alternative. Thank you for the opportunity to provide public comment.