Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas across the Mendocino and Los Padres National Forests are the reason I am filing this comment, and I want the agency to understand what is at stake before it acts. Reister Canyon, Snow Mountain, Skeleton Glade, and Briscoe on the Mendocino, and Black Butte, Bear Mountain, Camuesa, Tequepis, Condor Point, Little Pine, Santa Cruz, and Diablo on the Los Padres, represent the kind of unroaded California landscape that the 2001 rule was written to protect. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule puts all of that at risk, and the agency has not made a credible case that it should. The proposal claims the 2001 rule exceeded the agency's statutory authority. That claim was already litigated. A federal court of appeals addressed it directly and held otherwise, reversing the lower court's grant of injunctive relief: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain on the record the basis for any contrary legal position it now intends to assert, because simply declaring the authority question open does not make it so after a circuit court has resolved it. The agency also argues that the rule creates permitting and administrative burdens that justify rescission. The rule's own text answers that argument. The prohibition on road construction was never absolute: "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 as written already accommodates existing mineral leases and community wildfire protection needs. The agency is required to identify, specifically and on the record, which burdens are not already addressed by those existing exceptions, and to quantify them. A general assertion of burden is not analysis. The regulatory flexibility certification is a separate problem. The proposed rule certifies no significant impact on small entities, yet the agency's 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. The certification reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in areas like Santa Cruz, Condor Point, and Diablo. That approach makes the arithmetic come out small by design. The agency should withdraw the certification and conduct a proper assessment of the small entities actually operating in the potentially affected roadless areas, not a national average firm who may never have set foot in any of them. Finally, the proposal itself invites comment on reliance: it 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. Under settled administrative law, an agency changing an existing policy must assess the reliance interests its prior rule created, not merely invite comments about them and then ignore what it receives. This comment is one such interest. The areas I have named, across two national forests in California, are places whose roadless character I have relied on the 2001 rule to preserve. The agency must identify and weigh the reliance interests described in the comments submitted in this docket, including this one, before it takes any final action. The agency should not proceed with rescission. If it does proceed, it must answer each of the specific legal and analytical failures identified here before any final rule takes effect. Sincerely, Claire L San Francisco, CA

Re: RIN 0596-AD66, Docket No. FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I strongly oppose the proposed rescission and ask the Department to adopt the No Action alternative. I live in Santa Cruz County, California, and have worked in mortgage lending on the Central Coast for 35+ years. I know what wildfire does to communities and home values, and I take the Department's concerns seriously. I have also supported the National Forest Foundation, the Forest Service's chartered partner; my contributions funded nearly 30,000 trees on national forest land. That taught me how slowly a damaged forest recovers, and that protecting intact forest is cheaper than restoring it. Rescission is not needed to address wildfire, and what it gives up cannot be restored. 1. The loss is permanent; the benefit, by the Department's own account, is small. The preamble says management opportunities "would be modest and localized." The projected timber gain (5 to 10 percent more sawtimber; $5.2 to $11.4 million per year) assumes harvest across all 4.8 million operable acres, which the Department calls "unlikely." Against that, it estimates recreation losses of $6.1 million per year and total effects that "could exceed $100 million." Roads are rarely undone, and the agency already carries a $6.9 billion road and bridge maintenance backlog. Once roaded, intact watersheds, habitat, and quiet backcountry do not return. Trading permanent loss for modest, uncertain gain is poor policy. 2. The 2001 Rule already permits the wildfire work the Department cites. The preamble says the prohibitions "removed important management tools." But the Rule expressly allows removal of "generally small diameter timber" to "reduce the risk of uncharacteristic wildfire effects" (36 CFR 294.13(b)(1)(ii)) and road construction "needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event" (§ 294.12(b)(1)). The real complaint is that these exceptions were used in a "limited and inconsistent" way due to reviews and approvals. That is an administrative problem with an administrative fix, not grounds to strip protection from 58.5 million acres. By the Department's figures, the wildland-urban interface covers only 24 percent (9.8 million acres) of the affected lands; three-quarters lies away from the communities the rationale is meant to protect. 3. New roads would add to wildfire risk. Roads bring people, and people start fires. A national study of 1992–2012 records found humans ignited 84 percent of U.S. wildfires and nearly tripled the fire season (Balch et al., PNAS, 2017). The preamble concedes access "can increase human-caused ignition potential." Roads can also open private inholdings to development, as the Alaska petition requests; each new home at the forest edge adds ignition sources, fragments habitat, and adds to what firefighters must defend. 4. Rescission removes the national floor and leaves future development unanalyzed. The proposal authorizes no projects, yet admits later plan amendments "could increase the area where timber harvest and road construction would be allowed," with impacts "beyond those summarized above," and treats them as out of scope. It also adds flexibility for oil, gas, and coal leasing. The analysis measures near-term effects under today's plans while removing the only national limit on tomorrow's. The cumulative effect across 100-plus national forests is not evaluated. 5. Public input would fragment. These lands belong to all Americans. The 2001 Rule followed a national process with about 430 public meetings (66 FR 3244). Under rescission, each area would be decided forest by forest; a Californian would have to follow dozens of proceedings to have the voice available today in one. Tribes agree, citing "the unsustainable burden of project-level review." The process is also rushed: 21 days of comment on the notice of intent, 30 (since extended to 45) on a decision affecting 58.5 million acres, and only 29 of 64 requested Tribal consultations held. Recommended alternative Retain the 2001 Rule. If fuel-reduction work is slowed, fix that narrowly: (a) streamline approval of the existing exceptions within the wildland-urban interface, e.g., by delegating to regional foresters with fixed deadlines; (b) keep using the state petition process (5 U.S.C. 553(e); 7 CFR 1.28), as Idaho and Colorado did. This serves the Department's objectives without stripping protection from the three-quarters of affected land outside the interface. I recognize the needs of timber-dependent communities and the danger of wildfire, but the Department's own numbers show modest, uncertain gains against permanent loss. I respectfully urge withdrawal of this proposal. In closing, this land is largely as nature created it. Whatever one's beliefs about its origin, humans must leave some lands wild and untouched. Respectfully submitted, Forrest Cambell

Re: Comments on Proposed Rescission of the Roadless Area Conservation Rule, RIN 0596-AD66 Dear Secretary Rollins and U.S. Forest Service, I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain these protections. I am a California resident, and I understand firsthand the urgency of wildfire and the need for responsible forest management. But that urgency makes it especially important that wildfire policy be based on evidence rather than assumptions. The claim that eliminating roadless protections will meaningfully reduce wildfire risk is not supported by the available evidence—including the Forest Service's own analysis. The Forest Service's draft environmental analysis found little difference in the proportion of land burned or in fire intensity among wilderness, inventoried roadless areas, and other National Forest System lands. It also found that wildfire ignitions are approximately four times more common on other National Forest System lands than in inventoried roadless areas and wilderness. Other Forest Service research has found that forests with and without roads can experience similar fire rates and that the absence of roads has not prevented appropriate fuel-management activities in roadless areas. Roads are not simply neutral tools for fighting fire. They facilitate human access, and human activity is a significant source of wildfire ignitions. Roads also fragment habitat, alter drainage, increase erosion and sedimentation, facilitate invasive species, and create a continuing footprint in landscapes that are otherwise relatively intact. Nor does the argument for increased timber production adequately justify repeal. Inventoried roadless areas contain some of our nation's least-disturbed forests and provide public benefits that cannot be reduced to the value of timber: clean water, wildlife habitat, carbon storage, recreation, scenic value, and ecological resilience. Many roadless areas are remote and steep, making road construction and timber harvest expensive while creating long-term costs for taxpayers. The economic value of extracting timber should therefore be weighed against both those costs and the substantial value of keeping these forests intact. California's national forests are particularly important as watersheds and as habitat for wildlife. They are part of the natural infrastructure on which communities depend. Protecting intact headwaters and forest ecosystems is a form of long-term stewardship, not an obstacle to responsible forest management. I also question the premise that retaining the Roadless Rule prevents the Forest Service from addressing genuine wildfire or forest-health concerns. The Rule contains exceptions and existing authorities allow appropriate emergency response and management. The relevant question is not whether forests should ever be managed, but whether eliminating nationwide protection for millions of acres of intact landscapes is an effective wildfire strategy. The evidence presented thus far does not establish that it is. The Roadless Rule has protected these lands for 25 years. Once a road enters an intact landscape, its ecological consequences cannot simply be reversed. Before removing a longstanding national protection, the Forest Service should be able to demonstrate clear, evidence-based public benefits that outweigh the permanent costs of increased fragmentation and development. I do not believe the current proposal meets that standard. I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule in its entirety. Wildfire is a serious threat, but it should not be used to justify a policy whose wildfire benefits have not been demonstrated. We should use the best available science to protect communities while also protecting the intact forests, watersheds, wildlife habitat, and ecological resilience that are among our most valuable public resources. Thank you for considering my comments. Sincerely, Louisa Squires Santa Cruz, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The places I love most are deep in the woods, where I can see the stars at night, hear crickets, watch diverse wildlife firsthand, and smell clean air. These are places like no other, and they would be destroyed if the roadless rule were overturned. I photograph hawks and waterfowl in Northern California forests, in the Santa Cruz mountains where I used to live, and in parks like Yosemite. I go looking for nothing in particular, but I am always drawn to birds and other wildlife, photographing what I have the fortune to encounter when I am deep in the woods. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, for that reason and for the reasons that follow. The agency's own draft environmental impact statement acknowledges that bird richness declines with road presence in forested habitat. More specifically, the DEIS cites the findings that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres. The birds I photograph in those forests and mountains are not abstractions in a table: they are the wildlife those acres currently protect. Yet the DEIS cites these findings and draws no projection across the full extent of potentially affected habitat. Alongside this, the DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and then applies that range to nothing. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment, and explain in its response what that range means for bird communities specifically. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. This pattern, documented in the agency's own cited literature, receives no population-level projection anywhere in the document. The agency should project the effects on big game populations and hunter opportunity under each alternative, and that analysis should appear in the record before any final rule is adopted. I believe public land should be preserved as intact self-sufficient ecosystems that are not threatened by potentially dangerous human influences. The roadless rule has served that purpose. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The DEIS then concludes that these lands will continue to sequester and store carbon, a conclusion that simply ignores what harvest and roading would do to that figure. The agency must quantify the change in carbon storage and sequestration under each alternative rather than asserting continuity it has not analyzed. The most direct evidence against rescission comes from the agency's own biological findings. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. The agency anticipates harm and proposes no mitigation for it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule. On the question of roads and resources: the roads in San Francisco, where I live, are crumbling, which makes conditions hazardous for cars and people. The roads regularly used by taxpayers affect the majority of people. The new roads this proposal would open serve a narrow interest: those who want to profit from lumber and recreation, a small minority. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. We need to protect our remaining wild watersheds now more than ever. They sustain our clean water supply and support all life. Building new roads into country that currently has none, while diverting attention and funds from the infrastructure people depend on daily, adversely affects people's lives in both directions at once. The agency has not accounted for this tradeoff, and the record is incomplete without it. Sincerely, Rebecca Small San Francisco, CA

I am writing to express my strong opposition to the Department of Agriculture’s proposed complete rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, Subpart B). As an American citizen living in Northern California, I urge the U.S. Forest Service to select the "No Action Alternative" and preserve national roadless protections in their entirety. As a former Girl Scout, native Arizonan, former Texas resident, and current California resident, I have spent years exploring the vast expanse of the Great American West. I regularly hike, backpack, climb, and enjoy time outdoors. Having access to Inventoried Roadless Areas (IRAs) within the nearby Santa Cruz Mountains, the slopes of the Los Padres National Forest (Big Sur and Ventana wild lands), and the Stanislaus and Eldorado National Forests in the Sierra Nevada is central to my quality of life. These intact ecosystems provide pristine backcountry environments making world-class outdoor recreation possible. They are an irreplaceable heritage that must be protected, that future generations should be able to enjoy. The Draft Environmental Impact Statement (DEIS) fails to justify this sweeping policy reversal, arbitrarily disregarding its own findings on severe environmental and socioeconomic harms. I request that the Forest Service address the following substantive flaws: Unjustified Scale of Impacted Acreage: The proposal removes nationwide protections from approximately 44.7 million acres of IRAs, roughly 23 percent of the National Forest System. Eliminating a uniform national standard introduces severe fragmentation risks to remaining wild spaces without a cohesive conservation baseline. Substituting a predictable national standard with localized administrative discretion is no replacement and jeopardizes ecological connectivity across multiple western states. Disregard for Wildlife and Endangered Species: The DEIS acknowledges that repealing the Roadless Rule is "likely to adversely affect" 327 threatened and endangered species and 71 designated critical habitats. It confirms subsequent road construction and timber harvesting will harm terrestrial and aquatic wildlife through permanent habitat loss, introduction of invasive species, and disruption of critical seasonal migration corridors. Forcing hundreds of vulnerable species into further decline violates the agency’s obligations under the Endangered Species Act and National Environmental Protection Act mandate for rigorous scientific analysis. Quantifiable Negative Impacts to Human Populations: The DEIS outlines severe consequences for human communities that the agency has failed to properly mitigate: Drinking Water Degradation: The DEIS notes that repealing the rule will increase soil erosion, landslide risks, and sediment pollution in watersheds supplying clean drinking water to roughly 24 million Americans. This water also supplies vital irrigation for large-scale agricultural food production in the West, which supplies needed resources to the entire nation. Protecting forested headwaters is critical to maintaining this fragile water infrastructure. Elevated Wildfire Risk: While the agency frames this repeal as a tool for wildfire mitigation, scientific consensus and historical data show that human-caused wildfires are four times more likely to start near a road than in a roadless forest. Constructing new roads into these areas will inadvertently increase ignition risks. Wildfires are already a huge risk due to other environmental factors, increasing the likelihood of ignition is bad for the nation. Fiscal Burden on Taxpayers: The Forest Service suffers from a multi-billion-dollar maintenance backlog on its existing 370,000 miles of roads. The DEIS admits that projected timber sale revenues will be entirely insufficient to cover long-term infrastructure and maintenance costs of new roads, creating an ongoing fiscal drain. Construction will cost far more than what these roads generate from the sale of resources. Violation of Tribal Sovereignty and Trust Responsibility: The DEIS shows overwhelming opposition from consulted Tribal governments, noting the proposal fails to meet federal trust responsibilities. Removing a uniform national baseline shifts an unsustainable project-level review burden onto groups facing limited resources and exposes protected lands to industrial activity and mining interests, threatening sacred sites and essential subsistence resources. Based on the Forest Service's own analysis, rescinding the 2001 Roadless Rule will degrade drinking water for millions, accelerate the decline of over 300 protected species, and increase backcountry wildfire risks. Executing this proposal would be arbitrary, capricious, and a violation of the National Environmental Policy Act. I demand that the agency maintain the 2001 Roadless Rule in its entirety to preserve these lands for the humans and wildlife that depend on them to survive. Jessica Wood Campbell, California

I oppose the removal of the Roadless Rule, as it is crucial to protecting the ecosystems we all heavily rely on to survive as a species. Without maintaining environmental protections to preserve these areas, our world s climate and natural resource systems could collapse. The health of forests maintain the health of watersheds, and habitat for key species. While old growth forests absorb significantly more carbon than second growth stands, which is essential for climate change resilience. Although the proposed repeal is being justified as a wildfire-prevention measure, increasing roadbuilding will only increase wildfires because more than 80% of wildfires occur within 800 meters of roads. In addition, increasing timber production means cutting down more big, old trees. Once an old-growth tree is cut and sold, it will take longer than most human lifetimes to replace it. The Roadless Rule also protects recreation that provides millions in revenue. This recreation sustains American livelihoods in many ways worth protecting. Development and logging may only benefit a few while preserving these lands benefits billions of Americans and wildlife. So please maintain and fight for the Roadless Rule that has kept America green, healthy, and cherished for decades. Sincerely, Nicole E. Santa Cruz, CA

Keep the roadless rule in place. These are decisions that cannot be undone. If we destroy a forest it is gone and will take hundreds of years to return. We have so little protected nature left. There is no development that could be more vital than the carbon sink, habitat, and drinking water these untouched places provide. The whole world is not ours for the taking. - An American Sincerely, Zoe W-F Santa Cruz, CA

I've hiked in many places in the US over the last 60+ years. These lands belong to us taxpayers. Please keep these areas exactly as they are now - quiet, undeveloped, and free for Americans and tourists. I am going to see the Redwoods this weekend in Santa Cruz.I'm sure there will be too many people but I'd rather see them than the alternative.

I live in Port Angeles, WA, on the Olympic Peninsula and previously lived among the redwoods in Santa Cruz County, CA. So I know, close-up, that our forests are irreplaceable. We rely on them to breath, to help protect our water supply, and to soothe our souls, especially in these turbulent times. Rescinding the Roadless Rule will destroy the peace that attracts tourists who are the basis for our local economy, will cause great harm to wildlife and Wildlands as it leads to types of recreation that destroy wilderness areas and protected public lands, and will inevitably lead to greed destroying much of it through drilling for oil, mining for minerals, and building resorts -- all to make rich people richer while you absolutely ruin what we should leave for our children and future generations evermore. PLEASE do what you're paid to do: PROTECT forests and don't rescind the Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Redwood parks and trails shaped how I think about public land. I have hiked in numerous redwood parks and others, biked through nature away from civilization, photographed nature scenes rather than roads, and found that seeing wild animals and birds is a unique treat. What I am asking this agency to do is explain, specifically and on the record, why it intends to undo a rule that has protected these places for more than two decades without holding a single public meeting to justify it. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the 2001 Roadless Area Conservation Rule. It has held none to rescind it. I do not want my children to inherit fewer nature areas to visit than I have had, and I do not see how this agency can justify that outcome without at minimum confronting the evidence in its own record. On wildfire, the agency's own draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the justification for rescission includes fuels management, that finding demands an answer. I ask that the agency reconcile the 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 proposal departs from those prior findings. On economics, the 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'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 -$92 million to +$199 million. I think logically about this: we are very behind on current road maintenance, and the answer cannot be new roads. The agency must 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. On birds, the DEIS cites 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. Encountering birds in unroaded country is exactly the kind of experience that disappears when roads arrive, and no logged stand or rebuilt trail returns what a road network removes. The agency has not explained how this documented harm to bird communities factors into its decision. On the prior state-by-state approach, the agency's own record acknowledges that the USDA "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried replacing the national rule with state-specific approaches before and that effort was overturned. I ask that the agency explain how this proposal avoids the deficiencies the Ninth Circuit identified then, and address its own prior finding that local decision-making can incrementally erode nationally significant roadless values. On statutory authority, the Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency owes a clear explanation of the legal basis for any position to the contrary. Public land should be properly protected for all of us. Roadless areas protect our watersheds, shelter birds and wildlife, and give people places to travel away from roads and development. I oppose this rescission and expect the agency to respond specifically to each of these points before proceeding further. Sincerely, Kathleen Kernan Santa Cruz, CA

My name is Kelly Dykes, and I am a senior at UC Santa Cruz studying Marine Biology. I am writing to urge you to take a stand and protect the Roadless Area Conservation Rule. As someone who studies marine biology and spends a huge part of my life outdoors, I understand how connected healthy ecosystems are to the people and wildlife that depend on them. Forests are not just empty land waiting to be developed. They provide habitat, clean water, recreation, and carbon storage, and they support entire ecosystems that we cannot replace once they are gone. The Roadless Rule has protected millions of acres of our national forests from road construction and certain types of timber harvesting for more than 25 years. The Forest Service’s current proposal would rescind the 2001 rule and remove its national restrictions on road construction, reconstruction, and timber harvest across nearly 45 million acres of National Forest System lands.  This is especially concerning to me because I have built so much of my life around the outdoors. I surf, hike, snorkel, and spend time studying wildlife, and I have seen firsthand how much people depend on natural spaces for recreation and connection to the environment. As a marine biology student, I also know that protecting one ecosystem rarely means protecting just one species. Forests affect watersheds, rivers, fish, birds, and the communities that depend on them. These forests belong to all of us. They provide places for people to hike, explore, camp, and experience nature, while also providing habitat for wildlife and protecting watersheds and clean drinking water. As someone studying marine biology and hoping to spend my career protecting wildlife, I believe it is important to look at these forests as living ecosystems rather than simply as resources to be extracted. We cannot let the greed of politicians and billionaires start picking apart our beautiful country national park by park. Like you, I dream of a world that my future children and my grandchildren can miles of uninterrupted mountains, experience oceans bustling with life, and look up at giant old growth forests. Everyday I see my dream dying in the news and the press conferences, covered up by more distraction and division. My name is Kelly Dykes, and I am asking you to take a stand for these forests and the wildlife, communities, and future generations that depend on them. Please keep the Roadless Area Conservation Rule in place and protect our remaining roadless forests. Sincerely, Kelly Dykes Del Mar, CA

I've biked through California's San Gabriel Mountains, snowboarded among the forests surrounding Lake Tahoe, wandered beneath the redwoods of Santa Cruz, and spent countless hours hiking and exploring the mountains, forests, rivers, and creeks of North Georgia. Since moving to Georgia, I've developed an even deeper appreciation for the connection between healthy forests, clean water, wildlife, and human well-being. Time along the Chattahoochee River and hiking in the Blue Ridge Mountains has taught me that protecting a forest isn't only about protecting trees. It's about protecting an interconnected living system—and our place within it. That's why I'm asking the USDA to retain the 2001 Roadless Rule and the protections it provides to inventoried roadless areas across our National Forest System. Thank you for your consideration.

Hello my name is Rachel and I live in Santa Cruz, California. This comment is for 36 CFR Part 294 RIN 0596-AD66. I am commenting to urge you to keep national forests untouched. Do not repeal the 2001 roadless act. In the proposed bill you say the land is “fuel-filled” which to me makes me think the purpose of this road is to drill for oil or start logging in these areas. DO NOT DO THIS. This change/ adding roads will harm the ecosystem detrimentally, and as an avid backpacker, nature lover, and tracker of climate change, this proposal does not look good. A suggestion to help with managing the land: give the responsibility of the land back to the indigenous populations which have tended this land for centuries before the federal government (they did it better).

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The places I go, Black Butte, Bear Mountain, Bear Canyon, Chalk Peak, are places I go to find wildlife, all wildlife, and to be in a natural environment worth preserving. I am opposing the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) because public land should be managed to preserve the beautiful natural environment for the flora and fauna that live there, and for future generations to appreciate and enjoy. The proposal does the opposite. The agency's own record undermines the wildfire rationale offered for this rescission. The DEIS states plainly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Bear Mountain and the other places I named sit inside the landscape this rule protects. Opening that landscape to roads does not reduce fire risk; the agency's own findings say it compounds it. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence and fuel treatment 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 no stronger. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." 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 against recreation losses of at least $6.1 million a year, a net present value spanning -$92 million to +$199 million, and all of this against a road maintenance backlog already standing at $6.9 billion. The agency must reconcile those numbers and explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding a road network it already cannot afford to maintain. The state-by-state rationale fares no better on the record. The agency's DEIS quotes its own prior position describing "its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried a state-by-state replacement before, and the Ninth Circuit found it deficient. The agency should 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 court identified the last time. The authority question is already settled. When the agency's power to issue the 2001 rule was challenged in court, the Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the rule within the authority Congress granted under the Organic Act and MUSYA and rejected the argument that it created de facto wilderness. The agency must state, on the record, the legal basis for any position that contradicts that holding. Wildlife does not negotiate around roads. The DEIS draws on the federal grizzly bear recovery plan to note that increased contact and conflict in roaded habitat can end in grizzly mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Bear Canyon and Bear Mountain are not abstractions to me; they are the places I go to encounter wildlife in a landscape that still functions as one. The agency must respond specifically to the bear mortality data in its own DEIS and explain what mitigation, if any, it proposes to offset that harm should this rescission proceed. Flora, fauna, and future generations deserve a better answer than this proposal provides. Sincerely, Edward Shanken Santa Cruz, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tuolumne River roadless area and the Black Butte roadless area are places I care about. One sits in the Stanislaus NF in California, covering 17,217 acres. The other sits in the Los Padres NF, covering 5,116 acres. Rescinding the 2001 Roadless Area Conservation Rule would put both at risk. I oppose this proposal. California holds 381 inventoried roadless areas totaling 4,389,760 acres. That is an enormous legacy, and it rests on the protection this rule has provided. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The Tuolumne River area drains into one of California's most important watersheds. Opening roadless land to road construction threatens that hydrology directly. The agency has not shown how it accounts for that exposure, and I want a clear answer on that point in the record. The agency justifies part of this rescission on wildfire and fuels management grounds. But its own prior findings cut hard against that rationale. The agency's record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's own language. I want the agency to explain, directly and specifically, why this proposal departs from those findings and how the rescission can be squared with them. The fire data in the agency's draft environmental impact statement makes the problem sharper. The DEIS states that "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 contrast between 22.4 and 3.0 is not subtle. The Tuolumne River area and the Black Butte area are both in fire-prone California landscapes. I want the agency to quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that number explicitly against whatever wildfire hazard reduction the proposal claims to deliver. The regulatory flexibility analysis also fails. 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 analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not a real assessment. I ask that the agency withdraw the certification and analyze the impact on the specific small businesses operating in the potentially affected roadless areas, not the national average. Finally, the agency invited reliance interests and then ignored them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My interest in these areas, and the interests of others who have organized recreation, conservation work and community planning around the protections this rule provides, are exactly the kind of settled expectations that must be weighed when an agency changes course. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Ava Donovan Santa Cruz, CA

I am writing to urge the Forest Service to keep the 2001 Roadless Rule fully intact going forward, as it not only helps reduce wildfires but has many other important benefits as well. I care about this because I value having protected areas where Nature is largely “left alone” to simply be what it is without human interference. Amazing scenery, wildlife going through its natural life cycles, pure air and water. . . these not only have a right to exist, they also help us humans thrive too as part of the interconnected web of life. Beyond this, I have a lifetime - over 60 years now - of hiking, camping, and taking road trips to and within forests and parks across the country. These are memorable, lifetime “WOW!” experiences. My reasons for supporting the Rule are many. First and foremost: studies show that wildfires are four times more likely to start in areas with roads than in roadless forest tracts. A whopping 90% of wildfires start within half a mile of a road. The Roadless Rule provides ecologically-intact, unfragmented habitat for for wildlife such as elk and mule deer. It allows the living beings of the natural world - insects, mammals, birds, fish, and more to live, forage for food, mate, and raise their young in a protected space without the constant disruption of invasive human activity. Roadless forests, river and stream ecosystems, and other wilderness, are key to clean drinking water as well. These are important watersheds that millions of people rely on. These wilderness areas include some of the best game and cold-water fish habitat, plus iconic scenery and trails like the Pacific Crest Trail, drawing recreationists, anglers and hunters, and more. Further economic facts include but are not limited to these points: most logging in easily-accessed forest already has been cut down. Roads into wilderness are expensive to maintain and cost taxpayers up to $500,000 per mile due to the rugged terrain. The Roadless Rule has been widely supported by stakeholders in the outdoor recreation industry, outdoor enthusiasts, conservationists, state game and fish agencies, and elected officials. When the First Service first developed this Rule in 1999, it encouraged huge public participation in the rulemaking process, holding over 600 public meetings across the US. More than 1.6 million people submitted comments, with 95% of them supporting roadless area protection. The Roadless Rule remains popular today. I would like to make a different suggestion for helping to maintain the health of our wilderness areas: I would like to see greater collaboration/partnerships with and empowerment of indigenous Native American tribes, which would include their stewardship of these wilderness areas and their historic, cultural practices. These groups are connected to these lands in a way that other people are not: they have history and knowledge of co-existing with these lands for millennia. Their wisdom is key at this juncture in our history. An example of how indigenous wisdom and practices benefit: I live in California, near where the CZU Lightning Complex fires burned so hotly in and around Santa Cruz in 2020. Parks such as Big Basin State Park were severely damaged. Prior to this blaze, the Amah Mutsun Tribal Band indigenous to this area collaborated with partners and performed cultural and prescribed burns in San Vicente Redwoods park, reducing the fuel load. The result: while the CZU fires burned across the entire San Vicente property, the forest there has been more resilient than other nearby forests and parks. Again, I urge you to keep the Roadless rule in place. It is doing its job. It is important. The People want it. Thank you.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting has been part of my identity since I was 12 years old. It is how my father and I spend time together, and it has given me a connection to wilderness that every man, woman, and child in America deserves. The animals I hunt depend on roadless habitat for migration and survival, and the agency's own record tells me exactly what disrupting these habitats with roads would do to them. The DEIS cites the finding that "elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." The agency recorded that finding and then projected no population-level effect on big game anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity before this rescission goes any further. This isn't rocket science -- roads break up habitat for wildlife: deer, elk, mountain lions, etc. disrupting migration and affecting survivability. 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." I said in my comment that most wildfires are caused by human activities and that creating more roads only increases wildfire risk. The agency is now using wildfire management as a justification for rescission while sitting on data showing roaded lands ignite at nearly five times the rate of unroaded ones. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence 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. The economics do not hold up either. The agency's record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal extraction figures, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value range spanning -$92 million to +$199 million. An analysis that cannot establish a net benefit should not be used to justify expanding a road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year. Repair the roads we already have. The agency must reconcile the proposal with that internal economic record and explain on the record how this action serves the public interest. The biodiversity data deserve the same scrutiny. The DEIS cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and is never applied to the 40.1 million acres of potentially affected environment. I hike and camp in the Santa Cruz, San Francisco, and Sierra Nevada and Yosemite areas. The Sierra Nevada alone holds roadless areas whose ecological integrity depends on what that fragmentation range actually means at landscape scale. The agency must apply its own cited finding to the 40.1 million acres before it acts. Nevada holds 316 inventoried roadless areas totaling 3,186,206 acres. Across the Intermountain region, which includes Nevada, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstract numbers. They are the water supply for communities that have relied on the watershed protections the 2001 Rule has provided. Americans deserve access to wild spaces and responsible environmental stewardship. Destroying ecosystems that we have protected for generations is complete lunacy. My taxpayer money should protect wilderness and wild places the way hunters have for centuries as our nation's original conservationists, not subsidize a fraction of a percent of national timber production while accepting wildfire, fragmentation, and water risk that the agency's own record documents and declines to quantify. I oppose this rescission and demand that every unanswered question above receive a direct response before any final action is taken. Sincerely, Emily Casaretto Santa Cruz, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Bird watching is career-focused work for me, not a weekend hobby, and the forests I work in, Los Padres, Shasta-Trinity, and Stanislaus National Forests, are exactly the places this proposal would open to road-building. I oppose the rescission of the 2001 Roadless Area Conservation Rule. I bird watch frequently up in Shasta, and the science in the agency's own draft environmental impact statement explains why roads are a direct threat to what I go there to find. The DEIS cites 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) If roads go in, the birds I study and watch move out or disappear. The agency should explain how it weighed these findings against the rescission, and what it concluded. The proposal uses wildfire and fuels management as a justification, but the agency's own record undercuts that reasoning. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency should explain why this proposal departs from that finding, and reconcile the rescission with its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The proposal also argues that state-specific approaches can substitute for a single national rule. The agency has tried that before, and it did not survive review. The record shows that the agency previously expressed dissatisfaction with the Roadless Rule's nationwide approach and favored state-by-state rulemaking. The Ninth Circuit rejected that substitution. The agency must now explain how this proposal avoids the same deficiencies, and address its own prior finding that local, incremental decision-making erodes nationally significant roadless values that cannot be recovered once roads go in. The regulatory flexibility certification claims no significant impact on small entities, but the agency's own analysis names outfitters, guides, and tour operators as affected parties, and its 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 an estimated $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the potentially affected roadless areas. The agency concedes that some of those firms may lose those receipts. That is not a finding of no significant impact. The certification should be withdrawn and replaced with an assessment of the businesses actually operating in these areas. Finally, the proposal itself 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. I have built part of my career around these forests and the birds in them. The rule's protections are part of what makes that work possible. Under controlling precedent, an agency reversing course must identify and weigh the reliance interests its prior policy created. This comment is one such interest. The agency must account for the reliance interests submitted in response to its own invitation, including this one, before it proceeds further. Sincerely, Stephanie Mancilla Santa Cruz & Modesto CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas inside Los Padres and Inyo National Forests are where I hike and camp. I go to experience nature and enjoy the scenery, and I believe the places that make that possible deserve a serious federal commitment, not a rollback. This comment opposes the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. Bear Canyon, 14,328 acres inside Los Padres National Forest, and Boundary Peak, 210,884 acres inside Inyo National Forest, are the kinds of places this rule has protected. California holds 381 inventoried roadless areas totaling 4,389,760 acres. That is a lot of ground that biodiversity depends on. We need these places protected for wildlife. Biodiversity is essential to the future of mankind, and no serious management proposal can ignore what is lost when unroaded terrain is opened to roads. The agency's own record makes the fire case against this rescission plainly. I go to these forests understanding that roadless conditions limit the ignition risk that comes with human access, and the record supports that understanding. The agency's own environmental analysis states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Public lands should be managed to keep humans from making mistakes that cause wildfires. Roadless areas restrict access, thus restricting potential wildfire. We cannot afford to keep fighting wildfires caused by humans in the forest via roads. I ask that the agency explain why this proposal departs from those prior findings, 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 also weak on the agency's own terms. The record before the agency acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from negative $92 million to positive $199 million. That range cannot establish a net benefit. We cannot afford to maintain the roads we already have, and the agency is already $6.9 billion behind on road maintenance against a road budget of roughly $73 million a year. The agency must explain on the record how expanding a road system carrying that backlog is justified when its own numbers do not resolve in favor of doing so. The proposal argues that state-by-state approaches can substitute for a national rule. The record tells a different story. The agency's own language shows that it previously "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That experiment was litigated. The Ninth Circuit found it deficient. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. How a patchwork of state petitions would protect values at that scale is a question the proposal does not answer. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last tried this approach. On the question of statutory authority, the courts have already spoken. The record includes a Tenth Circuit holding stating: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency must explain, with specificity, the basis for any contrary position. Sincerely, Richard Popchak [Santa Cruz, CA

Hi, I am a resident of Santa Cruz, CA who believes protecting our wild lands and creatures is our non-negotiable responsibility as human stewards. I urge you to stand for the health, safety, and preciousness of our planet by preserving the Roadless Rule.