Read the comments.

I strongly urge the US Forest Service to retain the current Roadless Area rule as it exists and not be modified or eliminated. As a hunter and angler, I have enjoyed many roadless areas in the United States and especially within my home state of West Virginia. Such designated roadless areas as the Seneca Creek, North Fork Mountain, and Cheat Mountain roadless areas in the Monongahela National Forest and Sugar Knob area in the George Washington National Forests are among my favorite places in West Virginia to hunt, hike, camp, and fish. With a graduate degree in plant ecology, I can also attest that the forests in these areas are much healthier than adjoining federal lands managed for timber. This is to a large degree due to our Central Appalachian forests being heavily susceptible to invasive plant invasions which are often severe in managed lands but typically much less common in roadless areas. That is a simple reality that cannot be dismissed based on any sound science. Furthermore, roadless areas by definition are less fragmented than managed areas of the national forests. The Central and Southern Appalachians have many species that have great difficulty dispersing across roads, even relatively small forest roads. This is especially true for many if not most regional endemics such as land snails, lungless salamanders, and perennial plants. While highly mobile species like birds may often benefit from management actions, that is not the case for these other species that depend on these landscapes for survival. Considering the roadless areas occupy less than 1% of West Virginia, it is impossible for me to see how those of us that enjoy hunting, fishing, and hiking in these backcountry landscapes or the very large number of species that benefit from their existence would not be harmed by this proposed rule. I finally would like to say that I am a life-long, tenth-generation West Virginian. As a landowner and full-time resident within the Monongahela National Forest, I am disappointed that the Forest Service has proposed such a poorly justified rule change.

I strongly oppose the USDA's proposal to fully or partially rescind the Roadless Area Conservation Rule. I have lived in Tucker County, West Virginia for more than 40 years and spend time recreating in and around the Monongahela National Forest. A large part of Tucker County’s economy is driven by tourism as people flock to the state’s National Forest and Roadless Areas in particular. Professionally, I have provided place-based education opportunities and administered the building of multi-use trails within the Monongahela National Forest, including the Canaan Mountain Roadless Area. My life, and that of my family and community, are richer because we have the option of recreating, hunting, fishing, and seeking solace on these public lands. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Our national forests are public lands, and they should be protected for the benefit of everyone not opened to greater roadbuilding, more commercial logging, and expanded natural resource and mineral extraction. These lands are part of the public trust, and it is the government's charge and responsibility to be responsible stewards now and for future generations. The Roadless Area Conservation Rule, as it exists, helps protect and preserve the naturalness and wildness of these designated public lands as well as protecting the fish and wildlife habitats that are ALL Americans' birthright and that should not be used to financially benefit commercial industries and interests. The economics and reasoning for the rescission of the Roadless Rule simply do not add up. The Roadless Rule took away “industrial scale” logging, not forest health treatments; and it allows the Forest Service to meet its multi-use mission. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads. There is already over $6.9 billion deferred maintenance backlog according to the DEIS. Timber revenue typically does not cover the cost of the log itself, let alone pay forward to fund the maintenance or decommissioning of roads built to harvest the logs. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. The Forest Service has argued that rescinding the Roadless Rule could help address wildfire risk, but recent peer-reviewed research suggests otherwise. A 2026 study found that wildfires are approximately four times more likely to ignite near roads than in roadless areas. Roads increase human access and human-caused ignition sources. More wildfire mitigation has occurred in Roadless Areas on USFS lands than in roaded areas since the Roadless Rule was put into place. According to Forest Service data, roadless areas represent 21% of the forested landscape in national forests, and yet 34% of the total fuel treatment activities. Opening intact backcountry forests to additional road construction is not a sound wildfire prevention strategy. The lands designated in 2001 by the Roadless Rule represented the best remaining public lands. Experienced foresters, ecologists, and land managers within the Forest Service widely agree that they have adequate decision-making authority to protect and manage their local lands within the Roadless Rule. In four western states alone, there are currently 15 million grazing allotments in Roadless areas; and Utah alone has 83,000 acres of mineral leases in Roadless areas. Political appointees overseeing the agency, who generally lack the land management experience and multi-use conservation understanding of veteran Forest Service employees, are simply trying to meet a political deregulation agenda. In 2001 when the Roadless Rule was enacted, over 1.6 million people commented during the NEPA process with 90% of those comments offering overwhelming support. In 2025 during the initial comment period, the vast majority of comments were against revoking the Roadless Rule. Don’t ignore the voice of the public and let this well-vetted and beautifully simple regulation be rescinded simply because of the current administration’s focus on deregulation when there is no rationale or USFS data to support its removal. These wild landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. please preserve the Roadless Rule to continue to protect our protect our shared public lands through this policy for future generations.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around the Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Having visited the Monongahela National Forest many times over the past 25 years, I have never felt that the Forest required greater or more extensive road access. The existing Forest Roads are more than sufficient to provide reasonable access for recreation and occasionally sanctioned commercial activity, and thus to expand road building on the Mon into previously undisturbed areas and sensitive plant and animal habitat would go against the entire rationale behind our National Forests and the Mon in particular. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Bradley Stephens 248 Franklin St Morgantown, WV 26501-6906 brad.w.stephens@gmail.com

I cannot urge the Forest Service enough to keep the roadless rule in place exactly as it is today. I live in the Eastern US, where our forests were logged and destroyed during the early 20th century. Today, many of those forests are now in recovery thanks to the work of conservation policies like the roadless rule. Just recently I visited Seneca Creek roadless area, and it was incredible. The water clearness and unique ecosystem of mixed hardwood forests with red pine stands is not found near the mid-Atlantic except for isolated ridges and valleys in the highlands of the Appalachian Mountains. History shows that if we do not protect these areas through policy they will be logged, mined, and harvested in ways which are both environmentally and economically unsustainable. It is in the interest of all Americans, not just those who actively enjoy the scenery, peace, and nature these places offer, to keep them wild. Roadless areas provide millions of Americans with high quality ecosystem services such as clean drinking water. The environmental draft report published on the removal even noted that it would harm the quality of said ecosystem services. Your own documents show the danger to everyday Americans that repealing the roadless rule would have. It would be devastating to our country to repeat the mistakes of our forefathers and burn down our environment for short term profit which only exploits, never enriches, the communities it claims to help. On a final note, I'm young, only 20. I want to grow old alongside our forests and watch as they become second generation old growth wilderness. I hope that the future I live in is one where I can, and not one where I watch my favorite places on the planet disappear one by one. I hope that this submission matters, that the submissions of over 600,000 Americans matter, and that our government is one that listens to the people. I earnestly hope that the Forest Service decides to follow alternative 1, no action, not only for every American's sake, for nature's sake, but for my own as well. Attached are images I've taken inside roadless rule areas near me which showcase their beauty. Thank you, Owen Flickinger

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around the Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Having visited the Monongahela National Forest many times over the past 25 years, I have never felt that the Forest required greater or more extensive road access. The existing Forest Roads are more than sufficient to provide reasonable access for recreation and occasionally sanctioned commercial activity, and thus to expand road building on the Mon into previously undisturbed areas and sensitive plant and animal habitat would go against the entire rationale behind our National Forests and the Mon in particular. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Bradley W. Stephens Morgantown, WV

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Don’t do it. Ever. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, John

I would like to comment against the proposed removal of the Roadless Rule. I am a lifelong West Virginia hunter and outdoorsman and I have extensive experience in our states roadless areas. I think the Roadless Rule as-is provides a balance between allowing access for fire suppression or habitat improvement projects while preserving large, intact habitats for fish and game, which are increasingly rare in 2026. I have been to many of West Virginia's Roadless Areas including Seneca Creek, North Fork Mountain, Tea Creek, Middle Mountain, East Fork Greenbrier, Canaan, Glady Fork, and Little Mountain. These areas represent the some of the best habitat, solitude, recreation, and hunting and fishing opportunities in West Virginia. Please continue to support the Roadless Rule. Thank you.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. As a West Virginian and a citizen of the United States of America, I demand that this craziness of destroying the protected lands end. This Roadless Rule does not serve anyone who cares about the land of America. The creators of this 2001 Roadless Rule are self serving and do not care about this country and the beauty of our protected lands, protected for a reason because there are too many who would deface her and fall in line with the coal companies and other corporations that have defiled our land and waters rather than fulfill their promises to protect and restore the land and waters after they got what they wanted. There is no need for this total lack of compassion and empathy in our country. Our "representatives" have broken their word to represent the people. Enough is enough. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Mary Jane Oref 515 Greenbrier Ave White Sulphur Springs, WV 24986-2009 orefkane@hotmail.com

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Don’t do it. Ever. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, John Robeson 201 Brooks St Edgefield, SC 29824-1004 robesonjohn@gmail.com

Look, am I a hiker? No. But, guess what? For every lazy old slouch like me there are a thousand young and old people who enjoy these roadless areas! They like them for lots of reasons, but the main one is—you guessed it—because they are ROADLESS. A road less traveled is for Frost and for thousands of wanderers who want to see birds, not Buicks—or even bikes! They want to see and hear the beauty of the natural world. So do I, for that matter, even if I have my own places to visit that are not as hard on my old bones as some of these places. I want there to be undisturbed land for my grandkids to wander and explore without the noise, the pollution, and the ugliness of the vehicles that will surely mar these areas should this rule be dismissed. So, yes, I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. It would be just grand of you to leave our wild, wonderful WV wild and wonderful, and wooded and whimsical. Enough already. Stay away from these beautiful areas. Sincerely, Jodi Jones Sincerely, Jodi Jones PO Box 764 Davis, WV 26260-0764 jodijones1362@gmail.com

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Andrew Moore, I live in Pittsburgh, Pennsylvania, I am an environmental journalist and the author of two books of natural history, The Beasts of the East: The Fall and Rise of America’s Eastern Wilderness (Mariner Books, 2026) and Pawpaw: In Search of America’s Forgotten Fruit (Chelsea Green, 2015); and I am a member of the Pennsylvania Native Plant Society and the Wild Ones Western Pennsylvania Area Chapter. In my personal life, I am also an outdoor enthusiast and frequent Roadless Areas in both Pennsylvania and West Virginia. Areas that are especially important to me include the Clarion River Inventoried Roadless Area and the Hearts Content Inventoried Roadless Area, within the Allegheny National Forest; and the numerous and irreplaceable Roadless Areas of West Virginia, including Canaan Loop, Cheat Mountain, Cranberry Glades Botanical Area, Dolly Sods Roaring Plain, Gauley Mountain, and the Seneca Creek Inventoried Roadless Area, among so many others. I have also visited and backpacked in Roadless Areas in the Sierra Mountains of California, and I credit experiences in those wild, roadless mountains for teaching me about the vastness and the irreplaceable beauty and biological heritage of the United States of America. Furthermore, I place immense value on roadless areas in the West and other parts of the United States, places I may not have been to yet, but which I had planned to visit in the near future. The preservation of these landscapes by previous generations of Americans are among our most noble national achievements. We must honor that work and maintain our Inventoried Roadless Areas. I am also the father of a six-year-old boy, a Tiger Cub in Scouting America, and I look forward to taking my son into Roadless Areas so that he, too, can experience the value and wonder of a wild, roadless America. And it is my hope that in the preservation of these Inventoried Roadless Areas, future generations of Americans will be inspired to become the land stewards we so desperately need. Roadless Areas are our National Heritage and Must Be Preserved From Alaska’s vast Tongass to the red spruce forests of the West Virginia highlands, our national forests are an invaluable inheritance, providing innumerable benefits: Habitat for wildlife, including threatened and endangered species; safeguarding the water of farms, aquatic wildlife, and human communities; and unmatched and irreplaceable opportunities for hunters, anglers, hikers, and other appreciators of nature. The 58 million acres within inventoried roadless areas provide these opportunities and services like no other landscapes, while also supporting millions of visitors each year. These places unite all Americans who value the natural world, across the political spectrum. For more than two decades, inventoried roadless areas have helped the U.S. Forest Service meet its statutory mandate to “improve and protect the forest[s]” under its control. The Forest Service introduced the Roadless Rule in 2001 to implement a National Forest System management approach that would allow it to consider the "whole picture" of landscapes across the country, in order to protect the nationally significant ecological and social values of roadless areas. The Forest Service has previously warned that managing inventoried roadless areas on a forest-by-forest basis could allow incremental road construction and timber harvest, leading to the erosion of roadless qualities nationwide, while increasing the agency’s maintenance, and fiscal burdens. As such, the Roadless Rule advances essential goals of forest management: protecting wildlife, preserving clean water, and preventing wildfires. Opening inventoried roadless areas to development jeopardizes our natural heritage without providing the means to address potential harm. Road construction scars forest ecosystems: as Forest Service ranger Elers Koch has said, “Roads are such final and irretrievable facts.” When roads cause contribute to the local extinction of wildlife, those species may never return. When roads increase sedimentation in our waterways, they may remain “dirty” indefinitely. Roads can induce wildfires, and when those road-attributed fires burn through our national forests, old-growth trees, which have grown for thousands of years, can be destroyed in flash. And as we’ve seen, forest roads can only be removed with heavy machinery—and even decommissioned roads can persist for decades, or indefinitely. The protections inherent to the Roadless Rule are more pressing than ever: Megafires, accelerating habitat loss, and diminishing water supplies have heightened the need for coordinated forest management across the national forest system and increased the value of inventoried roadless areas. (COMMENT CONTINUED IN ATTACHED FILE)

It was only 500 years ago when the United States had no roads at all. I ask you to reflect on what the forests, the streams, and lands must have looked like then. Imagine cresting a hill to see nothing but wild lands until the far ocean. Imagine watching buffalo and salmon migrating by the millions. Today in 2026, we cannot fathom what the lands and streams once looked like, just like future generations will be shocked that we had the chance to protect what we have and squandered it – our fresh water, our clean air, our game and fishing populations, our recreation spaces, our wild places. To date, we have only managed to protect a fraction of our lands (for example, the Roadless rule protects fewer than 60 million of the nearly 2 billion acres in the US). I am writing in strong support of maintaining the protections of the 2001 Roadless Area Conservation Rule. This is deeply personal. Many of the regions protected by the Roadless rule are areas that I frequent. I hike, bike, go birding, do photography in Southern Massanutten dozens of times a year. I have also hiked, camped, birded, and explored other Virginia/West Virginia regions including: Dry River, Skidmore, Oak Knob, Gum Run, Little River, Seneca Creek, and Dolly Sods. On the West Coast, I have hiked, camped, birded, and explored Quilcene, Mt. Zion, Alpine Lakes Adj, Thorp Mtn, Teanaway, Eagle, Larch, and San Dimas regions – among many others. As an outdoors enthusiast, I believe the DEIS inadequately addresses the recreation losses from road construction and downstream activities, and I ask that the FEIS provide a thorough analysis of lost visitor spending and local economic multipliers in all impacted regions and specifically the regions named above. Without such analysis, the agency misrepresents the economic impact of rescinding this rule. The USDA’s argument that rescinding the Roadless rule will prevent large wildfires is not credible. 78% of human-caused wildfires on National Forest start within ½ a mile of a road (based on USDA data). The Roadless rule does not preclude forest management activities that help reduce the risk of wildfire. I ask the agency to quantify the expected increase in human-caused ignitions resulting from new road access and to quantify it against claimed reductions in wildfire hazard. I am specifically interested to see this analysis in the regions mentioned above and also in all impacted regions. Furthermore, building new roads will fragment ecosystems, which are already fragile as humans continue to develop and build. Fragmentation by roads has been found to reduce biodiversity by 13-75% (Haddad et al. 2015). Once again, healthy ecosystems gives us clean air, clean water to drink, pollinators to keep our crops productive, healthy soils to grow healthy food for healthy children, beautiful lands that people travel from around the world to see, etc. I ask that the agency provide an economic and environmental analysis of the negative impact of ecosystem fragmentation from new roads on these critical environmental benefits and ecosystem services. Finally, if the agency is looking to create more rural jobs, which I wholeheartedly support, I suggest creating jobs that help preserve these precious ecosystems - it would be a win-win for everyone. Given the agency’s goal of wildfire management and rural job creation, I ask that the FEIS include an analysis of alternative methods to accomplish their goal. I believe that it would be insufficient to consider rescinding the Roadless Rule without a careful economic and environmental analysis of alternative options, including greater funding for job creation around fire fighting, invasive species management, existing road repair, and forest management. I am writing this as an outdoor enthusiast, an angler, a birder and wildlife lover, an artist whose work is inspired by the natural places that I explore, and a passionate environmentalist. The Roadless rule preserves ecosystems – lands, rivers, flora, and fauna. It provides access to people who love to hike, camp, and fish (like me), and who simply want to breathe clean air, drink clean water, and eat healthy food (also like me). Let us keep our lands as wild and healthy as possible – for the land, for ourselves, and for our children. Thank you.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. They are set aside as having potential for wilderness designation. Allowing the construction of roads and other human infrastructure would destroy that potential. Even while not designated, they provide an important alternative in the full spectrum of National Forest land use and recreational opportunities. Roadless areas can be preserved without significant degradation as potential wilderness while still providing opportunities not available in designated wilderness, such as recreational bicycle use and hunting carts and other mechanical equipment not permitted in wilderness. The role of roadless areas as an in-between alternative to full wilderness and motorized lands open to timbering and other development is important and must not be compromised. Once roadless areas are degraded, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, David Johnston PO Box 42 Dryfork, WV 26263-0042 dsjohnstonWV@gmail.com

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. The whole purpose of protected natural lands is to enjoy them without the encroachments that will ensue if this is passed. I for one specifically visit these parts to enjoy being away from what the repeal would create. These are protected lands and should remain as such. Forests such as these are natural treasure that should be protected so all can enjoy them. Sincerely, Matt Kasprzak 1134 Colonial Ave Alexandria, VA 22314-1325 kasprzakmatt@gmail.com

Re: Special Areas; Roadless Area Conservation — Draft Environmental Impact Statement (FS-2025-0001) On behalf of the Vermont Mountain Bike Association (VMBA) and our 28 Chapters and nearly 9,000 members, I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. VMBA is a long-standing partner of the U.S. Forest Service on the Green Mountain National Forest. Through numerous challenge cost-share and volunteer agreements, our Chapters have built and now maintain over 100 miles of trail in the Forest, including trail systems in the Moosalamoo National Recreation Area and in both Rochester and Manchester districts, and our volunteers contribute more than 1,000 hours of stewardship each year. We know firsthand how much careful planning, partnership, and trust goes into building trails on National Forest land, and how easily that work can be undone. While few of the trails we currently manage sit within Inventoried Roadless Areas, the Roadless Rule matters to us for reasons that go beyond our existing or planned future trail map. First, the scale of what is at stake nationally is enormous. IMBA estimates that roughly 10,794 miles of trails currently open to mountain bikes lie within the approximately 45 million acres that would lose protection under this proposal, alongside more than 25,000 miles of hiking trails. These include nearby Eastern destinations our members travel to ride, such as the Seneca Creek and Tea Creek areas of the Monongahela National Forest and Wolf Ridge on the George Washington National Forest. Roadless areas are among the only places in the National Forest System where riders can find long, remote, quiet backcountry experiences that remain open to bikes. Once a road is built through that landscape, its character cannot be restored. Second, Roadless Areas represent the future of quality trail opportunities, including in Vermont. Backcountry, unfragmented landscapes are rare in the Northeast. The Green Mountain National Forest's roadless areas are exactly the kind of places where future, thoughtfully planned trail connections could offer experiences that cannot be replicated on roaded or developed land. Removing these protections forecloses options before communities like ours can plan for them. Third, the proposed approach shifts the burden onto forest staff and partners. Rather than pairing rescission with a replacement framework, the proposal defers decisions to individual forest plans and to state or Tribal petitions, one unit at a time. As a partner that already depends on limited Forest Service staff capacity, we are concerned this piecemeal approach will create years of uncertainty, uneven protections across forests, and more pressure on the very staff who make partnerships like ours possible. Fourth, Vermont has learned hard lessons about watersheds. The flooding our state experienced in 2023 and 2024 showed how road infrastructure on steep, forested slopes can concentrate runoff, damage trails, and threaten downstream communities. Unroaded forests protect clean water and resilience. New roads in steep terrain add maintenance liabilities the agency is already struggling to fund. Finally, the Forest Service's own analysis acknowledges the tradeoff. The draft EIS recognizes that expanded road-based access would come at the expense of quiet, remote backcountry experiences, could increase user conflicts, and could reduce recreation benefits by an estimated $6.1 million per year. Outdoor recreation is a cornerstone of Vermont's rural economy, contributing to more than $2.1 billion - almost 5% - of our state’s GDP. VMBA respectfully urges the Forest Service to retain the 2001 Roadless Rule. If the agency proceeds with changes, we ask that it adopt meaningful national safeguards, including a "No Net Loss of Trails" policy, baseline trail inventories, firm limits on new road construction, protective buffers around existing trails, and continued investment in local Forest Service staff and partnerships. Thank you for the opportunity to comment, and for your continued partnership with Vermont's mountain bike community. Nick Bennette Executive Director, Vermont Mountain Bike Association nick@vmba.org

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking and camping is one of the most important and meaningful ways my family and I connect to each other, decompress from the stresses of life, and find joy in living. Places like Seneca Creek and the Dolly Sods Roaring Plain in the Monongahela National Forest are within driving distance of our home in Maryland. It is a place my family has been and a forest I look forward to further exploring with my family. It disturbs me to my core to think this forest could be stripped of its wilderness, chopped down, habitats of living creatures paved over, polluted with runoff from roads, and the dark starry night skies blotted out with light pollution. This land belongs to the people of the United States, and I say this is NOT what I want done to my land. These places give my life meaning. They give my family connection. To spend time in the presence of roadless wilderness is one of the most awe-inspiring human experiences. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I ask that it be entered and addressed in full on the record. The Monongahela's 20 inventoried roadless areas total 174,885 acres and protect headwaters that feed the Potomac and eventually the drinking water of Washington, D.C. Seneca Creek alone covers 22,287 acres. The Dolly Sods Roaring Plain covers 13,392 acres. These are not abstract statistics. They are the places where my family breathes. The ecosystems at Dolly Sods are spruce-bog remnants more reminiscent of northern Canada than West Virginia, relics of the last ice age clinging to the highest ridges. The Monongahela shelters the West Virginia northern flying squirrel, the Cheat Mountain salamander, the snowshoe hare, the northern long-eared bat, and the red spruce. Road access will not leave any of this intact. It will open these irreplaceable places to being gutted by logging industries and other industrial uses. Why should my generation and the next be robbed of the very few remaining intact forests left in this country? The agency says the rule's permitting burden justifies rescission. But the rule already provides for what the agency claims it cannot do. 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 agency has not shown which specific burdens those existing exceptions fail to address. I ask that the agency identify which specific burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify those burdens with specificity. Across the Eastern region, which includes West Virginia, 286 municipal water intakes sit in watersheds containing affected roadless areas. West Virginia alone holds 25 inventoried roadless areas totaling 195,455 acres. My family, driving from Maryland to reach these forests, is among the users whose reasonable expectations were shaped by two decades of the rule's protections. 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. That is not a procedural footnote. It is a legal deficiency. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Finally, the agency's own fire data undermines a core justification for rescission. 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 agency claims new road access will reduce wildfire hazard. Its own numbers say the opposite. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire risk before this proposal advances another step. Keep the Roadless Rule. Protect Seneca Creek, the Dolly Sods Roaring Plain, and the Monongahela National Forest. Let all 58.3 million acres of wild National Forests remain intact, wild, beautiful, and the absolute American priceless treasure that they are to all living creatures. Sincerely, Rachel Smith Baltimore, Maryland

As a state that relies heavily on eco-tourism, i vehemently appose destruction of our natural resources and land for more roads. We are moving into wv specifically because of its eco tourism small business opportunities. Do not do this! I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Megan Bailey 697 Lancaster Pike Oxford, PA 19363-1132 mbailey.k9connect@gmail.com

Please preserve the Roadless Rule and protect our shared public lands for future generations. I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Margaret Reishman 30 Bradford St Apt 7 Charleston, WV 25301-3056 bella_gardens@outlook.com

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. I am adamantly opposed to removing the Roadless Rule and support it' in it's current state. There is no reason to remove it. Sincerely, stephen jones 3621 Carswell Pl Jefferson, MD 21755-8223 jonesst195@gmail.com