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I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I am Matt Anthon, a student and outdoor educator residing in Corvallis, OR. I spend my professional time with elementary students running around in the woods and helping them understand the natural world around us. I spent my academic time studying ecosystems, animals, natural relationships, and their importance to our Earth. An area currently protected under the roadless rule is the Three Sisters Wilderness. This area is important to many Oregon residents, including myself, but more importantly, this area includes a vast ecosystem. Animals like the American black bear, Sierra Nevada red fox, American pika, multiple species of bats, Ospreys, Bald Eagles, Rubber boas, and many, many more call the Three Sisters Wilderness home. Revoking the roadless rule puts every one of these animals at risk of habitat loss and population declines. "Ecocide" is a term that has found its way into academic curricula at many levels, meaning an extensive destruction of ecosystems caused by humans. Often committed with the knowledge that long-term damage is likely. Ecocide is harmful to any being that is dependent on natural resources, including us. If direct harm to humans is the type of plea you'd like to hear, revoking the roadless rule is likely to increase wildfires and degrade clean water sources for millions of residents. If the only type of plea that you listen to is economic-based, I'd like to highlight the impact of this decision on outdoor recreation economies. Oregon is a hub for outdoor recreation of all kinds, and it fuels the state's economy heavily. If the repeal is approved, the local economy would reflect this loss of land. I enjoy living in a world where I can experience an undefiled environment, continue to inspire future recreators and scientists, and afford to feed myself, and I hope this continues throughout my lifetime. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake that will impact the ecosystems, residents, and YOU. If the public has any real say in what happens in this decision, let it be known that WE oppose the proposal to rescind or alter the Roadless Rule,” and support “Alternative 1, the No Action alternative.”

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Five generations of my family have gathered and camped along Sherman Creek, adjacent to the South Huckleberry Roadless Area in Colville National Forest in Washington. We go there to enjoy the beautiful scenery, fish, birdwatch, hike, and watch the creek go by. That place, and others like it where I hike and photograph birds, plants, and other organisms in their natural habitat, represent exactly what the 2001 Roadless Area Conservation Rule was meant to protect. I oppose the proposed rescission of that rule under Docket FS-2025-0001, and I ask the agency to respond in full to the concerns below. The agency justifies rescission in part on permitting and administrative burdens, but its own legal description of the rule undercuts that rationale. The rule, as the proposal acknowledges, "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)." If exceptions for public health and safety, existing mineral leases, and community wildfire protection are already written into the rule, the agency owes the public a precise accounting of which burdens those exceptions leave unaddressed. I ask the agency to identify those specific remaining burdens and quantify them, with supporting data, before proceeding further. The birds I watch and photograph along the Tam McArthur Rim Trail in the Three Sisters Wilderness and in the South Huckleberry Roadless Area would fare worse under any regime that allows road construction to expand into currently protected habitat. The agency's own analysis does not hide this: 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. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres. The scale of potential harm to avian communities across that landscape is not speculative; the agency has already documented the mechanism. I want the agency to explain how it squares those documented effects with a decision to rescind the rule. I believe public lands should be managed to ensure the health and function of natural ecosystems, with special care given to protect the biota, hydrology, and soils, and this proposal moves sharply in the opposite direction. The agency must explain how that degradation risk was weighed against the claimed benefits. Finally, the agency's own fire data cuts against the proposal's wildfire rationale. 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 effects analysis concedes that road access could increase the number and frequency of wildfires. The agency must quantify the expected increase in human-caused ignitions that new road access would produce and weigh that figure honestly against whatever reduction in wildfire hazard it claims to address.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Willamette, Siuslaw, and Deschutes national forests have shaped three generations of my family. I have been going to Opal Creek since the 1980s, and it is a special place to Oregonians. My family was heartbroken when wildfire destroyed much of that landscape, and I have volunteered many hours helping restore access and trails there. From summiting my first mountain to my son doing the same in the Three Sisters area, these forests have been a constant. I hike, camp, and do volunteer trail work across these forests because I believe in stewarding the land for current and future generations. Proposed mining at Opal Creek would heavily impact forest recovery and water quality for the entire watershed, and I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The roadless areas I know include Opal Creek and Middle Santiam in the Willamette, Drift Creek and the Siuslaw, and the Three Sisters, West South Bachelor, and Bend Watershed areas in the Deschutes. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The birds I want to hear singing without the roar of traffic live in these places. The agency's own record states 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. The agency's own citation found elk survival rates rose during a road closure and fell again when the gates were removed. The proposal justifies rescission in part on wildfire grounds, but the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I live near a national forest in Oregon. We have had our worst wildfire year ever, with lives lost and resources damaged. All research shows more roads in forests increase risk, not reduce it. We cannot afford to increase that risk. 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 draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Water quality is crucial to all life, and roadless areas are the keystone to that resource. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. Roadless areas are critical to Bend's economy both recreationally and as a clean water source for the community. More roads will impact the watersheds that communities depend on. The agency must explain how it has weighed water quality and municipal supply risk for the communities downstream of these areas. The economics do not hold together. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Mountain biking is a new sport for our family, and roadless areas create a safe and peaceful opportunity that depends on these places staying unroaded. The agency should reconcile its proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Our public lands need to be managed for the long-term benefit of people, the planet, and wildlife. The primary purpose is not resource extraction and corporate profit. Finally, the procedural record here is indefensible. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the original rule. It has held none to undo it. The public has consistently spoken up for public lands and for keeping roadless areas. The government needs to listen to the people and not yield to short-term corporate profit. My family's decades of use, volunteerism, and investment in these forests are exactly the reliance the agency invited and then ignored. We continue to lose wild areas, wildlife species, carbon-storing old-growth, and protected watersheds. Once many of these things are lost, they will be gone forever. Sincerely, Nelson Kline Salem, OR

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Bill Van Bang and I am a GIS analyst from Portland, Oregon. I chose to raise my family here in the Pacific Northwest because of access to the outdoors to hike, hunt, fish, camp, and enjoy the wilderness fart outside the city. I have spent the past twenty years exploring and enjoying the Opal Creek, Bull of the Woods, Mount Jefferson, Salmon-Huckleberry, Mount Hood, Three Sisters, and Mark O. Hatfield Wilderness areas. Allowing road construction, development and commercial logging in currently protected Inventoried Roadless Areas will increase fire risk in areas that contain our remaining diverse and fire resilient forests. Allowing increased logging and roads will threaten clean drinking water sources and endanger the entire ecosystem of the watershed including 2.2 million Oregonians. It will also increase taxpayer burden as the existing National Forest road system has nearly $7 billion in deferred maintenance. For the reasons listed above, fully or partially rescinding the Roadless Rule would be a tremendous mistake that will cause irreversible damage to the health of Oregonians and the planet. I oppose the proposal to rescind or alter the Roadless Rule and support the Alternative 1, the No Action Alternative. --Bill Van Bang

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to eliminate or weaken the Roadless Rule. This reckless action would devastate public lands, waste taxpayer resources, and undermine the water, wildlife habitat, and recreation opportunities on which millions of Americans depend. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean drinking water, provide refuge for vulnerable species, and serve as critical carbon sinks critical to mitigating the worsening impacts of climate change. People hike, forage, bike, fish, camp, ski, climb, and find solace in these remote places. Roads spread invasive species, fragment wildlife habitat, and erode the very ecological resilience we need in the face of a warming climate. More roads in the backcountry also mean more fires: research shows wildfires are more likely to ignite near roads. Once roads and clearcuts fragment these landscapes, the damage is permanent. Weakening or repealing the Roadless Rule would be a grave mistake. I do not support any of the proposed action alternatives that roll back the Roadless Rule. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule in place. I have lived in Oregon for the last 50 years. It is very important to me to save these precious places that add value to my life in all the ways stated above. I like to hike in the beautiful Three Sisters Wilderness, camp at Cascade Lakes, take the canoe out on Waldo Lake. I don't want these places to be destroyed. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026) https://doi.org/10.1186/s42408-026-00450-2 Mildrexler, D.J., Berner, L.T., Law, B.E. & Both, M.S. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation 321, 111950 (2026) https://doi.org/10.1016/j.biocon.2026.111950 Sincerely, Deborah Rocha Eugene, OR 97405-4733 drr@efn.org

I am deeply concerned about the administration’s proposal to eviscerate the roadless rule, which was carefully crafted and overwhelmingly supported by the public when it was introduced - and continues to receive widespread public support for its protection of public lands. These lands include the last remaining intact forests not protected as wilderness areas. Those forests provide crucial carbon storage, sources of clean drinking water for over 60 million people, and habitat for countless threatened and endangered species. They tend to be located in close proximity with cherished public lands in parks and monuments and contain miles of recreational trails. The claim that roads are needed for “management flexibility” and wildfire concerns are flawed. Existing rules allow access for reducing wildfire risks and for restoration efforts. Historical records reveal very few wildfires have occurred in roadless areas, while 90% of ignitions are within a half mile of a road and 88% of such fires are human caused. If wildfire risk is indeed a concern, focus should be placed on the wild land/urban interface, not on roadless areas, For much of my life I have hiked, camped, and worked as a volunteer to maintain trails from the Columbia River Gorge through Mt. Hood and Three Sisters in Oregon, the Lake Tahoe area, the Eastern Sierra and the White Mountains in California. I know from experience that the Forest Service is unable to maintain the roads and trails already in its system and that the recreation economy sustains numerous small rural towns, and that roadless areas provide much needed peace and quiet that countless people regard as being essential to their lives. Please preserve the roadless rule!

I grew up in eastern Oregon and also lived in Washington grown. I’ve hiked thr Pasayten, Eagle Cap, Alpine Lakes, and Three Sisters Wilderness areas. I don’t want roads that will pollute the forest, the land, and the water. We need Roadless spaces in my beloved states, so leave them roadless!

As a backcountry fly fisher who fishes and recreates in areas including the Deschutes National Forest, Three Sisters Wilderness, and Baker-Snoqualmie National Forest, I urge the U.S. Forest Service (USFS) to reject the proposed rescission of the 2001 Roadless Rule. For more than two decades, the Roadless Rule has conserved some of the most important fish and wildlife habitat in the National Forest System while allowing many of the management activities needed to maintain healthy forests. The rule does not prohibit hunting, fishing, grazing, recreation, habitat restoration, hazardous fuels reduction, wildfire mitigation, mining, or access to valid existing rights. Instead, it provides a common-sense framework for limiting new road construction in some of the nation's most intact backcountry landscapes. Rescinding the rule will harm durable access, game migration, and opportunities for future hunters and anglers across the country. USFS currently manages approximately 370,000 miles of roads and faces a deferred maintenance backlog of roughly $10.8 billion, with ~55% of that backlog tied to roads alone. Meanwhile, the proposed rule cites an annual National Forest System sawtimber harvest of just $5.2 to $11.4 million per year in revenue to the Treasury and Forest Service and $4.6 to $10.6 million per year in revenue to the timber industry if the rule were to be rescinded. This proposed action is not fiscally responsible. Building additional roads into currently roadless areas would create new long-term maintenance obligations while diverting resources from the existing infrastructure the agency already struggles to maintain. Roadless areas provide critical habitat for fish and wildlife, conserve clean water, and support the hunting and fishing opportunities that define America's outdoor heritage. These landscapes help maintain secure habitat for elk, mule deer, native trout, and countless other species that depend on large, unfragmented landscapes. They also protect headwater streams and watersheds that supply clean drinking water to communities across the country. The Roadless Rule was developed through one of the largest public participation efforts in federal land management history, generating approximately 1.6 million public comments, 99% of which were in support of the rule. Any decision to weaken or eliminate these protections should be supported by clear evidence that doing so would improve land management outcomes without sacrificing wildlife habitat, watershed health, recreational opportunities, or fiscal responsibility. America's roadless areas remain some of our most valuable public lands. The Forest Service should focus on maintaining existing infrastructure, conserving intact habitat, and ensuring future generations inherit the same hunting, fishing, and backcountry opportunities we enjoy today. While I remain open to common sense, locally informed improvements to the Roadless Rule, Alternative 2 and 3 would remove protections from millions of acres and go far beyond the targeted reforms both I and Backcountry Hunters & Anglers have supported. I respectfully urge the Forest Service to adopt the no action alternative and keep the 2001 Roadless Rule in place. Don't bulldoze the backcountry. Defend the Roadless Rule.

Dear Department of Agriculture Leadership: Greetings, I am writing in support of maintaining the Roadless Rule. For more than 3 decades, I have been a back-country hiker and camper in many of the wilderness areas of our beautiful country, from the forests of North Carolina, New York, Ohio, Minnesota, Oregon, Washington, New Mexico, California, Arizona, Colorado and Utah. I spend as much time as possible outdoors and I have seen all variety of conditions of forests, parks and public lands. The forests and undeveloped areas are cherished. I have hiked and camped in these lands and there is NOTHING like being in the healthy and undivided forests that are teeming with biodiversity and healthy trees and clean water. In places where roads are built, development always follows. These undeveloped lands are precious to maintain drinking water, biodiversity, and climate stability. You can SEE the difference in the biodiversity and the health of forests that have been reduced to mere strips of a few trees. All life begins to disappear. I want my children to be able to witness the wild places that I have seen. I want them to know that the animals in their story books are NOT extinct. We need our country's wild places left without roads to preserve the spirit of American land and freedom. Regarding the Three Sisters in the Deschutes National Forest, Oregon: Rescission of the Roadless Rule exposes the Three Sisters IRA, Deschutes National Forest, to road construction that will convert a zero-road-sediment watershed into one with chronic, irreversible non-point source pollution. The Forest Service has not demonstrated that any management objective justifies this degradation. "Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes." — Journal of Soil and Water Conservation, 2011 The Three Sisters IRA, Deschutes National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. “Klamath-Siskiyou case study mapped ~500 roadless areas and found roadless tracts bolster habitat representation and landscape connectivity, including smaller roadless patches. — Strittholt & DellaSala, 2001 (https://doi.org/10.1046/j.1523-1739.2001.99577.x)” “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205)” “Builds the first national forest-fragmentation database using high-resolution land cover data combined with road density. Demonstrates a methodology for assessing forest intactness across the U.S. and quantifies how few large intact forest patches remain, strengthening the case that the remaining roadless tracts are disproportionately valuable for biodiversity and ecosystem function. — Heilman et al., 2002 (https://doi.org/10.1641/0006-3568(2002)052[0411:FFOTCU]2.0.CO;2)” “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” With appreciation, CommentID: RLC-20261006-93YZ3Q

I live in oregon road less land is the most important, pristine and shrinking. To think that the government believes putting roads through places like the three sisters wilderness. Where elk and deer populations can exist largely without human influence most of the time. To not have places where one find solitude and piece. Without road traffic. The federal government should absolutely have to come to the people before destroying such sacred lands. I cannot put into words how it feels to hike or hunt into the wilderness and feel like you're possibly the first person step on this land.

The streams I fish in the Drift Creek area and all along the Cascades have shown me, over a decade, what logging and roadwork actually do to water. I have watched favorite spots go turbid, go warm, go empty. No fish. That experience is what I bring to this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. The agency's own record undercuts the wildfire rationale offered for this proposal. Its text states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding is the agency's, not an outside critic's. 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 draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not pencil out either, and I say that in the plainest sense. 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, 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 spanning -$92 million to +$199 million. That range cannot establish a net benefit. At the same time, the agency already carries a $6.9 billion maintenance backlog on existing roads against a road budget of roughly $73 million a year. New roads into country that has none add obligations the agency cannot meet with the resources it already has. The agency must reconcile the proposal with these numbers and explain how expanding a road system already in deficit serves the public interest. I hike and camp in the Three Sisters area and in the Mt. Jefferson roadless country regularly, looking for the quiet and isolation that only unroaded wilderness provides. The last time the agency tried to replace the national rule with a state-by-state approach, the courts found the result wanting. The agency's own record acknowledges "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 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 that doomed the last attempt at a state-by-state substitution. Finally, the statutory authority question was resolved by a federal court of appeals. That court stated, exercising jurisdiction pursuant to 28 U.S.C. Section 1291: "we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule 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. If the agency now takes a contrary position, it must say so plainly and explain the legal basis for that departure. Our public lands should be managed for forest health in the broadest sense: streams, habitats, endangered species, trees. Responsible management does not reduce to a single extracted resource. America's lands are as much a part of what makes this country what it is as her people, and anything short of protecting them is a failure toward the children and grandchildren who should inherit them. They deserve access to quiet, pristine wilderness. The agency should say, on the record, how this rescission is consistent with that obligation. Sincerely, Andrew Heaston Corvallis, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike and camp in National Forests to enjoy landscapes, bird and wildlife spots, and enjoy solitude, quietness and dark sky. Public lands must be managed for the current and future public good.That means envisioning the value our public lands have for recreation, wildlife survival, climate change control, water quality, and ensuring there are still undeveloped wilderness areas for future generations. I photograph wildlife, landscapes, and waterfalls and rivers. Road development impacts all of those by changing the scenery, impacting wildlife migrations and homes, and decreasing water flow and water clarity. The kids in my life instinctively notice the difference in a roadless area: the tree canopy, the sound of a waterfall or birdsong not competing with traffic noise. We don’t have the right to deprive future generations of undeveloped national forests. I want an explanation of why this proposal has not included multiple public meetings where the public can make their voices heard in person. Water wars are here. Climate change is fueling water scarcity. Development is fueling water quality issues. Watersheds fed by roadless areas are part of protecting our nation's water quality. Explain how roads and logging won't have a negative impact on watersheds and water quality. Hells Canyon NRA, includes some of Wallowa-Whitman NF, and was on my 2026 photography trip. Birds and butterflies abounded, and Snake River ran clear through the canyon. Proud locals bragged about their forest and generations of family trips to the remote areas. Development would impact the recreation industry and the livelihoods of those who depend on it. Birds would leave based on vehicle noise alone. Deschutes National Forest and a stay in Three Sisters Wilderness area this summer didn’t do it justice. Locals bragged about the lava tubes and waterfalls. Roads would destroy its viewscapes and pristine environment, and negatively impact the tourist and recreation economy. I've explored Daniel Boone NF and the Wolfpen area twice (2022, 2025) to photograph different plants and cliffs and rock formations that change color with morning light, and search for the elusive hellbender. Roads and logging would change that. The next generation deserves the right to experience the area as I have: undeveloped and peaceful. My 2026 visit to the Rogue-Umpqua Divide included hiking to waterfalls deep in the forest. This area is a watershed for drinking water for millions. Developing or building roads through this forest will destroy water quality, impact waterfall viewscapes, and impact the "wow" factor of the area including Crater Lake National Park that has viewscapes of the Rogue-Umpqua Divide. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Wallowa-Whitman NF (515,000 acres), Wallowa-Whitman NF, Oregon - Deschutes National Forest (136,000 acres), Deschutes NF, Oregon - Wolfpen (2,835 acres), Daniel Boone NF, Kentucky - Rogue - Umpqua Divide (6,728 acres), Rogue River NF, Oregon - Three Sisters (7,687 acres), Deschutes NF, Oregon I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

I'm a hiker and backpacker from Portland, Oregon, and I'm writing to urge the Forest Service to select Alternative 1, No Action, and keep the 2001 Roadless Area Conservation Rule in place. I oppose rescission. The places that matter most to me are Mount Hood, the central Cascades around Three Sisters and Broken Top, and the Alpine Lakes Wilderness. Those landscapes are special because they are wild from the trailhead to the summit, and much of what makes them that way is the roadless country that surrounds the designated wilderness. It shields the views, the quiet, and the headwaters that flow into it. Road building along those edges would change all of it. More than 25,000 miles of trails run through roadless areas nationwide, and rescinding the rule would remove the protection that keeps them wild. A road, once built, cannot easily be undone. The rule's value goes well beyond recreation. These roughly 58 million acres include the headwaters of streams that supply drinking water to downstream communities. Road building and logging on steep, erodible slopes increase sediment, damage fish habitat, and raise treatment costs for the people who depend on that water. Keeping these watersheds intact is far cheaper than repairing them. Rescission also does not make sense as a fire strategy. Most wildfires are started by people, and new roads bring more ignition sources into remote country. The Forest Service already cannot maintain the roads it has, so new ones would add washouts, failed culverts, and landslide risk, along with maintenance costs that taxpayers would carry. I understand the argument that roads aid fuels treatment and firefighter access. But the agency can thin and treat the areas near communities, where that work protects homes, without building new roads into the backcountry. Roadless areas also provide large, connected habitat for wildlife that needs room to move, and mature forests that store carbon as the climate changes. The rule has protected these lands for 25 years without closing them to the public. Hikers, hunters, anglers, and backcountry skiers all use them. I ask that the agency respond to these concerns in its final analysis, keep the Roadless Rule, and select Alternative 1. Thank you for considering my comment. Max Portland, OR

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule of 2001. I am a lifelong Oregonian and currently live in Oregon's southern Willamette Valley. I regularly recreate on public lands, including currently inventoried roadless areas that are protected from roadbuilding and timber harvest under the Roadless Area Conservation Rule. Threemile Lake located in the Tahkenitch Roadless Area of the Siuslaw National Forest is one of my favorite places to hike and bring kids to play on dunes. This area consists of coastal rainforest with ancient sitka spruce trees that have ferns growing way up high in the tree canopy. The forest supports wildlife and is a prime area for finding edible wild mushrooms. Tahkenitch Roadless Area also contains a rare coastal dune ecosystem that supports plant species uniquely adapted to shifting sands and the wet deflation zone. The Western Snowy Plover, federally recognized as threatened, nests on the beach in the area. I am also concerned in addition to potential roadbuilding and logging, rescinding the Roadless Rule would expand motorized corridors in the general area for recreational use impacting wildlife. Tenmile Creek is another roadless area further south which is less accessible to hiking and therefore even more valuable to wildlife. Another vitally important IRA is Iron Mountain in the Willamette National Forest in Lane County. A hiking trail takes you through forest and wildflower meadows that support over 300 native wildflower species. The views to the east are phenomenal and if roads were built and surrounding areas were logged the recreational value would be irreparably harmed. To get there, people travel through the small towns and support small businesses along the way. I also frequent Three Creeks Lake and surrounding areas in Deschutes National Forest adjacent to the Three Sisters Wilderness. Roadbuilding and logging in these areas would harm wildlife, recreational value and water resources. Many of the areas currently protected by the Roadless Area Conservation Rule are near the headwaters of watersheds that supply drinking water to our cities. Protecting clean water is vital to our future. According to the DEIS "inventoried roadless areas typically have good water quality due to limited disturbance,” and “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” My drinking water comes from watersheds partially within Inventoried Roadless Areas. I am also concerned that rescinding the Roadless Area Conservation Rule in whole or in part could increase fire risk. As the Administration itself states, “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. The increasing number of wildfires, size of wildfires and intensity of wildfires is a serious concern in the West and doing anything that increases the probability of human caused fires is unwise. Enough fires start due to lightening during our increasingly long fire season, that adding risk that the hot underbelly of a vehicle or a careless toss of a cigarette butt will ignite new fires is unacceptable. The DEIS states that a key purpose of proposing a rescission of the roadless rule is to have greater local decision-making and reduce regulatory burden. A return to decision-making at the individual national forest level means that concerned citizens like myself would have to track proposed roadbuilding and timber harvest across the state and comment on each project. This would limit the public’s ability to meaningfully weigh in. Entirely local planning and decision-making will not adequately account for public opinion. The result would be an erosion of protections needed to support clean drinking water, wildlife habitat, and recreational opportunities. Consistent nationwide protection measures are critical to protecting these values. For all of the above reasons, I believe that alternatives 2 and 3 of the draft EIS would be a serious mistake. I oppose the proposal to rescind or alter the Roadless Rule and I support “Alternative 1, the No Action alternative." I want the Forest Service to protect forests for the multitude of services they provide to people, wildlife, plants, and water resources. I do not want decisions about our public national forestland to favor the private construction industry and timber industry which would inevitably have a bigger voice at the table. The inventoried roadless areas are national treasurers. We cannot afford to serve private industry interests at the expense of the public interest. I urge the Forest Service to retain the current Roadless Rule under Alternative 1.

I adamantly oppose the proposed rescission of the roadless rule. The reasons for its popularity and usefulness are numerous, and have been well described by many commenters and proponents for keeping and legislating the rule. I support all of the comments submitted in opposition of its rescission. These public lands belong to all Americans. As more and more of our country is fragmented by development and roads, there are fewer and fewer public landscapes for regular folk to visit for a remote experience. Hunters, hikers, bikers, wildlife watchers, anglers, botanists, campers, and more visit these areas for experiences that exemplify the American experience in the natural world. These lands represent our heritage and our legacy. For many folks—like me— these roadless areas are destinations for spiritual solace. As our world continues exploding in population and resource extraction, roadless areas increase in value for their counter properties of “lands left alone” and minimal management. These roadless lands serve many roles that protect environmental functions upon which millions of Americans rely. Namely, they serve as filtrates that provide clean water. They provide habitat for endangered species. And, given the stated reason for rescinding the roadless rule, there is all the more reason to keep it in place. Fire study after fire study has shown that wildfire is more prevalent in roaded areas, where fire is often a consequence of human carelessness. It is counterproductive and nonsensical to build roads that will ultimately increase the incidence of wildfire. Personally, I look out at 2 roadless areas from my home—Adams Peak and Threes Sisters which are both in the Pedlar District of the George Washington Jefferson National Forest. Three Sisters is bordered by the Appalachian Trail, and offers a stellar remote experience. Going off trail down into the coves you feel like you are out in some western mountains in the middle of nowhere—a very special adventure. I also hike and bushwhack in the Adams Peak Roadless Area which feels very different from Three Sisters, and where ridge tops provide views of layers of mountains without visible development. Both areas offer migratory birds either stopover or breeding habitat, as well as to resident birds, that has not been compromised by the existence of roads, structure, and human disturbance. Over the years I have sought out and hiked in many of the roadless areas in both the George Washington and Jefferson National Forests, and in the Monongahela National Forest. I prefer these public lands where I can get a good sense of the Appalachian Forests, and I feel immense gratitude that we have these mostly undeveloped areas, and believe that they should retain their roadless status for the benefits of both wildlife and future generations of people like me who prefer and revere these areas. Finally, the backlog of maintenance required on forest service roads is estimated to be in the billions of dollars. These roads that are not maintained erode and contribute to degraded water quality. I urge you to reevaluate the proposal to rescind the roadies rule, and as a benefit to all Americans, to rather recommend legislation of the Roadless Rule. Thank you for considering my comments.

USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule. I have lived in the Willamette Valley most of my life, have birders and hunters in my family, and am an accomplished botanist. I have spent countless hours in the roadless areas of Oregon, particularly in the Ochocos, Kalmiopsis, and the Mt. Hood areas, enjoying and educating others about the unique plant communities in those areas. One of my fondest memories is a hiking/camping trip with my parents in the Three Sisters area. Waking up to a dusting of snow, I raced out of our tent singing strawberries and snow, strawberries and snow!!! Inventoried Roadless Areas provide valuable benefits to communities and ecosystems that are harmed and destroyed by road building. - Drinking water: I am one of millions in our country who rely on national forests for drinking water. Intact forests filter my drinking water, ensuring it is clean and safe. Roadless area are important parts of watersheds that supply clean water to many of us. - Wildfire risk: Roadless areas help protect Oregon communities from wildfires because wildfires are far more likely to start near roads and roughly 90% of wildfires are human caused and start within half a mile of a road. These facts contradict one of the administration’s stated rationales for rescinding the roadless rule. - Wildlife habitat: Roadless areas with intact unlogged and undammed streams provide healthy and connected landscapes for the Pacific Northwest’s wild species including, salmon, trout, elk, bear, frogs, countless birds, dragonflies, and more. All these beings deserve health homes just because they exist. They also nourish our souls, carry cultural significance, and literally feed many people, including my family when I was a child. They contribute to our well-being in ways, some obvious, and others we may only realize if we allow them to perish. - Protection from climate change: Healthy, old-growth forests provide help mitigate and slow climate change. They store carbon. And healthy forests with their mixture of ancient, young, and dead trees, are far more resilient to wildfire than logged over forests. - Roads are costly. Building new roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely, if ever, used. The existing road network carries an $8.5+ billion maintenance backlog. Please don’t expand the roads in our forests; instead reduce them. For all these reasons I ask you to keep the Roadless Rule in place as it is. Thank you.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I hike and camp across, the Deschutes, Mt. Hood, Siuslaw, Three Sisters, and others throughout Oregon and Washington, matter to me in direct and practical ways. I pay attention to bird calls when I am out there. I want to see wildlife. I want the salmon in cold clean water, the bears, the mammals that depend on intact forest. I am filing this comment to oppose rescission of the 2001 Roadless Area Conservation Rule and to ask the agency to answer several specific points its own record raises. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, with the affected area including Essential Fish Habitat and critical habitats managed by NMFS. The forests I hike feed those watersheds. Managing them so clean water reaches salmon populations, bears, and people downstream is not a secondary concern. It is the point. I want the agency to explain what specific protections replace the riparian and watershed buffering that the 2001 rule now provides to those 1,522 intakes and to the cold-water habitat in the Oregon forests named above. 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. Paying attention to bird calls, as I do when I am recreating, requires habitat where that is still possible. Opening these areas to roads degrades exactly that. I want the agency to address this finding directly and explain why it does not weigh decisively against rescission. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission in part on wildfire and fuels management grounds. Those two positions cannot both be true without explanation. I ask that the agency reconcile the proposal with 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 its own prior findings. What sense does it make to build more roads with our money when you can't maintain the ones you have. Its own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding infrastructure it demonstrably cannot maintain. The record also states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency has tried this argument before, and the Ninth Circuit rejected the state-by-state replacement approach it produced. The agency must address how this proposal avoids those same deficiencies and explain its own prior finding that local decision-making can incrementally erode nationally significant roadless values. On 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." The agency must address that court's holding that the 2001 rule fell within the authority Congress granted under the Organic Act and MUSYA, and did not create de facto wilderness, and must explain in plain terms the legal basis for any contrary position it now asserts. I have commented before in 2025 and no one has answered me. People who use these lands and pay for these lands have a right to decide and be heard. The agency held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. One person does not get to decide. We need to clean up what previous generations have destroyed, not add to it. Sincerely, Heather Cook Aurora, Oregon

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to eliminate or weaken the Roadless Rule which includes 58.5 million acres of National Forests and Wilderness areas. This reckless action would devastate public lands, waste taxpayer resources, and undermine the water, wildlife habitat, and recreation opportunities on which millions of Americans depend. The American public have spoken and the Roadless Rule is incredibly popular with both Democrat and Republican voters. This issue is so popular in fact, it is one of the only issues that unite both political parties. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean drinking water, provide refuge for vulnerable species, and serve as critical carbon sinks critical to mitigating the worsening impacts of climate change. People hike, find inspiration, take photos, make art, make music, camp, backpack, forage, bike, fish, camp, ski, climb, and find solace in these remote places. In addition, the American people find solitude, mental as well as spiritual wellbeing in these roadless areas. These wild places are a refuge from the hustle of city life and a momentarily escape from the technological world. These roadless wilderness areas also provide income for local communities including the outdoor industries, camping supplies, fishing equipment, trading posts, and hiking and trail guides. Roads spread invasive species, fragment wildlife habitat, and erode the very ecological resilience we need in the face of a warming climate. More roads in the backcountry also mean more fires: research shows wildfires are more likely to ignite near roads. Once roads and clearcuts fragment these landscapes, the damage is permanent. Weakening or repealing the Roadless Rule would be a grave mistake. I do and I know there's millions of other American citizens that love there public lands. For me here in the PNW there are so many diverse landscapes within the roadless wilderness. I love to keep discovering more areas and escape Portland, Oregon from time to time. I camp, backpack and take photos as well as make works of art inspired by these wild places that I have come to know personally. I would like to share a few places with you here that the Roadless Rule includes that are close to me. Indian Heaven Wilderness, Mount Hood National Forest, Mount Jefferson Wilderness, Mount Washington Wilderness, Three Sisters Wilderness, Hebo Mountain, Gilford Pinchot Nation Forest, Olympic National Forest and Wilderness. The list could go on and on. Each one of these special places hold a special place in my heart with stories and memories that are irreplaceable and I know it's the same for millions of other Americans too. These wilderness have become a sense of place, wellbeing and hold a hope of the future for me. I do not support any of the proposed action alternatives that roll back the Roadless Rule. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule in place and please continue to protect this rule that has been in place for 26 years. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026) https://doi.org/10.1186/s42408-026-00450-2 Mildrexler, D.J., Berner, L.T., Law, B.E. & Both, M.S. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation 321, 111950 (2026) https://doi.org/10.1016/j.biocon.2026.111950 Sincerely, Michael Farley Portland, OR 97211-6369 mfarley11@hotmail.com

Re: RIN 0596-AD66 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I oppose rescission of the 2001 Roadless Area Conservation Rule and request that the Forest Service retain the Rule or adopt substantially narrower alternatives. Rescission would remove national protection from approximately 58.5 million acres of Inventoried Roadless Areas after roughly 25 years. This would eliminate a landscape-level safeguard intended to prevent incremental fragmentation of roadless lands. Administrative Procedure Act and NEPA The Forest Service must provide a reasoned explanation for reversing longstanding policy and address important aspects of the problem, including reliance interests. Motor Vehicle Manufacturers Association v. State Farm, 463 U.S. 29 (1983); FCC v. Fox Television Stations, 556 U.S. 502 (2009). The Ninth Circuit has recognized that roadlessness itself has environmental significance, independent of wilderness designation. Smith v. U.S. Forest Service, 33 F.3d 1072, 1078–79 (9th Cir. 1994). It is therefore not enough to state that future projects will remain subject to NEPA. Project-level review cannot substitute for a national protection preventing incremental fragmentation. The EIS should analyze cumulative consequences of rescission, including road construction, timber harvest, habitat fragmentation, watershed impacts, wildlife connectivity, recreation, and loss of roadless character. Wildfire The proposal relies substantially on wildfire and forest-health concerns, but those concerns do not establish that nationwide rescission is necessary. Roads can improve access for some suppression and fuel-treatment activities, but can also increase human access and ignition risk, fragment habitat, facilitate invasive species, and create permanent maintenance obligations. The Forest Service should quantify the net wildfire effect rather than assume that additional roads necessarily reduce risk. The agency should evaluate whether fuel reduction and wildfire-response objectives can be achieved through existing roads, temporary access, targeted exceptions, or geographically limited amendments. It should also address recent research finding substantially greater wildfire ignition density near roads than in Inventoried Roadless Areas. Oregon Oregon contains extensive roadless lands on the Deschutes, Ochoco, Willamette, Mt. Hood, Umatilla, Wallowa-Whitman, Rogue River-Siskiyou, Fremont-Winema, and Siuslaw National Forests. These areas provide connected habitat, watershed protection, recreation, hunting, fishing, and solitude that cannot be recreated once permanent roads fragment them. This is particularly important in Central Oregon. Roadless landscapes around the Three Sisters, Mt. Jefferson, Paulina, Bachelor, and Metolius watersheds are part of the ecological and recreational landscape on which Central Oregon communities depend. The Forest Service should identify Oregon roadless areas vulnerable to new roads or commercial timber activity and the resulting cumulative effects. Alternatives and fiscal consequences Greater managerial flexibility does not itself establish that rescission is necessary. The Forest Service should evaluate retaining the Rule, targeted wildfire or forest-health amendments, geographically limited exceptions, temporary rather than permanent roads, and forest-plan-specific amendments. If these alternatives are inadequate, the agency should explain why with site-specific evidence. The proposal acknowledges a substantial backlog in Forest Service road and bridge maintenance. Before expanding the road system, the agency should quantify construction, maintenance, erosion, closure, and decommissioning costs and identify funding sources. Request I request that the Forest Service: 1. Retain the 2001 Roadless Rule unless it can demonstrate a legally and scientifically sufficient basis for rescission. 2. Address the Ninth Circuit’s recognition that roadlessness itself has environmental significance. 3. Quantify cumulative environmental consequences of foreseeable road construction and timber harvest. 4. Rigorously analyze roads’ competing wildfire-suppression and ignition effects. 5. Identify Oregon roadless areas and specific management needs allegedly requiring rescission. 6. Meaningfully evaluate narrower alternatives. 7. Address reliance interests created by 25 years of roadless protection. 8. Account for the fiscal consequences of expanding an already maintenance-constrained road network. The Forest Service should not equate increased managerial discretion with demonstrated environmental benefit. If the record cannot establish that rescission advances the agency’s responsibilities after accounting for cumulative consequences, the agency should retain the Roadless Rule. Thank you for including this comment in the administrative record for RIN 0596-AD66.

Dear Secretary Rollins and Chief Schultz: I oppose rescission of the 2001 Roadless Area Conservation Rule. I live in Oregon’s McKenzie River Valley and spend substantial time in western Oregon’s national forests hiking, studying and propagating native plants, and participating in trail work. My family survived the 2020 Holiday Farm Fire, but we lost our home and forest. Wildfire, forest resilience, roads, and water are concrete matters to me. Three Sisters Wilderness is one of the places I value most. I understand that rescission would not remove its statutory Wilderness protection. It nevertheless taught me the value of undeveloped lands surrounding and connecting protected places. Wilderness boundaries do not encompass every headwater, wildlife corridor, or ecological connection supporting the Cascade landscape. The Roadless Rule has limited road construction, reconstruction, and timber harvest in inventoried roadless areas for approximately twenty-five years. USDA now cites changed conditions, improved forest planning, and different policy priorities. To the extent its decision relies on factual findings contradicting those underlying the 2001 Rule, USDA should identify and explain the changes. In Organized Village of Kake v. U.S. Department of Agriculture, 795 F.3d 956 (9th Cir. 2015) (en banc), the Ninth Circuit held that USDA violated the Administrative Procedure Act by contradicting material findings supporting an earlier Roadless Rule decision without adequately explaining its departure. I support scientifically justified work that protects communities and improves ecosystem resilience. I do not accept that removing national protections from 44.7 million acres necessarily improves wildfire safety. USDA recognizes that roads may facilitate treatment and response but may also increase human-caused ignitions. Its analysis says high road-building costs and declining budgets mean the overall increase in treatment capacity would likely be modest. The existing Rule already permits roads needed to address imminent threats to public health and safety from fire or other catastrophic events and specified tree-cutting for restoration and reducing uncharacteristic wildfire effects. USDA should identify deficiencies in these exceptions and explain why targeted amendments could not address them with fewer consequences than nationwide rescission. I do not support Alternative 3. USDA estimates it would remove Roadless Rule designation and prohibitions from 31.7 million of the 44.7 million acres currently governed by the national Rule, retaining about 13 million acres. I mention it only because USDA itself identified approaches less sweeping than complete rescission. The economic analysis requires clarification. Its table labels $9.9 million to $22 million as annual timber benefits to society, while its narrative describes that amount as industry revenue and estimates producer surplus at $4.6 million to $10.6 million. USDA should reconcile those descriptions. USDA estimates that keeping existing roads and bridges in good repair would require $1.6 billion annually, compared with $270 million in FY2023 funding. Annual maintenance is estimated at $5,000 to $50,000 per mile. USDA should disclose expected additional mileage, funding, maintenance responsibility, backlog effects, and decommissioning costs—or explain how those uncertainties were considered. USDA says rescission would not itself authorize a particular road or timber sale, but it also identifies additional road construction and timber harvest as reasonably foreseeable. Later project review cannot recreate the national standard after rescission. The final analysis should address fragmentation, invasive species, watershed alteration, recreation settings, and wildlife connectivity. The DEIS reports that 40 percent of Pacific Northwest surface waters in the affected analysis are impaired. USDA should disclose regional consequences for water supplies, salmonid habitat, mature and old forest, wildfire ignitions, and habitat connectivity. The Tribal Summary reports that, as of December 5, 2025, the majority sentiment among consulted Tribal governments opposed rescission. Concerns included sovereignty, cultural sites, traditional foods, water quality, subsistence resources, and repeated project-level review. USDA should explain how consultation affected the proposal and address those concerns at the same policy scale. It should also assess significant reliance interests created during the Rule’s operation. I request that USDA select Alternative 1, No Action, and retain the 2001 Roadless Area Conservation Rule. I do not endorse Alternative 3 as a substitute. Before issuing a final rule, USDA should address prior findings, foreseeable effects, reliance interests, Tribal concerns, costs, and acknowledged uncertainties. Thank you for considering my comments. Respectfully submitted, Ken Rawles Vida, Oregon