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To the Department of Agriculture and the Forest Service: As someone whose work depends on knowing the difference between revision and erasure, I want to be direct: this isn't a reform, it's a rollback. I grew up going to this area, seeing the redbuds in bloom in the spring, swimming in the river in the summer. Nature is our shared heritage, and it supports clean, bountiful water, clean air, and life. I will lose clean and abundant water, breathable air, home for animals who help to maintain vegetation and the water cycle, recreation space for myself, and knowledge that nature is out there, regulating conditions for life on Earth. Regarding the Tuolumne River in the Stanislaus National Forest, California: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Freshwater extinction risk. Aquatic species face disproportionate extinction risk globally. A multi-taxon assessment of 23,496 freshwater species found that 24% are threatened with extinction, driven primarily by pollution, habitat fragmentation, and sediment loading from upstream disturbance (Sayer et al. 2025). — Sayer et al., 2025 (https://doi.org/10.1038/s41586-024-08375-z) Rescinding the Roadless Rule would open the Tuolumne River, Stanislaus National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Roads degrade watersheds. They cause erosion; silt up streams, harming fish; and they enable widespread logging that actually makes fires worse because it dries out the land. Trees and land are responsible for nearly half of rain over continents. The more we cut trees, the more we exacerbate never-ending drought. A rule that has survived multiple administrations and multiple rounds of circuit-court review should not be rescinded on the present record. Very truly yours, Erica Gies CommentID: RLC-20261007-D7HXTD

Docket ID: FS-2025-0001 Agency: U.S. Forest Service, USDA Subject: Strong Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Agriculture Secretary Brooke Rollings and Chief of the Forest Service, I am writing to express my unequivocal opposition to the U.S. Forest Service’s proposal to fully rescind the 2001 Roadless Area Conservation Rule. As an active recreationist who relies on the pristine wildlands of California's Sierra Nevada, I strongly urge the agency to maintain existing protections for our remaining Inventoried Roadless Areas (IRAs). The Draft Environmental Impact Statement (DEIS) fails to consider the permanent ecological and economic harm that lifting these protections will bring to the vital gateway landscapes surrounding Yosemite National Park, the Tuolumne River watershed, and the Eastern Sierra. I oppose the rule's repeal for the following substantive reasons: * Threats to the Yosemite and Tuolumne Wilderness Boundaries: The 2001 Roadless Rule protects critical, intact wild tracts on the western slope of the central Sierra, directly adjacent to Yosemite National Park within the Stanislaus and Sierra National Forests. This includes fragile forest buffers framing the Tioga Pass corridor and the high-elevation headwaters of the Tuolumne River watershed. Allowing commercial road construction up to the park boundaries fragments critical ecological buffer zones and risks severe soil erosion and stream sedimentation, threatening downstream municipal water supplies and world-class white-water and backcountry recreation. * Impact on Ansel Adams Wilderness Buffers: The IRAs adjacent to the Ansel Adams Wilderness provide a critical protective shield for one of the most heavily used alpine wilderness areas in the United States. Stripping roadless protections from these bordering lands will allow industrial infrastructure, commercial logging roads, and motorized traffic to encroach directly onto wilderness boundaries, destroying the solitude, dark night skies, and pristine wilderness character that draw millions of visitors to the region annually. * Degrading the Eastern Sierra and Mono Lake Basin: In the Inyo National Forest, roadless areas safeguard the fragile, high-desert sagebrush and alpine transition zones of the Mono Lake basin. These intact landscapes are vital for the regional recreation-based economy, supporting hiking, climbing, fishing, and pack-scouting. Opening these terrains to industrial use will fundamentally disrupt critical wildlife migration corridors for iconic species like the bi-state sage-grouse and Sierra Nevada bighorn sheep. * Flawed Wildfire Justifications: The Forest Service claims that rescinding the rule is necessary for wildfire mitigation, yet the agency's own data contradicts this. Over twenty years of data proves that roadless areas can be—and are—actively treated for fuels reduction using smarter, lower-impact methods. Furthermore, the DEIS acknowledges that building new roads introduces more human traffic and vehicle-related exhaust heat, which exponentially increases the risk of human-caused wildfire ignitions in the severe weather-driven terrain of the Sierra. * Fiscal Irresponsibility: The Forest Service currently faces an unsustainable multibillion-dollar deferred road maintenance backlog. Proposing to build and manage new roads in the rugged terrain of the Sierra Nevada while failing to maintain existing infrastructure is fiscally irresponsible and takes vital funding away from actual local forest restoration efforts. The 2001 Roadless Rule provides a balanced framework that allows for Tribal use, public safety, and wildfire management while protecting our last wild spaces. Do not strip protections from the wild forests that define California's natural heritage. I urge the USDA to withdraw this proposal and maintain the 2001 Roadless Rule in its entirety. Sincerely, Rosa Ramirez Crowley Lake, CA 93546 Rrosarosa819@Gmail.com

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking into the Sierra Nevada is for me as it was for John Muir. There is no substitute for immersion in wilderness to refresh the human spirit, and when I travel to places like the Tuolumne River roadless area in the Stanislaus National Forest or Devil Gulch in the Sierra National Forest and capture that beauty on my phone, the people back home are delighted beyond measure by the glimpse into the natural world. That experience is what I am defending here. I oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that this letter be entered into the record in full. The agency's own language on wildfire risk undercuts the case for rescission before that case can be made. The 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." If the agency now proposes to open the Sierra Nevada roadless areas and others like Bear Canyon in the Los Padres National Forest to new road construction on fuels-management grounds, it must explain how that action is consistent with those words. I ask that the agency reconcile this proposal with the ignition data in its own DEIS Table 21 and explain why it departs from its prior findings on fire occurrence and fuel treatment inside roadless areas. The economic rationale offered for rescission is, by the agency's own numbers, unconvincing. The record holds: "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." Americans like me expect the Forest Service to spend its budget, which originates with taxes we pay, in a transparent and responsible manner. We want those funds used to better maintain existing infrastructure and to enhance our recreational opportunities, not to build new roads into areas the rule now protects. That expectation only sharpens when the agency's own Cost Benefit Analysis cannot establish a net benefit and when the agency is already carrying a road maintenance backlog of $6.9 billion against a road budget of roughly $73 million a year. I ask that the agency reconcile this proposal with its own economic analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, and explain how expanding a road system carrying that backlog is a responsible use of public funds. The rule the agency proposes to rescind already contains the flexibility it now cites as justification for rescission. The record acknowledges that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If those exceptions already address public health emergencies, existing mineral leases, and community wildfire protection, then full rescission is not the narrowly tailored response the agency owes the public. The agency must identify, with specificity, which burdens the existing exceptions do not already resolve, and it must quantify them. The water that originates in the Tuolumne River roadless area and in the other Sierra Nevada inventoried roadless areas reaches communities downstream. Americans like me want those water supplies to remain healthy, without the watershed degradation that follows road construction and heavy equipment operations. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of watersheds fed by roadless areas have impaired streams today. Opening these areas to roads risks that record. Finally, the process the agency used to justify rescission is itself defective. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare foreseeable consequences out of scope and invite comment on them. There were more than 600 public meetings to make the rule, but none to undo it. Americans like me want our kids to inherit the same wild places we did. The agency must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as a full part of this action before any final decision is made. Sincerely, Kimberly S San Jose, CA

I oppose the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. The Forest Service should strengthen the Roadless Rule, not eliminate it. These are OUR lands, and I am not willing to watch them handed over to road-builders, loggers, and industrial grazers without a fight. I hike in Los Padres National Forest with friends, family, and colleagues. I have paddled the Tuolumne River during the calm season to experience a wild river at rest, while other friends and family have adventured in its higher flows. As an educator in STEM with a concentration in watershed management, I understand what intact, unroaded forests actually do: they burn at lower intensity, spread fire more slowly, and protect the watersheds that sustain communities and ecosystems alike. Roads increase human-caused ignitions and spread invasive plants. Wildfire risk in Los Padres is already severe, and I oppose any action that makes it worse. The agency's forest-health rationale collapses under the weight of its own document. The proposed rule states at the Rationale for the Proposed Rule section that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Yet the same document cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land, and states that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. Those findings cannot coexist with the stated rationale. The Forest Service must reconcile its forest-health justification with those internal findings before proceeding. The agency also badly underestimates what roadless recreation is worth and what its loss would cost. The Economic Benefits from Recreation in Roadless Area Forests section states that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." This figure is trivial set against roadless recreation benefits of upwards of $1.5 billion, and the same section acknowledges that the magnitude of losses is actually unknown. Roads accumulate. Settings shift and do not recover in a year. The agency must estimate cumulative recreation losses over 20 years as roads and settings change, rather than anchoring the analysis to a single-year 1 percent cap, and must compare those losses directly with projected timber revenue. In the timberland most likely to be opened by this rescission, the document itself states at the Implications for Forest Vegetation, Health, and Carbon section that "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest." Old and mature stands together make up the overwhelming majority of what would be unlocked for harvest, yet the document identifies no old-growth-specific safeguards beyond general land management plan compliance. The Forest Service must separately analyze and disclose protections specific to old-growth stands before this land base is opened to logging. California condors are an Endangered Species found in Los Padres National Forest, where I hike, and I am deeply concerned that formal Section 7 consultation with the Fish and Wildlife Service and NOAA Fisheries has not been completed. The agency must explain how it can finalize this rescission without completing that consultation. Finally, the 2001 Roadless Rule does not address livestock grazing, a federally subsidized industry that causes irreparable damage to western watersheds and contributes less than 4% to domestic beef by the person's own account. New road construction would let harmful grazing expand further into roadless areas and would foreclose any future consideration of Wilderness Act protection for these lands. The Forest Service should prioritize voluntary grazing-permit retirement within roadless areas and close vacant allotments and allotments where grazing conflicts with roadless-area values. I want a direct response to that demand. The Forest Service should withdraw this proposed rescission and adopt a stronger national rule protecting roadless lands from commercial logging, unnecessary roads, damaging grazing, new mineral development, and motorized use.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I grew up in are not abstractions. My father took me hunting deer through the Angeles Forest, around Barley Flats and into the backcountry, and what I carried home from those days was not just game but something harder to name: appreciation for the land and its beauty. We may be hunters, but stewardship always comes first. The elk, deer, and bear we hunt need a refuge. We need to be stewards. Now the agency proposes to rescind the 2001 Roadless Area Conservation Rule, and I am filing this comment in opposition to Docket FS-2025-0001 because that decision would open the very ground those animals depend on. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The areas I named in the Angeles National Forest, including Arroyo Seco, Strawberry Peak, Magic Mountain, and San Gabriel Add, and the Tuolumne River area in the Stanislaus, are part of that inventory. I spend weekends and holidays camping and hiking throughout the Angeles, Inyo, Tahoe, and Stanislaus forests to explore the natural beauty of California, and I want to keep experiencing it, others to experience it, and this land protected for the next hundred years and beyond. These mountains are where I photograph wildflowers in spring, deer, and one day a mountain lion. But mountain lions need protected forests and mountains to have a home. Roads are the core threat to that home. The agency's own record states that elk avoid areas near roads and select habitat away from them, that ideal summer elk habitat is unroaded land with cover and forage, and that elk survival rates rose during a road closure and fell again when the gates were removed. The DEIS also cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the rule's own Tribal record credits its protections with the recovery of deer populations in Alaska by preserving old-growth winter shelter. On bears, the DEIS quotes the federal grizzly recovery plan directly: increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation, and food reward all increase with the use of even secondary unpaved roads. I ask that the agency explain, as part of the record before it closes, how rescinding the rule is consistent with these findings, each of which comes from its own documents. The wildfire rationale the proposal offers fares no better on its own terms. The agency's record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding is the agency's own. I ask that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from its own prior findings. The economic case is equally strained. The agency's record concedes: "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 and a net present value ranging from -$92 million to +$199 million. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Across the Pacific Southwest region alone, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, a cost the proposal does not adequately account for. Finally, on statutory authority: a federal appellate court has already answered the question the proposal re-opens. The Tenth Circuit held, "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain, with specificity, the legal basis for any contrary position it now takes. Sincerely, Elizabeth Harris San Jose, CA

Several years ago, I had the opportunity to spend multiple days rafting the Tuolumne River in California. It remains one of the most extraordinary experiences I have ever had on public lands. What I did not fully understand at the time was that the wild landscape I was experiencing was not there by accident. The Tuolumne flows through and alongside inventoried roadless lands in the Stanislaus National Forest, including the Tuolumne River and North Mountain Roadless Areas. The Clavey River, which joins the Tuolumne in this remarkable canyon, is also surrounded in part by the Tuolumne River Roadless Area. For days, we traveled through a landscape that felt enormous, remote, and genuinely wild. There were stretches where the canyon and river seemed completely removed from the developed world. That experience changed the way I think about public lands. The Tuolumne itself has protections under the Wild and Scenic Rivers Act, and I am grateful for those protections. But a river does not exist separately from the landscape surrounding it. The forests, canyon slopes, tributaries, wildlife habitat, and undeveloped lands surrounding a river are part of what makes that ecosystem—and that experience—whole. That is why the Roadless Rule matters to me personally. I live in Colorado, more than a thousand miles from the Tuolumne River. But I have stood in these roadless lands. I have traveled through that canyon. I know what it feels like to experience a place that has remained largely wild. I want someone twenty, fifty, or one hundred years from now to be able to float that river and feel what I felt. Once we build roads into landscapes like these, we cannot truly make them roadless again. We should be extraordinarily cautious about giving up protections that have helped keep them intact. Please retain the 2001 Roadless Rule and the protections it provides to places like the Tuolumne River Roadless Area and roadless lands across our National Forest System.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests around Yosemite and the Stanislaus, including the Tuolumne River roadless area, are where I go to escape the constant pull in all directions that defines everyday life. I hike and camp there to experience untouched land, and the Tuolumne River area, all 17,217 acres of it in the Stanislaus National Forest, is precisely the kind of place the 2001 Roadless Area Conservation Rule was built to protect. I believe it should stay that way, with the Roadless Rule intact. I am filing this comment in opposition to the proposed rescission under Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and the Pacific Southwest region, which includes those areas, has 1,034 municipal water intakes sitting in watersheds that contain affected roadless land. Opening that country to roads and the extractive activity roads invite is not a minor administrative adjustment. It changes the character of places that, as I have experienced in the Tuolumne corridor, remain nearly untouched yet accessible in ways that make them genuinely available to the everyday, average American. Our extensive public lands make this country unique and special, and I do not think that value is being given serious weight in this proceeding. On the fire question, the agency's own data makes a case against the proposal it appears to be ignoring. The DEIS states that "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." Rescission means new roads; new roads mean more ignitions; the numbers in the agency's own table show the scale of that increase. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that figure openly against whatever wildfire hazard reduction it believes the proposal achieves. The fiscal argument against rescission is equally direct. The agency is already $6.9 billion behind on road maintenance against a budget of roughly $73 million a year. It does not make sense to build something we will not be able to maintain, especially given that we already cannot maintain existing roads appropriately. We should be fiscally responsible and not add to a growing backlog. The regulatory flexibility analysis does not engage this reality honestly. "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." That certification is reached by spreading losses across every small firm in the sector nationally rather than looking at the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw the certification and assess the impact on those specific firms, not the national average. The agency also invited comment on reliance and then performed no analysis of what it received. "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." I have spent time in these areas because the rule existed and the land remained open in the way it did. That is a reliance interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds. Finally, the alternatives analysis forecloses the comparison NEPA requires. "Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it 'would continue to restrict local decision-making discretion' and because analysing roadless values is 'an administrative and legal burden for the agency.'" A purpose defined as deregulation eliminates protective options by definition. The Black Butte roadless area in Los Padres National Forest and the Tuolumne River area in the Stanislaus deserve analysis under at least one alternative that takes their conservation values seriously. The agency should restate the purpose and need in terms of actual forest conditions and carry at least one fully protective alternative through to analysis.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Sierra Nevada range, from Lake Tahoe down through the Stanislaus and on to Bishop, is where I climb. The country I move through includes the Tuolumne River roadless area, 17,217 acres inside the Stanislaus National Forest. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. My view of what public land should be managed for is straightforward: environmental restoration and preservation. This proposal moves in the opposite direction, and the agency's own record explains why. The fire justification for rescission does not survive a reading of the DEIS. The agency's own 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." The Tuolumne River area and the broader Tahoe region are exactly the kind of high-elevation, fire-prone landscapes this finding describes. I ask that the agency explain why the proposal departs from these prior findings and reconcile the rescission with DEIS Table 21, which reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas across the decade 2014 to 2024. The DEIS itself states that human-caused ignitions increase in abundance with proximity to roads. The agency should quantify the expected increase in ignitions from new road access and weigh it against any claimed reduction in wildfire hazard before this rule proceeds. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Road construction in areas like the Tuolumne River watershed carries direct consequences for water quality downstream. The agency has not adequately addressed what opening these watersheds to road building means for the communities and intakes that depend on them. That question deserves a direct answer in the record. The regulatory flexibility analysis is not credible. 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. That certification is reached by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. Spreading a known loss across a national average firm does not assess whether the firms in these specific places are harmed. The agency should withdraw the certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas. Finally, the agency invites comment on reliance while never weighing it. 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. I have planned my use of these lands around the protections the 2001 rule provides. Under the legal standards that govern agency reversals, that kind of reliance interest must be identified and weighed, not solicited and ignored. This comment is such an interest. The agency must account for the reliance interests described in the record it is building, including this one. Sincerely, Joshua Thomas Daly City CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Saving roadless areas of nature is crucial to protecting healthy human as well as wild life, and that conviction is why I am filing this comment in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I have hiked all over the parks and forests around the Bay Area, including roadless areas in the Stanislaus and Los Padres National Forests, among them the Tuolumne River area, Bear Mountain, Bear Canyon, Black Butte, and Chalk Peak. I go there for the exercise and the quiet, to photograph flowers, and to spot hawks, eagles, bluebirds, coyotes, bobcats, and foxes. A healthy, undisturbed environment is crucial for all of them. The agency's own record confirms that concern: the DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) The birds I go looking for in the Los Padres are not incidental to this question. They are precisely the kind of species the science says a road would harm. I ask that the agency explain how this proposal can be squared with those findings and what mitigation it offers to the species that its own evidence shows cannot tolerate road noise. The proposal's wildfire justification troubles me most, because the agency's own words collapse it. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why the proposal departs from these findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally thin. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I do not want any more of my taxpayer dollars spent building new roads for returns that minor. These areas have been protected for years for a good reason, and the agency is already carrying a $6.9 billion maintenance backlog on the roads it has, against a road budget of about $73 million a year. The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system already this far underwater. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Clean water is essential for life. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency owes the public a direct answer to how it intends to protect that water quality record once the rule is gone. The proposal argues that state-by-state approaches can substitute for one national rule, but the agency's own record quotes its prior position: "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." That approach was already tried and was rejected by the Ninth Circuit. The agency should address how this proposal avoids those same deficiencies. On the question of authority, the agency has already lost this argument in court. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that court's finding that the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA, and state the basis for any contrary position it now advances. My kids and grandkids need more unlogged roadless places to explore and find peace in, not less. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That alone demands a full answer before any final action is taken. Sincerely, Peter Knopf Palo Alto, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Saving roadless areas of nature is crucial to protecting healthy human & animal life, and that conviction is why I am filing this comment in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I have hiked all over the parks and forests around the Bay Area, including roadless areas in the Stanislaus and Los Padres National Forests, among them the Tuolumne River area, Bear Mountain, Bear Canyon, Black Butte, and Chalk Peak. I go there for the exercise and the quiet, to photograph flowers, and to spot hawks, eagles, bluebirds, coyotes, bobcats, and foxes. A healthy, undisturbed environment is crucial for all of them. The agency's own record confirms that concern: the DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) The birds I go looking for in the Los Padres are not incidental to this question. They are precisely the kind of species the science says a road would harm. I ask that the agency explain how this proposal can be squared with those findings and what mitigation it offers to the species that its own evidence shows cannot tolerate road noise. The proposal's wildfire justification troubles me most, because the agency's own words collapse it. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why the proposal departs from these findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally thin. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I do not want any more of my taxpayer dollars spent building new roads for returns that minor. These areas have been protected for years for a good reason, and the agency is already carrying a $6.9 billion maintenance backlog on the roads it has, against a road budget of about $73 million a year. The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system already this far underwater. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Clean water is essential for life. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency owes the public a direct answer to how it intends to protect that water quality record once the rule is gone. The proposal argues that state-by-state approaches can substitute for one national rule, but the agency's own record quotes its prior position: "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." That approach was already tried and was rejected by the Ninth Circuit. The agency should address how this proposal avoids those same deficiencies. On the question of authority, the agency has already lost this argument in court. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that court's finding that the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA, and state the basis for any contrary position it now advances. My kids and grandkids need more unlogged roadless places to explore and find peace in, not less. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That alone demands a full answer before any final action is taken. Sincerely, Ann Knopf, 88 yo grandmother

Dear Chief Schultz: As someone who lives in an area whose water supply comes from the Hetch Hetchy Reservoir, the motion to rescind the Roadless Area Conservation rule is of great concern to me. The Tuolumne River, which provides almost 100% of the Hetch Hetchy Reservoir's water, runs directly through public land that is currently protected by the roadless rule. Water is life. The survival of our Bay Area communities quite literally depends on the downstream flow of water from the Tuolumne River, and repeal of the roadless rule jeopardizes the preservation of the Tuolumne River in a big way. Regarding the North Mountain in the Stanislaus National Forest, California: Forest roads are the single largest anthropogenic source of non-point sediment pollution in national forests. The North Mountain IRA, Stanislaus National Forest, currently contributes zero road-generated sediment to its streams. Every road mile constructed in this watershed introduces impervious surfaces, exposed soil, and direct sediment delivery points that did not previously exist. Roads built in the North Mountain IRA, Stanislaus National Forest, would remove riparian canopy at every stream crossing, exposing channels to direct solar radiation. Stream temperatures rise measurably at these points. For cold-water aquatic species, temperature increases of even 1–2°C alter dissolved oxygen concentrations, metabolic rates, and competitive dynamics. The effect is cumulative across multiple crossings within a watershed. The DEIS must provide watershed-level analysis specific to the North Mountain IRA, Stanislaus National Forest — not programmatic generalizations applied across all inventoried roadless areas. The geology, soils, slopes, precipitation, stream network, and downstream uses of this watershed are specific to this place, and the analysis must reflect that specificity. "Compacted forest roads exhibit significantly higher average runoff coefficients (65%) than undisturbed forested areas (7%). This leads to extreme soil erosion rates ranging from 20 to 500 tons per hectare per year in the short term, markedly surpassing the rates observed in undisturbed mountainous forested watersheds (approximately 1 to 5 tons per hectare per year). Forest roads serve as conduits for the transport of runoff and sediment, fundamentally altering water sediment transport processes within watersheds by intensifying channelized flow and enhancing sediment transport efficiency." — MDPI Forests (open access journal review article), 2024 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, including the headwaters of the Tuolumne River, it is vital for maintaining clean drinking water for communities across the country. With best wishes, Emeline

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The hustle and bustle is what I go to nature to escape. Whether I am in Yosemite, in the Los Padres National Forest, or along the Tuolumne River corridor in the Stanislaus, what I am looking for is the same: unspoiled beauty. Mountains, rivers, the microscopic, the biodiversity, the weather, a rare bird encounter I can photograph before the moment vanishes. That kind of beauty requires that the land stay intact. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens to unravel what protects it, and I oppose the proposal in full. The agency's own record undermines the wildfire rationale offered for this rescission. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." DEIS Table 21 confirms that fire density on roaded land runs far higher than inside the affected roadless areas. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, including the areas of the Los Padres, Stanislaus, and Sierra that I visit and photograph, among them Black Butte, Bear Mountain, Bear Canyon, Chalk Peak, Tuolumne River, and Ferguson Ridge. Opening roads into these areas would, by the agency's own numbers, increase ignition risk rather than reduce it. The agency must explain on the record why this proposal departs from those findings and reconcile the rescission with the ignition data its own DEIS contains. The economic case for rescission is no stronger. The agency's own record concedes that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal extraction figure, the agency's Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, while projecting recreation losses of at least $6.1 million a year and a net present value range spanning -$92 million to +$199 million. That range cannot establish a net benefit. Meanwhile, the Forest Service already carries a $6.9 billion road maintenance backlog. I photograph nature precisely because it is unspoiled by human impact, and the biodiversity and grand landscapes I seek in these California roadless areas generate the recreational values the agency's own analysis acknowledges. The agency must reconcile the proposal with those numbers and explain how it justifies expanding a road system its own budget cannot maintain. The birds I hope to photograph whenever a rare encounter allows tell a clearer story than any economic projection. 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, citing Kroeger et al. 2022, McClure et al. 2013, and Ware et al. Roads and the noise they carry would degrade exactly the conditions that make a rare encounter possible. The agency must account for these documented harm pathways in any final analysis and address whether the record supports the claim that local management decisions adequately protect what a national rule now protects. On the legal authority question, the proposal argues the 2001 rule exceeded statutory authority. The Tenth Circuit answered that argument directly, reversing the district court that had enjoined the rule and stating: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must state on the record the legal basis for any position contrary to that holding. The proposal also argues that state-by-state approaches can replace a national rule, but the agency's own prior record acknowledged that local decision-making can incrementally reduce nationally significant roadless values, and the Ninth Circuit found deficiencies the last time this agency substituted a state-by-state framework for the national rule. The agency must explain how this proposal avoids those same deficiencies. I go to these places for peace, for quiet, for the beauty that is unspoiled. What I photograph there cannot be recreated once roads go in. The agency must not proceed without reconciling this proposal with its own findings. Sincerely, Vanessa Abuabara Saratoga, 95070

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tuolumne River roadless area and the Black Butte roadless area are places I care about. One sits in the Stanislaus NF in California, covering 17,217 acres. The other sits in the Los Padres NF, covering 5,116 acres. Rescinding the 2001 Roadless Area Conservation Rule would put both at risk. I oppose this proposal. California holds 381 inventoried roadless areas totaling 4,389,760 acres. That is an enormous legacy, and it rests on the protection this rule has provided. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The Tuolumne River area drains into one of California's most important watersheds. Opening roadless land to road construction threatens that hydrology directly. The agency has not shown how it accounts for that exposure, and I want a clear answer on that point in the record. The agency justifies part of this rescission on wildfire and fuels management grounds. But its own prior findings cut hard against that rationale. The agency's record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's own language. I want the agency to explain, directly and specifically, why this proposal departs from those findings and how the rescission can be squared with them. The fire data in the agency's draft environmental impact statement makes the problem sharper. The DEIS states that "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The contrast between 22.4 and 3.0 is not subtle. The Tuolumne River area and the Black Butte area are both in fire-prone California landscapes. I want the agency to quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that number explicitly against whatever wildfire hazard reduction the proposal claims to deliver. The regulatory flexibility analysis also fails. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not a real assessment. I ask that the agency withdraw the certification and analyze the impact on the specific small businesses operating in the potentially affected roadless areas, not the national average. Finally, the agency invited reliance interests and then ignored them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My interest in these areas, and the interests of others who have organized recreation, conservation work and community planning around the protections this rule provides, are exactly the kind of settled expectations that must be weighed when an agency changes course. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Ava Donovan Santa Cruz, CA

Dear USDA Leadership: Spending time on public land teaches you things maps don't show. Roadless character is one of them. Growing up in this wilderness area meant a deeper understanding of community, a sense of purpose and care for my land and food systems. Protecting our natural spaces has to be highest priority for Americans to keep our home beautiful. Among many days in these forests, one has stayed with me. Every year my father and I put aside work and life stress and come together to camp and hike together and get lost in the wilderness. It brings us closer but also brings us peace, reminders of our responsibilities for our natural world, and builds confidence as we navigate unfamilar territory. The considerations above inform the position set out in the remainder of this comment. Regarding the Tuolumne River in the Stanislaus National Forest, California: The Tuolumne River IRA, Stanislaus National Forest, encompasses jurisdictional waters of the United States protected under the Clean Water Act, including stream channels and associated wetlands subject to Section 404 permitting requirements. Every stream crossing required for road construction in the Tuolumne River IRA, Stanislaus National Forest, involves placement of fill material — culverts, bridge footings, approach fills — into jurisdictional waters, constituting discharge under Clean Water Act Section 404. For the Tuolumne River IRA, Stanislaus National Forest, the DEIS must disclose the number and location of jurisdictional waters, quantify fill material discharges at each potential stream crossing, and document the Section 404 permitting pathway for each discharge point. "In a study in three headwater watersheds in the mountains of central Idaho, 70 percent of sediment deposition from roads constructed on the watersheds, where the slope ranged from 15 to 40 percent, occurred during the first year after construction, and one-fourth of this deposition occurred during road construction (Ketcheson and Megahan, 1996). Sediment generally traveled less than 100 m from its source. Average sediment travel distances from fills, rock drains, berm drains, and landings were between 4 m and 20 m, while that from cross drains was 50 m. The maximum travel distance from some cross drains was more than 250 m." — U.S. Environmental Protection Agency “Just as development and approval of forest plans must conform to existing laws and regulations, new laws or regulations, including this rule, can supersede existing forest plan management direction. This rulemaking process does not require amendments or revisions to forest plans. The NFMA reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). Together with other applicable laws, the NFMA authorizes the Secretary of Agriculture to promulgate regulations governing the administration and management of the National Forest Transportation System (16 U.S.C. 1608). — USDA Forest Service (https://www.federalregister.gov/documents/2001/01/12/01-726/special-areas-roadless-area-conservation)” Retention, not rescission, is the decision the record supports. With urgency, Ellie CommentID: RLC-20260830-P1BKRN

Dear Secretary Brooke L. Rollins, Outfitters and guides operating in roadless country under Forest Service permits constitute a regulated community whose interests have not, in my reading, been adequately addressed in the rationale for rescission. I spend ample time working, living, and recreating in areas around the Tuolumne river. This is beautiful country with an abundance of wildlife and opportunities for recreation. A recission of the roadless rule would not protect the forest in any way, but rather cause damage to habitat and potentially degrade this very important watershed. The Department is urged to retain the Roadless Area Conservation Rule in recognition of the public interest that connections of this kind represent — an interest that rescission would permanently diminish. Regarding the Tuolumne River in the Stanislaus National Forest, California: The aquatic ecosystems of the Tuolumne River IRA, Stanislaus National Forest, depend on the absence of road-generated fine sediment. Clean gravel substrates support macroinvertebrate production and fish reproduction. Intact riparian canopy maintains the cold water temperatures that govern dissolved oxygen levels and species composition. Roads eliminate both conditions. The roadless condition of the Tuolumne River IRA, Stanislaus National Forest, maintains the natural infiltration capacity of the forest floor, intact subsurface drainage pathways, continuous riparian canopy over streams, and undisturbed channel morphology. Road construction disrupts every one of these functions simultaneously — no mitigation measure restores them to pre-disturbance condition. The Clean Water Act requires the Forest Service to comply with state water quality standards in the Tuolumne River IRA, Stanislaus National Forest. The DEIS must demonstrate, with quantified analysis, that road construction in this watershed will not cause or contribute to violations of applicable sediment, turbidity, and temperature standards for all affected stream segments. "Road networks interact with stream networks at the landscape scale. Road networks appear to affect floods and debris flows and thus modify disturbance patch dynamics in stream and riparian networks in mountain landscapes. Road cutbanks intercept slower moving subsurface water, transforming it to surface flow that is 10 to 10,000 times faster and rerouting it along roadside ditches, thereby increasing surface runoff." — WildEarth Guardians, Forest Roads in California report (citing Jones et al. 2000 and Dunne 1978), 2000 “Road networks interact with stream networks at the landscape scale. Road networks appear to affect floods and debris flows and thus modify disturbance patch dynamics in stream and riparian networks in mountain landscapes. Road cutbanks intercept slower moving subsurface water, transforming it to surface flow that is 10 to 10,000 times faster and rerouting it along roadside ditches, thereby increasing surface runoff. — WildEarth Guardians, Forest Roads in California report (citing Jones et al. 2000 and Dunne 1978), 2000 (https://doi.org/10.1046/j.1523-1739.2000.99083.x)” “In a study in three headwater watersheds in the mountains of central Idaho, 70 percent of sediment deposition from roads constructed on the watersheds, where the slope ranged from 15 to 40 percent, occurred during the first year after construction, and one-fourth of this deposition occurred during road construction (Ketcheson and Megahan, 1996). Sediment generally traveled less than 100 m from its source. Average sediment travel distances from fills, rock drains, berm drains, and landings were between 4 m and 20 m, while that from cross drains was 50 m. The maximum travel distance from some cross drains was more than 250 m. — U.S. Environmental Protection Agency (https://www.epa.gov/sites/default/files/2015-10/documents/ch3c.pdf)” “Just as development and approval of forest plans must conform to existing laws and regulations, new laws or regulations, including this rule, can supersede existing forest plan management direction. This rulemaking process does not require amendments or revisions to forest plans. The NFMA reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). Together with other applicable laws, the NFMA authorizes the Secretary of Agriculture to promulgate regulations governing the administration and management of the National Forest Transportation System (16 U.S.C. 1608). — USDA Forest Service (https://www.federalregister.gov/documents/2001/01/12/01-726/special-areas-roadless-area-conservation)” My opposition to the proposed rescission is respectfully entered into the record. Yours in conservation, CommentID: RLC-20260827-FE6TX7

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tuolumne River roadless area sits inside the Sierra, and I can only reach the scenes I care about by walking there. That is the whole point. I backpack across the Sierra Nevada, through national parks, forests, and the lands between. I paddle the American and Sacramento Rivers. I photograph rare species and beautiful California landscapes with equal attention. What draws me to all of it is wildness that has not been cut open. The 2001 Roadless Area Conservation Rule protects that. This proposal to rescind it is wrong, and I want my objections in the record. The agency's own findings on fire undercut one of its central justifications. Its 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 leans on wildfire and fuels management as reasons to open these areas. That argument runs directly into the agency's own data. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The 17,217 acres of the Tuolumne River area are the kind of terrain at stake. I want a plain explanation of why the agency is departing from those prior findings and how it reconciles the rescission with the ignition data it collected. On authority: the proposal claims the 2001 rule exceeded what Congress granted. A federal appeals court reviewed that question and held otherwise, writing: "Exercising jurisdiction pursuant to 28 U.S.C. § 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 concluded the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency needs to address that holding directly and state the basis for any contrary position it now wants to advance. My view on management is straightforward. These lands have been working for many different groups of recreationists as well as industry for a long time. We should not discount what is already working for local economies to extract resources for someone else. That concern connects directly to a problem in the regulatory flexibility analysis. The agency certifies no significant impact on small entities while its own record states: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The certification is reached by spreading expenditure losses across every small firm in the sector nationally, not by looking at the outfitters and guides who actually hold permits in the affected areas. That method hides the real impact on the businesses that depend on places like the Tuolumne River area remaining intact. The agency should withdraw the certification and conduct an honest assessment of the small entities operating in the potentially affected roadless areas. Finally, the agency's own solicitation creates an obligation it has not met. 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. Under the standards courts have applied when agencies change course, those reliance interests must be identified and assessed, not invited and ignored. This comment is one such interest. People who have organized their recreation, their photography, and their understanding of what public land is for around the protection that rule provides have a stake in this decision. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Stephanie Jones Concord, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The western United States is the most beautiful area in the world, and I have spent as much time as I can hiking and camping throughout it. Granite Chief Wilderness in the Lake Tahoe Basin Management Unit in California has given me an escape from the increasing suburbanization and commercialization of the rest of the Lake Tahoe area. I hike, camp, and backpack there, and I would be devastated to see the environment degraded or portions of it removed from recreational use. I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001), and I ask that the agency give the specific points below a substantive answer. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Clean water is a necessity for human life to continue, and preserving watersheds in roadless areas will provide significantly more benefit to our society than the extractive activities this rescission would invite. The agency's own analysis recognizes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Roads through places like Granite Chief and the Tuolumne River roadless area in the Stanislaus National Forest would put that sediment directly into the watersheds those intakes depend on. I ask the agency to address, specifically and in the record, how rescission is consistent with its own findings on road-generated sedimentation and the water supply interests documented in DEIS Table 35. The wildfire rationale given for rescission sits in direct tension with the agency's own prior findings. The 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 Tahoe region already faces serious fire pressure. Opening roadless areas in that landscape to new road construction, on the stated premise of improving fire management, contradicts data the agency itself produced. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I also do not want my tax dollars spent building and maintaining new roads that will largely serve private companies and may not even remain open to the public, when the agency cannot maintain the roads it already has. The record before the agency states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. The agency must reconcile that analysis with the proposal and explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest. The state-by-state rationale for rescission has been litigated before. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That prior attempt at a state-by-state replacement failed in the courts. The agency's own findings have recognized that local decision-making can incrementally erode nationally significant roadless values. The agency needs to explain here how this proposal avoids the deficiencies that doomed the earlier approach. Finally, the agency's stated concern about statutory authority is not supported by the judicial record. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. § 1291, we REVERSE the district court’s order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and concluded it did not create de facto wilderness. The agency must set out in full the legal basis for any position contrary to that holding. Sincerely, Emily Wheeler Oakland, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Clean water is a basic human right, not a privilege. Clean water is fundamental to the health and well being of all living things. We sacrifice this precious resource at our own peril, and of future generations. With the thousands of miles of backcountry roads in existence, there is no new road for logging or mining or purportedly to reduce wildfires, that our children would choose as a their legacy if it comes at the loss of clean water. Quite simply, water is life. Roads lead to ruin. PUBLIC land is a PUBLIC good. It is managed on behalf of EVERY tax payer in America, today, those who fought for it before, and those who will inherit it in the future. Not one county, one state, nor even one region possesses the right to decide on behalf of all of us what is in OUR best interest. And certainly not one low approval administration, infected with billionaires, shamelessly self-dealing their way to greater wealth at everyone else's expense. The Tuolumne River is the headwaters for the fresh drinking water of 2.7 million Americans from the Central Valley to San Francisco. Its vitality is elemental to the health and well being of a large portion of the a state that is the fourth largest economy in the world. The North Fork Middle Fork of the American River remains nationally significant as a pristine, free-flowing Wild and Scenic River that offers world-class recreation and vital ecosystem habitats for countless species. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Tuolumne River (17,217 acres), Stanislaus NF, California - North Fork Middle Fork American River (11,245 acres), Tahoe NF, California 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: Twenty-four million people’s drinking water is asserted away Clean water matters to me, and my own tap may trace back to this country. I do not accept assurances in place of analysis. Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 2: Road sediment is quantified and then set aside Clean water matters to me, and sediment is not an abstraction when it is headed for water people drink. The agency quantifies the risk and then walks away from it. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.” The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 3: Unmaintained roads damage water, by the agency’s own admission Clean water matters to me, and roads nobody maintains do not stay harmless. The agency admits as much in its own analysis. “Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance.” The same document proposes adding road mileage against a maintenance shortfall it identifies as a cause of water quality damage. I ask that the agency reconcile the proposed increase in road mileage with the maintenance shortfall its own analysis identifies as a water quality cause. 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. Sincerely, Scott Crocker Berkeley, California

This comment is informed by direct experience with the following account. These areas must remain intact for future generations to enjoy the untouched beauty of our States. The unique feelings evoked by these places cannot be replicated elsewhere. Reducing the protections granted to these areas is selfish and unnecessary. The Department is urged, both legally and policy-wise, to retain the Rule and reject the current proposal. As someone who seeks out public lands, I want the Department to understand that the 2001 Rule is not regulatory excess; it preserves the appeal of certain places. Regarding the Tuolumne River in the Stanislaus National Forest, California: A study in Idaho found that 70% of sediment deposition from roads occurred in the first year after construction, with significant amounts traveling less than 100 meters from the source (Ketcheson and Megahan, 1996). This highlights the environmental impact of road construction. The Roadless Rule remains one of America's most supported conservation measures. Prior to its 2001 enactment, over 600 public hearings were held, and 1.6 million Americans expressed their support for protecting these forestlands. The USDA's rescission proposal in late 2025 garnered around 600,000 comments, with more than 99.8% opposing the roll back. A February 2026 national poll by Pew Charitable Trusts showed that 76% of likely voters support the Rule, with bipartisan backing from 71% of Republicans and 80% of both Democrats and independents. Additionally, over 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to ensure the Rule cannot be altered without Congressional approval. Building more roads in national forests would impose a burden on taxpayers. The Forest Service already has a 380,000-mile road system—twice the length of the U.S. highway system—yet struggles to maintain it. The estimated deferred-maintenance road backlog was about $15.6 billion in today's dollars, as reported by the Government Accountability Office, highlighting the agency’s ongoing maintenance challenges. Adding new roads to roadless areas would worsen this financial strain. U.S. National Forests serve as vital headwaters for many of our major rivers and are key for municipal water supply nationwide. According to DellaSala (2011), national forests provide drinking water to 124 million people across 33 states, with about one-third of all national-forest runoff coming from inventoried roadless areas. Roads are notorious for causing water pollution, with erosion from logging roads significantly higher than from undisturbed forest areas. The protections afforded by the 2001 Roadless Rule are crucial for maintaining safe drinking water for communities, including major cities like Los Angeles, Portland, Denver, and Atlanta. Forest Service Chief Tom Schultz previously testified about 24.5 million acres of inventoried roadless areas being near the Wildland-Urban Interface (WUI), but a GIS analysis by The Wilderness Society revealed this figure is inflated by nearly nine times—realistically, just 2.8 million acres are close to the WUI. Less than 5% of inventoried roadless area acreage is actually in proximity to the WUI, contrary to Schultz's claims. The administration has access to 23.3 million acres of non-roadless forest land near the WUI for fuel reduction, negating the need to encroach on roadless areas. Though proponents of rolling back the Roadless Rule argue for wildfire management, evidence suggests otherwise. A 2026 study in Fire Ecology analyzed 32 years of wildfire data and found that wildfire-ignition density was higher near roads. In conclusion, retaining the 2001 Roadless Rule is essential for conservation, safeguarding drinking water, and protecting our natural heritage for future generations.

Dear Secretary Rollins and Chief Schultz, As an artist, I understand the asymmetry between creation and destruction better than most — it takes nothing to erase what took a long time to build, and I'd ask the Department to consider what it means to destroy the wildlands it has spent so long trying to protect before finalizing this action. Growing up in California I have personally enjoyed exploring the wild places that past generations have worked so hard to protect for us, and feel so much gratitude for their past efforts every time I step into those spaces. Such experiences and attachments are among the values the Rule was created to secure for all Americans. Being in a wild place and noticing the silence of human-made noises, getting to enjoy the rushing of a creek or the sounds of the birds, is something we all deserve to experience, especially those of us who live in urban areas. The opportunity for time and space away from urban pollution and noise is a golden one. Specifically, rescinding this rule would affect the Tuolumne River in the Stanislaus National Forest, California: Rescinding the Roadless Rule would open the Tuolumne River, Stanislaus National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The roadless rule protects our drinking water, supports opportunities for outdoor recreation for all Americans, and maintains critical habitat for over 1,600 threatened species. Maintaining the Roadless Rule is supported bilaterally across parties, and the rule still maintains exceptions for wildfire mitigation - so rescinding it to address wildfire risk is a moot point. Don’t let your time in government be marked by supporting the removal of a rule that protects our dwindling wildlands. Having reviewed the proposal, I find no basis for rescission that outweighs the record supporting the Rule, and I ask the Department to reach the same conclusion. With urgency, Stephanie McKenna CommentID: RLC-20260822-B1QFAA