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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Green Mountain, the White Mountain, Piscah, George Washington, and Je!erson National Forests (to list a few) are where I go for my spirit to feel wild, for peace of mind. That is the plain reason I oppose this rescission, and I want the agency to read these concerns carefully. Protecting wilderness (as through the Roadless Rule) is a moral imperative. In the words from Edward Abbey's Desert Solitaire, "Wilderness is not a luxury but a necessity of the human spirit, and as vital to our lives as water and good bread. A civilization which destroys what little remains of the wild, the spare, the original, is cutting itself o! from its origins and betraying the principle of civilization itself." I'm deeply concerned for the vistas, mountain creeks, and forests I've lived and loved in my entire life. Elliott Knob, inside the George Washington National Forest in Virginia, is a serene place. Enough accessible roads sit close by, yet it remains far enough into the wilderness to stay wild. That balance is what the 2001 Roadless Area Conservation Rule protects. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. Elliott Knob at 9,380 acres is one of them, alongside Crawford Mountain at 9,892 acres, Saint Marys Addition at 1,454 acres, Adams Peak at 7,135 acres, Rough Mountain Addition at 1,142 acres, and Jerkemtight at 16,687 acres, all in the George Washington. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing a!ected roadless areas. Roads bring sediment. Rescission puts those intakes at greater risk, and I want the agency to say plainly how it intends to protect those drinking water sources if this rule falls. The agency's own record undermines its wildfire rationale for rescission. The 2001 rule states: "Building a road into a forest at high risk from uncharacteristic wildfire e!ects 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 this proposal departs from that prior finding 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 a!ected roadless areas. The economics do not hold up either. The agency's own record acknowledges: "the total timber volume a!ected 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." It does not make sense to ignore the billions of dollars inmaintenance backlogs on roads already accessible to the public. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year? The agency must reconcile those numbers in this record before proceeding. The agency argues that state-specific approaches can substitute for a national rule. But the agency's own prior record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide approach.' 70 Fed.Reg. at 25,656." That experiment was tried before and failed judicial review. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state scheme. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911, which authorized federal purchase of private land for national forests, was passed because of what happened when New England's mountains were clearcut. I have hiked those forests. I know what is at stake. The agency should leave the 2001 rule in place. Sincerely,

Please consider not repealing the roadless rule. The roadless rule has protected 45 million acres of untouched forests for 25 years. While protecting these forests, habitats, endangered species, and the drinking water of 25 million Americans has also been protected. These areas have been protected from industrial logging keeping old growth forests in check which are important in our mitigation of climate change. The choice to repeal this rule isn't a poor environmental decision, but it also takes land out of Americans hands. Public lands should stay public. This would affect families, hunters, anglers, hikers, and backpackers. I frequent the White Mountain National Forest area in New Hampshire. This area would be directly impacted by taking away the roadless rule. Pristine forests and habitats destroyed and hiking trails taken away. This is a bi partisan issue and I truly believe Americans on all sides of the political spectrum support keeping the roadless rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Pemigewasset Wilderness has been part of my family across three generations. I have gone since I was born, and it is meaningful to me, my parents, and my grandparents. Losing its purity would be a loss to family memory and to land I hope to share in an untouched form with my future kids. That is why I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and ask the agency to address each of the following points in its final record. The White Mountain National Forest holds 16 inventoried roadless areas totaling 240,669 acres, including the Pemigewasset Wilderness, whose headwaters feed rivers running to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region alone, 286 municipal water intakes sit in watersheds containing affected roadless areas. The New England mountains were clearcut once before, and the damage was so severe that Congress passed the Weeks Act of 1911 specifically to authorize federal purchase and recovery of those lands. These places, home to moose, black bear, brook trout, and Canada lynx, recovered under protection. The economic case for rescission does not hold together. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a spread so wide it cannot establish a net benefit. Meanwhile the agency already carries a $6.9 billion maintenance backlog on roads it cannot afford to keep, against a road budget of roughly $73 million a year. I think it makes no sense to increase roads that we need to use taxpayer dollars to maintain. This is a terrible and poorly analyzed plan, and reducing long-term spending means doing it pragmatically, not expanding infrastructure the agency cannot sustain. I ask that the agency reconcile the proposal with these figures and explain how an action whose own analysis cannot demonstrate a net benefit justifies adding to a road system already buckling under deferred maintenance. The proposal argues that state-by-state approaches can replace a national rule. The agency's record itself states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed exactly that state-by-state alternative and found it deficient. I ask that the agency address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time a national rule was replaced with a state-by-state approach. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The court that examined that question reached a different conclusion. 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 within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the record a direct explanation of any contrary legal position it intends to rely on. Finally, the proposal cites permitting and administrative burden as justifications for rescission. The rule as written already provides that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Additional exceptions address existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside those existing provisions. It should do so, with quantification, before any further action on this proposal. Public land should be managed for long-term value to the country and its people. The Pemigewasset Wilderness represents exactly that kind of value, accumulated across generations and irreplaceable once a road goes in. I ask the agency to answer each of these points in the record before it proceeds. Sincerely, Calvin Kinghorn San Francisco, CA

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I am a student at the State University of New York College of Environmental Science and Forestry and have a deep connection to the lands protected by the Roadless Rule. I hike in the Adirondack Park and White Mountain National Forests with family, friends, and fellow members of my college's outdoor club and appreciate these spaces for their lack of roads and vehicles. Without the protection of these areas, my personal quality of life as well as that of millions of Americans and critical biodiversity would be severely impacted. Removing these protections would allow environmentally sensitive and revered areas to be exploited beyond the current rate by opening them to the potential of development and logging. Eliminating the Roadless Rule is also not an effective tool to help fire management, as the supporters of this action are saying, studies show that fires are 4 times more likely to begin near a road (Aplet et al., 2026. "Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads"). Removing the protection on our forests would also threaten watersheds that provide clean drinking water to millions of Americans, increase the burden on taxpayers to fund additional road maintenance, and threaten habitats for biodiversity and the Indigenous people and cultural values that rely on it. If the U.S. Government truly cares about its citizens, taxpayers, and their livelihood, it should keep the Roadless Rule as is and focus instead on promoting the conservation of U.S. land and biodiversity. Fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake for the future of our land and people who rely on it. I strongly oppose the proposal to rescind or alter the Roadless Rule. I support Alternative 1, the No Action alternative.

I am requesting the roadless rule remain in effect. As a retired Bureau of Land Management employee, I think there is a misconception by some Americans about the impact of the roadless rule. In California’s Eastern Sierra, Bodie Hills and White Mountain range region, motorized vehicle travel is allowed to many places classified as “roadless.” Mining prospectors, grazers, rock collectors and sportsmen have great access to many remote areas. However, it is important that some areas remain classified as roadless for environmental and recreational reasons. The sportsmen I have met in the backcountry recognize the importance of wild places and they cannot be classified as subscribing to a particular political ideology. On balance, the roadless rule is working well and should remain in effect. Sincerely, Gary Johanson

The continental United States is very large, but has very few wilderness areas. Consequently those that do exist, particularly those in the densely populated part of the country that lies to the East of the Mississippi river, have outsized ecological and recreational value. The proposal to rescind the Roadless Area Conservation Rule (66 FR 3244) has the potential to render the United States more domesticated and more European in character. This would dramatically decrease my enjoyment of the few wilderness areas I have access to, including the Pemigewasset wilderness in New Hampshire's White Mountain National Forest. I would encourage the Forest Service to reconsider the proposed rescission of 66 FR 3244 and maintain the Roadless Area Conservation Rule in its current form.

I grew up on a beautiful lake in Maine. I started hiking the 4000 footers in Maine after being introduced to hiking by my 8th grade history teacher, who was an Appalachian Trail thru-hiker. My mom and I hiked all over the state together, creating memories that I will never forget, like hiking Mount Katahdin and meeting other AT thru-hikers along the trail. In 2024, I decided to thru-hike the AT. I walked home from Georgia, meeting some of my now best friends along the way and connecting deeply with the mountain range that has been home my entire life. As a part of my thru-hike, I walked through hundreds of miles of roadless areas, including those in the White Mountain National Forest and just north of the Caribou Mountain Speckled Wilderness area in Maine. New Hampshire and Maine are thru-hikers favorite states because of the wilderness that hikers experience. Now, I work for the Appalachian Trail Conservancy and make my living in part because of the Roadless Rule and the wilderness areas that the rule protects. The recission has bipartisan opposition and would drastically reshape the national forests that so many of us hold dear. I encourage the forest service to listen to the people of the United States and leave the Roadless Rule in place.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Much of my free time goes to exploring wilderness, and a great deal of it falls inside roadless rule areas: the Santa Rita Mountains in Arizona, the Sierra Nevada, across the Siskiyou, and in the east, White Mountain National Forest. I go looking specifically for the bird and plant species that depend on undisturbed ecosystems, the kind of habitat that disappears the moment a road goes in. This proposal would rescind the protections that make those places worth the trip, and I oppose it. The agency's own evidence on wildfire undercuts the rationale for 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." If the agency is justifying this rescission partly on fuels management grounds, it needs to explain why it is departing from that finding. I ask that it reconcile this proposal 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 what in the current record overrides what the agency itself documented. The birds I look for across the Siskiyou, the Sierra, the Santa Ritas, and the White Mountains are not incidental to the roadless rule. They are a direct product of it. 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. The Coronado's verified species list includes the elegant trogon and the Mexican spotted owl, and the White Mountain's includes Bicknell's thrush, each tied to the undisturbed conditions the rule protects. The 23 inventoried roadless areas of the Coronado total 482,687 acres, the Santa Ritas among them, and jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains, making those corridors the northernmost viable jaguar range on the continent. Opening any of it to road-building does not merely disturb habitat at the road's edge. It degrades the surrounding area through noise and fragmentation. The agency must address in the record how rescission squares with its own documented findings on road noise and bird abundance, and what specifically it expects to happen to species dependent on those corridors once the rule is gone. The economics do not hold up either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. A cost-benefit analysis that cannot establish a net benefit is a thin foundation for expanding a road system already carrying a $6.9 billion maintenance backlog. The agency should reconcile the proposal with those numbers. The state-by-state approach this proposal gestures toward has already been tried and overturned. The record itself 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 the Ninth Circuit identified when the national rule was last replaced with a state-by-state framework. Finally, the rule the agency proposes to rescind already contains the flexibility it claims to need. The DEIS acknowledges: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. If the agency's concern is genuine administrative burden, it should identify which specific situations are not already addressed by the existing exceptions for health, safety, and existing mineral rights, and it should quantify those burdens with actual data rather than assertion. Sincerely, Timothy Forker Brooklyn, NY

Draft Comment Blueprint Attn: Joshua White, Acting Director, Ecosystem Management Coordination Docket No: FS-2025-0001 | RIN: 0596-AD66 Re: Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule I am writing to express my strong opposition to the full rescission of the 2001 Roadless Rule. As a regular visitor to the White Mountain National Forest, the justification provided by USDA Deputy Secretary Stephen Alexander Vaden, claiming that a nationwide rollback is required to grant "access" for active forest management and wildfire reduction, is explicitly contradicted by the agency’s own data. Proceeding with this rule constitutes a textbook case of fiscal waste, administrative abuse, and analytical fraud for the following substantive reasons: 1. A Personal and Generational Stake in Intact Backcountry: Some of my earliest memories from childhood are my mom taking me on a backpacking trip up Mount Lafayette at age six. The deep wilderness experience of standing on Lafayette depends entirely on the pristine, unfragmented backcountry visible below it. Devastatingly, vital access points like the Liberty Springs Trail coming out of Franconia Notch are not off-limits if this rule gets revoked. Please don’t take this opportunity away from other parents and children by disrupting forests in their areas! Furthermore, commercial logging or logging roads near the Appalachia trailhead would completely ruin the gateway to the northern Presidentials like Mount Adams and Mount Madison, creating visual and noise pollution for hikers climbing out of the valley. I just went back to the Whites with my mom 20 years later. We hiked out of Appalachia and shared a similar special moment. Having lived near major metropolitan areas like New York and Boston since graduating college due to my career, traveling to these designated roadless areas is a vital escape that my peers plan for, look forward to, and rely on to maintain their well-being amid urban sprawl. 2. Fiscal Waste (The Road Maintenance Backlog): The U.S. Forest Service currently faces a multi-billion-dollar backlog in maintaining its existing public road network. Rescinding the rule to allow new commercial timber roads will severely exacerbate this deficit. According to the findings of the USDA’s own Draft Environmental Impact Statement (DEIS), repealing the rule will inherently inflate federal road maintenance costs while yielding little to no fiscal return. Spending taxpayer dollars to build new infrastructure when the agency cannot afford to maintain its current assets is a blatant waste of public funds. 3. Analytical Fraud (The Deceptive Wildfire Rationale): Deputy Secretary Vaden’s primary assertion that restrictions "exacerbate rising wildfire risk" is an arbitrary and unsupported narrative. The 2001 Roadless Rule already permits active fuel reduction and thin-burning management without building permanent roads. Furthermore, peer-reviewed fire science consistently demonstrates that roughly 90% of wildfires originate within a half-mile of a road. By introducing new roads into the backcountry, the USDA is actively increasing human-caused wildfire risks to nearby communities—the exact opposite of the rule's stated intent. Presenting a policy as a "wildfire solution" when agency data demonstrates it increases long-term risk and spending is a fraudulent manipulation of the NEPA process. 4. Abuse of Discretion (Disregarding Downstream Economic Damages): The DEIS admits that rescinding the rule will cause widespread environmental and economic harm. Over 25 million Americans rely on intact roadless watersheds for clean municipal drinking water. Commercial logging and subsequent road erosion will drastically increase sedimentation and turbidity. This will shift massive capital costs for advanced water treatment onto downstream local governments and taxpayers. Ignoring these quantified downstream economic liabilities to benefit private commercial extraction constitutes an abuse of the agency's public land mandate. Conclusion: Because the proposal relies on arbitrary claims that fly in the face of the USDA's own cost-benefit analysis and DEIS data, the agency must select the No Action Alternative (Alternative 1) and keep the 2001 Roadless Rule fully intact.

Our summer camp community uses the White Mountain National Forest for recreation and camping. We have often pondered how great this wilderness would be without the Kancamagus Highway and Route 302 dissecting it. Keeping large forest tracks standing is one of the key ways to counter climate change and keep our planet healthy. Allowing roads through our wilderness and further logging is an immense step backwards, both environmentally and economically. Let’s look at the big picture and do the right thing.

I have had the privilege of living very near to several IRA's in the last 6 years. I fundamentally oppose the recission of the roadless rule, and I believe it is not based in logic, science, or the law. The roadless rule should not be repealed and should remain as it has been. I went to college in Southwest Virginia and spent as many weekends as I could hiking, camping, and stargazing at Brush Mountain IRA and Brush Mountain East IRA in the Jefferson National Forest. During deer hunting season I volunteered with the Virginia Department of Wildlife Resources to test deer harvested for chronic wasting disease. A few Saturdays during the season we tested deer from various parking lots throughout Montgomery county. Many of those hunters hunted in the National Forest, and many on Brush Mountain. Kids harvested their first does in this IRA and families bonded hiking to tree stands in the Forest they had been hunting for decades. Brush Mountain and Brush Mountain East is a sacred place to everyone who has spent any time in Craig, Roanoke, and Montgomery county. Whether just passing through on a hike, spending four years of weekends there while in college nearby, or living there for generations, the IRA designation of Brush Mountain protects it as a sacred place. In 2021 I had the opportunity to camp host at a camground at the base of Mount Timpanogos. Growing up in the dense green forests of Appalachia, the wide-open Utah landscape kept me in awe every day. I spent every spare moment exploring the area, spending extra time hiking in the Unita IRAs and Wasatch-Cache Utah IRA. I spent a lot of time off-roading in rock crawlers, hauling my camper around to dispersed camp sites, and mountain biking all over Utah, but the time I spent hiking in the IRA is by far the most memorable. The Forest Service is already incapable of maintaining the roads that it has already built. Opening up acreage to build more roads when the ones that exist are not well maintained is illogical. As a lover of motorized recreation, never once have I thought, I wish there were more roads in the national forest. As a hiker and lover of intact wilderness for their ecological and environmental benefits, I am grateful every day for IRAs and the value they provide to big and small game species, the ecosystem overall, and for the peace and tranquility they offer to everyone who visits. The science shows that intact wilderness, like IRAs, are better for the ecosystem, for more productive environmental services, like water filtration and carbon sequestration, and in more cases than not, more resistant to fire when properly managed under the already existing rules and regulations under the roadless rule. It goes against all valid science to say that repealing the roadless rule will have any scientific, environmental, or ecological benefit. Finally, but maybe most importantly, the proposed recission of the roadless rule is illegal. The draft EIS is deficient in every way, arbitrary and capricious, and lacks any valid alternatives analysis. I am finishing my final semester of law school and have spent the last two years reading nearly every past and present NEPA, NFMA, and APA case. I have been a part of a team that has filed two lawsuits to stop the USFS from continuing on with two logging projects in the White Mountain National Forest. In my time working on these suits I have read some well-done Environmental Assessments and Environmental Impact Statements. I know what a well-done, comprehensive, and legally sound NEPA process looks like, and this roadless rule recission process is the furthest thing from well-done, comprehensive, or legally sound.

I frequent New York States Adirondack Park where I hike and backcountry ski. This is a place where I can get away from the everyday stress of work and suburban living. To be able to recreate in remote areas where there is no sign of human development is special. I look at that park as a treasure that I hope stays for many future generations. Now, this is a state protected park but the same preservation principles applies to federal parks that people,enjoy every day. Parks like New Hampshires White Mountain National Forest which I also occasionally visit. Once developed, it becomes very hard to erase human traces. I feel its extremely important to protect the parks we have established as the world around them continues to get busier. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I support the Roadless Rule and urge decision makers to keep this safeguard in place to help protect public lands around the country. I live in Maine and I feel lucky to be so close to the the White Mountain National Forest; it is one of my favorite places to visit, recharge, and spend time in nature. Of all the special natural areas that the Roadless Rule protects, the Wild River is one I am most connected to. The Wild River flows seventeen miles through Evans Notch, bringing water from the mountains into to the Androscoggin River. In the spring, the Wild River swells with snowmelt; white water kayakers love to paddle in these strong, cold, and clean waters. My husband and many members of our community drag their boats upriver beyond the gate to kayak downstream. In the summer, the water level of the Wild River drops and round, beautiful stones emerge. Along the river, there are pockets of deeper water that are perfect for swimming on a hot day. Within the river, there are native brook trout that thrive in these waters. I have caught and released one of these special fish when fly fishing. In the fall, the forest around the Wild River bursts with color. I have laced up my hiking boots, packed my tent in my backpack, and hiked along the Wild River to make camp at a backcountry camp site. I have poured the Wild River into my water filter and enjoyed a cool, refreshing drink. In the winter, the world around the Wild River becomes frozen - yet the waters still flow. I have slid beside the Wild River on cross country skis, hearing the water pulse beneath the ice. In every season, I support the Roadless Rule.

I am writing to express my strong opposition to the proposal to fully and partially rescind the Roadless Area Conservation Rule. I urge the U.S. Forest Service to maintain existing protections and select the Alternative 1, No Action. Shifting management to a piecemeal, forest-by-forest process risks fragmenting vital ecosystems and opening irreplaceable backcountry to industrial road construction and commercial logging. My opposition is deeply rooted in a lifetime of recreating in our national parks and public lands. Living near the White Mountain National Forest in New Hampshire, I see firsthand the profound ecological, economic, and recreational value that intact, roadless landscapes provide to local communities and regional watersheds. Just this week our forests are drawing in many tourists during peak foliage season, allowing local businesses to thrive. As a biologist and homeowner, I understand and appreciate how vital these areas are to fire management; soil, air and water quality; and biodiversity. Furthermore, my time spent on our national scenic trails—including life-changing experiences on both the Pacific Crest Trail (PCT) and the Appalachian Trail (AT)—fully shaped my understanding of why large, continuous wild spaces must be preserved. These trails and the roadless areas they traverse are national treasures that offer unmatched opportunities for solitude, personal growth, and outdoor recreation. To me, our remaining roadless national forests and the recreation opportunities within them are among the most precious and defining features of our country. The 2001 Roadless Rule has successfully protected clean drinking water, critical wildlife habitats, and carbon-storing forests for twenty-five years. Dismantling this rule would permanently degrade the wild character of these lands and harm ecosystems and future generations of hikers, backpackers, and outdoor enthusiasts. Please protect the integrity of our public lands, uphold the 2001 Roadless Rule, and select the No Action Alternative. Thank you for considering my comments.

To the US Forest Service and the Department of Agriculture, I strongly object to any and all efforts to rescind the Roadless Rule and/or to remove any national forests from the protection that the Roadless Rule provides. Not only are these efforts spectacularly irresponsible and short-sighted, but they are neither in the public interest nor morally acceptable. I see the trees changing colors in the White Mountain National Forest of New Hampshire and my heart sings. Surely, our nation can afford to leave these remaining wilderness areas as God and Nature created them. Katrin Rouner North Sandwich, New Hampshire

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The protected areas of the White Mountains are my literal home and my spiritual home as well as being tightly tied with my state’s ability to survive economically. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record of Docket FS-2025-0001. I live in the White Mountains region of New Hampshire and regularly go out into the woods for a hike or camping trip. The Carr Mountain area, at 17,110 acres in the White Mountain National Forest, is one of the few places beginner backpackers can go to learn outdoor skills, an important American legacy. The Carr Mountain area houses wetland and habitat that would be destroyed by logging, flooding a region's water system with difficult to remove pollutants. The Sandwich Range, at 16,797 acres, is one of the most popular areas for people to visit. It has an intrinsic beauty and sheds water directly into the lakes region of the state, one of the main tourist attractions in New Hampshire. These places have already seen a history of ecological damage that ruined the economy's long-term health. That history is not abstract. The Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut. We are being asked to forget that lesson. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. Logging in Carr Mountain and the Sandwich Range does not stay in those units. It enters the water. I ask the agency to explain how it will protect those 286 intakes and the downstream communities that depend on them if this rule is rescinded. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Building new roads that the agency has yet to prove it can maintain, in order to facilitate logging that yields fractions of a percent of national production, makes no sense. It would also decimate the thriving outdoor economy that New Hampshire enjoys, tanking our viability as a state. I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency also claims the rule imposes permitting and administrative burdens that justify rescission. But the rule as written states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The rule already accommodates the situations the agency says require relief. The agency must identify which specific burdens are not already addressed by these existing exceptions and quantify those burdens in this proceeding. Finally, the proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have organized my life around these protected areas. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Molly McCahan Plymouth, NH

I am writing in strong opposition to repealing the roadless rule act. This proposal would negatively impact 58.2 million acres of national forest land that is an integral part of our country. I grew up less than 3 miles from the White Mountain National Forest which over 235,000 acres could be affected. Growing up so close to the WMNF I was able to have a childhood filled with positive experiences in the vast wilderness. One of them being a club in high school where I had teachers who brought us reading, writing, and hiking through the White Mountains. Repealing the roadless rule act could be the reason our future generations don’t have that opportunity. Not only would repealing the roadless rule act negatively impact our ability to have access to public land to recreate, but over 60 million people rely on national forest land for drinking water. If we don’t have forests that are intact and managed properly people would lose drinking water. Not only do intact forests give people access to clean drinking water but it also creates crucial habitat for many animals including salmon, trout, elk and many other animals. The national forest service currently also has over 8.5 billion dollars of maintenance backlog, if they repeal and start adding to the roads it could cause even more fiscal stress. The forest service should not take any action on repealing the roadless rule act. Keep our forests protected.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I grew up living next to the White Mountain National Forest and consider myself so lucky to have had that access to nature and places to explore that are beyond beautiful. I can’t imagine having these places destroyed and not left as is for those that come behind us. This would disrupt and be so harmful to wildlife who need this room to survive and are a vital part of our ecosystem. It would also ruin the economy that these remote places rely on for people recreating. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a mistake. Again I oppose the proposal to rescind or alter the Roadless Rule, and support “Alternative 1, the No Action alternative.”

My home is 2.9 miles from White Mountain National Forest, and an Inventoried Roadless Area in the Sandwich Notch area. My wife, my sons (1 and 4), and our extended family explore this area on a weekly basis - sometimes daily. It is extremely special to us, and maintaining it in its current character is extremely important to us. The repeal of the roadless rule is an action without a need - roads cannot be undone (there are still abandoned roads from 200 years old that run all over our forest lands in New Hampshire). Fire prevention is not needed in our region, and nationwide the data seems to indicate that the overwhelming percentage of fires are caused by people close to roads. Fewer roads, fewer fires. Regardless, the places my family and I are building our memories rely on wild places, and repealing the Roadless Rule directly threatens our enjoyment of this lands. Further, as a licensed outdoor guide, my work and livelihood is directly threatened in New Hampshire and nationwide by any reduction in wild lands. I am submitted photos with my 1 year old son close to our home, overlooking one of the IRAs. Please, strengthen the Roadless Rule, rather than eliminating it.