Read the comments.

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.

The Caribou - speckled wilderness is a place where we connect with nature. It is a place where I have found myself—whitewater kayaking, picking blueberries, riding my bicycle along remote roads, camping with loved ones, hiking with my dog, fly-fishing for native trout, sharing a picnic with my parents along the shore of the wild river, and swimming in its forested swimming holes. When we experience and love a place like this, we come to understand that it is worth protecting and preserving—not only for ourselves, but for future generations.

I adamantly oppose altering the roadless rule in a way that would increase roads in federal and public lands for multiple reasons. First, ecologically it would devastate sensitive regions throughout the country. It would disrupt ecosystems and endanger species that are already vulnerable. It would increase access to and pollution of wild river systems. Second, it would harm outdoor economies by reducing untouched and remote regions that are a draw for millions of Americans each year. Finally, we need to know that wild, untouched areas still exist and the roadless rule helps provide that, enhancing the lives of all Americans. I strongly urge you to reject this proposal and stand for the present of all of us and the futures of our children.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Pisgah and Nantahala national forests have been important to my family for the last 30 years. Our children went to camp in those areas and grew to value their time in the backcountry there. I love being able to camp in places that are quiet and undisturbed, where wildlife can be seen in their own settings rather than in habitat that has already been lost to development. The Southern Appalachians hold black bear, hellbender, brook trout, cerulean warbler, more than 30 endemic salamander species, and the northern long-eared bat. The Nantahala holds 14 inventoried roadless areas totaling 52,304 acres and the Pisgah 18 areas totaling 99,369 acres. These are the places I am asking the agency to protect, and I oppose rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The proposal rests in part on wildfire and fuels management as a rationale for rescission. The agency's own record undercuts that rationale. Its draft environmental impact statement reports 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, and states that human-caused ignitions increase in abundance with proximity to roads. The agency also found that "Older trees (∼100 years) are the next generation of old growth and already possess qualities associated with large, old trees, such as large canopies, deep root systems, and thick, fire-resistant bark." I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that increase honestly against any claimed reduction in wildfire hazard. The wildfire analysis is not the only place where the agency's own data cuts against its conclusions. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself concedes that road access could increase the number and frequency of wildfires, yet the proposal does not resolve that tension. The agency must explain why it departs from its own prior findings and must reconcile the rescission with what its own DEIS Table 21 reports. On economics, "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The places I have camped and watched wildlife for thirty years support exactly those businesses. The agency should withdraw the certification and assess impact on the small entities actually operating inside the potentially affected roadless areas. My family's relationship to the Pisgah and Nantahala is itself a reliance interest the proposal invites and never weighs. "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 legal standards that govern agency change of course, reliance interests created by a prior policy must be assessed, not simply invited and then set aside. Kids today already face extra stress from the challenges of social media, unresolved global conflicts, and inadequately addressed climate change. We need to do everything we can to protect wild spaces for them to escape to. Those spaces include the roadless headwaters of Shining Rock and Linville Gorge, which protect the last wild river sources flowing to both the Atlantic and the Gulf along with salamander species found nowhere else on Earth. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Anna Cone Franklinville, NC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The White Mountains are sacred. I cannot think of another word for them. I do not get there as often as I would like, but roadless areas in the White Mountain National Forest are places I hold as genuinely irreplaceable. Wildlife and the natural spaces they depend on have been pushed and pushed already. They have more value left as they are than anything else that can be imagined. These lands belong to the people of this country, those of the past, present, and future. The people of the past and the people of the present have paid for these lands with their tax dollars to preserve them for nature, and for those in the future who will continue preserving them. The proposed rescission of the 2001 Roadless Area Conservation Rule works against that obligation, and I ask the agency to answer the following points in the record before proceeding. The proposal invokes wildfire and fuels management as part of its rationale. The agency's own findings directly contradict that reasoning: "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 White Mountain's 16 inventoried roadless areas total 240,669 acres and serve as headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Opening roads into those drainages increases ignition risk by the agency's own measure. I ask that the agency explain why this proposal departs from its own prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside affected roadless areas. The economic justification for rescission does not hold up against the agency's own numbers. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." New Hampshire alone holds 15 inventoried roadless areas totaling 234,681 acres, and across the Eastern region, which includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. The recreational and watershed values at stake in places like the Pemigewasset and Wild River are not marginal. I ask that the agency 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 expanding a road system already carrying a $6.9 billion maintenance backlog constitutes sound management when the agency's own analysis cannot establish a net benefit. The proposal argues that state-specific approaches can substitute for a national rule. The agency's own record notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried that state-by-state substitution before, and it failed in court. Moose, black bear, American marten, Bicknell's thrush, brook trout, Canada lynx, and the northern long-eared bat all inhabit the White Mountain roadless areas. Their habitat does not respect state lines, and neither do the watersheds these areas protect. The agency must address its own prior finding that local decision-making incrementally erodes nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time a state-by-state approach was attempted. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. That question was already answered. 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 court found the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The Weeks Act of 1911 itself was passed specifically because of what happened when New England's mountains were clearcut. The White Mountains are what they are because of federal protection, not despite it. The agency must explain the legal basis for any position contrary to the Tenth Circuit's holding before this rescission proceeds further. Sincerely, John Minkle Malden, MA 02148

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.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Melissa Laplante from Gorham, NH. My husband and I moved to this area to partake in the recreational activities within the White Mountain National Forest about 10 years ago. In particular, the Great Gulf Wilderness, the Wild River Wilderness, the Cherry Mountain Wilderness and the Pemigewasset Wilderness. Here, we hike, ski, bike, paddle, and hunt. In the time we have lived here, we have seen our town blossom due to the attraction of these areas, for recreational purposes, such as ourselves, but also for the clean water and air. Like-minded individuals interested in conservation and outdoor recreation have settled in our small town, which is still recovering from mill closures 20 years ago. We’ve seen small businesses open to cater to this community and thrive. We see our neighbors on the trails, and then at the local outdoor minded brewery after a backcountry ski day. We visit with family and friends who are staying in Gorham for access to these trails regularly. Both of us were in education, and see what a positive impact this land has on the area’s youth. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative.

As a New Hampshire resident, I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. Removing it would strip protection from about 235,000 acres of the White Mountain National Forest, roughly a quarter of the forest, and from about 45 million acres nationwide. These lands belong to all Americans, and they should stay as they are. The White Mountains drive our economy. The White Mountain National Forest draws more than 6 million visitors a year, more than Yosemite. New Hampshire's outdoor recreation economy is worth nearly $4 billion a year, and the people who hike, ski, fish, hunt, and paddle here fill our inns, restaurants, gear shops, and guide services. North Country towns depend on that business. Visitors come for unbroken backcountry, not logging roads and clearcuts. Roadless areas protect our water and wildlife. The headwaters of the Pemigewasset, Saco, Androscoggin, and other rivers start in these forests and supply communities downstream. New roads mean erosion, runoff, and sediment in streams that hold native brook trout. Large unfragmented forests are also what moose, black bear, and pine marten need, and they will matter even more as the climate warms. These lands buffer our Wilderness and trails. Roadless areas border the Pemigewasset, Sandwich Range, Presidential Range–Dry River, Great Gulf, and Wild River Wilderness areas, and much of the Appalachian Trail and our 4,000-footers. Roads and logging up to their edges would degrade the experience that defines the White Mountains. The wildfire rationale does not fit New Hampshire. Our wet northern hardwood and spruce-fir forests are not the fire-prone western landscapes cited to justify this change, and the existing rule already allows fuel reduction where it is needed. Nothing here requires removing protections wholesale. The public has already spoken. The original rule drew more supportive public comments than any federal rule before it. New Hampshire's congressional delegation has raised concerns, and the state House recognized the value of outdoor recreation this spring. A short comment period is not enough to undo a protection Americans have supported for 25 years. I urge you to withdraw this proposal and keep the Roadless Rule in place, in New Hampshire and across the country. Sincerely, Kyle Dimick

Dear Secretary Rollins: I am writing to express my strong opposition to the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the agency to take Alternative 1, the No Action alternative, and retain full Roadless Rule protections. I live in Webster, NH, and my family has a camp in Pittsburg, NH. I regularly spend time and recreate in the White Mountain National Forest and deeply value the unfragmented landscape that these 15 roadless areas provide to New Hampshire and the citizens of the United States, including Carr Mountain (17,110 acres), Cherry Mountain (8,766 acres), Dartmouth Range (9,233 acres), Great Gulf Extension (15,110 acres), Jobildunk (3,660 acres), Kearsarge (4,554 acres), Kilkenny (28,766 acres), Kinsman Mountain (8,999 acres), Mt. Wolf - Gordon Pond (11,846 acres), Pemigewasset (32,255 acres), Pemigewasset Extension (15,840 acres), Presidential – Dry River Extension (10,555 acres), Sandwich Range (16,797 acres), Waterville (4,312 acres), and Wild River (46,878 acres). These undisturbed areas are a primary reason NH is such a special place to live. Protecting wildlife is important to me. I am an avid birder and one of my hobbies is monitoring and documenting wildlife. The DEIS states that eliminating the Roadless Rule would "adversely affect" 327 threatened and endangered species and 71 critical habitats for these species. In New Hampshire, these roadless areas protect 16 distinct ecosystems that provide diverse habitat for many species, including 5 federally listed and 19 species of concern. Many of these species need large expanses of unfragmented habitat to survive. The DEIS cites findings that habitat fragmentation reduces biodiversity by 13-75% and that bird richness declines with the presence of roads in forests. And it's not just the listed species; it's the hundreds of other species that contribute to the biodiversity of the White Mountain National Forest and make it such a treasure to the people of NH and those from around the country and world who visit to experience its beauty and solitude. It is critically important that roads do not further fragment what little area remains in New Hampshire, and across the United States. The wild, undisturbed areas of the White Mountain National Forest provide a sense of culture and natural heritage. These areas are part of an expanse of natural spaces where many people, including me, find solace and a way to recreate and recharge from the stress of modern life. The landscape is a part of who we are. According to a study by the Granite Outdoor Alliance, in 2024 outdoor recreation and enjoyment contributed $4.2 billion to the New Hampshire economy and supported over 33,000 jobs. This economic benefit expands beyond recreation to support retail, tourism, hospitality, and manufacturing. Logging will not offset the long-term economic losses we would incur by rescinding the 2001 Roadless Area Conservation Rule. The agency's own activity-tracking data show that timber harvest within potentially affected IRAs has averaged only about 500 acres per year, with volume inconsequential to overall nationwide harvest levels, across the 44.7 million acres covered by the rule. That trivial historical harvest level undercuts the claim that roadless prohibitions are a meaningful driver of the national forest health and timber supply problems the agency describes. The Forest Service should explain, with data, how opening land that has produced inconsequential harvest volume for over two decades will now deliver the promised benefits. For these reasons, I strongly urge the U.S. Forest Service and the U.S. Department of Agriculture to abandon the proposed rescission and instead support Alternative 1, the No Action alternative. Thank you for the opportunity to provide public comment.

Dear Special Areas: Roadless Area Conservation, Dear I am writing to say I am not in favor of U.S. Department of Agriculture's announcement that it is proposing a complete rollback of the 2001 Roadless Rule. I am surprised that this is even on the agenda, The Roadless Rule to protect millions of acres of national forest lands and the headwaters of some of the nation's most critical drinking water sources. There is no national emergency that would justify breaking into the resources that we have kept in trust for generations. It is almost certain that we will have a water shortage in the future. Global warming, droughts, downpours, fire, is ripping the fabric of our agricultural lands. The Oglalla aquifer, the Great Salt Lake, the Colorado River, are drying up, as is the Otter Tail River on which my community depends. We are spending our children's inheritance. Daily the flames of discontent, fear and anger are fanned to justify a political agenda that has no room for basic human needs. Disrupting more than 80,000 miles of rivers and streams, and fish and wildlife habitat they protect, is irresponsible, We need to helping ensure clean drinking water for more than 25 million Americans, including residents of Denver, Atlanta, and Bozeman. Please hear us when we say there is no basis for this dramatic and drastic action Here's what we need from you. We need farmers who are not weighed down with debt under the constant pressure of having to be more productive is driving the return on their labor continuously down. That is an emergency! We need to farm our dump sites, which are ever-growing, with effective recycling to reclaim precious metals. We need clean water to drink that isn't contaminated by hormones, pesticides and micro-plastics, That is an emergency. We need wind and solar energy that doesn't threaten our planet. That's the real emergency. We need more parks to accommodate the crowds of visitors that recreate in our natural environment. We need to stand up to the idea that free-enterprise is more important than social cohesion and environmental health in America. The Founders built a government that was wise, flexible and responsive to what brings happiness for the most people, not how we could make the most money by exploiting every inch of our beautiful and wild land. I see a generation coming up that loves the outdoors, that wants to test themselves, be it in a kayak down a wild river, or rock climbing up a mountain in the pine scented forests. Wealth has a way of take care of themselves, They are blindly governing our nation by their ideology to short sighted and dangerous ends. Leave the Roadless Rule as it is: a significant protection for rivers, clean water, and wildlife across the country. Because in a year, or five years, or even twenty, we will stand in a broken country, knowing that we allowed this thievery, and trying to figure out how to put it back together and clean up. Sincerely, Deb Wallwork 30 S. Washburn Ave Minneapolis, MN 55405 debmn@mac.com Sincerely, Deb Wallwork

Nine years ago, in the fall, I took the woman who is now my wife on a seven-day backpacking trip through New Hampshire's White Mountains: Franconia Notch, Mount Lafayette, Mount Garfield, and deep into the Pemigewasset and Wild River Wildernesses. It was the first time I took her fly fishing. There were no screens and no noise, just a river so clear it looked like liquid diamonds. We watched trout rise to insects and forgot to cast. At night the stars were so bright they made us feel small, and closer to each other and to the place. The next day she caught her first trout, was so elated she lost her footing and fell in, and when I ran to rescue her I tripped and went in face first. We couldn't stop laughing. That's when I knew she was the one. I'm a father of two small kids now, and this year I'm taking them into country like that for the first time. I want them to have the kind of memories that shaped me. The Roadless Rule is a big part of why country like that still exists. Roadless areas make up less than 2% of the American land mass, yet they hold habitat for 25% of our threatened and endangered species. About 70% of the public land inside them supports native trout and salmon, including 90% of it in New Hampshire. Roads bring sediment, fragmented habitat, and fish barriers, and a road, once cut, isn't undone. I understand the wildfire concern, but 78% of human-caused fires on National Forests start within a half mile of a road. The 2001 rule already allows fuels reduction and restoration work. And the Forest Service can't maintain the roads it already has, with a $10.8 billion backlog, more than half of it roads. These lands belong to all of us. Please keep the 2001 Roadless Rule in place, so my kids and their kids can find these places the way I did. The 2001 Roadless Area Conservation Rule conserves over 58 million acres of multiple-use public lands managed by the U.S. Forest Service that provide some of the best places to hunt and fish in America. Repealing safeguards afforded by the Roadless Rule will jeopardize intact fish and wildlife habitat and I urge the U.S. Department of Agriculture to uphold strong protections for all roadless areas. Across the country, roadless areas provide irreplaceable habitat for native trout and salmon, big game, and other wildlife. The 2001 Roadless Rule generally prohibits new road construction and industrial logging, while at the same time keeping these public lands open to habitat improvement projects, hazardous fuels reduction, hunting, fishing, OHV riding, firewood cutting, grazing, and camping. The 2001 Roadless Rule already allows for balanced forest management, including timber harvest, to reduce the risk of uncharacteristic wildfire, as well as to restore habitat for sensitive fish and wildlife species. Importantly, hazardous fuels treatments in roadless areas are commonplace, helping protect at-risk communities and restoring forest health. If rescinded, new road construction and associated industrial-scale logging will fragment fish and wildlife habitat, degrade water quality and quantity, and reduce backcountry hunting and fishing opportunities on public lands. There are 370,000 miles of roads in the National Forest System with a maintenance backlog of $10.8 billion, 55% of which is due to dilapidated roads that cause sedimentation and erosion that reduce water quality, create barriers to fish migration, and create public safety hazards. We need to take care of the roads we already have, not add more roads that we don’t have the funding or personnel to maintain. Roadless areas provide some of the best fish and wildlife habitat and hunting and angling opportunities for Americans of all walks of life. I strongly support maintaining protections for all roadless areas and keeping these public lands a great place to hunt and fish.

I live in Bellingham, Washington and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, camping, wildlife watching, living in or near a National Forest community, and I am a retired fish biologist from the U.S. Forest Service. Undeveloped, roadless areas are so important for wildlife, watersheds, and humans that seek peace and respite from our busy world and the overabundant cruelty, fraud, and constitutional violations that have come from this current administration. Baker Lake Trail is one place that has shaped my views on this proposal. It is within the Mount Baker Noisy - Diobsud Inventoried Roadless Area in Mount Baker-Snoqualmie National Forest. Baker Lake is a beautiful area that supports many fish species, has a wild river upstream of the lake, and has old forests with trails winding through them. It is a great place to go swimming during hot days, and hiking any time. I am concerned about the cost of expanding the National Forest road system. Failing roads contribute sediment to streams and become fish passage barriers. The money that would be spent on new roads and their maintenance should be spent on habitat restoration, ecological research, trails, and maintenance for existing roads to prevent problems. I am concerned about wildlife habitat and landscape connectivity. Habitat fragmentation is a huge problem that limits wildlife populations because of decreased access to food and shelter, decreased genetic variability, and increased interface with humans. Many of our wildlife populations are currently struggling and their sustainability is challenged. Some have already winked out, or are on their way to extinction (such as the northern spotted owl, bull trout, and mountain caribou). I am concerned about clean water and healthy watersheds. New roads can often create fish barriers, cause sediment contribution to streams and higher water temperatures, cause invasive plant introductions, and create pollution and temperature problems during construction; aquatic habitat and fish populations require intact riparian buffer zones and clean, cold water. Roadless areas matter to me for recreation and the experiences they provide. New roads will make it much harder to find escape from civilization, which is one of the main reasons people love to recreate in national forests. I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. The more roads, the more chance for human caused wildfires. The Roadless Rule already contains exceptions that allow road construction to protect public health and safety. I am concerned about increased timber development pressure in currently roadless areas. Roadless lands will be at greater risk to being logged if the recission occurs. This administration has become known for its callous disinterest in the conservation of natural areas in lieu of resource extraction for profit. The Forest Service needs to hold onto its Roadless lands in the face of this, not log more. I believe maintaining a national conservation baseline matters. Protection for these lands should not depend entirely upon shifting administrative priorities. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? I believe the push to rescind this rule is coming from profit-seeking entities that want to log and mine national lands. This needs to be addressed truthfully by the USDA. For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments. Wendy Cole

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Department to adopt the No Action alternative. I travel from Massachusetts to the White Mountain National Forest roughly 15 weekends a year to hike, backpack, and fish. The Pemigewasset Wilderness is where I fell in love with the outdoors. The roadless forest surrounding White Mountain Wildernesses is integral to the landscape. Roads or logging at their edges would change what it means to visit them. The White Mountain Forest Plan does not provide the protection the Department claims. The proposed rule asserts that local land management plans will adequately protect roadless values. In the White Mountain National Forest, the 2005 Forest Plan classified a substantial share of inventoried roadless land as suitable for timber harvest. Rescission would open those areas to road construction and logging under the current plan. Any protections the plan does provide can be changed through future amendments, while a national rule offers durability that a forest plan cannot. The affected lands include some of the most used and valued backcountry in New England. Roadless areas surround much of the Pemigewasset Wilderness, including the land visitors cross from Lincoln Woods and Crawford Notch. The Chocorua roadless area, next to the Sandwich Range Wilderness, contains some of the forest's most popular trails, including Champney Falls and Piper. The Wild River roadless area extends well beyond the designated Wilderness into surrounding watersheds. The Great Gulf area lies on the Northern Presidentials, home to the forest's most intensive trail system. Roads and logging here would directly degrade the experiences that bring millions of visitors to the White Mountains each year. The stated rationale does not fit the White Mountains. The Department justifies rescission largely by pointing to wildfire, drought, and insect outbreaks. USDA's own announcement describes high wildfire hazard in roadless areas as primarily a Western problem. The White Mountain National Forest is a wet northern hardwood and spruce-fir forest where those conditions are not the driving management challenge. Where fuel reduction or public safety work is genuinely needed, the 2001 Rule already includes exceptions for it. A rescission justified by Western fire conditions should not strip protections from eastern forests where that justification does not apply. The benefits are small and the costs are real. New Hampshire's multibillion-dollar outdoor recreation economy depends on exactly the remote backcountry character these areas provide. Out-of-state visitors like me bring money to New Hampshire towns that would not otherwise be spent there, on lodging, food, and gear. Meanwhile, the Forest Service already carries a multibillion-dollar deferred maintenance backlog on its existing roads. Building new roads in roadless areas when the agency cannot maintain the ones it has invites erosion and water-quality damage in the headwaters of the Pemigewasset, Saco, and Androscoggin rivers. Visitors and local businesses have relied on these protections. I have planned years of trips around the assurance that these areas would stay roadless. I keep returning to the Pemigewasset and Wild River areas precisely because they have remained wild. For a quarter century, visitors and the businesses that serve them have relied on that assurance, and the Department should weigh those reliance interests. The analysis fails to disclose forest-level impacts. The proposed rule and draft EIS present impacts largely at the national scale. The Department should disclose, forest by forest, how many inventoried roadless acres would become open to road construction and timber harvest under current plans, and where. The public cannot meaningfully evaluate this proposal without knowing which trails, watersheds, and backcountry areas would be affected. At a minimum, the Department should not apply rescission where its rationale does not hold. If the Department proceeds despite these concerns, it should adopt an alternative that retains the Roadless Rule's protections in national forests where wildfire risk is not the primary management challenge, including the White Mountain National Forest. For these reasons, I urge the Department to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule.

Remain Roadless The USDA rescinded the 2001 Roadless Rule, opening 45 million acres of our healthiest, intact forests to commercial logging and timber companies; a decision across 35 states that cuts deep in this administration’s ongoing death by a thousand cuts public lands management. Our forests protect watersheds, retain snowpack, filter air and water, and hold wildlife biodiversity that is the very character of the American West. Healthy forests are synonymous with healthy rivers here in Colorado, especially as we endure our 26th year of megadrought. Shall we trust commercial logging to responsibly manage Alaska’s Tongass NF and her stunning cycle of life in salmon and 800 year old growth? How about New Mexico’s Upper Gila River headwaters - the southwest’s last wild river, and home to endangered Gila Trout, the Southwest willow flycatcher, and 330 native wildlife species? What of Greater Yellowstone’s massive elk migration? This ruling fails to see the intrinsic value of wild forest and intact animal and plant communities in a natural cycle of life. For our part, we hike, climb, hunt, fish, camp, and steward the timeless dance of life through seasons. Don’t break the cycle. Subsidizing commercial logging while propping up more motorized recreation invites more wildfire and degrades the wild character of our wildest remaining forests. Keep the Roadless Rule, bring back the 6,000 furloughed USFS employees, and let the USFS manage our forests using good science. Dave Showalter, conservation photographer and author focused on the American West.

USDA’s proposal to eliminate the Roadless Rule is a direct threat to Northern California’s public lands, recreation, and natural heritage. I am asking you to oppose it forcefully and without compromise. The North Fork Smith Roadless Area contains trails, old forest, wild river headwaters, and rare serpentine landscapes that cannot be recreated after roads and industrial activity cut through them. These lands support hiking, hunting, fishing, wildlife observation, and the recreation economy of the broader North Coast. The argument that nationwide repeal is necessary for responsible forest management is unacceptable. The existing rule contains exceptions for legitimate emergencies and necessary management. Eliminating the entire safeguard is an extreme response that would expose millions of acres to unnecessary roadbuilding and development. Please demand that USDA withdraw the proposed repeal, support congressional action protecting Inventoried Roadless Areas, and oppose any funding used to carry out this rollback. Public forests belong to the public. Their future must not be handed to logging, mining, or development interests.

Wilderness is a resource that cannot be reproduced. We must do all we can to conserve our wild areas. Americas remaining unfettered Wilderness is it's greatest legacy. The wild areas of America are the heart of the country. In the words of Aldo Leopold "Perhaps our grandsons, having never seen a wild river, will never miss the chance to set a canoe in singing waters." I do not want my grandsons to lose the ability to see wild America. We do not need more roads, we need more trees. May the cottonwood's seeds swath our screens and the crane's horn call to our ears forever in the United States of America.

I submit this comment in opposition to the proposed rescission as applied to the White Mountain National Forest (NH/ME, ~368,000 acres of inventoried roadless area, including the Kilkenny, Pemigewasset, Sandwich Range, and Wild River units) and the Green Mountain National Forest (VT, ~80,000 acres of roadless land outside designated wilderness). I am a civilian without a legal background but here is what I understand to be true: Under the Administrative Procedure Act, 5 U.S.C. § 706(2)(A), and Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29 (1983), an agency rule is arbitrary and capricious where the agency fails to examine relevant data, offers an explanation that runs counter to the evidence before it, or fails to consider an important aspect of the problem. USDA’s stated rationale for this rescission is centered on wildfire risk reduction and fuels management, yet the agency has provided no region-specific finding that this rationale applies to the low-fire-risk forests of the Northeast. A single national rationale applied without differentiation to ecologically and climatically distinct regions is precisely the kind of unreasoned, one-size-fits-all action the arbitrary-and-capricious standard is designed to prevent. Notably, USDA has already demonstrated that regional tailoring of roadless management is both administratively workable and consistent with the agency’s obligations: the Idaho Roadless Rule (2008, ~9.3 million acres) and Colorado Roadless Rule (2012, ~4.2 million acres) remain in effect and are expressly excluded from this very rulemaking. The agency’s own proposal therefore establishes that a national, undifferentiated rescission is not the only reasonable course available — and under NEPA’s requirement to consider a reasonable range of alternatives, 42 U.S.C. § 4332(2)(C); 40 C.F.R. § 1502.14, along with the precedent set in Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), which USDA itself cites in this proposal, I request that the agency either withdraw the rescission as to the White Mountain and Green Mountain National Forests or formally analyze and respond to a New England-specific alternative in the final EIS and rule, consistent with the state-specific approach already adopted for Idaho and Colorado. I ask that this comment, including the specific alternative requested, be entered into the administrative record and addressed in USDA’s response to comments.

Subject: Public Comment in Strong Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule (Supporting Alternative 1) To: U.S. Forest Service / U.S. Department of Agriculture Re: Draft Environmental Impact Statement – 2001 Roadless Rule Rescission Docket Dear Public Lands Management Team, I am writing as a PhD ecologist, as well as an active hiker, trail runner, and angler in New Hampshire’s White Mountain National Forest (WMNF), to express my strong opposition to Alternative 2 (Full Rescission) and Alternative 3 (Modified Roadless Rule) in the Draft Environmental Impact Statement (DEIS). I urge the U.S. Forest Service to adopt Alternative 1 (No Action) to preserve the 2001 Roadless Area Conservation Rule in its entirety. 1. ECOLOGICAL SCIENCE, BIODIVERSITY, AND AVIAN DECLINES As an ecologist, I view Inventoried Roadless Areas (IRAs) as vital ecological refugia. Contiguous, unfragmented forests sustain foundational ecosystem functions, including carbon storage, hydrological regulation, and microclimate stabilization. Roads fragment contiguous canopy, introduce invasive species, and create detrimental edge effects. Protecting unfragmented canopy is especially urgent given severe avian declines. Peer-reviewed research (e.g., Rosenberg et al., Science 2019) documents a net loss of nearly 3 billion breeding birds in North America since 1970—a 29% overall drop. Forest-dwelling species have been hit especially hard, losing over 1 billion individuals, while radar monitoring shows a 14% drop in spring migratory bird biomass in recent years. Long-distance Neotropical migrants relying on interior forests like those in the WMNF are highly vulnerable to edge effects and nest parasitism caused by road corridors. Rescinding or altering the Roadless Rule will destroy essential breeding and stopover habitat, compounding these population collapses. 2. COLDWATER FISHERIES AND AQUATIC INTEGRITY My experience angling in the White Mountains underscores the hydrological necessity of roadless protections. Native wild brook trout (Salvelinus fontinalis) depend on cold, clear, unpolluted headwaters. Road construction and logging destabilize soils, driving sedimentation and thermal stress in mountain streams. IRAs like the Kilkenny, Wild River, and Sandwich Range headwaters protect pristine water quality and climate-resilient refugia that native fish require to survive. 3. RECREATIONAL EXPERIENCE AND THE OUTDOOR ECONOMY When hiking and trail running through the WMNF’s roadless areas, the experience depends on uninterrupted solitude, intact wild scenery, and natural soundscapes. Allowing industrial roads and timber harvest into these spaces degrades high-quality non-motorized recreation, directly undermining New Hampshire’s vibrant outdoor recreation economy. 4. COUNTERING WILDFIRE RATIONALE IN THE DEIS The DEIS suggests rescinding the rule is necessary for forest health and wildfire management. Ecological and fire data contradict this premise: Roads drive ignitions: Approximately 90% of wildfires start within a half-mile of a road, and nearly 88% are human-caused. Extending roads into IRAs increases human ignition vectors. Low historical burning: Data show roadless areas do not burn at higher rates or severity than roaded forest lands. Existing flexibility: The 2001 Rule already contains explicit exceptions allowing hazardous fuel treatments, tree cutting for public safety, and emergency fire suppression. Eliminating protections entirely is an unjustified overreach. CONCLUSION The 2001 Roadless Rule is a cornerstone of science-based land stewardship. I urge the Forest Service to reject Alternatives 2 and 3, and select Alternative 1 (No Action) to safeguard our forests, biodiversity, and clean water. Sincerely, Donald C. Dearborn, Ph.D. Ecologist

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The White Mountain National Forest is my family’s backyard. We hike the land, paddle the waters, leaving only footprints but taking countless memories and photos with us. What I go looking for out there: "We have seen bobcats, bears, fishers, otters, moose, porcupines, etc., etc." We paddle Pond of Safety, the Androscoggin, Saco, Pemigewassit, Ammonoosuc Rivers. What I photograph out there: "We photograph unfragmented woodlands and the wildlife inhabiting them." The Weeks Act was passed in 1911 in response to the greedy raping of this land. Scars from that raping remain. To undo the protection of the Roadless Rule is short-sighted, idiotic, and asinine. Damage to existing roads due to heavy rains (due to climate change) has yet to be repaired - there is not money for repairs, thanks to the draining of the Forest Service budget to fund stupid ego projects like the Reflecting Pool in DC. Why build new roads if existing roads are impassible and there is no money to maintain them? More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and by the agency’s own data about 24 million Americans drink water that starts there. Fewer than 12 percent of those watersheds have impaired streams today. The agency’s own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. These are the last unroaded third of the national forests. A logged stand grows back. A road doesn’t. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting them. It has held none to undo it. Just last week there was a wildfire in Rumney, NH, on Rattlesnake Mountain. It began near a road. The absence of roads PROTECTS the forest and wildlife. The Kilkenny region is a gorgeous wilderness that requires backpacking on foot to traverse. That relative inaccessibility means that wildlife is free to live undisturbed. We have been hiking the Cherry Mountain region for 35+ years. The views have grown in, but that’s what we love about it. This is true wilderness and must remain so! I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Kilkenny (28,766 acres), White Mountain NF, New Hampshire - Cherry Mountain (8,766 acres), White Mountain NF, New Hampshire - Dartmouth Range (9,233 acres), White Mountain NF, New Hampshire - Great Gulf Ext. (15,110 acres), White Mountain NF, New Hampshire - Wild River (46,878 acres), White Mountain NF, New Hampshire - Presidential - Dry River Ext (10,555 acres), White Mountain NF, New Hampshire I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Lynne Bishop Jefferson, NH

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The entire White Mountain region in New Hampshire and Maine is my playground. I have been hiking, skiing, paddling, and photographing this country since I was a small child, first camping in the Pemigewasset with my family and later through the Wild River, Kilkenny, and the other roadless areas of the White Mountain National Forest. The remoteness of Kilkenny is its greatest appeal, a true wilderne treat to behold. Losing any of it would be devastating. I oppose the rescission of the 2001 Roadless Area Conservation Rule. New Hampshire holds 15 inventoried roadless areas totaling 234,681 acres. 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 the federal government to purchase private land for national forests, was passed specifically because of what happened when New England's mountains were clearcut. I do not want to see that repeated. These forests should be managed for all of us to enjoy, not treated as a commodity. The flora and fauna that inhabit this region need a place to thrive. I've paddle the Magalloway and the Androscoggin, and photographed plants, animals, waterfalls, and amazing views. Clean water is life, and across the Eastern region, which includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. I do not want to see my money wasted laying the forest bare for timber extraction, ruining watersheds, causing erosion, and harming habitats. 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 must explain how opening these watersheds to road-building serves the water quality that 286 downstream intakes in this region depend on, and it must do so specifically in light of its own sediment findings. The proposal justifies rescission partly on wildfire and fuels management grounds. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside these areas. On the economics, 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 must reconcile the proposal with its own cost-benefit analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified by figures this small. The proposal also argues that state-by-state approaches can replace the national rule. The agency's own 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 rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already reviewed that reasoning and found it wanting. The agency must explain how this proposal avoids the deficiencies identified when the national rule was last replaced with a state-by-state approach, and address its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. A court that reviewed that question 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." The agency must address the Tenth Circuit's holding that the 2001 rule was authorized under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and state clearly the basis for any position to the contrary. I have recreated in the Pemigewasset, the Wild River, and Kilkenny for decades. More and more people are heading into these regions precisely because roadless character is worth seeking out. I ask that the agency preserve the 2001 rule and answer each of these points before taking any further action. Sincerely, Lisa Melone South Berwick, ME