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My name is William Barnes. I am writing to oppose the rescission of the Roadless Rule. I grew up in and around New Bern, North Carolina, just north of the Catfish Lake North Roadless Area in Croatan National Forest. My family worked fields in the spring, summer, and fall, and depended on hunting and fishing throughout the year. I've seen first-hand what deregulation does to our rivers. I remember the dread of not knowing if it was safe to eat what we caught in the Neuse River. I do not want to see this blatant exploitation of our resources continue until there's nothing left. A measured, iterative timeline of changes that would align our regulations with any challenges introduced by the Roadless Area Conservation Rule would be considered, but we have seen time and time again that the government is willing to do the easy work of destroying, but will not apply the effort required to protect and conserve. So here we are again facing reckless destruction on the whims of out of touch bureaucrats wearing a cheap veneer of good intent. In NC, we are still suffering from the absolute mess of 'reforming' mental health care before anything was in place to protect the people that needed support. My youngest brother is among those who have been unable to receive the help he needs in part because of that. So do not try to sell me on tearing everything apart with only a statement of good intent in exchange. This administration's efforts to destroy data collection laws to help obscure facts and further protect abusers from accountability also damages any confidence I held in the findings and arguments used to justify changes like this and you have proven time and again that you are incapable of writing responsible policy. As an example: DEIS Materially Alters the 2020 Alaska FEIS Fish Habitat Finding It Relies On (pp. 243, 318) The DEIS materially alters the 2020 Alaska Roadless Rule FEIS fish habitat finding it relies on, and the alteration removes the grounds most affected by this rulemaking. At page 318, in Appendix 4 (Review of the Final Environmental Impact Statement for the 2020 Alaska Roadless Rule), the DEIS states: "The 2020 FEIS evaluated effects to fish habitat and found that there would be overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy (page 3-138)." The cited page is accurate as a locator, and the 2020 FEIS is listed in the DEIS's own references and publicly available. The problem is that page 3-138 does not say what the DEIS reports. The finding reads: "Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including the riparian management strategy, and the lack of old-growth harvest or associated road construction allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas." The source is in the record and the page cite is right; the defect is that the DEIS reports the source as saying something it does not say. Under 7 CFR 1b.7(f)(2)(v) the agency must make factual corrections, and under 1b.7(f)(3) it should cite where in the EIS or the supporting record the correction is accounted for. This is a rule-level question about what the DEIS says a source in its own record says, and about whether a conclusion premised on deleted protections can be carried forward. It is not answerable by deferral to site-specific analysis: no project-level NEPA document corrects the DEIS's restatement of its own source, and no project-level analysis can supply the programmatic conclusion that removing the T77 and Conservation Priority Area restrictions leaves fish-habitat effects "minimal." A conclusion stated without the record support it claims does not satisfy the hard-look requirement. See Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). I re-state, for posterity and to be as clear as possible, that I oppose the rescission of the Roadless Rule.

Re: Proposed Rescission of the 2001 Roadless Area Conservation Rule (Docket # FS-2025-0001 / RIN 0596-AD66) Dear Mr. Schultz, I'm a professional photography guide who has spent fifteen years taking paying clients into backcountry protected by the 2001 Roadless Area Conservation Rule. I respectfully ask the Department to reconsider the proposed rescission. My work spans national forests nationwide, but Washington State shows what's at stake. I've watched the sunrise from Suntop in the Mt. Baker-Snoqualmie National Forest countless times, photographed the stars from its ridges, and shared that peace with clients. Once a road goes in, that character is lost for generations. My opposition rests on conditions in places like Suntop and on deficiencies in the Draft Environmental Impact Statement (DEIS). 1. Clean Water Act Section 404 Deficiencies The Suntop Inventoried Roadless Area (IRA) contains jurisdictional waters of the United States, including stream channels and wetlands subject to Section 404 permitting. Every road stream crossing places fill material (culverts, bridge footings, approach fills) into these waters, a Section 404 discharge. The DEIS must disclose the number and location of jurisdictional waters in the Suntop IRA, quantify fill discharges at each potential crossing, and document the Section 404 permitting pathway for each. Deferring CWA impacts to site-specific analysis is not adequate when the programmatic decision itself changes watershed protection status. 2. DEIS Materially Alters the 2020 Alaska FEIS Fish Habitat Finding At page 318 (Appendix 4), the DEIS states: "The 2020 FEIS evaluated effects to fish habitat and found that there would be overall effects to fish habitat are expected to be minimal whether the Roadless Rule is in place or not, because of the strong protections to fish habitats provided by Forest Plan standards and guidelines and the riparian management strategy (page 3-138)." The page cite is right, but the text is altered. The 2020 FEIS reads: "Overall effects to fish habitat are expected to be minimal under all alternatives, because of the strong protections to fish habitats provided by Forest Plan LUDs, Forest-wide standards and guidelines including the riparian management strategy, and the lack of old-growth harvest or associated road construction allowed in the T77 watersheds and TNC/Audubon Conservation Priority Areas." Three material alterations: It deletes the third ground entirely: no old-growth harvest or road construction in T77 watersheds and Conservation Priority Areas, the only constraint on roads in high-value salmon watersheds. It deletes "LUDs." LUDs allocate management prescriptions; standards condition activity. They are distinct protections. It substitutes "whether the Roadless Rule is in place or not" for "under all alternatives." The 2020 FEIS noted protective differences among alternatives for these waters. At page 243, the DEIS repeats this conclusion without attribution, presenting it as its own finding. Yet the same page states: "Roads pose the greatest risk to fish resources on the Tongass, partly because they pose the largest risk of management-caused sediment input to streams." The DEIS can't name road sediment the greatest risk while resting a minimal-effects conclusion on protections stripped of the road ban in high-value watersheds. Appendix 4 discloses that the Tongass Plan Revision will consider alternatives without IRA designations, so the DEIS relies on a finding predicated on protections this rulemaking removes. Requested Actions Under 7 CFR 1b.7(f)(2)(v) and 1b.7(f)(3), I request that the Forest Service: Correct the restatements at pages 318 and 243 to reproduce the full 2020 FEIS basis, including Forest Plan LUDs and the T77/Conservation Priority Area prohibition, and restore "under all alternatives." Supply attribution and a page citation at page 243. Supplement the Tongass aquatic analysis under 7 CFR 1b.7(f)(2)(iii) to state whether "minimal effects" holds without the T77/Conservation Priority Area restrictions, with a road-mileage and stream-crossing basis. These are programmatic questions that can't be deferred. A conclusion without record support fails NEPA's hard-look requirement. (See Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002).) The 2001 Roadless Rule has withstood a quarter-century of litigation, review, and administration changes. That durability warrants leaving it in place. Please abandon this proposed rescission. Sincerely, Toby

Dear USDA Leadership: As an outdoor recreationist and wildlife conservationist, I want to clearly state that I strongly oppose repealing or weakening the 2001 Roadless Area Conservation Rule. Wild, protected places like this don't stay that way on their own, they stay that way because rules make them stay and people who care enough to advocate for them. Rolling back this rule would have real consequences for our national forests and those who enjoy them. As someone who lives on the West Coast, I am so fortunate to have access to roadless areas to recreate in within a few hours of my home. One area in particular, Diamond Peak, holds a special place in my heart. Diamond Peak is remote, rugged and beautifully wild. It's area is home to countless wildlife species including endangered gray wolves. From winter snowshoeing, to summer backpacking this area holds so much beauty for visitors to explore. This beauty should be preserved. Much of the charm of this rugged, roadless area is due to the lack of roads. To get somewhere you need your own strength and power to reach the destination. I've stood on the summit of Diamond Peak and saw from a bird's eye view the expansive landscape full of forests, rivers, mountains, lakes — and enjoyed the quite solitude that comes from being in untouched wilderness. Contrary to one of the arguments for repealing the Roadless Rule, more roads will also increase human-caused wildfires, ignited by unattended campfires or sparks from vehicles. We simply cannot afford extra wildfire risk in this region. We need to be doing all that we can to reduce fire risk which includes protecting roadless areas from development. Repealing the Roadless Rule opens up this area, and others, to road development that threatens to produce more wildfires, which then close down trail systems, stretch resources thin, and alter the landscape for generations. Regarding the Diamond Peak, North in the Willamette National Forest, Oregon: Roadless areas are disproportionately important habitat for federally listed threatened and endangered plants and animals. Rescinding the Roadless Rule would open the Diamond Peak, North, Willamette National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Roadless forests are essential to wildlife's survival. Across the United States, grizzly bears, wolverines, Canada lynx, native salmon, and dozens of other endangered species depend on the roadless stretches of our forests to keep them safe from destructive human activities. A recently released report found that rescinding the Roadless Rule would put 7.4 million acres of designated endangered species critical habitat and nearly 1,800 miles of protected rivers and streams at risk — and could hasten the extinction of more than 400 threatened and endangered plants and animals protected under the Endangered Species Act. Failure to Connect Species/Habitat Baseline to Rescission-Specific Impacts Analysis The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Rescinding a settled rule is the kind of decision that should be made only on a strong record, and the record here doesn't support it. Faithfully, CommentID: RLC-20260908-MIJROE

FS-2025-0001-223869 As a member of the Backcountry Hunters and Anglers and a frequent wildlife observer on both the Los Padres and Lake Tahoe Basin Mgmt Unit forests, I have spent many hours on the ground in multiple inventoried roadless areas. I can vouch that these areas are vital for wildlife and fragmentation of habitat with roads here and elsewhere will cause irreparable damage to our nation’s wildlife and plant life. In Lake Tahoe, much of the Pyramid Roadless Area and the Freel Peak Roadless Areas drain directly into Lake Tahoe, a part of our priceless national heritage. These roadless areas provide vital habitat for wildlife crossing in and out of the Tahoe Basin, and contain sensitive plant and animal species. The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Your decision directly affects the quality of our nation’s wildlife and plant populations and my hunting experience on public lands. I recommend you choose Alternative 1. Thank you for the opportunity to comment.

Dear Brooke L. Rollins, I write in opposition to the proposed rescission as a birder who has watched the federal scientific literature on road-density effects accumulate across two decades, and who finds that literature dispositive against rescission. Time spend in the habitat and witnessing bird and inspect species is of great joy but also sorrow. Knowing that if we do not protect these spaces, we rob future generations. During the pandemic, taking my kids hiking for outdoor learning gave us much needed reprieve from learning on screens. It was a way to connect to each other, the land and wildlife. Briscoe Creek Regarding the Briscoe in the Mendocino National Forest, California: Conservation status G2 reflects the vulnerability of Northwestern Pond Turtle (Actinemys marmorata) in the Briscoe Inventoried Roadless Area, Mendocino National Forest, where 7.2 - Dams & water management/use acts at Serious - moderate severity across Pervasive (71-100%) scope. Absent roads, Briscoe functions as a refuge where Northwestern Pond Turtle is buffered from 7.2 - Dams & water management/use. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. If the DEIS does not evaluate how rescission affects Northwestern Pond Turtle (Actinemys marmorata, G2) in Briscoe with respect to 7.2 - Dams & water management/use, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. "Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups." — Landscape Ecology (Springer Nature), 2025 “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” Failure to Connect Species/Habitat Baseline to Rescission-Specific Impacts Analysis The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Rescission would not be a reasoned policy choice on the record presented; the Department should not finalize it. Respectfully, CommentID: RLC-20260908-OTV7WU