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I write to oppose rescinding the 2001 Roadless Area Conservation Rule (the Roadless Rule). The United States Department of Agriculture (USDA) has insufficient information to understand the effects this action will have upon the environment and local communities in areas of increased road development. Under the Supreme Court's decision in Seven County Infrastructure Coalition v. Eagle County, Colorado (Seven County), the USDA must evaluate environmental impacts that are reasonably foreseeable under a rule change. In its environmental impact statement, USDA did not fully consider the impacts of road development in previously undeveloped forest land on soil, air, and water quality; plant and animal communities, including threatened and endangered species; or forest health. USDA justified this omission because "it is uncertain if there would be any future project-level decisions, and what those decisions might entail." This argument is patently absurd. USDA proposes a rule that would allow the development of roads where road development was not previously allowed. It then claims uncertainty as to what projects would result from this proposal. To clarify this uncertainty, I suggest to the USDA that allowing the development of roads will result in road development projects. Road development is not only a reasonably foreseeable impact but a straightforwardly obvious impact of rescinding the Roadless Rule. USDA is therefore obligated by the National Environmental Policy Act (NEPA) to prepare a full environmental impact statement evaluating the likely consequences, possibility of mitigation, and alternatives to road development in previously roadless areas. USDA's justification for rescinding the Roadless Rule is to increase multiple-use opportunities and allow management for wildfires, insect and disease infestations, and community protection. While USDA may not be able to determine every road project that will occur if the Roadless Rule is rescinded, it can easily note areas currently in need of wildfire or disease management or where roads would increase multiple uses. In every such instance, a road would not be permitted under current regulations and would be permitted if the proposed rule were finalized. Each potential road development is therefore a reasonably foreseeable consequence of rescinding the Roadless Rule. The impacts of each must be included in an EIS under NEPA and Seven County. I request USDA identify a range of potential road development in currently roadless areas if the Roadless Rule is rescinded. I further request that, across this range, USDA assess the environmental impacts of road development development on soil, air, and water quality; plant and animal communities; and forest health. I finally request USDA fully consider the environmental impacts of road development on the environment and local communities in its consideration of rescinding the Roadless Rule. Without this full assessment, USDA lacks sufficient information to ascertain whether rescinding the Roadless Rule will actually achieve its purported goals. USDA's environmental impact statement declined to consider the impacts that this proposed rule, if finalized, would have upon the environment and local communities. Because USDA has not accounted for the impacts of road development in this rule intended to allow road development, I strongly oppose finalizing the proposed rule for Special Areas: Roadless Area Conservation, 2026 FR 16965.

To the Department of Agriculture and the Forest Service: As someone who has spent almost two decades enjoying this area and raising my children here, I value these forests and the protections provided by this rule. I have found peace and connection by enjoying this area. If this rule is rescinded, it become more at risk of wildfire, threatening my home, my community, and generations' abilities to enjoy recreating in the area. Regarding the Dome Peak in the Routt NF, Colorado: Dome Peak contains the headwaters of Hinman Creek, Coulton Creek, Lester Creek, Cabin Creek, and Farwell Creek—a network of cold, high-elevation streams that feed into the Elk River system and ultimately the Colorado River basin. These headwaters are critical spawning and rearing habitat for four federally endangered fish: bonytail (*Gila elegans*), Colorado pikeminnow (*Ptychocheilus lucius*), razorback sucker (*Xyrauchen texanus*), and humpback chub (*Gila cypha*, federally threatened). The cold water temperatures and clean spawning substrates maintained by intact riparian vegetation and undisturbed stream channels in this roadless area are irreplaceable for these species' survival across their entire range. Greater Sage-Grouse in the Dome Peak IRA depends on the unroaded landscape to moderate exposure to 7.1 - Fire & fire suppression. Road construction in this area eliminates the spatial buffer between the threat source and occupied habitat. NEPA requires the agency to take a hard look at the effects of rescission on Greater Sage-Grouse (Centrocercus urophasianus) in the Dome Peak IRA. The DEIS fails this standard without site-specific analysis of 7.1 - Fire & fire suppression at the severity and scope documented by NatureServe. "Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term." — Conservation Biology (Wiley), 2013 Unreconciled Contradiction Between Road-Access Fire Rationale and IRA Ignition-Density Data The Draft EIS never reconciles its own comparative fire data with its road-access rationale for rescission. On the one hand, the document states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and its Wildfire Occurrence discussion reports IRA ignition density at "12 fires per million acres per year," compared to "42 fires per million acres per year" on other NFS lands—roughly 3.5 times higher. Yet elsewhere the DEIS suggests increased road access under Alternatives 2 and 3 will aid fire management, without addressing whether more roads will instead push ignition density in currently roadless areas toward the higher rate already observed on roaded lands. This is precisely the kind of internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002); and Seven County Infrastructure Coalition v. Eagle County (2025), consistent with APA 5 U.S.C. § 706(2)(A). I request a dedicated section reconciling these figures before finalization. Let the Roadless Rule stand. Best, CommentID: RLC-20260906-LOHWR7

Dear Secretary Brooke L. Rollins: As someone who regularly spends time on US Forest Service Land protected by the roadless rule, I find it very concerning that there is an effort to repeal this rule. When I moved to California 7 years ago, one of the main reasons I chose this state was because of the access to pristine wilderness areas. Growing up in Texas, I did not have access to this and being in a place where I can spend time in areas that cannot be reached by vehicle has been truly life changing. The thought that this wilderness area might soon be opened up to roads and the logging, mining, and drilling that is meant to accompany those roads is horrifying. The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. This process, if allowed to move forward, will compromise waterways and wildlife biodiversity, destroy recreation areas, worsen climate change, and greatly increase the risk of wildfire in states where wildfires are already a major threat. This goes far beyond the extreme negative implications of my personal enjoyment of these wilderness areas. It actually threatens the well being of communities in the rural and urban cities surrounding these areas. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area. Unreconciled Contradiction Between Road-Access Fire Rationale and IRA Ignition-Density Data The Draft EIS never reconciles its own comparative fire data with its road-access rationale for rescission. On the one hand, the document states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and its Wildfire Occurrence discussion reports IRA ignition density at "12 fires per million acres per year," compared to "42 fires per million acres per year" on other NFS lands—roughly 3.5 times higher. Yet elsewhere the DEIS suggests increased road access under Alternatives 2 and 3 will aid fire management, without addressing whether more roads will instead push ignition density in currently roadless areas toward the higher rate already observed on roaded lands. This is precisely the kind of internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002); and Seven County Infrastructure Coalition v. Eagle County (2025), consistent with APA 5 U.S.C. § 706(2)(A). I request a dedicated section reconciling these figures before finalization. With respect, Emeline

To Whom It May Concern at the U.S. Forest Service: As a professional, I note that the Department's proposal inverts the ordinary burden of proof: rather than requiring those who would develop roadless areas to demonstrate that development serves the public interest, it restores a default in which that demonstration is no longer required. We must preserve and protect the lands that make this country so special. Re; Bull Of The Woods in the Willamette National Forest, OR: Suckley's Cuckoo Bumble Bee (Bombus suckleyi), ranked G2 by NatureServe and federally listed (PE), is present in the Bull Of The Woods IRA, Willamette National Forest, where it confronts 7.1 - Fire & fire suppression at Negligible or <1% pop. decline severity across Pervasive - large scope. Road construction in Bull Of The Woods introduces sediment, alters hydrology, and delivers chemical contaminants to adjacent habitats — the direct physical drivers of 7.1 - Fire & fire suppression. The agency cannot satisfy its analytical obligations with a national-level discussion of roadless values. The DEIS must address 7.1 - Fire & fire suppression as it affects Suckley's Cuckoo Bumble Bee (Bombus suckleyi) specifically within the Bull Of The Woods IRA, Willamette National Forest. "The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads." — Fire Ecology (Springer Nature), 2026 Unreconciled Contradiction Between Road-Access Fire Rationale and IRA Ignition-Density Data The Draft EIS never reconciles its own comparative fire data with its road-access rationale for rescission. On the one hand, the document states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and its Wildfire Occurrence discussion reports IRA ignition density at "12 fires per million acres per year," compared to "42 fires per million acres per year" on other NFS lands—roughly 3.5 times higher. Yet elsewhere the DEIS suggests increased road access under Alternatives 2 and 3 will aid fire management, without addressing whether more roads will instead push ignition density in currently roadless areas toward the higher rate already observed on roaded lands. This is precisely the kind of internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002); and Seven County Infrastructure Coalition v. Eagle County (2025), consistent with APA 5 U.S.C. § 706(2)(A). I request a dedicated section reconciling these figures before finalization. Retain the Roadless Rule. Yours sincerely, CommentID: RLC-20260908-100IK4

To the U.S. Forest Service: As a biologist with a Master's degree in biology, I'm trained to distinguish between correlation and causation. The Department's logic here skips that step entirely. I have had a life long obsession with steelhead, a Rainbow Trout that goes out to the ocean then comes back to freshwater to spawn. This is what brought my family and I to Washington state. With so many threats to this already ESA listed species, the recinding the roadless rule would set steelhead recovery back many many years. If a single memory can stand for the whole of that attachment, it is this one. My first steelhead I caught in the Hoh River rainforest was one of the most special moments of my life. As a grown man, I cannot remember the last time my knees shook from so much adrenaline, excitement, and awe of this fish that had left freshwater, swam all over the ocean, and found its way back to this little river. I cannot express in words how much these fish mean to me from a recreational, scientific, and ecological perspective. The standing connection and the specific experience above together illustrate what the Rule has made possible over twenty-five years of operation. Regarding the Mt. Baker North in the Mt Baker-Snoqualmie National Forest, Washington: The Mt. Baker North IRA (16,873 acres) in Mt Baker-Snoqualmie National Forest possesses unique ecological characteristics — including distinct species assemblages, watershed configurations, and ecosystem composition — that a programmatic analysis covering 2,332 roadless areas cannot adequately evaluate. A programmatic EIS cannot evaluate the specific impacts of road construction on the particular watersheds, wildlife corridors, and ecological systems within the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest. NEPA does not permit substituting generic, landscape-scale analysis for site-specific impact evaluation. The DEIS must include individualized analysis of the Mt. Baker North IRA (16,873 acres), Mt Baker-Snoqualmie National Forest, addressing site-specific impacts to watersheds, wildlife habitat, and ecological integrity. A programmatic EIS covering 2,332 areas does not meet NEPA's requirement under 40 CFR 1502 for analysis commensurate with the significance of the action. "Inventoried roadless areas considered in this rule constitute roughly one-third of all National Forest System lands, or approximately 58.5 million acres. Of the 58.5 million acres of inventoried roadless areas considered in the FEIS, approximately 34.3 million acres have prescriptions that allow road construction and reconstruction. The remaining 24.2 million acres are currently allocated to management prescriptions that prohibit road construction; however, protections in these existing plans may change after future forest plan amendments or revisions. Over the past 20 years, roads have been constructed in an estimated 2.8 million of those 34.3 million acres of inventoried roadless areas." — USDA Forest Service The Draft EIS never reconciles its own comparative fire data with its road-access rationale for rescission. On the one hand, the document states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands," and its Wildfire Occurrence discussion reports IRA ignition density at "12 fires per million acres per year," compared to "42 fires per million acres per year" on other NFS lands—roughly 3.5 times higher. Yet elsewhere the DEIS suggests increased road access under Alternatives 2 and 3 will aid fire management, without addressing whether more roads will instead push ignition density in currently roadless areas toward the higher rate already observed on roaded lands. This is precisely the kind of internal contradiction agencies must resolve under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983); Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002); and Seven County Infrastructure Coalition v. Eagle County (2025), consistent with APA 5 U.S.C. § 706(2)(A). I request a dedicated section reconciling these figures before finalization. The Department is urged to resolve this proceeding in favor of retention, not rescission. Yours truly, Garrett Rowles CommentID: RLC-20260901-ZYCHBW