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(Note: This comment has been submitted as part of the document entitled "20261006_McNamara_FS-2025-0001-223869_Opposition.pdf". It has been submitted as a separate comment here as well for additional documentation purposes.) As a Colorado resident, I oppose the proposal to either partially or fully rescind the Roadless Area Conservation Rule. This proposal claims: “there is a need to increase local management flexibility and, where necessary, allow for active management to respond to changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface.” Per the current code of regulations (as of Oct 6, 2026) in Title 36 Part 294, roads and temporary roads can already be constructed for a number of exceptions including, but not limited to: a) a road being needed pursuant to reserved or outstanding rights (such as existing mining claims), b) a temporary road being needed to protect public health and safety in cases of imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property, and c) a temporary road is needed to facilitate tree cutting, sale, or removal within the first one-half mile of the community protection zone to reduce the wildfire hazard to an at-risk community or municipal water supply system. There are plenty of provision in the 2001 Roadless Rule to allow for active management of roadless land to mitigate wildfire and natural disaster risk and respond to changing and localized conditions. Fully or partially rescinding the existing roadless rule is unnecessary to mitigate wildfire and community safety hazards at the wildland-urban interface. Additionally, the rationale for this proposal states: “The Secretary of Agriculture has broad authority under statutes such as the Organic Administration Act of 1897 and the Multiple-Use Sustained-Yield Act of 1960 to manage the National Forest System for a variety of uses. Just as the establishment of the 2001 Roadless Rule was discretionary, this proposed rule is an exercise of discretion to determine the most appropriate process for balancing competing values and uses in inventoried roadless areas within that legal framework.” The Multiple-Use Sustained-Yield Act of 1960 (MUSYA) provides the Forest Service authority to manage national forest and grasslands ‘‘for outdoor recreation, range, timber, watershed, and wildlife and fish purposes.’’ The National Forest Management Act of 1976 (NFMA) reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). In defining ‘‘multiple use,’’ the MUSYA clearly provides that under multiple-use management some land will be used for less than all of the possible resource uses of the national forests and grasslands. The Roadless Area Conservation rule, currently allows a multitude of activities including motorized uses, grazing, and oil and gas development that does not require new roads to continue in inventoried roadless areas. The National Forest System contains an extensive system of existing roads; the current roadless rule does not close or otherwise block access to any of those roads. Under the existing roadless rule, management actions that do not require the construction of new roads are allowed, including activities such as timber harvesting for clearly defined, limited purposes, development of valid claims of locatable minerals, grazing of livestock, and off-highway vehicle use where specifically permitted. Existing classified roads in inventoried roadless areas may be maintained and used for these and other activities as well. Forest health treatments for the purposes of improving threatened, endangered, proposed, or sensitive species habitat or maintaining or restoring the characteristics of ecosystem composition and structure, such as reducing the risk of uncharacteristic wildfire effects, are also already allowed under the current rule where access can be gained through existing roads, by equipment not requiring roads, or under the exceptions started above.

The 2001 Roadless Rule, the limited number of roads within inventoried roadless areas and the inability to reconstruct or build new roads to provide the needed access further limit management flexibility. Taken together, the prohibitions have removed important management tools for key areas where there are needs or opportunities to address overgrown and fuel-loaded national forests. This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 (16 U.S.C. 1600 et seq. ). The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency's land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit's expected distinct roles and contributions to the local area, region, and Nation. The land management planning framework ensures each land management plan addresses similar conservation objectives as the 2001 Roadless Rule was intended to address, such as ecological integrity (including air, soil, and water), sources of public drinking water, diversity of plant and animal communities (including federally listed threatened and endangered species), sustainable recreation, scenic character, and protection of cultural and historic resources. At the same time, this planning approach allows for place-based, collaborative decisionmaking that is responsive to specific on-the-ground resource conditions, rather than a “one-size-fits-all” national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities. In 2001, USDA and the Forest Service asserted that a national prohibition was the best means to reduce conflict and potential for incremental impacts to the ecological and social values of these areas. Since then, conditions across National Forest System lands have changed substantially, especially in the Western United States where many inventoried roadless areas are located, with increasing drought, extreme temperatures, wildfire frequency and severity, and insect and disease outbreaks. Alongside these landscape changes, the Agency's land management planning framework has become more adaptive, science-based, efficient, and effective. These changes, combined with evolving Department priorities for active forest management and deregulation, diminish the basis for a national prohibition. The proposed rule would return land management decisionmaking for inventoried roadless areas to local Forest Service officials—giving them the flexibility to address conservation and resource issues informed by input from stakeholders, communities, and state, local, and tribal governments. Local decisionmaking would remain subject to the substantive requirements of the Endangered Species Act, National Forest Management Act, and other related laws and regulations.

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

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

To the U.S. Department of Agriculture: In my work as an expedition guide, I have spoken with enough guests to know that what they come to Alaska and pristine quiet places for is precisely the character of land that the 2001 Rule has protected. I have spent the past 5 years up in Alaska taking clients to see the beauty and the productivity of an isolated roadless place. I have passed bears and other animals on the trail who do not threaten me because they have an abundance of food and nutrients and we are just passing by together. One visit made that connection concrete. Just last week, we were taking guests along a river bed near Port Althorp and getting to show them what a productive salmon run looks like. We showed them how the dead salmon end up in the forest and return nutrients back to the forest from the water. We passed a bear who was readily on their way to the salmon, wanting nothing to do with us. These guests came back with countless stories and pictures and an understanding of what the world looks like when it is untouched and protected. This is exactly the experience they come looking for when they come travel here. The story recounted and the relationship underlying it are both, in the relevant sense, products of what twenty-five years of roadless protection has made possible; rescission would begin to unwind both. Regarding the Chichagof in the Tongass National Forest, Alaska: Headwater Networks Supporting Pacific Salmon Fisheries — The Chichagof IRA contains the headwaters of the Pelican Creek, Lisianski River, Kadashan River, Neka River, and other major drainages that support world-class salmon populations. These watersheds are classified as "Properly Functioning". Roads authorized by rescission in the Chichagof IRA, Tongass National Forest, alter natural drainage patterns by concentrating and redirecting surface flows, increasing runoff velocity, and delivering higher peak discharges to downstream flood-prone areas. The DEIS must evaluate the flood hazard potential of road construction in the Chichagof IRA, Tongass National Forest, as required by Executive Order 11988, including analysis of increased impervious surface, altered runoff patterns, and downstream flood risk. "Just as development and approval of forest plans must conform to existing laws and regulations, new laws or regulations, including this rule, can supersede existing forest plan management direction. This rulemaking process does not require amendments or revisions to forest plans. The NFMA reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). Together with other applicable laws, the NFMA authorizes the Secretary of Agriculture to promulgate regulations governing the administration and management of the National Forest Transportation System (16 U.S.C. 1608)." — USDA Forest Service This comment joins the record in opposition to the proposed rescission action. With concern, CommentID: RLC-20260824-UUV9QX

To the U.S. Department of Agriculture: In my work as an expedition guide, I have spoken with enough guests to know that what they come to Alaska and pristine quiet places for is precisely the character of land that the 2001 Rule has protected. I have spent the past 5 years up in Alaska taking clients to see the beauty and the productivity of an isolated roadless place. I have passed bears and other animals on the trail who do not threaten me because they have an abundance of food and nutrients and we are just passing by together. Just last week, we were taking guests along a river bed near Port Althorp and getting to show them what a productive salmon run looks like. We showed them how the dead salmon end up in the forest and return nutrients back to the forest from the water. We passed a bear who was readily on their way to the salmon, wanting nothing to do with us. These guests came back with countless stories and pictures and an understanding of what the world looks like when it is untouched and protected. This is exactly the experience they come looking for when they come travel here. The story recounted and the relationship underlying it are both, in the relevant sense, products of what twenty-five years of roadless protection has made possible; rescission would begin to unwind both. Regarding the Chichagof in the Tongass National Forest, Alaska: Headwater Networks Supporting Pacific Salmon Fisheries — The Chichagof IRA contains the headwaters of the Pelican Creek, Lisianski River, Kadashan River, Neka River, and other major drainages that support world-class salmon populations. These watersheds are classified as "Properly Functioning". Roads authorized by rescission in the Chichagof IRA, Tongass National Forest, alter natural drainage patterns by concentrating and redirecting surface flows, increasing runoff velocity, and delivering higher peak discharges to downstream flood-prone areas. The DEIS must evaluate the flood hazard potential of road construction in the Chichagof IRA, Tongass National Forest, as required by Executive Order 11988, including analysis of increased impervious surface, altered runoff patterns, and downstream flood risk. "Just as development and approval of forest plans must conform to existing laws and regulations, new laws or regulations, including this rule, can supersede existing forest plan management direction. This rulemaking process does not require amendments or revisions to forest plans. The NFMA reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). Together with other applicable laws, the NFMA authorizes the Secretary of Agriculture to promulgate regulations governing the administration and management of the National Forest Transportation System (16 U.S.C. 1608)." — USDA Forest Service This comment joins the record in opposition to the proposed rescission action. With concern, CommentID: RLC-20260824-UUV9QX