Read the comments.

Under "Effects of Alternative 2 - Proposed Action," the subsection "Municipal Water Use" at p. 131 reads in its entirety, as to the finding: "If additional road construction or timber harvest result in a decrease in water quality, and or reduce the efficacy of water treatment." That is a conditional clause with no main clause. It names a possible cause and stops before stating any consequence. Every sentence that follows it reports exposure - how many people draw water from these watersheds - not effect. Alternative 1 receives one sentence, at p. 130: "Alternative 1, in general, has little risk of potential adverse effects and provides the greatest protection of water quality." Alternative 3's discussion at p. 132 cross-references Alternative 2 and repeats the exposure count in Table 36. The result is that the DEIS discloses who is exposed and never discloses what happens to them. The DEIS supplies the mechanism itself, one page earlier, and does not carry it forward. At p. 130 it states: "Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation." Rescinding the prohibition permits road construction and timber harvest in the very watersheds the DEIS has already identified as containing municipal intakes. Increased sediment and turbidity in a surface-water source raise treatment cost and can exceed treatment capacity during storm and post-disturbance runoff, forcing intake shutdowns and reliance on alternate supply. That is the sentence the DEIS began at p. 131 and did not finish, and it is the finding the FEIS must make. The scale of what is undisclosed is the DEIS's own. At pp. 129-130 it reports that "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas" and that "Approximately 24 million people utilize water which originates within potentially affected inventoried roadless areas," with Table 35 breaking that out by region. For the Proposed Action the DEIS states that "The Intermountain Region is also affected in that over 1 million people receive water directly from watersheds containing inventoried roadless areas" (p. 131) - and then states no effect on them. The record contains a named, quantified system inside that figure. The Salt Lake City Department of Public Utilities told the agency (DEIS Vol. III, pp. 246-247) that "Our community opposes any federal action that could put our regional water quality at risk for 400,000 users throughout the Salt Lake City metropolitan area," that "The Wasatch Mountains east of Salt Lake City provide 60% of our daily water supply," and that "Protecting our water quality and our public health is the foremost responsibility of our work at SLCDPU." Table 35 puts the entire Intermountain Region, which covers Utah, at 1,118,900 people served by intakes; the single system documented in the agency's own record is 400,000 of them, roughly a third of the region's whole intake-served population. "Salt Lake" appears once in Volume I of the DEIS, in a list of references cited under Recreation. "Wasatch" does not appear in Volume I at all. The obligation to make this finding is stated by the agency, in this document. At p. 127 the DEIS says: "The Forest Service is required to manage National Forest watersheds that supply municipal water under multiple use prescriptions in land management plans (36 CFR part 219)." A rescission that removes the rule-level prohibition on road construction across watersheds holding more than 7,000 municipal intakes cannot be evaluated against that requirement on a record that states no effect for any alternative. See Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989); Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). The sentence that closes this section at p. 131 - "Most forest plans acknowledge the need for protections for municipal watersheds with plan components that have an overall management objective to maintain and improve watershed status" - does not supply the missing finding and cannot defer it. No plan component is identified, none is cited, and "most" concedes that some plans have none. The decision under review is made at the rule scale and made now: the prohibition either stands or is removed nationally, and the watersheds it currently covers either keep that protection or lose it on the effective date. Whatever a later project-level analysis may add, it cannot supply the effects disclosure NEPA requires for the decision actually before the agency.

Dear Chief: My name is Kevin, I'm a composer, and I stand for preserving our pristine backcountry. I oppose rescinding the roadless rule. I have many memories from peaceful walks, time with friends, and creative inspiration provided by Arroyo Seco. A favorite story of mine is hiking the Arroyo Seco Primitive Trail and camping for a few nights with some friends I was able to share backpacking with friends and family at Arroyo Seco, for many being the first time they tried it. Bulldozed road beds would disrupt or end that experience. Regarding the Arroyo Seco in the Angeles National Forest, California: Most listed species are declining, not recovering. A review of all ESA-listed species found that 52 percent had declining status trends, compared with 8 percent improving. The authors concluded that threats are persistent and pervasive, funding has been insufficient, and at least ten times more species probably qualify for listing than have been listed (Evans et al. 2016). — Evans et al., 2016 (https://doi.org/10.1002/bes2.1308) We need to stop infringing upon the natural world for our own means, even with the guise of wildfire protection, which the data shows isn't accurate. We need to support the environment first, as it's our remarkable home that provides endlessly. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “Early quantitative analysis showing roadless areas substantially complement biodiversity conservation, with many roadless areas overlapping areas important for imperiled species. — DeVelice & Martin, 2001 (https://doi.org/10.1890/1051-0761(2001)011[1008:ATETWR]2.0.CO;2)” Quantified Caribou Sensitivity in the Biological Assessment (1% Roads → 42% Decline) Never Carried Into the DEIS Effects Analysis The Draft Biological Assessment for USFWS species states at page 66: "The research predicts that for every 1% increase in roads in the matrix habitat, there will be a 42% decline in southern mountain caribou abundance (Lochhead et al. 2022)." This is the agency's own screening document quantifying an extraordinary sensitivity of a listed species to precisely the activity the rescission would newly allow — yet the DEIS's effects analysis nowhere presents, applies, or even acknowledges this ratio in evaluating alternatives. NEPA requires that an EIS contain "a reasonably thorough discussion of the significant aspects of the probable environmental consequences," and general statements do not substitute for the quantified analysis the agency itself possesses. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208, 1213 (9th Cir. 1998); Klamath-Siskiyou Wildlands Ctr. v. Bureau of Land Mgmt., 387 F.3d 989 (9th Cir. 2004). I request that the DEIS incorporate the Biological Assessment's quantified road-density findings for southern mountain caribou into its species effects analysis and disclose the projected consequences of foreseeable road construction in affected matrix habitat. The Department's consideration of this comment and its underlying position — that the Rule should be retained — is appreciated. Best regards, CommentID: RLC-20260909-RGD2QJ

I have spent much of my life in these woods and the thought of deforestation and logging roads running through them breaks my heart. These areas are irreplaceable. Please do not allow this to happen. By the Assessment's Own Definition, Grizzly Core Habitat Is Lost the Moment a Road Is Built The USFWS Biological Assessment states at page 125: "By definition core habitat for grizzly bears is lost when a road is constructed, unless it is mitigated by the creation of new secure habitat elsewhere through road decommissioning or other actions." This is not a prediction subject to project-level uncertainty; it is a definitional identity: road construction in grizzly core habitat equals core habitat loss, full stop, absent compensatory decommissioning. The rescission makes road construction newly possible across previously protected portions of grizzly recovery zones (see the SSA reliance finding at p. 122), yet the DEIS neither quantifies the core habitat placed at risk nor identifies any mechanism ensuring the compensatory mitigation the definition requires. Where the agency's own document establishes a per-se loss mechanism, NEPA requires the acreage exposed to that mechanism be disclosed and analyzed by alternative. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). I request the FEIS map and quantify grizzly core habitat within potentially affected IRAs by recovery zone, and state whether and how compensatory secure-habitat creation would be assured.

Roadless Rule Comment—FS-2025-0001-223869 My family and I have had a concession on USFS lands since 1917. I grew up literally living on USFS land in the summers, and directly adjacent to National Forest in the Lake Tahoe Basin in the winters. I have skied, backpacked, hiked, biked and driven throughout multiple national forests in our country. Additionally, I own property adjacent to the Los Padres National Forest and frequently recreate there as a OHV trail user with my Jeep. I am writing to urge you to support Alternative 1, no change. I am disturbed and appalled that despite receiving over 600,000 comments advocating for no change to the roadless rule from all different types of public land owners (hunters, anglers, OHV’ers, hikers, and others), the USFS has prepared an EIS recommending rescinding the rule, and states that this is largely to better manage wildfire. Over the last 50 years of living on the National Forest and managing recreational use, I personally have experienced both the 2007 Angora Fire and the 2021 Caldor Fire in Lake Tahoe. I have also personally put out at least 5 human-caused fires that were started on or near a road. I’ve also seen the ineffectiveness of roads and bulldozed lines as large fires in CA such as the 2025 Gifford, 2021 Caldor and 2018 Carr fire jumped lines and roads multiple times. The Draft EIS states that "the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected Inventories Roadless Areas compared to other NFS lands" and acknowledges that "if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads" (Comparison of Alternatives, pp. 20-36). This ignition-density comparison is uncited, and the agency's own admission that road access correlates with human-caused ignition is never reconciled with any fire-risk rationale for expanding road access under Alternatives 2 and 3. A peer-reviewed three-decade national forest fire record found ignition density near roads reaching 7.99 fires/1000 ha versus 1.97 fires/1000 ha in Inventoried Roadless Areas — evidence squarely on point that the agency should engage. Under Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998), and Sierra Club v. Marsh, 872 F.2d 497 (1st Cir. 1989), the agency must confront contrary evidence rather than ignore it. I request the agency cite its ignition-density source and add explicit reconciliation analysis before finalizing this document. In addition, Forest Service Chief Tom Schultz recently 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. The argument that rescission is needed for more fuels management and is false. The current roadless rules allows for fuels management under certain circumstances, including to reduce fuel loads in the wildland-urban interface and to improve habitat for threatened, endangered, or sensitive species. This already has been done in multiple roadless areas in the Tahoe Basin. The Forest Service’s own research shows that roadless areas have historically received a larger proportion of fuels management projects than other areas of the National Forest System. (Sean P. Healy, Long-term forest health implications of roadlessness, Environmental Research Letters. September 2020. https://doi.org/10.1088/1748-9326/aba031). As a property owner and business owner near wildfire-prone areas in two parts of California, your decision impacts me personally and professionally if a fire starts off a newly built road because Alternative 2 or 3 was approved. I could lose my home and my business. Please choose Alternative 1. Thank you for considering my comment.

As a citizen dedicated to the preservation of our nation's public lands, and an avid visitor to our national parks including frequent visits to the Boundary Waters Canoe Area every year, I am writing to express my unwavering support for the Roadless Area Conservation Rule. Decades of ecological research confirm that roadless areas are irreplaceable cornerstones of biodiversity, clean water infrastructure, and climate resilience. The existing protections must be vigorously maintained and defended against any attempts at commercial expansion or fragmentation. Scientific data points overwhelmingly demonstrate the necessity of protecting these wild landscapes: Terrestrial Biodiversity Strongholds: Although roadless regions comprise a minority of National Forest System lands in the lower 48 states, they provide critical habitat for 57% of vulnerable terrestrial wildlife species. Furthermore, the ranges of over 400 species listed under the Endangered Species Act directly overlap with these protected areas. Wildlife Stress and Displacement: Anthropogenic disturbance from roads profoundly impacts wildlife behavior. Peer-reviewed data shows that road noise alone can displace wide-ranging megafauna and trigger significant physiological stress responses at distances exceeding one mile from the roadway. Aquatic Ecosystem Protection: Intact forest canopies and headwaters within roadless areas regulate stream temperatures and maintain pristine water quality. Conversely, forest roads are primary drivers of aquatic degradation, increasing erosion rates exponentially and introducing destructive sediment loads into native fisheries. Wildfire Ignition Risks: Empirical data contradicts the claim that road building and commercial logging enhance forest health; in reality, over 90% of human-started wildfires occur within a half-mile of a forest road. Roads additionally act as corridors for invasive plant species, which dry out quickly and provide volatile, highly flammable fine fuels. Opening intact backcountry to industrial activity compromises ecological integrity, fragments critical migration corridors for species like elk, grizzly bears, and native trout, and degrades municipal watersheds relied upon by millions of downstream residents. I urge the agency to uphold the Roadless Rule in its entirety to safeguard our remaining wild places, protect public resources, and honor the empirical science that proves intact forests are safer and ecologically richer when left undisturbed. Respectfully submitted, Angela Schuster Minneapolis, Minnesota 55407 By the Assessment's Own Definition, Grizzly Core Habitat Is Lost the Moment a Road Is Built The USFWS Biological Assessment states at page 125: "By definition core habitat for grizzly bears is lost when a road is constructed, unless it is mitigated by the creation of new secure habitat elsewhere through road decommissioning or other actions." This is not a prediction subject to project-level uncertainty; it is a definitional identity: road construction in grizzly core habitat equals core habitat loss, full stop, absent compensatory decommissioning. The rescission makes road construction newly possible across previously protected portions of grizzly recovery zones (see the SSA reliance finding at p. 122), yet the DEIS neither quantifies the core habitat placed at risk nor identifies any mechanism ensuring the compensatory mitigation the definition requires. Where the agency's own document establishes a per-se loss mechanism, NEPA requires the acreage exposed to that mechanism be disclosed and analyzed by alternative. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). I request the FEIS map and quantify grizzly core habitat within potentially affected IRAs by recovery zone, and state whether and how compensatory secure-habitat creation would be assured.

To the U.S. Forest Service: I have grown up in an area surrounded by wilderness protected by the Roadless Rule. These lands are a huge draw for people to visit and live in the area as they provide innumerable opportunities for hiking, backpacking, fishing, hurting, paddling, whitewater rafting, and just spending a day by the river or in the woods alone. Rescission of this rule would cause a loss of habitat for plants and animals and a source of recreation for humans that will never be able to be replaced I have spent 33 years in these forests protected by the Roadless Rule, they are precious to me and many people I know. As a 9 year old with my family, I backpacked 35 miles of the Foothills Trail which introduced me to the wild beauty of the wilderness of Upstate South Carolina. We planned this 3 day trip specifically to connect with nature and each other, away from "real" life and its distractions. If this rule was rescinded, I would lose access to the beauty of areas where I regularly hike and spend time on the river (or those areas would be degradated as a consequence). My 80 year old father also spends the equivalent of weeks out there each year, drawn by their peace and quiet. We are risking the loss of connection to ourselves by rescinding this rule, as well as risking the lives and well being of countless species of plants and animals who call it home. “In 2001 the Agency Found These Prohibitions Benefited Listed Species; the Rescission Never Engages Its Own Prior Finding Both Draft Biological Assessments open with the same acknowledgment (USFWS BA p. 10; NMFS BA p. 7): "In the promulgation of the 2001 Roadless Rule, the Forest Service found that the Rule's prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species or adversely modify designated or critical habitat; were not likely to jeopardize proposed species or adversely modify proposed critical habitat; and may beneficially affect threatened, endangered, and proposed species and critical habitat… The Services concurred with the determination." The agency thus stands on a concurred-in finding that the prohibitions it now proposes to delete benefit listed species — and the current assessments anticipate widespread adverse effects from deleting them. When an agency reverses course, it "must show that there are good reasons for the new policy," FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009), and where the prior policy rested on factual findings, it may not simply disregard them — the principle applied to this very rule's Tongass history in Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015) (en banc). Neither the DEIS nor the assessments explain what changed in the biology. I request the FEIS directly address the 2001 beneficial-effect finding and state the factual basis for departing from it.” “On the topic of the Forest Service's claim that this action would reduce fires: The Draft EIS reports that "77 percent and 74 percent were reported as naturally ignited in wilderness areas and potentially affected IRAs, respectively," while "the majority (57 percent) of fires with cause determinations on other NFS lands were reported as human caused" (Environmental Impacts, Wildfire Occurrence section), yet no dataset or cause-determination methodology is cited to support either figure. These percentages materially qualify the fire-risk rationale for opening IRAs to road construction, since a peer-reviewed 2026 study found ignition density highest within 50 meters of roads (7.99 fires/1000 ha) and lowest in wilderness and roadless areas (1.75 and 1.97 fires/1000 ha respectively) — evidence directly bearing on whether expanded road access would increase, not decrease, fire risk. Did the agency consider this or comparable ignition-density research, and if so, where does the record explain its rejection? An agency must rely on accurate, disclosed data rather than unsupported statistics. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). I request the agency cite its fire-occurrence dataset and cause-determination methodology and reconcile it with contrary ignition-density findings.” The Department should keep the Roadless Rule in place. I think the record supports that, and so does the public. Respectfully submitted, CommentID: RLC-20260904-JTO8PV

Please do not rescind the Roadless Area Conservation Rule. More roads mean more wildfires. Research from The Wilderness Society, shows that from 1992-2024, wildfires were four times as likely to start in areas with roads than in roadless forest tracts. Another study showed that more than 90 percent of all wildfires nationwide occurred within half a mile of a road. The Draft EIS's fire-occurrence discussion states that IRA ignition density is "essentially equivalent to" wilderness and represents "less than one-third (29 percent) of the ignition density on other NFS lands," a finding that directly qualifies the fire-risk rationale for rescission discussed earlier in Common to All Alternatives, pp. 20-36. Yet the deterministic review confirms this specific 29 percent ratio is uncited nowhere in the document. This matters because an independent peer-reviewed source, Aplet et al. 2026, found wildfire-ignition density near roads (7.99 fires/1000 ha within 50 m) far exceeds that in wilderness (1.75) or Inventoried Roadless Areas (1.97) — evidence supporting, not undermining, the EIS's own uncited figure, yet never cited or reconciled by the agency. Under Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998), an agency may not rely on unsupported or unexamined scientific conclusions. I request the agency cite the source dataset underlying the 29 percent figure, incorporate it explicitly into the Purpose and Need discussion, and address the Aplet et al. findings on the record. The Draft EIS's treatment of species affected by this rulemaking is internally inconsistent and should be corrected before the agency proceeds. The document states that "more than 300" threatened, endangered, or proposed species may be affected by the rulemaking, while separately disclosing that 327 species received "likely to adversely affect" determinations in the accompanying consultation documentation. If these figures describe the same universe of species, the rounded "more than 300" figure understates the agency's own count by dozens of species; if they describe different categories, the DEIS never says so. This matters given that at least ten times more species than are currently listed likely qualify for ESA protection, underscoring the need for precise, not approximate, species accounting. Under Native Ecosystems Council, 428 F.3d 1233, 1245 (9th Cir. 2005), agencies may not present inconsistent or unexplained figures on the very resource at issue. I request that the agency reconcile these numbers, clarify each figure's scope, and correct any error. I have hiked and camped in many forests and national parks for over 40 years, the forests are a treasure to our country and to the people and should be protected not destroyed. As a passionate hiker and wildlife enthusiast, I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Even though roadless areas only make up 2% of land in the lower 48 states, they contain habitat for 57% of vulnerable terrestrial wildlife. As many as 414 plants and animals listed as endangered, threatened or proposed for listing under the Endangered Species Act have ranges that overlap with roadless areas. Because they are not fragmented by roads, these Roadless Areas provide habitat for many imperiled species such as California condors, grizzly bears and wolves in the Yellowstone area, native salmon and trout in the Pacific Northwest, migratory songbirds in the Appalachian hardwoods and more. They also sustain wild salmon, especially in Alaska where they are the lifeblood for both the fishing industry and traditional subsistence practices of Indigenous communities.  Roads fragment habitat and degrade migration corridors that game species like elk and mule deer rely on. Protected roadless areas help ensure these migratory game corridors remain intact and protected from roads and the industrial development roads enable. Since 2001, protected roadless areas have offered abundant outdoor recreation opportunities such as hunting, fishing, camping or other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. According to maps from Outdoor Alliance’s GIS Lab, roadless areas protect 11,337 climbing routes and boulder problems, more than 1,000 whitewater paddling runs, 43,826 miles of trail, and 20,298 mountain biking trails. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Trails traverse protected roadless areas. I also urge you to extend the public comment period on the proposed rescission of the Roadless Rule from 32 days to at least 120 days, as is customary for a decision of this magnitude. Nicole Kentucky