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Dear Secretary Rollins and Chief Schultz: I am writing to express my strong opposition to the recission of the 2001 Roadless Rule. The Roadless Rule is supported by peer reviewed research as well as the Forest Service's own analysis, and I want the land I love spending time to be protected in the future. I am concerned about fire risks associated with expanding roads and the potential impact on water quality, especially for major cities like Los Angeles that get most of their water from the Sierras. The DEIS's Own Tables 14 and 21 Contradict the Rationale's Forest-Health Causal Chain. The Rationale for the Proposed Rule states 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” (DEIS p. 19). The comparative data the DEIS itself publishes contradict each step of that chain, and the FEIS must correct or withdraw the assertion. First, fire. Table 21 (DEIS p. 98) reports ignition density from the Interagency Fire Occurrence Reporting Module for 2014–2024: human-caused ignitions at 3.0 fires per million acres per year within potentially affected IRAs against 22.4 on other NFS lands, and natural ignitions at 8.5 against 16.8. The DEIS’s own text on that page explains why, finding that ignitions “increase in abundance with proximity to roads, supporting the notion that roads facilitate human access” and in turn more human-caused fires. The access the proposed rescission would restore is the variable the agency’s own data associate with a sevenfold higher human ignition rate. Second, the premise that the 2001 Rule produced a lack of active management. The DEIS reports that the Forest Service Activity Tracking System shows “an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs” over the last decade (p. 15). On the same pages it concedes that “There is no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions” (p. 14), and at p. 75 that while “Some of this annual mortality is observed within IRAs,” it is “not possible to characterize the mortality observed on IRAs on a national scale.” The agency thus states that it can measure neither the exceptions actually granted nor the roadless-specific mortality outcome, while asserting a causal relationship running from the first to the second. The rationale is therefore not merely unsupported; it is contradicted by the analysis printed in the same document. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A). Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not pass over a risk the record permits it to analyze). I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3). The Department should not rescind the 2001 Roadless Area Conservation Rule. CommentID: RLC-20261007-FAEAQ6

I implore you not to rescind the Roadless Rule. Having struggled with severe depression all my life, I cannot overstate how important these wild lands are to me. In my lows of loneliness and isolation, the one source of love, of community, of acceptance I could count on has been forests like the ones whose protections you consider removing. In an America without wild, roadless lands, where a person in pain can no longer retreat to the healing solitude of nature, I would have ended my life long ago. It breaks my heart to think of the harm rescission would do to the species who live on these lands, not to mention the people like me who depend on them for solace. The Rationale for the Proposed Rule states 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” (DEIS p. 19). The comparative data the DEIS itself publishes contradict each step of that chain, and the FEIS must correct or withdraw the assertion. First, insect and disease. Table 14 (DEIS p. 75), “Percent of NFS forested acres at risk of tree mortality due to major forest insects and diseases, by land classification,” sets the actively managed lands — NFS ownerships outside designated areas — against inventoried roadless areas in the potentially affected environment. Northern Region: 50.4 percent outside designated areas against 34.2 percent in IRAs. Southwestern: 17.5 against 13.5. Pacific Southwest: 18.9 against 15.2. Pacific Northwest: 34.7 against 23.5. The DEIS states the conclusion in its own words on the same page: “the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas.” In the four western regions holding most of the roadless estate, the lands the rule has restricted from vegetation management carry less insect and disease risk than the lands it has not. Second, fire. Table 21 (DEIS p. 98) reports ignition density from the Interagency Fire Occurrence Reporting Module for 2014–2024: human-caused ignitions at 3.0 fires per million acres per year within potentially affected IRAs against 22.4 on other NFS lands, and natural ignitions at 8.5 against 16.8. The DEIS’s own text on that page explains why, finding that ignitions “increase in abundance with proximity to roads, supporting the notion that roads facilitate human access” and in turn more human-caused fires. The access the proposed rescission would restore is the variable the agency’s own data associate with a sevenfold higher human ignition rate. Third, the premise that the 2001 Rule produced a lack of active management. The DEIS reports that the Forest Service Activity Tracking System shows “an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs” over the last decade (p. 15). On the same pages it concedes that “There is no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions” (p. 14), and at p. 75 that while “Some of this annual mortality is observed within IRAs,” it is “not possible to characterize the mortality observed on IRAs on a national scale.” The agency thus states that it can measure neither the exceptions actually granted nor the roadless-specific mortality outcome, while asserting a causal relationship running from the first to the second. The rationale is therefore not merely unsupported; it is contradicted by the analysis printed in the same document. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A). Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not pass over a risk the record permits it to analyze). I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3).

Please keep the amazing piece of policy, the roadless rule, live and enforced. America is its land, and it's people. I am connected to desolation wilderness in the Tahoe basin. Increased devistation will only result in a less secure climate, resulting in more wildfires and harm done to innocent families that garner no benefit from the destruction and increase to shareholder value. My name is Nathaniel Griffin and I will only suffer if this rule is removed. We must encourage sustainable practices, not allow devastation in our birthright. Thank you Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. Notwithstanding these findings, the DEIS concludes at p. 113 that "the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." No source is cited for that conclusion, and no estimate of the ignition increase appears anywhere in the effects analysis for either action alternative. Its two supporting assumptions are unquantified and uncommitted. At p. 109 the DEIS reasons that "not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." At p. 113 it states that "public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas." Neither alternative commits to any level of access restriction, no proportion of closed roads is estimated, no basis is given for expecting any particular proportion, and the rescission itself transfers that decision to local responsible officials. The analysis thus supplies the mitigating assumption while the rule removes the national requirement that would deliver it. The DEIS states the method for closing this gap and does not perform it. At p. 109: "As discussed in Wildfire Occurrence, past fire occurrence information on NFS lands, inventoried roadless areas, and wilderness can be used to evaluate the potential effects of new road construction." The necessary input is already in the document. Figure 15 (p. 98), "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs," is the ignition-to-road-distance gradient measured inside the affected area itself. Figure 15 appears in the body of the DEIS once, as that caption. No text discusses it and no effects analysis applies it. Because the DEIS announces this analysis, presents the data for it, and then substitutes an uncited qualitative conclusion that runs against its own cited sources, its effects finding for wildfire occurrence is not supported by the record before the agency. An explanation that runs counter to the evidence before the agency does not satisfy reasoned decisionmaking. Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not defer analysis of an effect that is properly assessed at the programmatic scale). This is a challenge to the sufficiency of the agency's explanation under 5 U.S.C. § 706(2)(A), not to the scope or depth of analysis the agency selected. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of ne

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.

We are losing roadless areas all across the country. Once they are penetrated by roads and vehicle, they are changed for all future generations. This must stop now. Road-Proximity Ignition Finding Rests on a Designation-Level Analysis and an Undisclosed Figure 15 At Draft EIS page 98, in the Wildfire Occurrence discussion, the agency states: "Consistent with other research findings, these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." The Comparison of Alternatives table in Chapter 2 carries that finding into the effects comparison, stating that under alternatives 2 and 3, "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." The Draft EIS therefore treats an increase in the number and frequency of wildfires arising from road proximity as a reasonably foreseeable effect of the proposed action. The analysis the Draft EIS presents does not support that finding at the magnitude asserted, for two reasons established by the document's own text. First, the two analyses the Draft EIS documents measure land designation, not road distance. Table 18 (p. 95) and Table 21 (p. 98) both compare other NFS lands, potentially affected IRAs, and wilderness, using Interagency Fire Occurrence Reporting Module (InFORM) Fire Occurrence Data Record ignitions with a point of origin on NFS lands for 2014-2024. A contrast among land designations cannot isolate a road-proximity effect, and the Draft EIS concedes the confounding on the same page. It states that "Other NFS lands typically have more land management activities, infrastructure (such as powerlines), and public recreation that can lead to human caused ignitions," and it reports that other NFS lands have "about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates" (p. 98). Natural ignitions are not caused by road access. The agency's own explanation for the natural-ignition differential - biophysical difference and detection rate - applies with equal force to the human-ignition differential in Table 21, and the Draft EIS neither tests nor excludes it before attributing that differential to roads. Second, the only analysis in the Draft EIS that measures ignitions against road distance is Figure 15, "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs" (p. 98). Unlike the captions of Tables 18 and 21, the Figure 15 caption identifies no data source and no period, and the figure carries none of the documentation supplied for those tables in footnotes 38 through 40 at page 94. The narrative does not reference Figure 15 or report any value from it - no distance classes, no ignition counts by cause, no exposed area, no densities. The one within-IRA road-distance analysis in the document is presented with none of the information a reader would need to evaluate it, while the two designation-level analyses that cannot answer the road-distance question are fully documented. I request that the Forest Service supplement the wildfire occurrence analysis (7 CFR 1b.7(f)(2)(iii)) to report the data underlying Figure 15 - the distance classes, ignition counts by cause, exposed area, and resulting ignition densities - and to state whether the road-distance relationship within the potentially affected IRAs survives the confounders the Draft EIS itself identifies at page 98. If it does not, the finding at page 98 and the Fire and Fuels row of the Comparison of Alternatives require factual correction under 7 CFR 1b.7(f)(2)(v). Absent one or the other, the Final EIS would assert a reasonably foreseeable effect for which it has disclosed no supporting analysis: not a cause-effect relationship established within the meaning of 7 CFR 1b.11(a)(23), and not a reasoned explanation under 5 U.S.C. Sec. 706(2)(A). See Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). Forum. This concern is directed to both the Draft EIS and the proposed rule. The road-proximity ignition finding supplies a factual predicate for the wildfire rationale stated in the Purpose and Need, and the Purpose and Need is the standard against which alternatives were measured for elimination from detailed study. An answer given only in the Final EIS response-to-comments appendix would leave the concern unanswered as a comment on the rule. Protect what's left. Keep the Rule.

Here is a revised, high-impact version that preserves all your facts, statutory references, data, citations, and personal connection while paring down the character count significantly. Dear Chief Tom Schultz: As someone who has spent a career weighing irreversible decisions against reversible ones, I take this rescission seriously. I love showing my children what makes the USA unique—our variety and quantity of wild nature. When these areas lose their wild character and face greater fire risk due to roads and added access, they lose their inherent value. Regarding Blue Lake in the Gifford Pinchot National Forest, Washington: Forest plans provide the legal framework for managing national forests under the National Forest Management Act of 1976. The Roadless Rule supplements these plans by adding a uniform layer of protection against road construction and commercial timber harvest across all inventoried roadless areas (IRAs) (USDA Forest Service, 2001, 66 FR 3244). Rescinding the Roadless Rule would open Blue Lake to road construction and ground disturbance, making specific comments on this area necessary. It is wrong and shortsighted. The DEIS’s Own Tables 14 and 21 Contradict the Forest-Health Causal Chain The Rationale for the Proposed Rule asserts that the 2001 Roadless Rule limited active management, contributing to forest health challenges (DEIS p. 19). The DEIS’s own data directly contradict this logic: Insect and Disease Risk: Table 14 (p. 75) shows that the percentage of forested acres at risk of mortality from insects and disease is lower in IRAs than in actively managed NFS lands outside designated areas across key western regions: Northern (34.2% in IRAs vs. 50.4% outside), Southwestern (13.5% vs. 17.5%), Pacific Southwest (15.2% vs. 18.9%), and Pacific Northwest (23.5% vs. 34.7%). As the DEIS notes (p. 75), risk is "similar or lower in potentially affected IRAs." Fire Risk and Road Access: Table 21 (p. 98, 2014–2024 data) shows human-caused ignitions are nearly eight times higher outside IRAs (22.4 fires per million acres/year) than within IRAs (3.0), while natural ignitions are also higher outside (16.8 vs. 8.5). The DEIS explicitly notes that ignitions "increase in abundance with proximity to roads." Restoring road access introduces the very variable associated with a vastly higher human ignition rate. Lack of Active Management Premise: The DEIS records an average of 500 acres/year of timber harvest and 1.8 million acres of hazardous fuels reduction within IRAs over the last decade (p. 15). Yet the agency concedes there is "no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions" (p. 14) and that mortality on IRAs cannot be characterized nationally (p. 75). Asserting a causal link while failing to track exceptions or mortality outcomes is unsupported. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A) (Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. BLM, 284 F.3d 1062 (9th Cir. 2002)). I request a formal factual correction under 7 CFR 1b.7(f)(2)(v) reconciling the Rationale with Tables 14, 21, and pp. 14–15—either by withdrawing the forest-health causal chain or detailing region-by-region where IRAs suffer worse health outcomes than actively managed lands. This cannot be deferred to project-level NEPA, as it forms the rule-level premise used to eliminate alternatives. If retained in the FEIS, state which acres and regions support this assertion and account for the response under 7 CFR 1b.7(f)(3). Please make the right choice, Laura Gahan

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 Secretary Rollins and Chief Shultz: I am writing as an avid user of the roadless areas not only in my home state of Idaho, but across the United States. Although Idaho may have its own roadless rule, I still value the over 40 million acres of roadless areas across all America's public lands. These areas are important to me because they exist to protect watersheds, promote biodiversity of fish, wildlife, and plant species, as well as provide irreplaceable recreational opportunities. With over 300,000 miles of existing roads on National Forests today that cannot be properly maintained, more roads by means of rescinding the Roadless Rule is exactly what the Forest Service should not be attempting to do. Building roads into roadless areas is likely to result in more wildfires. Roads will not stop nor lessen the increasing amount or frequency of wildfires. More roads = more people = more fires. In the Wildfire Occurrence section on page 98 of the Draft EIS, the agency states: "Consistent with other research findings, these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." The Comparison of Alternatives table in Chapter 2 carries that finding into the effects comparison, stating that under alternatives 2 and 3, "if there is an increase in public road access, there could be an increase in the number and frequency of wildfires as human-ignitions are more likely near roads." The Draft EIS therefore treats an increase in the number and frequency of wildfires arising from road proximity as a reasonably foreseeable effect of the proposed action. The analysis presented in the Draft EIS does not support that finding at the magnitude asserted, for two reasons established by the document's own text. First, the two analyses of the Draft EIS documents measure land designation, not road distance. Table 18 (p. 95) and Table 21 (p. 98) both compare other NFS lands, potentially affected IRAs, and wilderness, using Interagency Fire Occurrence Reporting Module (InFORM) Fire Occurrence Data Record ignitions with a point of origin on NFS lands for 2014-2024. A contrast among land designations cannot isolate a road-proximity effect. It states that "Other NFS lands typically have more land management activities, infrastructure (such as powerlines), and public recreation that can lead to human caused ignitions," and it reports that other NFS lands have "about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates" (p. 98). Natural ignitions are not caused by road access. The agency's own explanation for the natural-ignition differential - biophysical difference and detection rate - applies equally to the human-ignition differential in Table 21, and the Draft EIS neither tests nor excludes it before attributing that differential to roads. Second, the only analysis in the Draft EIS that measures ignitions against road distance is Figure 15, "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs" (p. 98). The Figure 15 caption identifies no data source and no period, and the figure carries none of the documentation supplied for those tables in footnotes 38 through 40 on page 94. The narrative does not reference Figure 15 or report any value from it - no distance classes, no ignition counts by cause, no exposed area, no densities. The one within-IRA road-distance analysis in the document is presented with none of the information a reader would need to evaluate it, while the two designation-level analyses that cannot answer the road-distance question are fully documented. I request that the Forest Service supplement the wildfire occurrence analysis (7 CFR 1b.7(f)(2)(iii)) to report the data underlying Figure 15 - the distance classes, ignition counts by cause, exposed area, and resulting ignition densities - and to state whether the road-distance relationship within the potentially affected IRAs survives the confounders the Draft EIS itself identifies on page 98. If it does not, the finding on page 98 and the Fire and Fuels row of the Comparison of Alternatives require factual correction under 7 CFR 1b.7(f)(2)(v). Absent one or the other, the Final EIS would assert a reasonably foreseeable effect for which it has disclosed no supporting analysis: not a cause-effect relationship established within the meaning of 7 CFR 1b.11(a)(23), and not a reasoned explanation under 5 U.S.C. Sec. 706(2)(A). See Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). This concern is directed to both the Draft EIS and the proposed rule. An answer given only in the Final EIS response-to-comments appendix would leave the concern unanswered as a comment on the rule.

To the U.S. Forest Service: I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit Sam’s Knob near my home in Asheville, NC. Protecting these unfragmented landscapes is deeply personal to me because I hike the backcountry trails and I value the pristine wildlife habitat. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Esther Hales Omission of Invasive-Species Establishment and Treatment Cost from the Quantified Cost Column of Cost Benefit Analysis Table 1 The Comparison of Alternatives table states that “Forest Service data indicates less than one percent of the affected environment has mapped invasive plant populations,” and that where activities increase under alternatives 2 and 3, “they could potentially increase the extent or the number of invasive plant species, especially if they create ground disturbance” (DEIS p. 32). The invasive plant species effects discussion repeats that conclusion (DEIS p. 116) and adds the agency’s own cost finding for alternative 2: “there would also likely be an increased cost associated with detecting and treating new invasive plant populations.” Neither passage projects an acreage, a spread rate, or a dollar figure for any alternative. The only acreage given is the existing 270,787 acres of invasive plants within the alternative 3 affected area, which is a baseline, not an effect. This is not a general objection to qualitative analysis. Table 1 of the Cost Benefit Analysis (p. 5) monetizes the benefit side of this rule at $9.9 to $22.0 million per year in timber benefit to society, and it monetizes two cost categories: lost recreation benefits at -$6.1 million and forgone passive use values at -$5.3 to -$11.5 million. Invasive-species establishment and treatment appears nowhere in that table, although the Cost Benefit Analysis states at p. 27 that road construction “contributes to soil erosion, sedimentation, risk of invasive species and habitat fragmentation,” and although the DEIS states that detection and treatment costs would likely rise. The agency has identified the effect, identified the cost, and then left it out of the only table in which costs are quantified. The stated reason for qualitative treatment does not reach this category. The Cost Benefit Analysis explains that “the rulemaking would not compel, require, or authorize any site-specific activities” and that “it is difficult to predict quantitative changes in costs or benefits” (p. 20). But lost recreation benefits and forgone passive use values are equally non-site-specific, and the agency monetized both across the same acreage on the same programmatic assumptions. Whatever method supported those two lines is available for this one. If it is not, the analysis should state why this category alone is different. Deferral to project-level analysis does not answer this either. The rescission itself fixes the acreage in which the prohibitions on road construction, reconstruction, and timber harvest no longer apply; the exposure follows from that rule-level determination, not from any later project decision. In Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), a programmatic EIS was held inadequate for deferring analysis of the spread of Port-Orford-cedar root disease to the site-specific stage where the programmatic decision governed the exposure. The invasive plant species discussion here rests on “future project design features and management requirements to mitigate invasives species introduction and spread” (DEIS p. 116) without disclosing what those measures are, what they cost, or what residual spread they leave after mitigation. The quantification direction is one the agency invoked itself. The Cost Benefit Analysis records at p. 4 that this rule was determined significant for purposes of Executive Order 12866 and requires OMB review, and that Executive Order 13563 “emphasizes the importance of quantifying both costs and benefits, reducing costs, maximizing net benefits.” A regulatory analysis prepared under those orders that monetizes the benefit side and two selected cost categories, while omitting a cost the agency’s own effects analysis says will rise, gives no reasoned basis for the omission and does not permit a reasoned comparison of alternatives.

Dear Ms. Rollins: As an outdoor enthusiast, I write to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to note that the Department's statutory obligations under the Multiple Use — Sustained Yield Act and the National Forest Management Act require a genuine accounting of the non-commodity values the Rule protects — an accounting that the proposed rescission's record has not provided. I've been lucky to call the PNW home for the last 26 years and the Larch and Gifford Pinchot areas around the Gorge and Mt. Hood mean more to me than can adequately be expressed. I urge to resist the fascistic impulse to acquiesce towards corporations with nothing to offer beyond the carving up of our shared outdoor resources. We live in an area that is still dealing with the impacts of the Celilo Falls destruction. I urge you again to reconsider allowing additional development in an effort to boost the bottom lines of short term corporate interests. Like the falls, once these resources are destroyed we cannot get them back. Regarding the Larch in the Mt. Hood National Forest, Oregon: The threat mechanism classified as 4.1 - Roads & railroads (IUCN-CMP 4.1) is actively degrading habitat for Cascade Torrent Salamander (Rhyacotriton cascadae, G3) in the Larch Inventoried Roadless Area, Mt. Hood National Forest, at Serious - slight severity across Restricted (11-30%) scope. The persistence of Cascade Torrent Salamander in Larch under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 4.1 - Roads & railroads to one that accelerates it. NEPA requires the agency to take a hard look at the effects of rescission on Cascade Torrent Salamander (Rhyacotriton cascadae) in the Larch IRA. The DEIS fails this standard without site-specific analysis of 4.1 - Roads & railroads at the severity and scope documented by NatureServe. "The expansion of road networks degrades the slope stability and further increases the susceptibility to landslides. Deforestation, infrastructure construction, and mining triggered about 16% of fatal landslides from 2004 to 2016. High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians, which means that forests protecting both biodiversity and landslide risks to human society are important conservation targets." — Proceedings of the National Academy of Sciences, 2022 The "No Direct Effect" Framing Is Contradicted by the Assessments' Own "Reasonably Certain" Findings and by the Record The USFWS Biological Assessment frames the action at page 377: "The Forest Service has determined that rescinding the Roadless Rule will have no direct effect on ESA-listed resources because it does not authorize, fund, or carry out future forest management activities." The same document undoes that framing. Page 376: "it is reasonably certain that active forest management and road construction will increase in these areas." Page 24: "it is reasonably certain to occur that there would be an increase in new proposals for uses involving road construction or reconstruction." And the agency's own Tribal Summary Impact Statement records the decisive rejoinder (p. 2): "The Hopi Tribe noted that removing prohibitions, in itself, has an impact." An agency may not deconstruct a programmatic action into harmless paperwork while its own documents find the consequences reasonably certain; reasonably foreseeable effects of removing a prohibition are effects of the action. 42 U.S.C. § 4332(2)(C); Kern v. U.S. Bureau of Land Mgmt., 284 F.3d 1062 (9th Cir. 2002) (programmatic NEPA analysis may not defer all effects); Ocean Advocates v. U.S. Army Corps of Eng'rs, 402 F.3d 846 (9th Cir. 2005). I request the FEIS analyze the reasonably certain increase its own assessments find, rather than resting on the no-direct-effect formulation. The Rule has protected these forests across multiple administrations. I'm asking this one to do the same. Respectfully, CommentID: RLC-20260909-YP9YL1

Dear Ms. Rollins: I'm an Alabama native, a backpacker, an educator, an adventurer, a wife and a mother. As someone who has traversed many roadless areas across the U.S., I submit these comments in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I've backpacked in Cheaha many times, marveling at the wildness that is still available to us in the midst of a modern world. I have appreciated delicate, ephemeral flowers blanketing the forest floor, firefly larvae sparking on creek banks, and the sacred feeling of being far from anything constructed by humans. This removal creates space to connect with creation. My son is almost 2 now, but when he was still in my womb I backpacked with my husband and father in a roadless area. I thought to myself that this would be one of the most wonderful things I could ever hope for my son - to have a place where he could stand outside of development and just connect with the land, animals, and plants of a place. No sound of cars passing by, no marker of time or modern expectations, only the sun and moon sculpting the rhythm of a day. Alabama contains some of the most biodiverse places in the United States, places researched and written about by people like E.O. Wilson, Scot Duncan, and Bill Finch. The roadless areas in our state and our country protect endangered mussel species, bats, and healthy soil and watersheds to name a few. The health of humanity ultimately depends on the health of our wild places. Beyond this large scale impact, my heart would break if my son grows up in a world where these truly wild places no longer exist. I want him to be able to backpack in the woods and not come across a road. To be able to just live in "time outside of time", even if only for a few days. Regarding the Cheaha A in the Talladega National Forest, Alabama: Mussel Spawning and Recruitment Habitat in Upper Cheaha Creek Headwaters — The Upper Cheaha Creek headwaters support four federally endangered mussel species—Coosa moccasinshell, Southern clubshell, Southern pigtoe, and Triangular kidneyshell—along with the federally threatened finelined pocketbook. These mussels depend on stable, sediment-free stream substrates for spawning and larval development, and on specific host fish species that carry their larvae. The roadless condition of this drainage preserves the hydrological and geomorphological stability these species require. Systemic Asymmetry Between Quantified Economic Benefits and Unquantified Environmental Costs This EIS's own comparison table concedes that "less than one percent of the affected environment has mapped invasive plant populations," then describes the incremental risk from Alternatives 2 and 3 only in vague terms—that increased ground disturbance "could potentially increase the extent or the number of invasive plant species" (Comparison of Alternatives, pp. 20-36). No acreage projection, spread-rate model, or dollar cost accompanies this statement, even though the same document quantifies economic benefits down to specific dollar figures and job counts elsewhere. Independent research confirms roads are a documented driver of "facilitation of invasive species" and habitat fragmentation (Hoffmann et al. 2024), yet the EIS never applies comparable rigor to that side of the ledger. This asymmetry violates NEPA's requirement of forthright, balanced disclosure under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), and the reasoned-analysis standard of Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). I request quantified, alternative-specific invasive-species spread projections and cost estimates matching the specificity given to economic projections. Cutting roads through wild land is irreversible. Keep the Rule that prevents it. Respectfully submitted, Stephanie

Dear Secretary Rollins and Chief Schultz, As someone who has spent a substantial portion of recreational time on public land specifically because of the conditions roadless designation maintains, I am submitting these comments to urge the Department to conduct a more rigorous accounting of public value before rescinding the 2001 Roadless Area Conservation Rule. While I know the Mt. Baker Snoqualmie National Forest best, I have also spent significant time in some of the last wild places on Earth - including the salmon runs of Alaska, wonderfully intact and protected by the Roadless Rule. I continue to explore the Mount Baker Snoqualmie National Forest, and find it beloved and respected by others who frequent it. Time in the protected forest and proximity to it is one of the reasons I live and enjoy living in the Skagit Valley. I have made my life and livelihood here, and without it I would no longer feel at home. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Trombulak et al., 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Rescinding the Roadless Rule would open the Mt. Baker West, Mt Baker-Snoqualmie 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. Recission of the roadless rule would be devastating for me personally and for my community who love and respect the outdoors. Unquantified Roadless-Specific Forest Health Data Supporting Causal Rationale The DEIS asserts 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" (Rationale for the Proposed Rule, pp. 18-19), yet this three-step causal chain is offered with no acreage figures, no roadless-specific fire, insect, or disease incidence statistics, and no comparison of forest health outcomes between roaded and roadless lands. An agency asserting materially changed conditions must articulate a rational connection between facts found and the choice made, not a bare assertion, 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 Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), and unsupported factual premises violate APA 5 U.S.C. § 706(2)(A). I request quantified, roadless-specific data on acres affected, fire risk indices, and treatment backlogs, with a direct roaded-versus-roadless comparison, before this rationale is relied upon to justify rescission. Failure to Provide Sensitivity Analysis for Acreage-Derived Percentages The Draft EIS's own acknowledged 0.4-million-acre discrepancy between the 44.7-million-acre IRA figure and the 44.3-million-acre National Forest System land figure is never carried forward into any of the derivative percentages presented in the Affected Environment section, including the 56 percent Tongass figure, the 66.5 percent timber-harvest restriction figure, the 54.5 percent road-construction restriction figure, and the 2.8 percent NWPS overlap figure (pp. 20-36). Having conceded uncertainty in the base acreage, the agency cannot present percentages calculated from it as precise without disclosing how that uncertainty propagates. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), an agency that identifies a data-quality problem must grapple with its implications for downstream conclusions rather than disclose it in passing. Presenting these figures without error bars is also arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request that the agency provide sensitivity ranges or error bars for every acreage-derived percentage in this section before finalizing the rescission. I oppose this rescission, clearly and without qualification. I'm asking the Department to withdraw the proposal. With respect, E Burnham CommentID: RLC-20260908-0HAQRV

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 Chief Schultz: For an outdoor enthusiast, the specific quality of roadless country — its acoustic character, the absence of mechanical intrusion, the compounding effect of distance from a trailhead — is precisely what the 2001 Rule was designed to preserve, and what rescission would place in permanent jeopardy. The unique character of roadless areas makes them a invaluable birthright for us and future generations of Americans. Finding a place without road noise or the sound of engines is increasingly difficult and we must protect the few that remain. I journey into the wilderness and roadless areas specifically for the difficulty and sense of adventure they offer, far from the sanitized viewing points and car-dependent activities. Rescission would steal the opportunity from me and others to enjoy the unique inheritance of America's national lands free from the impacts of noise and air pollution. Rescission would diminish the few vibrant watersheds we have remaining which support fishing, hunting, and drinking water Regarding the Comanche Peak Adjacent Area in the Arapaho & Roosevelt NFs, Colorado: “The expansion of road networks degrades the slope stability and further increases the susceptibility to landslides. Deforestation, infrastructure construction, and mining triggered about 16% of fatal landslides from 2004 to 2016. High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians, which means that forests protecting both biodiversity and landslide risks to human society are important conservation targets. — Proceedings of the National Academy of Sciences, 2022 (https://doi.org/10.1073/pnas.2113416118)” Uncited Methodology for Historical Timber Harvest Baseline in IRAs The Draft EIS's timber harvest baseline for inventoried roadless areas rests on an uncited data pull. The document states that "the best available information on activities that have been implemented within IRAs over the last decade comes from the Forest Service Activity Tracking System" and reports "an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction," but nowhere identifies the specific FACTS query, parameters, or extraction date used to generate these numbers. The phrase "best available information" itself concedes limitations without disclosing their scope, and a single ten-year average obscures whether harvest activity is increasing, decreasing, or concentrated in particular years or forests — information directly relevant to evaluating the current Rule's effect on management flexibility. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), and APA 5 U.S.C. § 706(2)(A), unsupported general statements do not satisfy the hard-look standard. I request the agency cite the specific FACTS query and extraction date and disaggregate the average by year. Absence of Quantified Nationwide Cumulative Timber Harvest, Road Construction, Sedimentation, and Fragmentation Analysis The Draft EIS justifies rescinding roadless protections across up to 58 million acres nationwide based on generalized narrative about "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," and elsewhere asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests." Nowhere does the DEIS convert this narrative into a quantified nationwide or regionally stratified projection of harvest volume, road-mile construction, sedimentation, or fragmentation, even though it performs comparable granular quantitative analysis for the Tongass National Forest alone. NEPA requires "a detailed statement… on… reasonably foreseeable environmental effects of the proposed agency action," 42 U.S.C. § 4332(2)(C), and while Seven County Infrastructure Coalition v. Eagle County, No. 23-975, 605 U.S. ___ (2025), narrows review of effects outside agency authority, it does not excuse omitting cumulative effects of actions the agency itself controls. Tiering under 42 U.S.C. § 4336e(11) requires specific commitments, not open-ended deferral. I request a quantified nationwide analysis or an explicit, enforceable tiered commitment to project-level review. Twenty-five years of it working ought to count for something. Do not move forward with rescission. Respectfully submitted, CommentID: RLC-20260906-3PPQS4

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