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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 To whom it may concern: I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them. Issue 1: Rescission of the Roadless Area Conservation Rule (hereafter “Roadless Rule rescission”) will result in increased habitat fragmentation, loss of habitat connectivity, and increased road-related mortality in a number of federally-listed species, including the Southern Sierra Nevada distinct population segment of fisher (Pekania pennanti), Bi-State distinct population segment of greater sage-grouse (Centrocercus urophasianus), and Sierra Nevada bighorn sheep (Ovis canadensis sierrae). Conservation assessments and strategies for these species have identified roads as significant sources of mortality and habitat fragmentation in these species. These significant impacts should be analyzed and addressed in the EIS, including in specific areas of concern – such as the Boundary Peak roadless area (Bi-state sage-grouse); Kings River, Dinkey Lakes, Black Mountain, and Greenhorn Creek roadless areas (Southern Sierra fisher); and San Joaquin and Hoover roadless areas (Sierra Nevada bighorn sheep). Additionally, I ask the agency evaluate impacts of the Roadless Rule rescission to big game populations, such as elk, mule deer, pronghorn, and moose. These impacts should be assessed to evaluate effects to habitat connectivity and population-level impacts in these species and how it may affect hunting and wildlife viewing activities by the public. Additionally, I ask that the agency evaluate impacts of the Roadless Rule rescission to federally-listed plant species, such as whitebark pine (Pinus albicaulis). Lastly, I ask the agency to evaluate the impacts of the Roadless Rule rescission on species of conservation concern identified in revised Land Management Plans on national forests. Issue 2: I ask that the Roadless Rule rescission EIS evaluate cumulative effects of the proposed action with other recent agency-wide policy changes proposed by the U.S. Forest Service. In particular, these cumulative effects should include the proposed amendment to the existing Travel Management Rule (36 CFR 212) announced on August 21, 2026 on the agency’s website. It should also include cumulative effects of any other recent policy changes that broadly affect National Forest System roads, such as Land Management Plan revisions and amendments. Issue 3: The U.S. Forest Service’s own fire data shows that wildfire ignitions are closely associated with roads and road access. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System lands against 3.0 fires per million acres inside the affected roadless areas (DEIS Table 21, 2014-2024). The DEIS states that human-caused ignitions have increased in abundance with proximity to roads. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard. I also ask the agency to conduct a thorough evaluation of the effects of roads on wildfire ignitions on national forests and other federal lands using he best available science information. Issue 4: I ask that the agency please address effects of the Roadless Rule rescission on the potential spread of invasive species, such as cheatgrass, on National Forest System lands. Numerous scientific publications have linked roads and road construction to increased cover and spread of invasive plants and their potential to increase the frequency and rate of spread of wildfires in wildlands. I request that the agency respond in the record to each of the issues raised in my comment and that it analyze in the DEIS an alternative that retains the 2001 Roadless Rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Susan Roberts Mammoth Lakes, California

To: USDA Forest Service – Regulatory Management Re: Public Comment Opposing the Repeal of the 2001 Roadless Area Conservation Rule (36 CFR Part 294) Focus: Transportation Infrastructure Fiscal Deficits, Deferred Road Maintenance Backlog, and Compliance with the Travel Management Rule (36 CFR Part 212) I. Summary of Objection I am writing to express my strong opposition to the proposed repeal of the 2001 Roadless Area Conservation Rule. Expanding eligibility for road construction into currently designated Inventoried Roadless Areas (IRAs) is fiscally irresponsible and legally flawed given the U.S. Forest Service’s current multi-billion-dollar deferred maintenance backlog across its existing transportation network. Expanding the road system into remote terrain directly conflicts with the agency’s regulatory obligations under the Travel Management Rule (36 CFR Part 212) and constitutes arbitrary and capricious decision-making under the Administrative Procedure Act (APA, 5 U.S.C. § 706). II. Substantive Grounds for Opposition 1. Failure to Comply with the "Minimum Road System" Mandate (36 CFR § 212.5(b)) Under 36 CFR § 212.5(b), the Forest Service is legally mandated to identify and maintain a "minimum road system needed" that is safely managed and reflects actual funding capabilities. The agency currently manages over 370,000 miles of National Forest System roads, a substantial portion of which is unmaintained, severely degraded, or subject to long-term closures due to safety hazards, washouts, and severe erosion. Repealing the Roadless Rule to permit new permanent or temporary road construction across 58.5 million acres directly contradicts 36 CFR § 212.5(b). The agency cannot lawfully or logically expand its infrastructure system when its current network demonstrably exceeds what available federal appropriations can safely maintain. 2. Fiscal Arbitrary and Capricious Decision-Making (5 U.S.C. § 706) Under the Administrative Procedure Act, an agency action is arbitrary and capricious if it ignores critical operational realities or fails to offer a rational connection between the facts found and the choice made. The Forest Service faces an estimated deferred maintenance backlog exceeding $8 billion for roads, trails, and associated drainage structures (such as culverts and bridges). Constructing new roads in remote, high-elevation, steep, or topographically complex IRAs inherently involves high capital outlay and accelerated recurring maintenance burdens. Reopening these areas to potential development without demonstrating how the agency will finance long-term maintenance—or address the existing multi-billion-dollar deficit—violates the standard of reasoned decision-making under the APA. 3. Environmental Degradation from Unmaintained Infrastructure (NFMA & NEPA) The National Forest Management Act (16 U.S.C. § 1608) and National Environmental Policy Act (42 U.S.C. § 4321 et seq.) require full evaluation and long-term stewardship of soil and water resources. Unmaintained roads and deferred drainage structures are well-documented primary drivers of sediment discharge into aquatic habitats, severe landsliding, and culvert blowouts during storm events. Adding new road segments into pristine watersheds while existing arterial and collector roads remain unmaintained multiplies these cumulative environmental impacts. The Draft Environmental Impact Statement (DEIS) must rigorously model the cumulative watershed impacts of adding infrastructure liability to an already under-resourced transportation budget. III. Conclusion & Requested Action The Forest Service must prioritize maintaining and bringing into compliance its existing road and trail network before considering any policy shift that expands infrastructure into currently roadless areas. I request that the Forest Service withdraw the proposed rule repeal and retain the 2001 Roadless Area Conservation Rule in full to protect intact watersheds, maintain fiscal integrity, and uphold its statutory obligation under 36 CFR § 212.5(b). Respectfully submitted, BN

I write to express my strong opposition to the U.S. Forest Service's proposed revisions to the Travel Management Rule (36 CFR Part 212), announced August 21, 2026, and noticed in the Federal Register on August 24, 2026 (Docket No. FS-2026-0100). We urge the Forest Service to withdraw this proposal and retain the existing 2005 Travel Management Rule framework. The proposal would extend e-bike access onto trails currently designated non-motorized. Many of these trails were designed and are maintained for hikers, equestrians, and traditional mountain bikers; introducing motorized and higher-speed use raises genuine safety concerns, increases erosion on trails not engineered for it, and was adopted without the route-specific environmental review such a change warrants. With the USFS’ own acknowledgement of little enforcement and management, the opportunity for recreationalists not following the rules is high. There will be an increase in user conflict. The anticipated - and unanticipated – potential environmental degradation involved in this change cannot be underscored enough. We respectfully request that the Forest Service: Withdraw the proposed shift to an "open-unless-closed" default and retain the current closed-unless-open framework; Retain the national minimization criteria in any revised rule; Require route-specific, science-based environmental review — including wildlife, watershed, and soil impact analysis — before any new roads, trails, or vehicle types (including e-bikes) are added to the system; and Extend the public comment period and hold in-person and virtual public hearings in affected forest communities.

Let me look up the specific rule so your comment references it accurately. Let me pull the actual rule text so your comment engages with its specifics. Here's your comment, formatted to engage directly with the rule's specifics. A few things worth knowing first: the comment period closes September 23, 2026, submitted via regulations.gov under docket FS-2026-0100. This is a notice of intent to prepare an EIS, so the agency is specifically asking for input on alternatives, effects, and relevant information. Comments that name concrete impacts and point to specific provisions carry more weight than general opposition, so I've anchored yours to the actual mechanics you're worried about: the open-unless-closed presumption, the class 1 e-bike exemption, and the "maintenance and administrative capacity" language that ties directly to your resourcing concern. --- **Re: Docket FS-2026-0100 — Travel Management; National Forest System Lands (91 FR 54686)** I am writing to express my strong opposition to the proposed revision of the Travel Management Rule. I am a hunter and hiker who spends significant time in National Forest backcountry, and I believe this rule will cause serious and lasting harm to wildlife, wildlands, and the quality of public access it claims to improve. My central concern is that the proposed "open unless closed" presumption arrives at exactly the moment when new vehicle technology has made deep backcountry access dramatically easier. Advanced electric bikes and capable four-wheel vehicles now let people reach remote country that was effectively self-limiting a decade ago. This is not a marginal increase in access. It is an unprecedented one, and a presumption favoring access will accelerate it rather than manage it. The proposed exemption of class 1 electric bicycles from motor vehicle use designation requirements (36 CFR 212.51(a)) illustrates the problem. Treating these as ordinary bicycles ignores how far and how fast they let riders penetrate into areas that were previously reached only on foot or horseback. The EIS should take seriously the alternative, which the notice already identifies, of retaining class 1 e-bikes as motor vehicles subject to designation. I want to speak directly to the "maintenance and administrative capacity" standard the rule lists as one basis for closure. In practice, the Forest Service does not have the staff or funding to actively manage expanded access, and it may well face further reductions. A framework that presumes routes are open unless the agency can produce specific, documented justification to close them shifts the burden precisely backward. When an agency lacks capacity, the realistic result of an open-unless-closed presumption is not careful local decision-making. It is unmanaged access by default. The EIS should analyze whether the agency can realistically administer this framework at current and projected funding levels, and what happens to resource protection when it cannot. My own experience already reflects where this is heading. Each year I encounter more people pushing further into remote areas on e-bikes and advanced vehicles. This has disrupted hunts and sharply reduced the solitude and quality that draw people to these lands in the first place. Increased motorized penetration displaces game, fragments habitat, and degrades the backcountry experience for everyone seeking a quiet, primitive setting. These are foreseeable effects the EIS must evaluate honestly, not defer to speculative future site-specific decisions. I urge USDA to retain the current Travel Management Rule (the no-action alternative) or, at minimum, to preserve the minimization criteria and the requirement that motorized routes be affirmatively designated rather than presumed open. I am adamantly opposed to this change. Thank you for considering my comment.

It is not reasonable to assume, as the Department does here, that recession of the rule will have only a "modest" impact on the environment due to the likelihood that new roads will only result in around .5 mile distance from existing roads. The Department has failed to consider the incremental impact that adding new access has on wildlife segmentation. In addition, one half-mile of road surface added over the entire breath of the landscape that the roadless rule covers, has not been considered. Similarly, the combined impact of new roads in conjunction with the impact to the environment created by the Department's new "access management regulations"(see 36 CFR Parts 212 and 261) which presume motorized access is allowed unless otherwise prohibited has not been considered. Again, the incremental impact of presuming motorized access, combined with the addition of new roads for additional access to existing roads creates impacts that the Department has not considered. That is, even new roads less that .5 mile from existing roads will have more than a modest impact on wildlife habitat segmentation and disruption in conjunction with the Department's concurrent new rule to presume access to new roads. I am a hunter, hiker and climber in Washington State and I oppose recession of the roadless rule.