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I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. My name is Dawson Autry and I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rescission of the Roadless Area Conservation Rule is, as far as I can tell, purely about removing regulatory burden. It does not promise road development. It does not promise logging. It simply strips away protection from some of the last remaining old growth forestland in the world, for no reason the agency has made plain. This is old growth. It takes centuries to even approach that designation. Reforestation efforts across the world today pale in comparison to what true old growth forest represents. If roads go in and that land is destroyed, nothing like it may never be able to grace the earth again. The Forest Service held more than 600 public meetings and took 1.6 million public comments to put this rule in place. To undo something so substantial without a single comparable public process is, to me, a mistake. I ask that the agency explain what process it believes substitutes for that record of public participation, and why rescission of a rule built on 1.6 million comments requires none of its own. On water, the agency's own data shows that 24 million Americans drink water that originates in these roadless areas. Roads are known to cause contamination in the areas where they are built. The agency's own analysis confirms this directly, finding that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Rescinding this rule opens those watersheds to exactly that kind of harm, affecting the drinking water of millions of Americans with little to no real benefit. I ask the agency to explain on the record what specific, quantified benefit justifies that risk to public water supplies. On wildfire, the proposal invokes forest health and fuels management as justification for rescission. The agency's own record says the opposite: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal offers no reconciliation with that finding. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. On the state-by-state approach, the agency has already traveled this road and lost. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Courts rejected that state-by-state substitute before. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last tried to replace the national rule with state petitions. On statutory authority, the proposal argues the 2001 rule exceeded what Congress authorized. A federal appellate court already answered that question: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain on the record the basis for any position to the contrary. Finally, on administrative burden, the rule as written already contains exceptions, including for "the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency has not identified which specific burdens those exceptions fail to address. It must do so, with quantification, before rescission can stand as a proportionate response to any genuine operational difficulty. Future generations deserve to have this land, to experience the beauty the world has to offer, and we are discussing potentially opening the door to take that away.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet found in backcountry areas is not available anywhere near roads and human development. I have hiked and camped in many such places, and I know that feeling of time slowing down, that grounded, peaceful quality that simply does not exist where roads are found. Each backcountry location is incredibly unique in so many ways, and each one we have matters for that variety, for the ecosystems found there, and for ourselves and our children's children to be able to experience. The proposal before the agency would put all of that at risk, and the agency's own record makes a poor case for doing so. Start with fire. The agency's own findings state that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nevertheless justifies rescission partly on wildfire and fuels management grounds. The agency needs to explain, in plain terms, why this proposal departs from its own prior findings on fire occurrence, and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold up either. The record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Those are small numbers to set against significant permanent losses. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. Meanwhile, the road system the agency would expand already carries a $6.9 billion maintenance backlog. How does an action whose own analysis cannot demonstrate a net positive outcome justify enlarging that liability? The agency has also been down this road before. The record quotes the agency itself expressing dissatisfaction with the Roadless Rule and rejecting its "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That dissatisfaction led to a state-by-state replacement, and the Ninth Circuit struck it down. The proposal moves in the same direction again. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and it must explain how this proposal avoids the specific legal deficiencies identified the last time it tried to substitute state processes for one national rule. Finally, the existing rule already accommodates a range of management needs. It "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The exceptions for public health and safety, existing mineral leases, and community wildfire protection are already in the text. The agency claims administrative burden justifies rescission, but it has not shown which specific burdens those exceptions fail to address. It should identify them, by category, and quantify them before going further. The places I am writing about are irreplaceable. That variety of ecosystems, that quiet, that slow-down feeling, once a road cuts through it, it does not come back. The agency has not made a factual, legal, or economic case sufficient to justify this rescission, and I urge it to withdraw it. Kristen Portland, Oregon

I strongly object to rescinding the 2001 Roadless Area Conservation Rule by removing and reserving 36 CFR part 294, subpart B. DO NOT MAKE THIS CHANGE

Re: RIN 0596-AD66; Docket FS-2025-0001 — Roadless Area Conservation To the U.S. Dept. of Agriculture and U.S. Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and request that USDA select the No Action Alternative and retain the Rule. If changes are necessary to address wildfire, forest health, or unusual local conditions, USDA should adopt targeted amendments rather than eliminate the nationwide conservation framework. USDA argues that rescission would provide greater local flexibility. Local conditions certainly matter, but local decision-making and national minimum protections are not mutually exclusive. The Roadless Rule establishes a conservation baseline while already allowing exceptions. USDA should identify specific situations in which those exceptions are inadequate and address those problems directly. Road construction and fiscal responsibility-USDA's analysis states that approximately 18.2 million acres of affected inventoried roadless areas are covered by existing plans that could allow permanent road construction following rescission. At the same time, the Forest Service has a $6.9 billion deferred-maintenance backlog for existing roads and bridges. Before making millions of additional acres potentially available for roads, USDA should fully consider the long-term costs of constructing, maintaining, repairing, monitoring, and eventually decommissioning them. Forest Service research also documents hydrological, ecological, aquatic-habitat, wildlife, biodiversity, and other effects associated with forest roads. Wildfire-I recognize the need to reduce wildfire risk and protect communities. However, USDA has not demonstrated that complete rescission is necessary to accomplish these objectives. The proposal itself acknowledges that increased public access can increase human-caused wildfire ignition. Where a community, watershed, or infrastructure faces a demonstrated wildfire threat that cannot reasonably be addressed under the existing Rule, USDA should create a narrowly tailored exception. Roads genuinely necessary for community protection or ecological restoration should be distinguished from roads facilitating commercial timber harvest, mining, energy development, or other resource extraction. Forest plans are not an equivalent replacement-Individual forest plans do not provide the same consistent national protection as the Roadless Rule. USDA acknowledges that plans may later be amended, potentially allowing additional roads and timber harvest. Rescission therefore replaces a national conservation standard with protections that can vary by forest and change over time. It also shifts the burden to citizens, Tribes, communities, and other interested parties to repeatedly participate in forest-plan amendments and individual project decisions to protect areas currently covered by a national rule. Roadless lands have multiple values-Roadless areas should not be evaluated primarily according to resources that might be extracted from them. They provide watersheds, wildlife habitat, biodiversity, hunting and fishing, recreation, scenic landscapes, cultural resources, carbon storage, scientific value, and opportunities for quiet and remote recreation. Once roads fragment an intact landscape, restoring its previous roadless character can be difficult, expensive, or impossible. The potential permanent loss of these values deserves substantial weight. Tribal concerns-USDA reports that the majority sentiment among Tribal governments consulted was opposition to rescission. Concerns included sacred sites, gathering areas, water quality, subsistence resources, cultural survival, ancestral homelands, and the burden of repeatedly participating in project-level reviews. These concerns demonstrate a significant problem with replacing national protection with project-by-project decision-making. USDA should give substantial weight to Tribal consultation before making such a consequential change. A better alternative-I urge USDA to retain the 2001 Roadless Rule while addressing demonstrated management problems through targeted amendments. Any new exception should require a showing that road construction is necessary and that a less environmentally damaging alternative is not reasonably available. USDA should also fully account for lifecycle road costs and preserve national protections for watersheds, wildlife, biodiversity, cultural resources, Tribal interests, and remote recreation. A national conservation standard and responsible local forest management can coexist. Where the Rule creates a demonstrated obstacle to necessary management, USDA should address that specific problem rather than rescind nationwide protections covering millions of acres. For these reasons, I respectfully request that USDA withdraw the proposed rescission of 36 CFR Part 294, Subpart B and retain the 2001 Roadless Area Conservation Rule. Thank you for considering my comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I live in North Carolina, have family property near the Horse Heaven roadles area in Virginia and travel extensively each year in the western states, I spend many weeks each year moving through this country on foot, by canoe, and by paddle, buying gas, eating at local restaurants, sleeping in local lodging. These roadless areas are not abstractions to me. I am also an engineering geologist, and I have built roads into new terrain. I know what that work costs and what it leaves behind. I have seen many debris flows, some of which have killed people, that were initiated at a dirt road built in a mountainous area. I have paddled extensively in Idaho, Utah, Oregon, Virginia and North Carolina. Construction in these areas leads to substantial siltation of rivers. I see firsthand the damage done to rivers by debris flows that start at excavated and disturbed roadways. Virginia alone holds 64 inventoried roadless areas totaling 393,682 acres. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. I have also worked on water supply dams, and I see the struggles that water treatment plants face when treating sediment-laden water from construction and debris flow runoff. New roads can substantially increase the money spent on filtering and cleaning drinking water. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I ask that the agency explain in detail how it weighed this sediment loading against the drinking water supply function these watersheds perform, and how it accounts for the cost that burden shifts onto water utilities and ratepayers. The economic case for rescission does not hold together. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." As an engineering geologist who has been involved firsthand in building roads into new areas, I can say plainly: the initial cost is enormous and maintenance is an ongoing and costly outlay of funds. The agency is already carrying a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. I ask that the agency reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system it cannot already maintain. The rule the agency proposes to rescind already permits what the agency claims it cannot do. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The proposal justifies rescission partly on permitting and administrative burden grounds. The agency must identify which specific burdens are not already addressed by those existing exceptions and quantify them with precision. The agency's regulatory flexibility analysis is not credible. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The local outfitters, guides and tour operators who hold permits in the affected areas are not protected by spreading an aggregate loss across every small firm in the sector nationally. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, this comment is itself a reliance interest the agency invited and then failed to weigh. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." I, like most Americans, want to leave a legacy for my child and her cousins and all their descendants. There is not much land to save, and most of this is land that is particularly difficult to develop. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Let's leave it better than we found it for our kids. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Gary Rogers Greensboro, NC

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The garden I keep is deliberately wild and messy, a patch set aside for pollinators and wild birds, because I watch the numbers decline every year and I understand what that loss means. No bees, no food. It is that simple, and it is that serious. I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The bird communities that depend on unroaded forest are among the things this proposal would most directly harm. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Roads do not merely open ground for timber; they alter the acoustic and ecological conditions that make forest habitat functional for wildlife. A logged stand grows back. A road, once cut, does not. The agency must explain how it weighed these documented effects on bird communities against whatever benefit it claims to achieve, and that explanation must be specific enough to be tested. The proposal's treatment of drinking water is not adequate. The agency's own environmental review states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." That sentence quantifies the stakes and then leaves them unaddressed. The DEIS gestures toward forest plans as a substitute for the rule's protections without identifying a single enforceable provision in any of those plans that is equivalent to what would be rescinded. Water is life, and protecting watersheds from timber-related sediment is imperative. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. The sediment question goes deeper than that general failure. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number appears in the document and then nothing follows it. There is no projection of how much sediment would reach the more than 7,000 municipal intakes downstream once roadless protections are removed. The agency must quantify projected sediment delivery to those intakes before it acts. The maintenance problem makes the road-building logic harder still to follow. The agency's own analysis states: "Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance." The same document proposes opening these areas to new road construction. I work hard to pay my taxes, and when I see those dollars directed toward actions that benefit the wealthy and connected while degrading resources that belong to every American, it matters to me. Adding road mileage to a system the agency itself says is undermaintained, and then citing that maintenance failure as a cause of water quality harm, is a contradiction the record does not resolve. The agency should reconcile the proposed increase in road mileage with the maintenance shortfall its own analysis identifies as a water quality cause. Finally, the alternatives analysis fails on its face. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose statement written entirely around deregulation forecloses the comparison that environmental review exists to produce. The agency held more than 600 public meetings and received more than a million and a half comments before writing the rule it now proposes to undo. It has held none to undo it. I want my son and his family and future children to inherit a world with wildlife, water, and clean air. The agency must restate the purpose and need in terms of actual forest conditions and analyse at least one fully protective alternative before this proceeding goes further. Sincerely, Jennifer Wei Belmont, NC

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain the protections in 36 CFR part 294, subpart B. I am a birder, photographer, and outdoor guide in northern Arizona. Natural quiet is an essential part of why I spend time outdoors. Being able to hear and identify birds by their calls is central to my experience, and I already encounter places where ATV and other motorized noise makes that difficult. It is becoming increasingly hard to find outdoor spaces where natural sounds are the dominant sounds. My concern extends beyond my own enjoyment. Wildlife depends on sound to communicate, detect threats, and navigate its surroundings. The National Park Service has documented how human noise can interfere with wildlife communication and behavior. Natural soundscapes deserve meaningful protection as part of a healthy ecosystem. Although this proposal does not itself authorize a particular road or ATV route, removing national roadless protections would create opportunities for future road construction and associated disturbance. Roads can fragment habitat, damage vegetation, compact soil, and contribute to erosion and sediment entering waterways. Those consequences need to be considered alongside any claimed benefits of increased access. I support thoughtful access to public lands, including access for people with disabilities. But access should be carefully planned around ecological limits and the qualities that make a place worth visiting. More roads are not automatically a public benefit. Birders, hikers, photographers, and others also need places where they can experience wildlife and natural quiet. The proposal’s own discussion of recreation acknowledges that expanded road access could reduce opportunities for quiet, remote recreation and create conflicts among users. Please give those losses meaningful weight in the environmental and economic analyses. Quiet recreation and intact landscapes have lasting value, even when that value is difficult to express in dollars. I am also concerned about adding roads when the proposal identifies an existing $6.9 billion deferred maintenance backlog for roads and bridges. Before removing these protections, the agency should fully evaluate the long-term costs of road maintenance, enforcement, restoration, and damage to soil and water. I recognize the importance of wildfire preparedness and protecting communities. Those needs should be addressed through carefully justified, targeted measures. I ask the Forest Service to explain why existing exceptions and less damaging alternatives cannot meet specific management needs while retaining national roadless protections. Please retain the 2001 Roadless Rule and strengthen the analysis of cumulative impacts on natural soundscapes, birds and other wildlife, habitat connectivity, water quality, and quiet recreation. Future generations deserve opportunities to experience public lands where they can hear birds, wind, and water without persistent motorized noise.

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain 36 CFR Part 294, Subpart B and select the no-action alternative. I live in South Lake Tahoe and spend a significant amount of my time hiking, backpacking and recreating on National Forest lands. Protecting the undeveloped character of these landscapes is incredibly important to me, both personally and as a member of a community whose quality of life and economy are closely connected to our surrounding public lands. I understand the need for active forest management and wildfire-risk reduction, especially living in the Sierra Nevada. However, I do not believe that requires eliminating the nationwide protections of the Roadless Rule. The existing rule already contains exceptions that allow necessary management for public safety, forest health and other legitimate purposes. Repealing the rule would remove an important national safeguard against new permanent roads, habitat fragmentation and development in some of our remaining undeveloped National Forest lands. Once these areas are roaded and fragmented, their roadless character is extremely difficult to restore.

The following comment refers to Special Areas; Roadless Area Conservation at 91 FR 53827. This commentary is in oppostion of rescinding the 2001 Roadless Area Conservation Rule by removing and reserving 36 CFR part 294, subpart B. The 2001 Roadless Area Conservation Rule represents one of the most significant conservation achievements in American history, and its protection should be maintained in full. Roadless areas are among the last remaining intact forest ecosystems in the contiguous United States. They provide clean drinking water to approximately 60 million Americans, serving as natural filtration systems whose value no engineered alternative could replicate at comparable cost. They provide critical habitat for hundreds of threatened and endangered species, including grizzly bears, wolves, and bull trout, whose survival depends on large, connected wilderness corridors that roads fragment irreparably. They store carbon at rates that make them meaningful contributors to climate mitigation — a function that, once destroyed by road construction, requires decades to restore and in many cases cannot be restored at all. The economic argument for the Roadless Rule is as strong as the ecological one. Intact forests generate substantial and sustained economic returns through recreation, tourism, hunting, and fishing — industries that depend on the very wildness that road construction eliminates. A 2023 analysis found that outdoor recreation contributes over $780 billion annually to the US economy. The communities adjacent to roadless areas benefit disproportionately from this economy, and they are disproportionately harmed when extraction-driven road building degrades the landscapes that draw visitors and support local businesses. The argument that roadless protections foreclose economic opportunity misreads the evidence. The timber and mineral resources accessible only through new road construction in currently roadless areas represent marginal economic returns compared to the sustained, renewable economic value of intact ecosystems — while imposing permanent, irreversible costs: erosion, watershed damage, wildlife displacement, and the loss of the solitude and wildness that no restored landscape fully recovers. Roads, once built, are permanent interventions. The Roadless Rule preserves optionality — future generations retain the choice of what to do with these lands. Removing the rule eliminates that choice permanently, in exchange for short-term extraction value that accrues to few and at cost to many. The Roadless Rule should be maintained, strengthened where possible, and treated as the settled conservation consensus it has become over more than two decades of bipartisan public support.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests and parks of this country are worth defending. I hike and camp in U.S. parks and forests specifically to take time with the beauty these areas have to offer. The wildlife filling them is irreplaceable. This letter opposes the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The agency's own record undermines the wildfire rationale it offers for rescission. The draft environmental impact statement states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Opening roadless areas to road construction does not reduce fire risk by the agency's own prior findings. It increases the likelihood of human-caused ignitions. The DEIS Table 21 data, by the agency's own account, shows far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain in this proceeding why the proposal departs from these findings and how it reconciles the rescission with that ignition data. The agency also says the rule imposes permitting and administrative burdens that justify eliminating it. But the rule already accommodates a range of management needs. As the agency's own materials describe, it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Existing exceptions also address mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside these provisions. It has not quantified those burdens anywhere in the record. The agency must identify, precisely and with supporting data, which claimed burdens the rule's current exceptions do not already resolve. The regulatory flexibility analysis accompanying this proposal reaches a conclusion that the record cannot support. The proposed rule certifies no significant impact on small entities, yet, as the agency's own materials state, "the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification rests on spreading a $9 million annual expenditure loss across every small firm in the relevant sector nationally, rather than examining the outfitters, guides and tour operators who actually hold permits in the affected areas. The analysis concedes some of those firms may lose those receipts entirely. Averaging across a national population of firms that have no stake in these specific areas produces a number that obscures real harm to real permit holders. The agency should withdraw the certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas, not a national average that dilutes and hides their exposure. Finally, the agency solicits comment on reliance interests. The proposed rule asks for "any reliance interests in the current rule that could be affected by this proposal" at 91 FR 53830-31, and the Cost Benefit Analysis weighs none. I hike and camp in these forests in part because the Roadless Rule has provided a stable protection for the lands and wildlife I go there to find. The wildlife in these areas is irreplaceable, as I stated. That is a reliance interest. The rule has been in place long enough that people like me have organized our expectations around it. An agency that changes course is required to identify and weigh the reliance interests its prior policy created, not simply solicit them and then ignore them in the analysis. This comment constitutes such an interest. The agency must identify and genuinely weigh the reliance interests expressed in the comments it receives, including this one, before any final action is taken. Sincerely, Kristen N Allegheny County, PA

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in Wenatchee, Washington, below the Okanogan-Wenatchee National Forest. I hold a Ph.D. in geoscience from the University of Wisconsin–Madison, I make documentary films about earth science, and I’m an avid outdoorsman on this beautiful country’s public land. The wildfire rationale conflicts with the Department's own analysis. The Department gives rising wildfire risk as the main reason for rescission. Yet the draft EIS for this proposal states that "road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions." A study published in Fire Ecology on January 29 of this year looked at federal wildfire records from 1992 through 2024. It found that areas within 50 meters of a forest road were as much as four times more likely than roadless areas to see ignitions, and the result held in every Forest Service region. Allowing new roads into the areas that now have the fewest roads would add ignition sources to them. The final EIS should explain how rescission reduces wildfire risk given what the draft already concedes about roads and ignitions. The 2001 rule already allows fuel reduction. Under 36 CFR 294.13(b)(1)(ii), generally small-diameter timber may be cut in inventoried roadless areas to reduce the risk of uncharacteristic wildfire effects. The Department has not shown why that exception is inadequate, or why removing the rule entirely is necessary to get the fuel work it describes. The agency cannot maintain the roads it already has. By the Forest Service's own reporting, its system of roughly 380,000 miles of roads carries a deferred maintenance backlog measured in billions of dollars. Adding road mileage to a system the agency already cannot afford to maintain is not sound stewardship. The final rule should explain how new roads would be funded and maintained. Roads are a major source of human-caused sediment in mountain watersheds. The Forest Service's own research on forest roads has documented this for decades. Road cuts, fills and stream crossings deliver fine sediment to channels, and that sediment fills the spawning gravels and cold-water refugia fish depend on. In the Wenatchee and upper Columbia basins those fish include ESA-listed spring Chinook, steelhead and bull trout. Public money is already being spent to recover those populations, and roadless headwaters are among the last places their habitat still works as it should. Opening those headwaters to road building would undercut that investment. The fish downstream are already federally protected. The roadless headwaters of the upper Columbia drain into rivers that hold Upper Columbia spring Chinook, listed as endangered in 1999; Upper Columbia steelhead, listed under the Endangered Species Act; and upper Columbia bull trout, listed as threatened in 1998. Before finalizing any rescission, the Department should analyze, watershed by watershed, how new road construction in these basins would affect listed fish and the recovery efforts already underway. The public process does not match the scale of the action. The 2001 rule followed more than 600 public meetings and drew about 1.6 million public comments, more than any other rule in the nation's history at the time. This proposal would remove those protections from 44.7 million acres. A 30-day comment period with a 15-day extension is not enough for the public to review a draft EIS and cost-benefit analysis of that size. I urge the Department to withdraw the proposed rule and keep the 2001 Roadless Area Conservation Rule in place. Ethan C. Parrish, Ph.D.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas around Mt. Rose have been part of my life for 35 years. I have hiked with others and camped in or near Rose - Galena, Rose - Whites Canyon, Rose - Summit, and the Mt. Rose roadless area in the Lake Tahoe Basin Management Unit. I have paddled Lake Tahoe, a world-renowned treasure, and I have been privileged to spot the quite unique band-tailed pigeon in these mountains, along with grouse and other upland species. These places, the Galena drainage, White's Creek drainage, and the Mt. Rose summit country, make northwest Nevada unique. They draw millions of outdoor lovers now, an economic force that was a trickle when I moved here and is a major driver today. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. We have already seen wildfire in the Toiyabe up close, human caused as the population grows. The agency's own data on fire should stop this proposal The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal offers wildfire management as a justification for rescission, while the agency's own draft environmental impact statement records the opposite. The Humboldt-Toiyabe is the largest national forest in the lower 48, scattered across mountain ranges rising from the Great Basin desert, each roadless range a sky island with its own ecology, its own water, its own wildlife. Roads into that terrain, according to the agency's own finding, multiply the chance of ignition. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and to reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside these roadless areas. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. A federal appellate court already answered that question. Exercising its jurisdiction, the Tenth Circuit stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the rule was within the authority Congress granted and did not create de facto wilderness. The agency has not explained what has changed in the law since that ruling. I ask the agency to address the Tenth Circuit's holding and explain the legal basis for any contrary position it now takes. The rule already permits what the agency says it cannot do. The agency's own description states: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The proposal cites permitting and administrative burden as reasons to rescind the rule entirely, but the rule as written already carves out exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific burdens fall outside those exceptions. Nevada holds 316 inventoried roadless areas totaling 3,186,206 acres, and the Humboldt-Toiyabe alone holds 354 inventoried roadless areas totaling 3,383,849 acres. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Runoff into the Truckee from logging in the basin would be a disaster, and clean water from these drainages is not a burden, it is the point. The agency must identify, with specificity and on the record, which burdens are not already addressed by the rule's existing exceptions. Finally, the agency certified no significant impact on small entities while its own Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year and its own DEIS names outfitters, guides, and tour operators as affected parties. . That is not a regulatory flexibility analysis; it is an averaging exercise designed to obscure the real harm. Much of the U.S. is still scarred by logging for the benefit of a few, while the many who depend on intact forests for their livelihoods and their lives are left with the damage. The agency should withdraw the certification and assess the actual impact on the small businesses operating within the potentially affected roadless areas. Sincerely, Susan Juetten Carson City, Nevada

October 6, 2026 I am writing to express my continued opposition to repeal of the U.S. Forest Service’s Roadless Area rule (36 C.F.R. pt. 294). As a law professor specializing in natural resources and public land law, my views on this matter are based on more than 40 years researching, writing, and teaching about America’s public lands, including national forest history, policy, and law. The roadless rule has served the nation well since its adoption in 2001. It has not seriously hindered timber production on the national forests; rather the decline in timber production is due to numerous other factors, including mill closures, overriding ecological concerns, and less costly alternative timber sources. By all accounts, there is little commercially viable timber that is readily accessible on the roadless lands, which are generally in remote, higher elevation, and often steep terrain. In fact, significant amounts of commercially viable national forest timber remain available on the existing, lower elevation national forest lands that are managed for multiple-use purposes. Opening the roadless national forest lands will do little to address the growing wildfire risk. In fact, research shows that the presence of roads is a frequent factor in human-caused fire ignitions in forests. Most roadless acreage is remote and not proximate to the Wildland Urban Interface (WUI) zone, so there is little need to undertake hazardous fuel reduction projects on existing roadless lands. Given current budget cuts and personnel reductions, the Forest Service simply does not have the capacity to meaningfully extend its fuel reduction work onto roadless lands. Besides, the Roadless Area rule contains exceptions that would allow necessary hazardous fuel reduction projects to proceed near WUI zones. The roadless areas were initially set aside to address watershed protection and wildlife conservation, and to provide diverse recreational opportunities. By any measure, this has proven a success, meeting these important Forest Service multiple use statutory objectives. Rescinding the Roadless Area rule will adversely impact these important resource uses with little gain, as recognized in the explanatory material accompanying the Federal Register notice, i.e., the acknowledgment that few roads, timber sales, or energy projects are likely to be constructed on the roadless lands. Further, existing and accessible Forest Service roads provide those interested in motorized and off road vehicle recreation adequate opportunities to pursue these recreational activities. There is simply no compelling legal, policy, or practical reason to rescind the rule and to put watershed, wildlife, and recreation uses and values at risk. There is little doubt that the construction of roads, timber sales, and energy projects will divert Forest Service resources from other multiple use purposes at a time when the agency is facing severe budget cuts and workforce reductions. Given the number of public comments on the rule recission proposal, it is clear that the public does not support this change in agency policy. Because state, local, and tribal governments enjoy a special privileged status regarding participation in forest management decisions, including proposals for exceptions to the roadless rule, the local decision-making rationale for revising the rule is neither necessary or compelling. Moreover, the clear direction of Forest Service policy during the past 30 years has been toward conservation rather than the production of commodities that often negatively impacts ecological integrity. And should the agency rescind the rule, that decision will undoubtedly be challenged in court, as will most road building, timber harvesting, and other development decisions affecting roadless lands, putting a costly and unnecessary burden on the agency. All of which can and should be avoided by not rescinding the roadless rule in this time of budgetary pressures, workforce reductions, and political divisiveness. In short, the proffered rationale for rescinding the roadless rule is far outweighed by the myriad benefits derived from the existing rule and the costs that will attach to its recission, which would not significantly benefit the national forests or the nation. Thank you for considering my professional and personal views on this matter, which do not necessarily reflect the views of my employer. Robert B. Keiter Wallace Stegner Professor of Law University Distinguished Professor University of Utah S.J. Quinney College of Law Salt Lake City, UT 84112

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and the removal of protections under 36 CFR part 294, subpart B. As a San Diego resident who values hiking, wildlife, and public lands, I want our national forests protected for future generations. The Trump administration’s push to eliminate these safeguards puts irreplaceable public resources at risk. Describing conservation protections as a “regulatory burden” fails to recognize their public value. USDA should fully evaluate the potential consequences of expanded road construction and timber harvesting, including habitat fragmentation, erosion, water quality degradation, loss of carbon storage, and damage to outdoor recreation. The analysis should also account for the long-term taxpayer costs of maintaining additional roads and restoring disturbed landscapes. I support effective wildfire prevention and responsible forest management. However, USDA should demonstrate why existing management tools and exceptions are insufficient before eliminating nationwide protections. Claims of greater flexibility should be supported by evidence showing that rescission would improve public safety without sacrificing conservation. National forests belong to the American people. Their future should reflect long-term stewardship, meaningful Tribal consultation, and public participation. I urge USDA to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule. Once intact forests are fragmented, the damage can last far beyond any administration.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Pemigewasset Wilderness has been part of my family across three generations. I have gone since I was born, and it is meaningful to me, my parents, and my grandparents. Losing its purity would be a loss to family memory and to land I hope to share in an untouched form with my future kids. That is why I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and ask the agency to address each of the following points in its final record. The White Mountain National Forest holds 16 inventoried roadless areas totaling 240,669 acres, including the Pemigewasset Wilderness, whose headwaters feed rivers running to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region alone, 286 municipal water intakes sit in watersheds containing affected roadless areas. The New England mountains were clearcut once before, and the damage was so severe that Congress passed the Weeks Act of 1911 specifically to authorize federal purchase and recovery of those lands. These places, home to moose, black bear, brook trout, and Canada lynx, recovered under protection. The economic case for rescission does not hold together. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a spread so wide it cannot establish a net benefit. Meanwhile the agency already carries a $6.9 billion maintenance backlog on roads it cannot afford to keep, against a road budget of roughly $73 million a year. I think it makes no sense to increase roads that we need to use taxpayer dollars to maintain. This is a terrible and poorly analyzed plan, and reducing long-term spending means doing it pragmatically, not expanding infrastructure the agency cannot sustain. I ask that the agency reconcile the proposal with these figures and explain how an action whose own analysis cannot demonstrate a net benefit justifies adding to a road system already buckling under deferred maintenance. The proposal argues that state-by-state approaches can replace a national rule. The agency's record itself states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed exactly that state-by-state alternative and found it deficient. I ask that the agency address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time a national rule was replaced with a state-by-state approach. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The court that examined that question reached a different conclusion. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the record a direct explanation of any contrary legal position it intends to rely on. Finally, the proposal cites permitting and administrative burden as justifications for rescission. The rule as written already provides that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Additional exceptions address existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside those existing provisions. It should do so, with quantification, before any further action on this proposal. Public land should be managed for long-term value to the country and its people. The Pemigewasset Wilderness represents exactly that kind of value, accumulated across generations and irreplaceable once a road goes in. I ask the agency to answer each of these points in the record before it proceeds. Sincerely, Calvin Kinghorn San Francisco, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The backcountry trails of the Lake Tahoe Basin are where I go to find native wildflowers, and that landscape, its water, its clarity, its living detail, is what this comment is about. Rescinding the Roadless Area Conservation Rule puts every element of that place at risk, and I am asking the agency to answer, concretely and on the record, for each contradiction its own documents expose. The agency has framed rescission partly as a wildfire management tool. Its own analysis says the opposite. The agency's record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The Tahoe forest sits in exactly the high-risk category this language describes. Opening roadless areas to road construction there would, by the agency's own reasoning, increase ignition risk rather than reduce it. I ask that the agency explain why this proposal departs from those prior findings, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency also cites permitting burden as justification. Yet the rule as written already accommodates the work the agency claims is being blocked. It states that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the existing exceptions for public health, safety and reserved rights are insufficient, the agency has not demonstrated where or why. I ask that it identify, with specificity, which burdens are not already addressed by those exceptions, and that it quantify them rather than assert them. Water is not an abstraction in Lake Tahoe. The lake itself is the region's foremost attraction, and the quality of tap water in the surrounding communities is something residents and visitors alike depend on and take pride in. Destruction to that watershed would not only affect drinking water for everyone living and traveling here; it would damage the very thing that makes this place what it is, the lake, its famous clarity, the reason tourism exists at all. The agency's own analysis acknowledges that roads and their associated facilities can produce up to ninety percent of the sediment from a timber sale operation. In a basin where water quality defines the economy and the ecology both, that figure cannot be treated as acceptable collateral. I ask that the agency address, directly and with specific reference to the Tahoe watershed, what sediment and runoff consequences it foresees and how those consequences were weighed. The regulatory flexibility certification accompanying this proposal is also internally inconsistent. The agency's own language exposes it: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The method used to reach that certification distributes an aggregate expenditure loss across every small firm in the sector nationwide, which obscures what happens to the outfitters and guides who actually hold permits in areas like the Tahoe forest. The native wildflower photography I do in these backcountry corridors depends on the same access infrastructure that those permit holders provide and protect. The certification should be withdrawn and replaced with an assessment of the small entities that are actually operating in the affected roadless areas. Finally, the agency has placed foreseeable consequences beyond the scope of its analysis while simultaneously asking the public to comment on them. Its own language makes this plain: "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." That is not a coherent process. A decision of this scope requires that the agency analyze the foreseeable plan-amendment scenario, including expanded timber harvest, as part of this action, not as something future administrators will address without today's public input. I oppose rescission of the Roadless Area Conservation Rule and ask the agency to respond substantively to each of the points above before any final action is taken. Sincerely, Emilie Comer Tahoma, CA

Please DO NOT rescind the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B!!!!!!!!!!!!!!!!!!!!!!!!!!!!! This is a terrible idea that will lead to wholesale destruction and development of millions of acres of wilderness, destroying ecosystems and critical habitat for plants and animals for whom that landscape is HOME. It's not a negotiable commodity subject to prerogative management, it is their food and shelter and their survival depends upon keeping it intact. Furthermore, research shows that increased roads and human accessed areas actually INCREASES wildfire risk, as the vast majority of wildfires are human caused. As someone who lives in an area increasingly ravaged by catastrophic fires, doing anything to heighten that risk is not only poor management, it's outright reckless and incompetent. I'm so tired of politicians and corportations seeing natural landscapes as something on a commodities balance sheet. Roadless places are not unused or empty, they are being used by the thousands of plants, animals, and insects that have called them home for eons longer than humans have even been around. The idea that we are somehow set apart from nature and do not rely on keeping this places intact is sheer hubris, ignorance, and arrogance. We destroy wild places to not only their peril, but our own. I vehemently oppose rescinding the Roadless Rule, as do the vast majority of Americans. Please do your job and represent OUR voices, not those of corporations who stand to profit from the destruction of some of the last remaining intact wild places we have.

See Attached File: As a South Dakota resident who enjoys using roadless areas, I oppose rescinding the 2001 Roadless Rule. My interest and passion come from experiencing these places. Their value to me includes solitude, viewing natural surroundings, and the opportunity to enjoy public land away from roads and vehicle traffic. Beyond my own personal enjoyment, it is also important to know that we are retaining large, intact landscapes and clean rivers and lakes. These roadless areas deserve consideration and respect. My comment concerns the proposed removal of the protections in 36 CFR Part 294, Subpart B, which restrict road construction, road reconstruction, and timber harvest in inventoried roadless areas, subject to exceptions. USDA proposes relying on individual forest planning and management decisions in place of these national protections. My personal concern is what that change would mean for wildlife, water quality, and landscapes that sustain the activities I enjoy and contribute to my community's economy. (USDA, proposed rule, 91 FR 53827, August 20, 2026.). When I choose a roadless area for fishing or hiking, the undeveloped setting is part of the reason I go. The Sand Creek Roadless Area in Wyoming is a wonderful example of a Roadless Area that my husband and I have explored multiple times. We are drawn to the roadless area for the amazing water quality that sustains an incredible fishery. My husband and I explored the Sand Creek area and found it to be a wonderfully peaceful and beautiful location that my husband and I enjoyed for hours, catching Brown Trout and then releasing them back to the water for others to enjoy. My background and career were in a science-based field, and with that background I am fully aware that a good fishery depends on healthy watersheds. Forest Service research identifies effects of roads on hydrology and aquatic habitat and emphasizes that those effects must be evaluated in their local environmental context. This supports examining individual watersheds rather than assuming that national estimates adequately describe the risks to places people fish. (Gucinski and others, Forest Roads: A Synthesis of Scientific Information, 2001, PNW-GTR-509.) I feel strongly that the NOI and DEIS fail to provide science-based rationale for rescinding a Rule that has been in place for nearly 25 years. A Rule, for example, that protected large intact landscapes for recovery of the Grizzly Bear in the Lower 48. For this reason and so many other reasons, the 2001 Roadless Rule must be retained! I recognize and encourage that where the USDA identifies a specific management problem, it should first evaluate whether existing exceptions or a narrowly tailored approach can address it while preserving roadless characteristics. Over my career in the USDA Forest Service (USDA), I gained a practical working knowledge of Forest Plans (programmatic) and NEPA (site-specific). I acknowledge that Forest Plans vary in age and thus protection for Roadless Areas if “The Rule” is rescinded. More importantly, the limitations referred to in the NOI and DEIS do not tell me whether the places I value would retain equivalent protection over time. The agency should explain what protections would remain; how it accounts for the loss of quiet recreation, how it impacts wildlife that are dependent on large intact landscapes, and how it may impact water quality and quantity. My fishing and hiking experiences have taught me that the character of a place matters as much as the ability to reach it. Once roads and development change that character, the experience may be difficult to recover. I urge USDA to retain the Roadless Rule, address demonstrated management needs through targeted approaches, and clearly disclose the local recreation and watershed consequences of any proposed change. Future generations should have the opportunity to enjoy these public lands as roadless places. le(s)