Read the comments.

Dear Chief: As an outdoor enthusiast, I am filing these comments to note that the proposed rescission of the 2001 Roadless Area Conservation Rule was not preceded by the kind of comprehensive public engagement that produced the original Rule — a disproportion that raises procedural concerns the Department should address before the proposed action is finalized. I believe in the protection and preservation of the beauty of Appalachian and all its natural resources. I’ve seen countless times where kowtowing to financial incentive or outside pressure has been detrimental to this region and its people. I love this region with all that I am. Allowing access for logging under the guise of “wildfire” protection is a joke. If people lose access to any part of this region because of construction or logging, then the fundamental rights of nature have been violated. Regarding the Bearwallow in the Pisgah National Forest, North Carolina: The Bearwallow IRA (4,113 acres) in Pisgah 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. Road construction impacts in the Bearwallow IRA (4,113 acres), Pisgah National Forest, depend on site-specific variables — slope, soil type, drainage patterns, habitat connectivity — that differ fundamentally from other roadless areas and demand individualized analysis under NEPA. The DEIS must provide site-specific NEPA analysis for the Bearwallow IRA (4,113 acres) in Pisgah National Forest, as required by 40 CFR 1502. A programmatic assessment of 2,332 roadless areas does not satisfy the requirement for analysis proportional to site-specific impacts. "Construction or maintenance of farm roads, forest roads, or temporary roads for moving mining equipment: Roads must be constructed and maintained in accordance with best management practices to assure that flow and circulation patterns and chemical and biological characteristics of waters of the U.S. are not impaired and that the reach of the waters of the U.S. is not reduced, and that any adverse effect on the aquatic environment are minimized. Road fill shall be bridged, culverted or designed to prevent the restriction of expected flood flows. The fill shall be properly stabilized and maintained during and following construction to prevent erosion. Construction and maintenance of crossing shall not disrupt the migration or other movement of aquatic life. The discharge shall not take, or jeopardize the continued existence of, a threatened or endangered species, or adversely modify or destroy the critical habitat of such species." — U.S. Army Corps of Engineers, Sacramento District The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. Faithfully, MacKenzie May

To the Roadless Rule Rulemaking Team: As someone who has made a practice of noticing what's actually present in a place, I'd say that what's present in roadless areas is time — accumulated, undisturbed time — and that's the thing you can't put back. This July we spent 5 days in the Bob Marshall wilderness on a trip that tested me and provided a solitude and wildness that deserves to be protected. It was a truly incredible experience of vast forests and rivers and mountains and wildlife and humans along side it all coexisting. Adding roads to an area like this would destroy the ecosystem and fragment one of the few remaining large wilderness areas we have left. The Department should understand that the Rule's rescission would produce real and lasting consequences — not only for the lands themselves, but for the people whose lives have been shaped by access to them. Regarding the Stony Mountain in the Bitterroot National Forest, Montana: NEPA requires analysis proportional to the significance of the proposed action. The Stony Mountain IRA (44,057 acres) in Bitterroot National Forest has unique watershed, habitat, and ecological characteristics that a programmatic EIS addressing 2,332 areas in aggregate does not and cannot analyze. The DEIS treats 2,332 inventoried roadless areas as interchangeable units for purposes of impact analysis, but the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest has distinct ecological conditions that produce site-specific impacts no programmatic document captures. The DEIS must provide site-specific NEPA analysis for the Stony Mountain IRA (44,057 acres) in Bitterroot National Forest, as required by 40 CFR 1502. A programmatic assessment of 2,332 roadless areas does not satisfy the requirement for analysis proportional to site-specific impacts. "Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. Activities in waters of the United States regulated under this program include fill for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports) and mining projects. Section 404 requires a permit before dredged or fill material may be discharged into waters of the United States, unless the activity is exempt from Section 404 regulation (e.g., certain farming and forestry activities). The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment or (2) the nation's waters would be significantly degraded." — U.S. Environmental Protection Agency The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Research - Wildlife Habitat” “Tongass roadless areas contain very large biomass and soil carbon stocks, underscoring old-growth protection as a critical climate solution with global significance. — Research - Climate Solutions” Rescission action is opposed; the Department is urged to allow the Rule to stand. With respect, Catherine

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

Dear Tom Schultz, I am a concerned citizen and I've spent my entire life in the shadow of the Gifford Pinchot and Mt. Hood National Forests. I am a graduate student and counselor-in-training (CIT), and offer this thoughtful research. As an activist and counselor-in-training, I believe it's my responsibility to disagree with any administration that seeks to rescind the Roadless Rule. Among many days in these forests, one has stayed with me. The very first hike I ever did as a kid was at Silver Star Mountain, and I'll never forget how the hills there roll with wildflowers. I remember drawing pictures of Indian paintbrush for weeks after. The Department is respectfully asked to deny the proposal to rescind the Rule and to preserve the protections that have kept these landscapes available to the public. Regarding the Silver Star in the Gifford Pinchot National Forest, Washington: NEPA requires analysis proportional to the significance of the proposed action. The Silver Star IRA (7,779 acres) in Gifford Pinchot National Forest has unique watershed, habitat, and ecological characteristics that a programmatic EIS addressing 2,332 areas in aggregate does not and cannot analyze. A programmatic EIS cannot evaluate the specific impacts of road construction on the particular watersheds, wildlife corridors, and ecological systems within the Silver Star IRA (7,779 acres), Gifford Pinchot National Forest. NEPA does not permit substituting generic, landscape-scale analysis for site-specific impact evaluation. The DEIS must include individualized analysis of the Silver Star IRA (7,779 acres), Gifford Pinchot 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. "Section 7(a)(2) of the ESA requires Federal agencies to consult with the United States Fish and Wildlife Service, NMFS, or both, to ensure that their actions are not likely to jeopardize the continued existence of endangered or threatened species or adversely modify or destroy their designated critical habitat. NMFS concludes that the proposed action is likely to jeopardize the continued existence of 16 ESA-listed anadromous fish species and Southern Resident killer whales, and it will result in the destruction or adverse modification of designated or proposed critical habitat for the 16 anadromous fish species. FEMA has not structured its proposed implementation of the NFIP in Oregon so that FEMA is positioned to know or reliably estimate the general and particular effects of the program on ESA-listed species or their designated critical habitat." — NOAA National Marine Fisheries Service “Klamath-Siskiyou case study mapped ~500 roadless areas and found roadless tracts bolster habitat representation and landscape connectivity, including smaller roadless patches. — Research - Biodiversity Conservation. Additonally, "Due to the proximity to the Portland-Vancouver metropolitan area, the Mountain Hemlock Zone...is expected to provide a both a high level and a wide range of human benefits, including timber production, high quality water, wildlife habitats, recreation opportunities ( especially skiing and backcountry recreation), special forest products such as huckleberries and mushrooms, and more." (Diaz, Nancy M., and United States. Forest Service. Pacific Northwest Region. 1997. Plant Association and Management Guide for the Mountain Hemlock Zone : Gifford Pinchot and Mt. Hood National Forests. : [Portland, Or.?] : U.S. Dept. of Agriculture, Forest Service, Pacific Northwest Region.)” The Rule has withstood sustained legal and political challenge; the Department should not undo that stability without adequate justification. With thanks, CommentID: RLC-20260825-815UIP

Dear Ms. Rollins: I'm a water user whose creek runs out of national forest land. The rule has been keeping the creek clear. Don't lift it. As a California central valley resident, I am concerned about how this ruling will impact the environment on local and national levels. I am concerned about how the proposed logging and drilling will severely effect our water, air, and land quality. The Department is urged to retain the Roadless Area Conservation Rule in recognition of the public interest that connections of this kind represent — an interest that rescission would permanently diminish. Regarding the Elk Creek in the Mendocino National Forest, California: NEPA requires analysis proportional to the significance of the proposed action. The Elk Creek IRA (23,182 acres) in Mendocino National Forest has unique watershed, habitat, and ecological characteristics that a programmatic EIS addressing 2,332 areas in aggregate does not and cannot analyze. Road construction impacts in the Elk Creek IRA (23,182 acres), Mendocino National Forest, depend on site-specific variables — slope, soil type, drainage patterns, habitat connectivity — that differ fundamentally from other roadless areas and demand individualized analysis under NEPA. The DEIS must provide site-specific NEPA analysis for the Elk Creek IRA (23,182 acres) in Mendocino National Forest, as required by 40 CFR 1502. A programmatic assessment of 2,332 roadless areas does not satisfy the requirement for analysis proportional to site-specific impacts. "When a party argues that an agency action was arbitrary and capricious due to a deficiency in an EIS, the reviewing court must account for the fact that NEPA is a purely procedural statute. Under NEPA, an agency's only obligation is to prepare an adequate report. Judicial review is typically conducted under the Administrative Procedure Act's deferential arbitrary-and-capricious standard. Under that standard, a court asks not whether it agrees with the agency decision, but rather only whether the agency action was reasonable and reasonably explained. Agencies must take a 'hard look' at the environmental consequences of their actions in the context of projects under consideration." — Supreme Court of the United States The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. 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. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. The Department is asked to close this rulemaking without rescinding the 2001 Roadless Area Conservation Rule. Sincerely, Kimberly Marquith CommentID: RLC-20260823-RQHHIX