Read the comments.

To the Roadless Rule Rulemaking Team: My name is Leah. I am commenting on behalf of out collective humanity, which is at risk of being completely degraded. We are of the forest and the forest is of us. The difference between the two is a manmade construct invented to justify what is the rape of our natural lands and ultimately ourselves. Opening up 45 million acres of forest to deforestation is a mistake which cannot be taken back. We must defend our humanity, our Earth, and the plants and animals which call it home. The White Mountain National forest is one of the most beautiful, biodiverse and spirtual place on the planet. There is nothing like looking out over hundreds of thousand of acres of undisturbed forest. Should the roadless rule be rescinded, no longer will you be able to see that. You will see clearcuts, roads machinery and development. I do not want to lose access to one of the only undisturbed places in New England. Regarding the Pemigewasset in the White Mountain National Forest, New Hampshire: Headwater Streams and Native Fish Passage — The area protects the headwaters of the East Branch of the Pemigewasset River and tributary systems including Franconia Branch, Zealand River, Nancy Brook, and Carrigain Brook—all classified as "Functioning Properly" under the USFS Watershed Condition Framework, indicating intact aquatic ecosystems. Wood Turtles (endangered, IUCN) and native fish species depend on unobstructed movement through these cold-water tributaries for spawning and refuge. The East Branch is identified in the Forest Plan as eligible for Wild & Scenic Rivers designation, reflecting its ecological and hydrological significance as a functioning headwater system. Species such as Monarch (G4), Northern Myotis (G2), Tricolored Bat (G3) already face climate-driven stress in White Mountain National Forest. The connected refugia between Pemigewasset and Cherry Mountain — 2 ecosystem types across ~35,985 acres — is their adaptive buffer. Road construction eliminates that buffer at precisely the time these species need it most. Under NEPA's cumulative effects mandate, the DEIS must evaluate how rescission affects the climate refugia network connecting Pemigewasset and Cherry Mountain in White Mountain National Forest. Analyzing 3 climate-threatened species and 2 shared ecosystem types area-by-area violates 40 CFR 1508.7 by ignoring the network-level impact. "Landscape connectivity of refugia is important to their effectiveness. Priority management actions for climate change refugia include: decommission roads; protect roadless headwaters; remove or modify barriers (culverts, dams); increase connectivity. Forest canopies and riparian corridors buffer against climate extremes and variability with consequences for both temperature and water balance. Managing climate change refugia for local persistence of valued resources gains time for systems to adapt and for managers and society to develop longer-term solutions." — PubMed Central (PMC), 2016 The Department asked the public to weigh in. The public is weighing in. Keep the Roadless Rule. Thank you, CommentID: RLC-20261003-0QABY6

Dear Chief Schultz: As someone who has gotten out on public land in all kinds of conditions and knows the difference a road makes — to noise, to use patterns, to what the land becomes — I'd urge the Department to hold this rule. Regarding the Arroyo Seco in the Angeles National Forest, California: Approximately 13,056 acres of shared ecosystem types — California Chaparral — connect Arroyo Seco and Magic Mountain across 15.4 miles in Angeles National Forest. This combined refugia footprint supports 7 climate-threatened species. Neither area alone provides sufficient refugia extent; the ecosystem network spanning both areas does. Road construction in Arroyo Seco degrades climate adaptation capacity not just within Arroyo Seco but across Magic Mountain as well. The 7 species shared between both IRAs lose access to the full 13,056-acre refugia network. The same is true in reverse: development in Magic Mountain diminishes the refugia value of Arroyo Seco. Under NEPA's cumulative effects mandate, the DEIS must evaluate how rescission affects the climate refugia network connecting Arroyo Seco and Magic Mountain in Angeles National Forest. Analyzing 7 climate-threatened species and 1 shared ecosystem types area-by-area violates 40 CFR 1508.7 by ignoring the network-level impact. "In an 18-year experimental study, connected plots showed rates of plant extinction decreased by 2 percent per year, and rates of plant colonization (new plant species coming in) increased by 5 percent per year over the duration of the study. The effects compound over time — plant biodiversity has increased by 14 percent over 18 years and is still going up. Connecting habitat fragments via corridors can not only stave off biodiversity loss, but also encourage biodiversity gain that compounds over time." — Save the Redwoods League, 2019 Failure to Substantively Respond to Content of Majority-Opposition Comments [challenge-008] The Notice of Intent section reduces overwhelming public opposition to a bare percentage, stating that "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support," without any accompanying discussion of what those commenters actually said. No substantive response section addressing the content categories raised — water quality, carbon storage, invasive species spread — appears associated with this passage. Independent research the agency should engage directly documents that roads cause "increased mortality from road construction," "spread of exotic species," and sediment delivery that is "long-lasting and cumulative and cannot be effectively mitigated" (Trombulak & Frissell 2000). Did the agency consider comments raising these documented mechanisms, and if so, where in the record is that consideration explained? Reducing majority opposition to a percentage without engaging its substance violates the requirement that agencies give reasoned consideration to public comment under Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978), and is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request a substantive, topic-by-topic response to the content of majority-opposition comments before this rescission is finalized. Failure to Address Confounding Causal Factors for Forest Health Decline [challenge-021] The Rationale for the Proposed Rule attributes forest health decline to the 2001 Rule's limits on active management, stating that the Rule "has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns" (pp. 18-19). This single-cause narrative ignores other well-documented drivers of the same trend, including decades of fire suppression policy, climate-driven drought and insect mortality, and wildland-urban interface development pressure that independently affect forest health regardless of roadless status. Nowhere in this section does the agency analyze or rule out these confounding factors, or explain why roadless designation, rather than these alternative causes, should bear responsibility for the observed conditions. Under State Farm, 463 U.S. at 43, an agency cannot ignore an important aspect of the problem, and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), requires reasoned engagement with contrary explanations. I request that the agency add an express analysis distinguishing roadless-attributable effects from these confounding causes, consistent with APA 5 U.S.C. § 706(2)(A). Rescission should not be finalized; the Roadless Area Conservation Rule should remain effective. Hopefully, CommentID: RLC-20260904-W5VTDL

To the Department of Agriculture: For someone who plans trips around what public land hasn't been developed, the 2001 Rule isn't background policy — it's a load-bearing part of how I think about where it's still worth going. I live and recreate in Utah. Bears ears, uinta mountains, so much area is protected now and I don't want oil companies drilling on this land, roads being built on this land. Money can't replace native species, native/historical dinosaur foot prints, rock art. Wild fires are made worse by roads. Native habitat, reintroduction of species like beavers and fish help restore the environment One visit made that connection concrete. I've camped in the uinta mountains for 20+ years. There are multitudes of alpine lakes that you can't drive to, you have to hike to. The lakes you can drive to have become so crowded, filling up with reservations a year in advance. The considerations above inform the position set out in the remainder of this comment. Regarding the 418040 in the Uinta National Forest, Utah: Under 40 CFR 1508.7, the ecological connection between 418040 and 418006 (11,714 acres, 23.5 miles apart) in Uinta National Forest constitutes a cumulative effects relationship. 14 species move between these IRAs, including imperiled species: Suckley's Cuckoo Bumble Bee (G2). Analyzing either area without reference to the other violates NEPA's cumulative impact mandate. The 23.5-mile corridor between 418040 and 418006 sustains gene flow for 14 species, including Suckley's Cuckoo Bumble Bee (G2). Road construction in either IRA severs this exchange, isolating populations that depend on movement between areas for genetic diversity and recolonization after local disturbance. Analyzing 418040 in isolation ignores the 14 species it shares with 418006 (11,714 acres, 23.5 miles away) in Uinta National Forest. Analyzing 418006 in isolation makes the same error in reverse. The DEIS must assess the connected system because fragmentation impacts are invisible at the single-area scale. "One of the most severe consequences of habitat loss due to road construction is the creation of isolated pockets of habitat that cannot support viable populations in the long term. Reductions in the range of species may decrease probability of their successful movement between habitat patches, which affects gene flow. Genetic theory suggests that the reduction of gene flow between subpopulations may lead to greater inbreeding and loss of genetic diversity within fragments, the raw material that allows populations to evolve in response to environmental changes." — Corlatti et al. 2009, Conservation Biology, 2009 “One of the most severe consequences of habitat loss due to road construction is the creation of isolated pockets of habitat that cannot support viable populations in the long term. Reductions in the range of species may decrease probability of their successful movement between habitat patches, which affects gene flow. Genetic theory suggests that the reduction of gene flow between subpopulations may lead to greater inbreeding and loss of genetic diversity within fragments, the raw material that allows populations to evolve in response to environmental changes. — Corlatti et al. 2009, Conservation Biology, 2009 (https://doi.org/10.1111/j.1523-1739.2008.01162.x)” “Researchers have concluded that wildlife corridors increase movement between habitat patches by approximately 50%, compared to patches that are not connected by corridors. Linking protected areas, such as national parks and wilderness areas, as well as other crucial habitats, ensures larger, cohesive landscapes of high biological integrity that allow for the migration, movement, and dispersal of wildlife and plants. — Center for Large Landscape Conservation (citing Gilbert-Norton et al. 2010), 2010 (https://doi.org/10.1111/j.1523-1739.2009.01405.x)” The proposed rescission lacks the factual and legal basis necessary to satisfy APA requirements; the Rule should remain in place. Respectfully, CommentID: RLC-20260901-Y7FPYW

Dear Chief: The accumulation of time spent in areas currently protected under the 2001 Roadless Area Conservation Rule has shown me, as an outdoor enthusiast, that there is no administrative substitute for the Rule's categorical protection — forest planning, project-level NEPA review, and management prescriptions have all proven insufficient to prevent road encroachment absent a rule of this kind. The spaces in NH and beyond protected by the roadless rule have inspired me from childhood. They have led me down a road to a career in Environmental Education. Teaching the next generation about the wonders the natural world, and how important ecosystem services are to our livelihoods is my whole life. With this occupation I have deep sense of the importance that wild places have in our collective identity as Americans, and strongly oppose this identity being stripped through legislation. One visit made that connection concrete. I have had the privilege of backpacking through the Absaroka Mountains in Wyoming, walking past the point furthest from roads in the continental US. In that two weeks of backpacking through remote terrain I saw places, plants, and animals worth fighting for every day. From the headwaters rivers to the abundance of life within them, the lack of roads in these wild places is key in protecting it from the consumptive practices that destroy biodiversity and ecosystem services in so many other places. What is conveyed above represents the kind of public reliance interest that federal rulemaking is obligated to consider; the rescission of the Rule would extinguish protections on which millions of Americans similarly depend. Regarding the Pemigewasset in the White Mountain National Forest, New Hampshire: Pemigewasset and Kinsman Mountain in White Mountain National Forest are not ecologically independent. 31 species depend on connectivity between these IRAs — separated by just 9.5 miles — for genetic exchange, demographic rescue after local extirpation, and access to seasonal resources. Shared imperiled species include: Northern Myotis (G2), Tricolored Bat (G3). Absent road construction, the 9.5-mile corridor between Pemigewasset and Kinsman Mountain in White Mountain National Forest remains permeable to wildlife movement. The roadless condition of both IRAs preserves gene flow, seasonal migration routes, and recolonization pathways for 31 shared species, including Northern Myotis (G2), Tricolored Bat (G3). NEPA requires the DEIS to assess cumulative impacts (40 CFR 1508.7). The 31-species network spanning Pemigewasset and Kinsman Mountain in White Mountain National Forest — including Northern Myotis (G2), Tricolored Bat (G3) — demands joint analysis. Evaluating rescission impacts on each IRA separately violates this requirement. "CEQ scoping regulations require connected, cumulative, and similar actions to be considered together in the same EIS — where proposals up for decision are functionally or economically related, those proposals must be considered in one EIS. The obligation to address cumulative impacts is not limited to actual proposals but must also include impacts from actions which are merely being contemplated. The agency is required to look at cumulative impacts 'of other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions.'" — Council on Environmental Quality, Major Cases Interpreting the National Environmental Policy Act The 2001 Roadless Area Conservation Rule reflects a considered, durable judgment; that judgment should not be reversed. Faithfully, CommentID: RLC-20260828-E6CSJV

Dear Secretary Rollins and Chief Schultz, Years of birding the NH roadless country has shown me what the federal scientific literature already documents — that road density is the single most consequential anthropogenic variable for natural community composition — and the 2001 Rule singularly protects that. For this, it deserves to be retained and enforced. I have spent many years exploring, studying, and recreating in the NH White Mountains and surrounding habitats. This place is special to me and I have seen the continued struggles of the area even without new roads carved into it. Protecting the White Mountains and other wild areas requires strong laws and minimal disruption. More roads will only compound the current issues facing these places. The considerations above inform the position set out in the remainder of this comment. Regarding the Pemigewasset Ext in the White Mountain National Forest, New Hampshire: Headwater Protection for the Pemigewasset-Merrimack River System — The Pemigewasset Extension contains the headwaters of the Sawyer River, Nancy Brook, Carrigain Brook, and other tributaries that feed the East Branch Pemigewasset River—a major drainage system already documented as impaired for aluminum, pH… Absent road construction, the 6.8-mile corridor between Pemigewasset Ext and Pemigewasset in White Mountain National Forest remains permeable to wildlife movement. The roadless condition of both IRAs preserves gene flow, seasonal migration routes, and recolonization pathways for 32 shared species, including Mountain Avens (G2), Northern Myotis (G2). 40 CFR 1508.7 defines cumulative impact as the incremental impact of an action added to other past, present, and reasonably foreseeable actions. Road construction in Pemigewasset Ext and Pemigewasset constitutes connected action affecting 32 shared species. The DEIS must analyze these impacts cumulatively, not in isolation. "Incorporating effects of human-made barriers in isolation-by-distance regressions, Epps et al. (2005) found evidence that fenced highways cause a rapid decrease of gene flow between populations of desert bighorn sheep (Ovis canadensis nelsonii) in southern California." — Corlatti et al. 2009, Conservation Biology (review citing Epps et al. 2005), 2005 “Incorporating effects of human-made barriers in isolation-by-distance regressions, Epps et al. (2005) found evidence that fenced highways cause a rapid decrease of gene flow between populations of desert bighorn sheep (Ovis canadensis nelsonii) in southern California. — Corlatti et al. 2009, Conservation Biology (review citing Epps et al. 2005), 2005 (https://doi.org/10.1111/j.1461-0248.2005.00811.x)” “One of the most severe consequences of habitat loss due to road construction is the creation of isolated pockets of habitat that cannot support viable populations in the long term. Reductions in the range of species may decrease probability of their successful movement between habitat patches, which affects gene flow. Genetic theory suggests that the reduction of gene flow between subpopulations may lead to greater inbreeding and loss of genetic diversity within fragments, the raw material that allows populations to evolve in response to environmental changes. — Corlatti et al. 2009, Conservation Biology, 2009 (https://doi.org/10.1111/j.1523-1739.2008.01162.x)” “Medium connectivity results in metapopulation dynamics, where local demography is largely independent among patches but recolonization balances local extinction events; high connectivity leads to high occupancy (recolonization and/or demographic rescue outweigh local extinctions) and little to no genetic differentiation. Severe fragmentation will leave patches isolated like islands, where local extinctions will no longer be counterbalanced by colonization. — Cheptou et al. 2017, Philosophical Transactions of the Royal Society B, 2017 (https://doi.org/10.1098/rstb.2016.0037)” This proceeding should conclude with the Rule retained and no rescission action taken. Yours truly, CommentID: RLC-20260824-573FYS