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Hello. I am an engineer for the energy industry who (in addition to my engineering degree) also holds a degree in Wildlife Biology from a top agriculture University. In addition to my professional credentials, I have also contributed thousands of volunteer hours to the exploration & mapping of caves across the U.S., including those in the Grand Canyon NP, Mammoth Cave NP, Tonto National Forest, & Fern Cave Federal Wildlife Refuge. I have also volunteered as a citizen scientist assisting the collection of microbes caves. Those microbes are studied at top universities by labs focused on novel drug discovery, material science, & carbon sequestration. My recreational interests are extensive -- I cave, rock climb, backpack, day hike, overland/off-road, etc. throughout the United States. In the last 10 years, I have travelled to several dozen National Forests for these activities including the Chattahoochee NF, Bridger-Teton NF, Daniel Boone NF, Monongahela NF, Petrified Forest NF, & Shasta-Trinity NF. While doing so, I strive to shop locally, dine locally, & support the small rural towns. For me, the biggest draw to areas such as this is the remote & unbroken environment. As any wildlife biologist can attest, habitats change dramatically when the continuous forest is interrupted by open space such as those created by roads. Additionally, as any caver can attest, some of the most fragile ecosystems on the planet can be hiding in plain sight (often just under our feet). I am especially concerned about sedimentation caused by building roads & logging in areas that would have otherwise been roadless. Not only can such activities degrade drinking-water supplies on the surface, but it can also destroy underground conduits of water such as those found in karst landscapes. This impact wields a double-edged sword: both the humans & the habitats that are reliant on the underground water supply are jeopardized. This impact isn't limited to a few rural towns or scattered populations, either. Nearly 40% of the drinkable groundwater in the U.S. comes from karst aquifers! Professionally, I am no strange to Federal documentation. I frequently write supporting documents for nuclear power plants that are reviewed by the U.S. Nuclear Regulatory Commission. I draw upon this experience when I review the documentation "supporting" the proposal to rescind the Roadless Rule & I am deeply troubled by the gaps in supporting evidence as well as failures of adequate planning. Below is an example of such: The DEIS does not analyze a reasonable range of alternatives. The USFS states this itself: "The alternatives evaluated in detail in this DEIS focus on the geographic locations (boundaries) in roadless rulemaking" (DEIS p. 34). Alt. 1 retains the 2001 Rule's prohibitions; Alt. 2 removes them nationwide; Alt. 3 "would continue the existing Rule's exceptions and provides for locally led boundary modifications" (DEIS p. 35). No alternative analyzed in detail varies the prohibitions & exceptions themselves according to stated resource criteria. NEPA requires "a reasonable range of alternatives to the proposed agency action... that are technically and economically feasible, and meet the purpose and need of the proposal," 42 U.S.C. Sec. 4332(2)(C)(iii), & the DEIS cites the parallel requirement at 7CFR1b.7(h) on the same page where it describes its own range as boundary-focused. The rest of this comment is attached as a file because the online portal's character limit is preventing the discussion of the matter in full.

As a Washington State resident who understands firsthand what the Roadless Rule protects where I live, I oppose this rescission. I have hiked and camped in roadless areas across the Olympic National Forest, including Quilcene, and have studied the history of previous deforestation in the area. Rescinding the Rule would impact trails and natural features like Mt Townsend, where road construction is currently illegal, and timber harvest on those roads. The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range ("a 4 to 10 percent increase in total sawtimber harvest" (p. 30)) and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics. This is not a limit of the analytical method, because the DEIS performs the quantified work for one forest. It states that "[t]he environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while the 2020 Alaska Roadless Rule FEIS "provides more specific, localized effects analysis for the Tongass National Forest affected environment, which supplement the broader nation-wide analysis" (p. 238). Carrying that analysis forward, the DEIS reports "an estimated 49 miles more of potential new road constriction [sic] within the Tongass compared to leaving the Roadless Rule in place" and an average road density of 0.23 miles per square mile (p. 239). By the DEIS's own accounting the Tongass is "nearly 1/4 of the potentially affected inventoried roadless area acreage" (p. 238). One quarter of the analysis area therefore receives a projected road-mile figure and the remaining 30.8 million acres receive none. The omission cannot be deferred to project-level review, because the DEIS's own statement of need rests on quantified national targets. At p. 79 the DEIS relies on Executive Order 14225 and on the One Big Beautiful Bill Act section 50301, which "directs the Forest Service to sell at least 250 million board feet more each year for the next 10 years," and on the National Active Forest Management Strategy's goal of "an increase in timber production nationally by 25 percent." At p. 40 the DEIS says the amounts and locations are uncertain because "the rulemaking would not compel, require, or authorize any sitespecific activities." Both positions cannot hold. If the rescission is needed to meet a quantified national harvest target, then the harvest and the road construction required to reach that target are reasonably foreseeable effects of the rescission, and 42 U.S.C. 4332(2)(C) requires "a detailed statement... on... reasonably foreseeable environmental effects of the proposed agency action." If they are not reasonably foreseeable, the stated need for the rescission is unsupported, and every alternative eliminated for failing to meet that purpose was eliminated against a purpose the agency has not substantiated. The Forest Service should supplement analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and resulting sedimentation and fragmentation across the potentially affected environment under each action alternative, at the level of specificity the DEIS applied to the Tongass National Forest at pp. 238-239, and cite in the final EIS where that supplemented analysis is accounted for, as 7 CFR 1b.7(f)(3) provides.

The wildfire analysis establishes, from the agency's own data, that road access drives ignitions. P. 94 states that "the incidence of human-caused fires generally increases with proximity to roads," and it discloses its basis: the InFORM Fire Occurrence Data Record and the MTBS burned-area dataset, with primary comparisons focused on 2014-2024. P. 97 it reports the result - "ignition density is approximately four times greater on other NFS lands compared to the potentially affected IRAs and wilderness. Most of this difference is due to the greater density of human-caused ignitions within other NFS lands (Table 21)." Among fires with causes determined, 77 percent in wilderness and 74 percent in potentially affected IRAs were naturally ignited, against a 57 percent human-caused majority on other NFS lands. Aplet, Hartger & Dietz (2026) find ignition density lowest in designated wilderness (1.75 fires per 1,000 ha) and Inventoried Roadless Areas (1.97), and highest within 50 m of roads (7.99). The cause-and-effect link to this analysis is direct. Alternatives 2 and 3 remove the prohibition on road construction and reconstruction across the potentially affected IRAs. The DEIS's own measured relationship - human-caused ignition density rising with road proximity, by a factor of about four between unroaded and roaded NFS lands - predicts that converting unroaded acres to roaded acres increases human-caused ignitions on those acres. The DEIS has the data to estimate its magnitude. It does not do so. In the Fire Control discussion of Alternative 2 at p. 111, the DEIS analyzes only the benefit: "With increased road access, initial attack success rates would be expected to increase. Additional roads would provide safer, more effective, and more efficient containment opportunities, potentially reducing fire sizes and durations." No corresponding estimate of the ignition increase appears anywhere in the Alternative 2 effects analysis. The ignition side surfaces once, at p. 113, in the Alternative 3 discussion: "Alternative 3 has the same concern about new roads increasing ignitions, and these ignitions would be closer to communities, where they could potentially cause more damage. However, the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." That sentence carries no citation, no analysis and is a netting conclusion with one side of the ledger measured to a factor of four and the other side never estimated at all. The offset the DEIS relies on is bounded by its own finding. At p. 104 the DEIS reports that "[d]ata from the FODR for fires occurring between 2014-2024 indicate that initial attack success rates are high (more than 90 percent) for all land designations," with the differences across designations described as a trend rather than a gap (Table 24). If initial attack already succeeds on more than nine of ten fires everywhere, the improvement new roads can deliver is bounded at under ten percentage points of containment on fires that start. The DEIS performed the ignition-density comparison at the national scale, across all potentially affected IRAs, in support of a national rulemaking. Having quantified the baseline nationally, the agency cannot defer the corresponding effect to future site-specific analyses while relying on an unsupported national conclusion that the net effect is insignificant. The statement at p. 112 that "[t]he magnitude of these beneficial effects would depend on site-specific decisions regarding the amount and layout of the expanded road network" applies with equal force to the adverse effects, and the DEIS estimates neither. NEPA requires the agency to disclose the basis for the environmental conclusions it draws and to connect its data to those conclusions. 42 U.S.C. Sec. 4332(2)(C); Idaho Sporting Congress v. Thomas, 137 F.3d 1146, 1150 (9th Cir. 1998). Under 7 CFR 1b.11(a)(53) this comment bears on reasonably foreseeable impacts, on the choice among alternatives, and on compliance with applicable law. I request that the Forest Service supplement the wildfire analysis to estimate, using the InFORM FODR analysis already performed for Table 21, the expected change in human-caused ignition density and ignition count within the potentially affected IRAs under Alternatives 2 and 3, given the road mileage and road-access changes the alternatives make possible; that it state that estimate in the same units as the initial-attack benefit it credits at pp. 111 and 113 so the two can be compared; and that it either support the conclusion that "the net impact of new roads on fire occurrence is likely small or insignificant" with that comparison or withdraw it from the FEIS. If the agency retains the conclusion, it should identify where in the FEIS or the supporting record the quantitative basis for it appears.

Tongass 9.3-Million-Acre IRA Figure Carries the Alternatives Arithmetic with No Disclosed Vintage or Reconciliation The Draft EIS uses a 9.3-million-acre figure for inventoried roadless area within the Tongass National Forest as a term in its baseline and in the acreage comparison among alternatives, but nowhere states the vintage of that figure or whether it has been reconciled against the technical corrections the Draft EIS itself says have already changed the roadless inventory. At page 11, under "Inventoried Roadless Areas," the Draft EIS states that "[t]he 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands, including about 9.3 million acres within the Tongass National Forest." Footnote 4 to that same passage states: "While the original rule listed 58.5 million acres, mapping modernization and technical corrections reduced that to 58.2 million acres." At page 21, the Draft EIS states that "[m]odification of IRA boundaries would require rulemaking, though technical corrections may be approved by the Chief." Those three passages, taken together, establish the defect. The agency states that inventoried roadless area boundaries are subject to technical correction approved administratively by the Chief, outside rulemaking. It discloses that mapping modernization and technical corrections have already moved the national roadless total by approximately 300,000 acres. It then carries the Tongass figure without stating when the Tongass inventory was last corrected, what any such correction changed, or the date as of which the "current national roadless area maps" it relies on at page 21 are current. Page 12 likewise states that "[c]urrent areas are reflected in national maps at the Forest Service Roadless Area website" without a date. No citation in the Draft EIS attaches to the 9.3-million-acre figure itself. A reader therefore cannot determine from the document whether the corrections that reduced 58.5 million acres to 58.2 million acres touched the Tongass inventory at all. This is not a request for background information, because the figure is load-bearing arithmetic in the comparison of alternatives. Alternative 1 "[a]pplies to inventoried roadless areas totaling 44.7 million acres; including 9.3 million acres of the Tongass National Forest" (p. 21), and the Draft EIS designates alternative 1 the no-action alternative under 7 CFR 1b.7(h)(3)(iv), stating that "[i]t establishes a benchmark, or environmental baseline, against which the effects of the other alternatives are compared" (p. 21). Under alternative 2, "the 9.3 million acres of inventoried roadless area within the Tongass National Forest would be included in the 44.7 million acres no longer managed according to the 2001 Roadless Rule" (p. 23). Under alternative 3, the same 9.3 million acres is one of three addends in the stated removal total: 4.5 million acres of non-National Forest System lands and congressionally designated areas, plus 17.9 million acres within a half mile of existing roads or within the wildland-urban interface outside the Tongass, plus 9.3 million acres of Tongass inventoried roadless area, together making the "31.7 million acres" the alternative removes and leaving the "13 million acres" it continues to manage under the 2001 Rule (pp. 23-24). The cause-and-effect relationship is therefore direct and arithmetic. If the Tongass figure has moved since the inventory from which it was taken — as the Draft EIS's own account of Chief-approved technical corrections indicates it may have — then the acreage the Draft EIS reports as removed from roadless protection under alternatives 2 and 3, the residual it reports as retained under alternative 3, and the baseline against which every alternative's effects are measured are each misstated by the same amount. The disclosed magnitude of the action, and so the disclosed magnitude of its effects on the Tongass National Forest, is no more accurate than the figure. NEPA requires the environmental impact statement to describe the affected environment accurately, 42 U.S.C. 4332(2)(C), and the Draft EIS itself invokes 7 CFR 1b.7(h)(3)(iv) to make alternative 1 the benchmark against which every other alternative is measured. A baseline whose principal Tongass acreage term carries no stated vintage and no stated reconciliation cannot perform that function. The Department's procedures identify the making of factual corrections, 7 CFR 1b.7(f)(2)(v), and the supplementing, improving or modifying of analyses, 7 CFR 1b.7(f)(2)(iii), as actions the agency takes in response to substantive comments.

Re: Docket FS-2025-0001 / RIN 0596-AD66, Special Areas; Roadless Area Conservation I oppose rescission of the 2001 Roadless Area Conservation Rule and urge USDA to select the No Action alternative. What is lost cannot be restored. Roadless areas are among the last intact backcountry in our national forests. A road can be built in a season; the undisturbed forest, clean headwaters, and wildlife habitat it fragments take decades to centuries to recover, if they recover at all. NEPA requires an EIS to disclose any irreversible and irretrievable commitments of Federal resources (42 U.S.C. 4332(2)(C)(v)). The Final EIS must treat the permanent loss of roadless character as exactly that, not as a "modest and localized" effect. The stated purpose does not match the wildfire rationale. The Purpose and Need is framed around deregulation and Executive Orders directing expanded timber and energy production. Yet the 2001 Rule (66 FR 3244) already allows roads where needed to protect life and property from an imminent threat of fire (Sec. 294.12(b)(1)). It also allows cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire (Sec. 294.13(b)(1)). If these exceptions are too narrow or too slow to use, as the Rationale suggests, the proportionate remedy is to revise them, not remove all protections. The Final EIS should analyze that narrower alternative. It should also document specific cases where the Rule itself, rather than budget or staffing, prevented needed fire work. The analysis concedes roads increase ignition risk but does not weigh it. The Summary of Potential Impacts acknowledges greater access can increase human-caused ignitions. A national study of 1992-2024 data found ignition density highest near roads and among the lowest in inventoried roadless areas (Aplet et al., Fire Ecology 22:8, 2026). The Final EIS should quantify expected new ignitions on the 18.2 million acres where permanent roads could be built and weigh them against claimed suppression benefits. Costs outweigh benefits. The agency estimates $5.2-11.4 million per year in timber revenue to the Treasury and Forest Service. Against that sit a $6.9 billion deferred maintenance backlog for roads and bridges and an estimated $6.1 million per year in lost recreation benefits. The Final EIS should identify how new roads will be maintained and funded, and the water-quality effects of roads that are not. Foreseeable plan changes are excluded. The notice concedes later plan amendments could expand logging and roads beyond what was analyzed, yet treats them as out of scope. Given the timber and energy orders cited as this action's purpose, such amendments are reasonably foreseeable effects and must be analyzed. The analysis relies on narrowed ESA protections. The notice states local decisions remain subject to the ESA. But FWS and NMFS have since rescinded the regulatory definition of "harm," so habitat modification alone generally no longer constitutes take under Section 9. Section 7 consultation still applies to designated critical habitat, but listed species' habitat outside those designations has lost that protection. The Final EIS must analyze how this change affects its reliance on the ESA. Disposal risk. In 2025, a Senate committee's draft budget bill would have mandated the sale of millions of acres of Forest Service and BLM land and did not exclude inventoried roadless areas. Removing national protection and fragmenting these areas with roads would make them easier to justify for sale. The final rule should state that rescission is not intended to facilitate disposal. Any future disposal should require full public process, including disclosure of the buyer. Process. The 2001 Rule followed more than 600 public meetings and 1.6 million public comments. This rescission has offered a 21-day scoping period and a 45-day comment period, with public hearings only in Alaska. That is inadequate for 45 million acres of public land. These are public lands, owned by the United States on behalf of all its people. Please retain the 2001 Roadless Rule. Respectfully submitted.

I am deeply concerned about the idea to rescind the roadless rule and what that means for our future. The Department proposes this rescission to reduce regulatory burden, return land management decision-making for inventoried roadless areas to local Forest Service officials, and enable active management response to wildfire risk, insect and disease infestation, and wildland-urban interface (WUI) protection. None of these stated objectives is actually advanced by the proposed action, and the rulemaking record itself supplies the evidence that contradicts the Departmentand#39;s own rationale. Thus, the USFSs proposed action does not serve the purpose and need it claims to serve. NEPA obligates an agency to "study, develop, and describe appropriate alternatives"; to a proposed action, 42 U.S.C. 4332(2)(E), and courts have long held that an agency cannot select or, as here, propose an alternative that fails to accomplish the very purpose and need the agency has articulated The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I am a California resident writing in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule and on the adequacy of the draft EIS. My concern is the Sierra Nevada corridor: the Tahoe, Eldorado, Stanislaus, Humboldt-Toiyabe, Inyo, Sierra, and Sequoia National Forests. This rule does not govern Kings Canyon and Sequoia National Parks or the John Muir and Ansel Adams Wildernesses, which hold statutory protection. That is the point. The inventoried roadless areas at issue are the lands in between: the buffers and corridors that make those protected units ecologically functional rather than isolated islands. They are frequently indistinguishable from adjacent wilderness in condition and function, and they carry wildlife movement, watershed, and backcountry recreation values the designated units cannot sustain alone. My use is sustained and year-round. I backpack multi-day Sierra routes, run ultra-distance trail events across the Tahoe and Eldorado National Forests, and ride backcountry terrain in the eastern Sierra in winter. Much of that occurs in inventoried roadless areas, on terrain whose value depends on the absence of roads. The Tahoe region illustrates the stakes. Inventoried roadless areas comprise more than 80,000 combined acres across the Tahoe National Forest and Lake Tahoe Basin Management Unit, roughly a quarter of Forest Service lands in the Basin, including terrain near Luther Pass and Echo Lakes, lands skirting Desolation Wilderness, portions of the Tahoe Rim Trail, and Freel Peak. Luther Pass is occupied habitat for the Sierra Nevada red fox, federally endangered, and the American marten. The DEIS does not adequately analyze effects on listed species there, nor the conflict between new road construction and Lake Tahoe’s Total Maximum Daily Load program, under which two decades and hundreds of millions in public investment have targeted fine sediment reduction to restore lake clarity. Roads and disturbed surfaces are a principal fine sediment source. The stated justification is wildfire risk reduction, and the record does not support it. Aplet et al. (Fire Ecology, 2026), covering 1992 to 2024 across all eight contiguous Forest Service regions, found ignition density of 7.99 fires per 1,000 hectares within 50 meters of a road, versus 1.97 in inventoried roadless areas and 1.75 in designated wilderness. The Forest Service attributes roughly nine of ten wildfires to human causes. Roads into roadless terrain increase ignition sources in the places the agency says it wants to protect. Deficiencies I ask the agency to address: 1.The DEIS does not adequately analyze cumulative watershed effects in Sierra headwaters, including fine sediment impacts on Lake Tahoe clarity and effects on the Truckee, San Joaquin, Kings, Kern, and Owens River source waters serving millions of Californians. 2.It does not analyze how new road access increases human-caused ignition risk in high-hazard fuel types. 3.It does not evaluate a narrower alternative retaining roadless protections while permitting targeted fuels treatment where documented wildland-urban interface risk exists. 4.It does not analyze fragmentation and connectivity loss along the Sierra crest. Roadless areas in the Tahoe, Eldorado, Inyo, Sierra, and Sequoia National Forests form the corridor linking designated wilderness and Park units. The agency has not evaluated effects on species dependent on landscape-scale movement, including Sierra Nevada red fox, Sierra Nevada bighorn sheep, Pacific fisher, and wolverine, nor how fragmentation would degrade the wilderness character of adjacent designated areas it is obligated to preserve. I have an eight-year-old daughter. She has backpacked in Desolation Wilderness, Yosemite, and out of Mammoth Lakes, reaching those places through roadless areas in the Eldorado, Stanislaus, and Inyo National Forests. She may be the first generation in twenty-five years to inherit the absence of these protections. That asymmetry is the heart of my objection. The projected benefits are annual, modest, and reversible: a few million dollars in timber revenue and some administrative flexibility. The costs are permanent. A road cut into an unroaded drainage persists for generations through hydrologic change, sediment delivery, invasive species vectors, and fragmentation, long after the timber that justified it is gone. My daughter’s generation will inherit the roads. It will not inherit the revenue. The DEIS does not seriously analyze these irreversible and irretrievable commitments of resources, as NEPA requires at 42 U.S.C. 4332(C)(v), nor engage the policy Congress set at 42 U.S.C. 4331(b)(1), directing each generation to act as trustee of the environment for those that follow. I ask the agency to strongly withdraw the proposed rescission.