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To the Department of Agriculture and the Forest Service: I am writing to express my deep concern for the proposed rescinding of the Roadless Rule. As someone who lives near and recreates in multiple roadless areas I can’t express how strongly I feel about the negative impacts this will have. One area in particular is the Sawtooth area, which connects two valleys that hold great importance to me - the Chelan and the Methow. This is one of the main areas I can easily access by foot to quickly escape into nature. The lack of roads in this area provides a peaceful, serene environment that would be destroyed if roads were allowed here. If roads were to come into this area I would lose my most sacred spaces in which I am able to retreat and tend to my mental and physical health. Regarding the Sawtooth in the Okanogan National Forest, Washington: Slight or 1-10% pop. decline severity and Small (1-10%) scope characterize the impact of 6.1 - Recreational activities on Mount Rainier White-tailed Ptarmigan (Lagopus leucura rainierensis, T2) in the Sawtooth Inventoried Roadless Area, Okanogan National Forest — losses that the current Roadless Rule helps constrain. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 6.1 - Recreational activities on Mount Rainier White-tailed Ptarmigan. Analysis of 6.1 - Recreational activities effects on Mount Rainier White-tailed Ptarmigan (Lagopus leucura rainierensis) in Sawtooth must reference the species' T2 conservation status and the documented Slight or 1-10% pop. decline severity. The DEIS lacks scientific integrity without this baseline data. "On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches)." — Iranian Journal of Environmental Health Science & Engineering (PMC), 2013 Failure to Substantively Respond to Content of Majority-Opposition Comments 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. People travel from all over the world to visit our country because of the incredible wild, beautiful spaces we are lucky to live among. We have protected these places for great reason and the vast majority of people in this country do not want to see this change, myself included. Twenty-plus years of protection shouldn't end here. Keep the Rule. Sincerely, CommentID: RLC-20260908-92QQJG

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

Dear Department of Agriculture Leadership: As someone who grew up at Lake Tahoe and has built a lot of my outdoor life around what's available in roadless public land, I'd say this rule has done more for what I value about those places than any other single policy. The Grouse Lakes area was one of the first places I ever backpacked, and my family has been visiting it for decades to enjoy the solitude and pristine wild character of the area. It helped spark a lifelong love for the outdoors and wilderness which has enriched my life in countless ways. Wagon Wheel lakes has been an especially important place in my life. My father and I used to visit these lakes regularly, and now that he has passed away, it's a place where I feel close to him. We both loved how peaceful and pristine this area was, it's unique quality would be irreparably harmed by road access. Should the roadless rule be rescinded, the Grouse Lakes area, along with countless other special natural areas would be forever altered. Their defining quality, that of peaceful isolation would be irreversibly lost. This area holds a special place in my life, it's a place to relax and reconnect with my essential human spirit, and this is only possible because it is not easy to access. The lack of roads makes this place what it is a peaceful haven away from the world. Regarding the Grouse Lakes in the Tahoe National Forest, California: NEPA requires that cumulative impacts be assessed across connected resources, not within arbitrary administrative boundaries. Grouse Lakes and East Yuba in Tahoe National Forest — 21.0 miles apart, sharing 5 climate-threatened species and 23,648 acres of 2 ecosystem types — constitute a single climate refugia network that must be evaluated as such. The connected roadless landscape between Grouse Lakes and East Yuba in Tahoe National Forest currently provides exactly the climate refugia function that the agency's own NOI identifies as at risk. 5 climate-threatened species occupy 2 undisturbed ecosystem types spanning ~23,648 acres. This is not theoretical refugia — it is functioning refugia that roadless protection maintains. Without network-level analysis of the Grouse Lakes–East Yuba refugia corridor in Tahoe National Forest, the DEIS cannot accurately assess what rescission costs. The 5 shared climate-threatened species, the 2 shared ecosystem types, and the ~23,648 acres of connected refugia represent a climate adaptation resource that area-by-area review will systematically fail to account for. "Seed dispersal over sufficiently large distances can maintain ecological resilience in fragmented landscapes and buffer changes in local-scale functional diversity. Otherwise, functional diversity is maintained by local processes, meaning that ecological resilience of isolated forest fragments depends strongly on land use type and intensity. Habitat fragmentation and local disturbances jointly operate on ecological resilience at different scales. Forest fragments acting as intermediate stepping stones in the transfer of seeds maintained functional diversity across the landscape." — Diversity and Distributions (Wiley), 2016 Failure to Substantively Respond to Content of Majority-Opposition Comments 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. What the Roadless Rule has preserved over the past two-plus decades can't be rebuilt once it's gone. Please don't rescind it. Yours sincerely, CommentID: RLC-20260907-DCQ5KU