Read the comments.

Under "Effects of Alternative 2 - Proposed Action," the subsection "Municipal Water Use" at p. 131 reads in its entirety, as to the finding: "If additional road construction or timber harvest result in a decrease in water quality, and or reduce the efficacy of water treatment." That is a conditional clause with no main clause. It names a possible cause and stops before stating any consequence. Every sentence that follows it reports exposure - how many people draw water from these watersheds - not effect. Alternative 1 receives one sentence, at p. 130: "Alternative 1, in general, has little risk of potential adverse effects and provides the greatest protection of water quality." Alternative 3's discussion at p. 132 cross-references Alternative 2 and repeats the exposure count in Table 36. The result is that the DEIS discloses who is exposed and never discloses what happens to them. The DEIS supplies the mechanism itself, one page earlier, and does not carry it forward. At p. 130 it states: "Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation." Rescinding the prohibition permits road construction and timber harvest in the very watersheds the DEIS has already identified as containing municipal intakes. Increased sediment and turbidity in a surface-water source raise treatment cost and can exceed treatment capacity during storm and post-disturbance runoff, forcing intake shutdowns and reliance on alternate supply. That is the sentence the DEIS began at p. 131 and did not finish, and it is the finding the FEIS must make. The scale of what is undisclosed is the DEIS's own. At pp. 129-130 it reports that "there are more than 7,000 municipal water intakes within watersheds containing potentially affected inventoried roadless areas" and that "Approximately 24 million people utilize water which originates within potentially affected inventoried roadless areas," with Table 35 breaking that out by region. For the Proposed Action the DEIS states that "The Intermountain Region is also affected in that over 1 million people receive water directly from watersheds containing inventoried roadless areas" (p. 131) - and then states no effect on them. The record contains a named, quantified system inside that figure. The Salt Lake City Department of Public Utilities told the agency (DEIS Vol. III, pp. 246-247) that "Our community opposes any federal action that could put our regional water quality at risk for 400,000 users throughout the Salt Lake City metropolitan area," that "The Wasatch Mountains east of Salt Lake City provide 60% of our daily water supply," and that "Protecting our water quality and our public health is the foremost responsibility of our work at SLCDPU." Table 35 puts the entire Intermountain Region, which covers Utah, at 1,118,900 people served by intakes; the single system documented in the agency's own record is 400,000 of them, roughly a third of the region's whole intake-served population. "Salt Lake" appears once in Volume I of the DEIS, in a list of references cited under Recreation. "Wasatch" does not appear in Volume I at all. The obligation to make this finding is stated by the agency, in this document. At p. 127 the DEIS says: "The Forest Service is required to manage National Forest watersheds that supply municipal water under multiple use prescriptions in land management plans (36 CFR part 219)." A rescission that removes the rule-level prohibition on road construction across watersheds holding more than 7,000 municipal intakes cannot be evaluated against that requirement on a record that states no effect for any alternative. See Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989); Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 1208 (9th Cir. 1998). The sentence that closes this section at p. 131 - "Most forest plans acknowledge the need for protections for municipal watersheds with plan components that have an overall management objective to maintain and improve watershed status" - does not supply the missing finding and cannot defer it. No plan component is identified, none is cited, and "most" concedes that some plans have none. The decision under review is made at the rule scale and made now: the prohibition either stands or is removed nationally, and the watersheds it currently covers either keep that protection or lose it on the effective date. Whatever a later project-level analysis may add, it cannot supply the effects disclosure NEPA requires for the decision actually before the agency.

We are writing as concessionaires—our family has had a concession on U.S. Forest Service lands since 1917. As 2nd, 3rd and 4th generations, we grew up spending summers on USFS land and winters adjacent to the National Forest in the Lake Tahoe Basin. Our concession is directly adjacent to a roadless area, and depends in part on its status for our success. We have hiked, backpacked, skied, biked, hunted, observed wildlife, and driven throughout national forests across the country. As lifelong USFS concessionaires, property owners, business owners, and public-land users, we urge you to select Alternative 1—no change to the Roadless Rule. Inventoried roadless areas provide essential wildlife habitat, protect watersheds, preserve plant and animal communities, and maintain connectivity between ecosystems. We have spent many hours in roadless areas of the Lake Tahoe Basin Management Unit forests and have personally observed their importance. In the Tahoe Basin, the Pyramid and Freel Peak Roadless Areas provide habitat and travel corridors for wildlife moving into and out of the basin. They also drain directly into Lake Tahoe, an irreplaceable national resource. Constructing roads and authorizing associated development would fragment habitat and cause lasting damage to wildlife, plants, soils, and water quality. The Draft Environmental Impact Statement identifies habitat for more than 300 threatened, endangered, and proposed species, as well as 79 U.S. Fish and Wildlife Service and 19 National Marine Fisheries Service critical habitats. However, it does not adequately connect those baseline figures to the likely impacts of increased road construction, timber harvest, habitat fragmentation, and sedimentation under Alternatives 2 and 3. Research has documented measurable habitat degradation extending up to five kilometers from roads, including cumulative effects on isolation and population viability. The DEIS should address this research and provide species-specific or habitat-guild-level analysis before any change is finalized. Such analysis is required under Robertson v. Methow Valley Citizens Council, Neighbors of Cuddy Mountain v. U.S. Forest Service, and the Administrative Procedure Act, 5 U.S.C. § 706(2)(A). The claim that rescinding the Roadless Rule is necessary for wildfire or fuels management is also unsupported. The current rule already allows fuels management in certain circumstances, including projects intended to reduce fuel loads in the wildland-urban interface and improve habitat for threatened, endangered, or sensitive species. Such work has already occurred in roadless areas in the Tahoe Basin directly adjacent to our concession. Forest Service research has also found that roadless areas have historically received a larger proportion of fuels-management projects than other National Forest System lands. We have firsthand experience that reinforces the danger of expanding road access. We have witnessed both the 2007 Angora Fire and the 2021 Caldor Fire, and have personally extinguished multiple human-caused fires started on or near roads in our vicinity. Major California fires, including the 2025 Gifford, 2021 Caldor, and 2018 Carr fires, crossed roads and bulldozed fire lines multiple times. The DEIS itself states that wildfire ignition density is lower in designated wilderness and potentially affected roadless areas than on other National Forest System lands, while acknowledging that increased road access could increase the number and frequency of human-caused ignitions. The agency should cite the source for its ignition-density comparison and reconcile this evidence with any argument that additional roads would reduce wildfire risk. The Forest Service cannot adequately maintain the roads it already owns. The Economic Analysis reports a $6.9 billion deferred-maintenance backlog for roads and bridges in 2024. Other comments in the administrative record cite billions more in road-maintenance needs and indicate that the Forest Service receives less than 20 percent of the funding required to maintain its existing road network. Nevertheless, the DEIS and cost-benefit analysis do not quantify the construction and lifecycle maintenance costs of new roads or explain how those costs would increase the existing backlog. The Final EIS should provide that analysis. Expanding roads into roadless areas threatens wildlife, watersheds, public safety, and the long-term financial sustainability of the National Forest System. It could also directly affect our home, livelihood, business, and recreational opportunities if increased access leads to wildfire or environmental degradation. Please select Alternative 1 and retain the existing Roadless Rule. Thank you for considering our comments.

Dear Ms. Rollins: I'm an Alabama native, a backpacker, an educator, an adventurer, a wife and a mother. As someone who has traversed many roadless areas across the U.S., I submit these comments in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I've backpacked in Cheaha many times, marveling at the wildness that is still available to us in the midst of a modern world. I have appreciated delicate, ephemeral flowers blanketing the forest floor, firefly larvae sparking on creek banks, and the sacred feeling of being far from anything constructed by humans. This removal creates space to connect with creation. My son is almost 2 now, but when he was still in my womb I backpacked with my husband and father in a roadless area. I thought to myself that this would be one of the most wonderful things I could ever hope for my son - to have a place where he could stand outside of development and just connect with the land, animals, and plants of a place. No sound of cars passing by, no marker of time or modern expectations, only the sun and moon sculpting the rhythm of a day. Alabama contains some of the most biodiverse places in the United States, places researched and written about by people like E.O. Wilson, Scot Duncan, and Bill Finch. The roadless areas in our state and our country protect endangered mussel species, bats, and healthy soil and watersheds to name a few. The health of humanity ultimately depends on the health of our wild places. Beyond this large scale impact, my heart would break if my son grows up in a world where these truly wild places no longer exist. I want him to be able to backpack in the woods and not come across a road. To be able to just live in "time outside of time", even if only for a few days. Regarding the Cheaha A in the Talladega National Forest, Alabama: Mussel Spawning and Recruitment Habitat in Upper Cheaha Creek Headwaters — The Upper Cheaha Creek headwaters support four federally endangered mussel species—Coosa moccasinshell, Southern clubshell, Southern pigtoe, and Triangular kidneyshell—along with the federally threatened finelined pocketbook. These mussels depend on stable, sediment-free stream substrates for spawning and larval development, and on specific host fish species that carry their larvae. The roadless condition of this drainage preserves the hydrological and geomorphological stability these species require. Systemic Asymmetry Between Quantified Economic Benefits and Unquantified Environmental Costs This EIS's own comparison table concedes that "less than one percent of the affected environment has mapped invasive plant populations," then describes the incremental risk from Alternatives 2 and 3 only in vague terms—that increased ground disturbance "could potentially increase the extent or the number of invasive plant species" (Comparison of Alternatives, pp. 20-36). No acreage projection, spread-rate model, or dollar cost accompanies this statement, even though the same document quantifies economic benefits down to specific dollar figures and job counts elsewhere. Independent research confirms roads are a documented driver of "facilitation of invasive species" and habitat fragmentation (Hoffmann et al. 2024), yet the EIS never applies comparable rigor to that side of the ledger. This asymmetry violates NEPA's requirement of forthright, balanced disclosure under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), and the reasoned-analysis standard of Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). I request quantified, alternative-specific invasive-species spread projections and cost estimates matching the specificity given to economic projections. Cutting roads through wild land is irreversible. Keep the Rule that prevents it. Respectfully submitted, Stephanie

To the Department of Agriculture: As someone who has used roadless national forest in multiple regions and in multiple seasons, I am submitting these comments to establish that the public value the 2001 Rule has protected is observable, documented, and not recoverable once road infrastructure has been authorized and constructed within currently protected areas. I remember walking with my husband on some of our very first dates in Cheaha park and now we love to take our children. Sitting at the top of the lookout always felt like stepping back in time and getting away from all of the stress of modern life. My family loves to hike the area and bulldozed roadbeds would ruin those experiences. Regarding the Cheaha B in the Talladega National Forest, Alabama: “In 2001 the Agency Found These Prohibitions Benefited Listed Species; the Rescission Never Engages Its Own Prior Finding Both Draft Biological Assessments open with the same acknowledgment (USFWS BA p. 10; NMFS BA p. 7): "In the promulgation of the 2001 Roadless Rule, the Forest Service found that the Rule's prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species or adversely modify designated or critical habitat; were not likely to jeopardize proposed species or adversely modify proposed critical habitat; and may beneficially affect threatened, endangered, and proposed species and critical habitat… The Services concurred with the determination." The agency thus stands on a concurred-in finding that the prohibitions it now proposes to delete benefit listed species — and the current assessments anticipate widespread adverse effects from deleting them. When an agency reverses course, it "must show that there are good reasons for the new policy," FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009), and where the prior policy rested on factual findings, it may not simply disregard them — the principle applied to this very rule's Tongass history in Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015) (en banc). Neither the DEIS nor the assessments explain what changed in the biology. I request the FEIS directly address the 2001 beneficial-effect finding and state the factual basis for departing from it.” “Road networks cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. In natural secondary forests, species richness, density and the proportion of invasive species significantly decreased with distance from the road; natural secondary forests contained only 5 invasive versus 67 native species, yet invasive species were concentrated near road edges. Human-induced changes to environmental conditions along roadsides increase soil moisture, soil disturbance, soil nutrients, exposure to sun and soil temperature, all of which are factors known to promote plant invasions. — Diversity and Distributions / Wiley Online Library, 2025 (https://doi.org/10.1111/ddi.70002)” The Analysis Concedes Recreation Losses Are "Most Likely," Quantifies Them as Costs, and Cannot Even Count the Visitors at Risk The Economic Analysis concedes at page 25: "In the long-term, any changes in aggregate economic benefit to recreationists that occur under the proposed rule are most likely to be losses because timber harvest and road construction is anticipated to negatively change the recreation settings and opportunities for trail-based and dispersed area recreation within potentially affected IRAs… The magnitude of those losses is unknown." At page 30 it books real costs: "Costs include forgone recreation benefits (minimum of $6.1 million annually) and forgone passive use values ($5.3 to $11.5 million annually) from increases in timber harvest in roadless areas." At page 28 it concedes the mechanism: "The construction and use of roads can degrade the unique characteristics of roadless areas… leading to loss of conservation values… These impacts from road development could negatively impact tourism and outdoor recreation." And at page 16 it admits it cannot even measure the exposure: "The number of recreation visits to IRAs is unknown and, thus, the recreation visitor spending in local communities associated with IRA recreation cannot be directly quantified." Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires an agency to analyze rather than wave through. Robertson, 490 U.S. 332; State Farm, 463 U.S. 29. I request the FEIS quantify recreation exposure (visitation and spending) in affected IRAs before relying on an analysis that concedes losses it cannot measure. When this process is over, I want the Roadless Rule still standing. I'm filing this comment to help make that happen. Most respectfully, CommentID: RLC-20260909-GQZC8R

Dear USDA Leadership: As an outdoor recreationist and wildlife conservationist, I want to clearly state that I strongly oppose repealing or weakening the 2001 Roadless Area Conservation Rule. Wild, protected places like this don't stay that way on their own, they stay that way because rules make them stay and people who care enough to advocate for them. Rolling back this rule would have real consequences for our national forests and those who enjoy them. As someone who lives on the West Coast, I am so fortunate to have access to roadless areas to recreate in within a few hours of my home. One area in particular, Diamond Peak, holds a special place in my heart. Diamond Peak is remote, rugged and beautifully wild. It's area is home to countless wildlife species including endangered gray wolves. From winter snowshoeing, to summer backpacking this area holds so much beauty for visitors to explore. This beauty should be preserved. Much of the charm of this rugged, roadless area is due to the lack of roads. To get somewhere you need your own strength and power to reach the destination. I've stood on the summit of Diamond Peak and saw from a bird's eye view the expansive landscape full of forests, rivers, mountains, lakes — and enjoyed the quite solitude that comes from being in untouched wilderness. Contrary to one of the arguments for repealing the Roadless Rule, more roads will also increase human-caused wildfires, ignited by unattended campfires or sparks from vehicles. We simply cannot afford extra wildfire risk in this region. We need to be doing all that we can to reduce fire risk which includes protecting roadless areas from development. Repealing the Roadless Rule opens up this area, and others, to road development that threatens to produce more wildfires, which then close down trail systems, stretch resources thin, and alter the landscape for generations. Regarding the Diamond Peak, North in the Willamette National Forest, Oregon: Roadless areas are disproportionately important habitat for federally listed threatened and endangered plants and animals. Rescinding the Roadless Rule would open the Diamond Peak, North, Willamette National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Roadless forests are essential to wildlife's survival. Across the United States, grizzly bears, wolverines, Canada lynx, native salmon, and dozens of other endangered species depend on the roadless stretches of our forests to keep them safe from destructive human activities. A recently released report found that rescinding the Roadless Rule would put 7.4 million acres of designated endangered species critical habitat and nearly 1,800 miles of protected rivers and streams at risk — and could hasten the extinction of more than 400 threatened and endangered plants and animals protected under the Endangered Species Act. Failure to Connect Species/Habitat Baseline to Rescission-Specific Impacts Analysis The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Rescinding a settled rule is the kind of decision that should be made only on a strong record, and the record here doesn't support it. Faithfully, CommentID: RLC-20260908-MIJROE

As a citizen of the United States of America, the recission of the Roadless Rule harms me by compromising my water supply and water quality, increasing my risk of exposure to fires and poor air quality, wasting my tax dollars, and disregarding due process and the spirit of NEPA. U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. The 2001 Roadless Rule protects these headwaters. The scale of municipal water dependency is quantified in the record the agency compiled. The eight Attorneys General (DEIS Vol. III, p. 41): "Approximately 350 major watersheds found in inventoried roadless areas serve as a source of drinking water for millions of people across the United States." The DEIS contains no inventory of municipal source watersheds within affected IRAs, no analysis of source-water effects, and no acknowledgment of Section 401 certification authority as a constraint on the promised project-level flexibility. 33 U.S.C. § 1251; 42 U.S.C. § 4332(2)(C). I request the FEIS inventory affected municipal source watersheds, analyze effects on each system identified in the record, and disclose the role of state and Tribal § 401 certification. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. Aplet et al. (2026) analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas. A separate analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Adding more roads increases the opportunity and likelihood of fires, which increases the likelihood that I will have to breathe poor-quality air full of particulates and other contaminants. In addition to contradicting the stated goal of “reducing fire risk”, building more roads in national forests is a drain on taxpayers. The Forest Service can’t afford to maintain its existing road network: the road-maintenance backlog is roughly $15.6 billion in today's dollars. The GAO 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 increase that deficit. One-Sided Purpose and Need Omitting Countervailing Conservation Values The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. This attempt to repeal the Roadless Rule does not adequately valuate the numerous ecological services provided by IRAs nor does it consider the downstream effects to wildlife or human communities. The logic is circular, the analysis unthorough, and the stated goals dishonest (fire suppression) and vague (more flexibility). Numerous studies documenting the benefits of keeping these IRAs intact, or documenting the likely harm that could be caused by disturbing these IRAs, have been hand-waved away without serious acknowledgement or discussion (e.g. DellaSala 2011, Aplet et al. 2026, Balch et al., PNAS 2017, Trombulak & Frissell 2000) as have court cases whose precedents this action is ignoring (e.g. Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co; Vermont Yankee Nuclear Power Corp. v. NRDC; Robertson v. Methow Valley Citizens Council), and Federal laws (e.g 42 U.S.C. § 4332(2)(C)(iii)). These concerns must be addressed fully and in good faith.

FS-2025-0001-223869 As a member of the Backcountry Hunters and Anglers and a frequent wildlife observer on both the Los Padres and Lake Tahoe Basin Mgmt Unit forests, I have spent many hours on the ground in multiple inventoried roadless areas. I can vouch that these areas are vital for wildlife and fragmentation of habitat with roads here and elsewhere will cause irreparable damage to our nation’s wildlife and plant life. In Lake Tahoe, much of the Pyramid Roadless Area and the Freel Peak Roadless Areas drain directly into Lake Tahoe, a part of our priceless national heritage. These roadless areas provide vital habitat for wildlife crossing in and out of the Tahoe Basin, and contain sensitive plant and animal species. The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Your decision directly affects the quality of our nation’s wildlife and plant populations and my hunting experience on public lands. I recommend you choose Alternative 1. Thank you for the opportunity to comment.

Dear Brooke L. Rollins, I write in opposition to the proposed rescission as a birder who has watched the federal scientific literature on road-density effects accumulate across two decades, and who finds that literature dispositive against rescission. Time spend in the habitat and witnessing bird and inspect species is of great joy but also sorrow. Knowing that if we do not protect these spaces, we rob future generations. During the pandemic, taking my kids hiking for outdoor learning gave us much needed reprieve from learning on screens. It was a way to connect to each other, the land and wildlife. Briscoe Creek Regarding the Briscoe in the Mendocino National Forest, California: Conservation status G2 reflects the vulnerability of Northwestern Pond Turtle (Actinemys marmorata) in the Briscoe Inventoried Roadless Area, Mendocino National Forest, where 7.2 - Dams & water management/use acts at Serious - moderate severity across Pervasive (71-100%) scope. Absent roads, Briscoe functions as a refuge where Northwestern Pond Turtle is buffered from 7.2 - Dams & water management/use. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. If the DEIS does not evaluate how rescission affects Northwestern Pond Turtle (Actinemys marmorata, G2) in Briscoe with respect to 7.2 - Dams & water management/use, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. "Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups." — Landscape Ecology (Springer Nature), 2025 “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups. — Landscape Ecology (Springer Nature), 2025 (https://doi.org/10.1007/s10980-025-02100-5)” Failure to Connect Species/Habitat Baseline to Rescission-Specific Impacts Analysis The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Rescission would not be a reasoned policy choice on the record presented; the Department should not finalize it. Respectfully, CommentID: RLC-20260908-OTV7WU

To Whom It May Concern at the U.S. Forest Service: In my retirement I have become a community scientist, and I am a very active volunteer with the Maryland Bird Conservation Partnership. I am deeply concerned about further forest fragmentation, which is a threat to forest interior dwelling birds. Losing bird species to extinction should be prevented for its own sake. But widespread species extinction, which is happening at a rapid pace, is a threat to humankind as well. In addition, as a practical day-to-day matter, I live in the Washington, DC, area, so I know how important clear, clean water from the mountains into the Chesapeake Bay Watershed is to the quality of life of all the people who live here. The 2001 Roadless Rule is policy that needs to stay in place if we are going to maintain hope for the survival of many species. Regarding the George Washington National Forest, Virginia: “More than half of migratory bird species in North America are experiencing population declines. Habitat loss and the resulting fragmentation on the breeding grounds are strongly correlated with observed population declines for the Connecticut warbler, which has experienced a total population decline of 62% since 1966 and declined by −8.99% per year between 2000 and 2017. Land-use practices that retain large, forested patches within landscapes will likely benefit breeding populations of this declining songbird. — PMC / Proceedings of the Royal Society B, 2021 (https://doi.org/10.1098/rspb.2020.3164)” “For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival rate. This model accounted for 78% of the total weight of evidence, and no other model was within 3.8 delta AICc units. From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. — PMC / Ecology and Evolution, 2014 (https://doi.org/10.1002/ece3.1049)”Edit quote One-Sided Purpose and Need Omitting Countervailing Conservation Values: The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values. This comment is against rescission. Most respectfully, Margaret Poethig

Dear Secretary Rollins and Chief Schultz: As a lifelong Oregonian, it is clear to me the value of the 2001 Roadless Area Conservation Rule and the protection it provides to forest lands that help make this state such a great place to live. These areas are still intact because of sustained regulatory protection, and removal of that protection will lead to their fragmentation. The Larch Roadless Area in Mt. Hood National Forest holds particular significance for me. I've gone on countless hikes in this area, to Wahclella Falls, Oneonta Gorge, and Wiesendanger Falls to name a few. The area makes up part of the Columbia Gorge's Waterfall Corridor, one of the crown jewels of the state. These hikes let me connect with our forests, enjoy time with my family, and admire truly breathtaking landscapes crafted by nature. To get to Wiesendanger Falls requires a 1.4 mile hike, past all of the crowds at Multnomah Falls, where you can have a moment of solitude to soak in the peace and awesome power of the falls. Like many places in roadless areas, the hike to get there is what makes it worth going to in the first place. If this rule is rescinded, I could lose access to recreate in these incredible places - the Multnomah Falls, Wahclella Falls, and Elowah Falls, and others I haven't had a chance to see yet, like Wahkeena Falls and Angels Rest. Not only that, but the integrity of the headwaters themselves could be compromised. Regarding the Larch in the Mt. Hood National Forest, Oregon: Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Oregonians painfully watch as thousands of acres of wildfires burn in our state every year - we don't need to rescind a policy that could make this even worse. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Portland, where I live, receive a significant portion of their water supply from national forests. The Analysis Concedes Recreation Losses Are "Most Likely," Quantifies Them as Costs, and Cannot Even Count the Visitors at Risk The Economic Analysis concedes at page 25: "In the long-term, any changes in aggregate economic benefit to recreationists that occur under the proposed rule are most likely to be losses because timber harvest and road construction is anticipated to negatively change the recreation settings and opportunities for trail-based and dispersed area recreation within potentially affected IRAs… The magnitude of those losses is unknown." At page 30 it books real costs: "Costs include forgone recreation benefits (minimum of $6.1 million annually) and forgone passive use values ($5.3 to $11.5 million annually) from increases in timber harvest in roadless areas." At page 28 it concedes the mechanism: "The construction and use of roads can degrade the unique characteristics of roadless areas… leading to loss of conservation values… These impacts from road development could negatively impact tourism and outdoor recreation." And at page 16 it admits it cannot even measure the exposure: "The number of recreation visits to IRAs is unknown and, thus, the recreation visitor spending in local communities associated with IRA recreation cannot be directly quantified." Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires an agency to analyze rather than wave through. Robertson, 490 U.S. 332; State Farm, 463 U.S. 29. I request the FEIS quantify recreation exposure (visitation and spending) in affected IRAs before relying on an analysis that concedes losses it cannot measure. These lands don't need roads, they need protection. The Rule gives them that. In earnest, Amber Gomez CommentID: RLC-20260907-X914GF

I am very concerned about the proposed rescinding of the Roadless Rule. Through my professional research, I understand how important the protections of our natural wild areas are to the future survival of species, including humans, on this planet. I am particularly alarmed at how little this proposed plan seems to take into account the crucial role wild forest lands play in mitigating climate change. I am also concerned about the dire effects on sensitive species the repeal of the roadless protections would cause. My work includes monitoring salmon runs, a very important keystone species, whose decline would puts a whole web of interrelated species into peril. Ultimately our quality of life, our livelihoods, and likely our very survival, depend on us using our intelligence and knowledge to protect what is left of our wild lands. Nothing can replace the clean water, clean air and habitat that require these protections. Do not allow short term foolishness to destroy the heritage of health we must pass to future generations. I have read and agree with the below concerns about the Draft Environmental Impact Statement about the Roadless Rule. Please address my concerns and provide a proposal that does not sell out our future. Thank you, Caroline Phillips One-Sided Purpose and Need Omitting Countervailing Conservation Values [challenge-022] The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values. I request that the Forest Service reverify the roads-mileage figure against current transportation-system records, disclose the results, and either update the DEIS or justify continued reliance on the older data. I request the agency apply changed-circumstances data specifically to roadless areas and explain, on the record, why it rejects its own contrary ignition-density findings. I request a revised, balanced Purpose and Need section addressing Conservation values. I request the agency complete government-to-government consultation consistent with E.O. 13175 before any final rule, and document in the record how Tribal input altered the proposal. No Action Alternative Fails to Quantify Environmental Benefits of Retention [compliance-025] The No Action alternative's treatment fails to quantify the environmental benefits of retaining the 2001 Roadless Rule's protections. The Purpose and Need section (pp. 18-19) describes only that the Department clarified the proposed action and used literature "to inform analysis," without presenting any quantified baseline of unfragmented habitat acreage, watershed protection metrics, or wilderness/recreation values attributable to continued retention. This is a status-quo narrative, not the comparative analysis NEPA requires: 42 U.S.C. § 4332(2)(C)(iii) mandates "an analysis of any negative environmental impacts of not implementing the proposed agency action," which necessarily requires quantifying what would be lost, not merely describing the decision process. No figure here approaches the rigor of the acreage, harvest-volume, and operability projections built for the action alternatives. Given documented links between road construction, habitat fragmentation, and invasive species spread, the agency should quantify habitat connectivity, watershed protection, and recreation/wilderness values under No Action with comparable specificity before finalizing this EIS. I request that the agency add a dedicated analysis quantifying the added maintenance burden and environmental risk of proposed new roads given this documented, unresolved funding shortfall before finalizing the decision. Given documented links between road construction, habitat fragmentation, and invasive species spread, the agency should quantify habitat connectivity, watershed protection, and recreation/wilderness values under No Action with comparable specificity before finalizing this EIS. DO NOT SELL OUT OUR FUTURE!

I have 17 years of land management experience with the US Forest Service and 21 years with the US Fish and Wildlife Service. I understand first-hand how these lands are critical to water and watershed protection, wildlife and fisheries habitat, reduced risk of wildfires, and world-class recreation. I live adjacent to the San Juan National Forest in southwest CO, and allowing impacts to these lands would be devastating. A study done in Colorado supports all my concerns. I include it here as part of my comments. https://roadless.org/resources/colorado-wildlands-report.pdf Rescinding the Roadless Area Conservation Rule (the Rule) threatens all of these benefits and gives control of these roadless public lands to greedy extractive industries and administration cronies. Road construction is not one threat — it is the enabling condition for most of the major threats that imperiled species and ecosystems face on National Forest lands. The Inventoried Roadless Areas exist in their current ecological condition because roads were never built. Rescinding the Roadless Rule activates a cascade of harm documented by NatureServe, the IUCN, and the U.S. Fish & Wildlife Service. I am also concerned with NEPA adequacy concerning this proposal, including the cumulative-effects analysis, range of alternatives, and other procedural requirements that a Draft EIS must satisfy. I will highlight my concern with a narrowly drawn purpose and need statement that forecloses meaningful alternative analysis. The Purpose and Need statement frames the rescission's justification exclusively around the Department's stated belief that "increased management flexibility in the administration of these lands is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without articulating any criteria against which intermediate alternatives—short of full nationwide rescission—could be meaningfully measured. This framing risks predetermining the outcome by defining the need in terms that only wholesale rescission can satisfy, foreclosing genuine consideration of a reasonable range of alternatives as NEPA requires under 42 U.S.C. § 4332(2)(C). As the Seventh Circuit recognized in the persuasive, out-of-circuit decision Simmons v. U.S. Army Corps of Engineers, 120 F.3d 664 (7th Cir. 1997), a narrowly drawn purpose and need statement that forecloses a reasonable range of alternatives violates NEPA's core mandate. I ask the agency to broaden its purpose and need framing with articulable criteria that permit genuine evaluation of intermediate management-flexibility options. The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values. I implore you to stop this action of rescinding the Roadless Area Conservation Rule. Nancy McGarigal Dolores, CO