Read the comments.

"Uncited "Forest Service Data" Source for Invasive Plant Mapping Statistic [challenge-028] The Draft EIS's invasive plant statistic lacks any traceable record support. The document states that "Forest Service data indicates less than one percent of the affected environment has mapped invasive plant populations" (Comparison of Alternatives, pp. 20-36), but names no dataset, survey year, or mapping methodology, and the source cited elsewhere in the record for related invasive species claims is silent on this specific figure. This matters because roads are widely recognized as a primary vector for invasive species spread, with research finding that roadless areas "provide barriers to invasive non-native species ingress" — a dynamic the agency cannot properly evaluate without knowing what baseline mapping data actually underlies its current-conditions estimate. A bare, unattributed statistic cannot support reasoned conclusions about invasive species risk under the action alternatives. Under Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), Center for Biological Diversity v. Bureau of Land Management [verify before filing], and APA 5 U.S.C. § 706(2)(A), I request the agency identify the specific dataset, survey year, and methodology, such as the TESP-IS database, supporting this figure before finalizing the rule. As a member of the Washington Native Plant Society, and a steward of a local natural area, I have seen first-hand how invasive species ALWAYS follow new roads into previously intact wilderness. And after they arrive, spread and choke out the native plants, they are almost impossible to control. Roadless areas are a national treasure and need to be protected."

Dear Secretary Rollins and Chief Schultz, As someone who has spent a substantial portion of recreational time on public land specifically because of the conditions roadless designation maintains, I am submitting these comments to urge the Department to conduct a more rigorous accounting of public value before rescinding the 2001 Roadless Area Conservation Rule. While I know the Mt. Baker Snoqualmie National Forest best, I have also spent significant time in some of the last wild places on Earth - including the salmon runs of Alaska, wonderfully intact and protected by the Roadless Rule. I continue to explore the Mount Baker Snoqualmie National Forest, and find it beloved and respected by others who frequent it. Time in the protected forest and proximity to it is one of the reasons I live and enjoy living in the Skagit Valley. I have made my life and livelihood here, and without it I would no longer feel at home. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Trombulak et al., 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Rescinding the Roadless Rule would open the Mt. Baker West, Mt Baker-Snoqualmie 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. Recission of the roadless rule would be devastating for me personally and for my community who love and respect the outdoors. Unquantified Roadless-Specific Forest Health Data Supporting Causal Rationale The DEIS asserts that the 2001 Roadless Rule "limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns" (Rationale for the Proposed Rule, pp. 18-19), yet this three-step causal chain is offered with no acreage figures, no roadless-specific fire, insect, or disease incidence statistics, and no comparison of forest health outcomes between roaded and roadless lands. An agency asserting materially changed conditions must articulate a rational connection between facts found and the choice made, not a bare assertion, under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983), Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), and unsupported factual premises violate APA 5 U.S.C. § 706(2)(A). I request quantified, roadless-specific data on acres affected, fire risk indices, and treatment backlogs, with a direct roaded-versus-roadless comparison, before this rationale is relied upon to justify rescission. Failure to Provide Sensitivity Analysis for Acreage-Derived Percentages The Draft EIS's own acknowledged 0.4-million-acre discrepancy between the 44.7-million-acre IRA figure and the 44.3-million-acre National Forest System land figure is never carried forward into any of the derivative percentages presented in the Affected Environment section, including the 56 percent Tongass figure, the 66.5 percent timber-harvest restriction figure, the 54.5 percent road-construction restriction figure, and the 2.8 percent NWPS overlap figure (pp. 20-36). Having conceded uncertainty in the base acreage, the agency cannot present percentages calculated from it as precise without disclosing how that uncertainty propagates. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), an agency that identifies a data-quality problem must grapple with its implications for downstream conclusions rather than disclose it in passing. Presenting these figures without error bars is also arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request that the agency provide sensitivity ranges or error bars for every acreage-derived percentage in this section before finalizing the rescission. I oppose this rescission, clearly and without qualification. I'm asking the Department to withdraw the proposal. With respect, E Burnham CommentID: RLC-20260908-0HAQRV

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 a conservationist, I've spent time understanding the legal architecture of the 2001 Rule, and what I see in this proposed rescission is an agency trading durable protection for administrative convenience. I understand the frustration that extra regulation can bring to land management, but the 2001 Roadless Rule has shown many benefits. The fact that exception processes already exists points to a lack of desire on the Agency's part to put in the effort required to make good decisions, rather than the need to fully repeal existing rules. Fine sediment from new road surfaces would embed spawning gravels, fill interstitial spaces that shelter macroinvertebrates, and reduce hyporheic exchange — the movement of water between the stream and its bed that regulates temperature and nutrient cycling. These effects persist for the life of the road and for years after decommissioning, because road prism material remains in the floodplain long after the road surface is removed. “Failure to Address 2001 Rule's Own Forest-Health Exception (36 CFR 294.13(b)(1)(ii)) The Draft EIS asserts that "the 2001 Roadless Rule prohibited cutting, sale, or removal of timber—except when one of a limited set of exceptions applied," using this framing to support the conclusion that the Rule caused a lack of active forest-health management. But the agency never engages with the actual text of the exception it is describing: 36 CFR 294.13(b)(1)(ii) (2001 ed.) expressly authorized timber cutting to "maintain or restore the characteristics of ecosystem composition and structure ... to reduce the risk of uncharacteristic wildfire effects." That provision directly undercuts the premise that the 2001 Rule categorically blocked forest-health treatments, yet the DEIS neither cites it nor explains why it proved insufficient in practice. Under Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), the agency must respond to contrary evidence already in its own record. Failing to do so here is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request that the agency address this exception directly and document why it did not achieve the forest-health outcomes the rescission now claims are necessary.” “Failure to Connect Road Maintenance Funding Shortfall to New Road Construction Risk The Draft EIS fails to connect its own documented road-funding crisis to the risk of authorizing new road construction into currently roadless areas. The document states that "the Forest Service received approximately $270" million in FY2023 against an estimated $1.6 billion annual maintenance need for the existing 368,000-mile system (pp. 43-246), and elsewhere shows appropriated funding declining nearly 70 percent over twenty years. Yet no analysis in this section examines what incremental deferred-maintenance liability, erosion risk, or culvert-failure exposure new roads under the action alternatives would add to an already underfunded network. This is precisely the kind of important aspect of the problem an agency cannot ignore under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983). 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.” The fact is, exceptions exist to the current rule allowing for fuels treatments and even road building. Rescinding the rule as a whole acts as a workaround to a process that should be improved internally; instead the preferred alternative strips protections from millions of acres without doing the due diligence of analyzing the potential adverse impacts that will come with the resulting road building and management activities. Respectfully submitted, CommentID: RLC-20260907-08THCY