Read the comments.

Dear Secretary Rollins: The experience of traveling through genuinely roadless country has shown me that the 2001 Rule codified something the public had long sought but lacked the regulatory mechanism to secure — and the Department's proposed rescission would dismantle that mechanism without commensurate justification in the record. I live on Rattlesnake creek in Missoulla. I enjoy hiking up into the wilderness area every summer. I would hate to see logging or any road building in this area that so many of us Missoulians use. I would loose the ability to experience wilderness so close to home. Regarding the Rattlesnake in the Lolo National Forest, Montana: In the Rattlesnake Inventoried Roadless Area, Lolo National Forest, Whitebark Pine (Pinus albicaulis, G3, T) faces documented threat from 5.3 - Logging & wood harvesting at Slight or 1-10% pop. decline severity across Small (1-10%) scope. Road networks serve as vectors for the secondary impacts classified under 5.3 - Logging & wood harvesting: they open previously inaccessible terrain to resource extraction, facilitate introduction of invasive species, and concentrate human disturbance along corridors through Whitebark Pine habitat. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite 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. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. Finally, these figures serve the final rule as well as the environmental impact statement. The proposal reverses findings the Department made in 2001 about the effect of roadless protections on management, and this FACTS baseline is the factual finding on which that reversal rests. Where a new position rests on factual findings that contradict those underlying the prior policy, the explanation must be more detailed, not less. FCC v. Fox Television Stations, 556 U.S. 502, 515–16 (2009); Encino Motorcars, LLC v. Navarro, 579 U.S. 211, 221–22 (2016). I request that the final rule preamble address the corrected figures and the disaggregated series directly, and not by cross-reference to the FEIS response-to-comments appendix. Rescission serves the fewest. The Rule serves the most. Keep the Rule. Warm regards, Daniel Volkmann

I am a rock climber, whitewater kayaker, angler, hiker, mountain biker, hunter, and equestrian who uses inventoried roadless areas constantly, and I do volunteer trail work myself. I also have a friend whose primary job is conducting professional fishery surveys on rivers like the Colorado, and another friend who works for the U.S. Geological Survey doing sonar-based hydrographic surveys — work that depends directly on the low-sediment water conditions this rule would put at risk. This rule guts the resource all of that depends on, and it should be withdrawn. USDA's own numbers admit near-term timber gains would be "modest and localized," yet the rule could impose over $100 million/year in net costs, including $6.1 million annually in lost recreation value — while the agency already carries a $6.9 billion road/bridge maintenance backlog it can't fund. You're proposing to build more roads you already can't maintain, to chase benefits you can't quantify. That's not policy, it's vandalism with a cost-benefit annex. This isn't a close legal call. USDA's rationale — that NFMA forest-level planning, not a national rule, is the right vehicle here — is the exact argument Wyoming made trying to kill this rule, and the exact argument the Tenth Circuit rejected in Wyoming v. USDA, 661 F.3d 1209 (10th Cir. 2011), holding nothing in NFMA "precludes national action on a conservation issue within the power of the Forest Service," and reinstating the Rule nationwide. Kootenai Tribe v. Veneman, 313 F.3d 1094 (9th Cir. 2002), and California ex rel. Lockyer v. USDA, 575 F.3d 999 (9th Cir. 2009), went the same way. USDA is relitigating a theory that has already lost twice. Under State Farm, 463 U.S. 29 (1983), and Encino Motorcars v. Navarro, 579 U.S. 211 (2016), an agency reversing a 25-year policy with entrenched reliance interests owes a "more detailed justification," not less. USDA's own preamble instead asks commenters to do its reliance analysis for it. That is precisely the abdication those cases forbid. Roadless watersheds supply drinking water to roughly 25 million Americans (PLOS Water, 2026) — over a third of Colorado's and New Mexico's populations. An onX analysis found 99% of Wyoming's roadless acreage functions as elk security habitat, the exact kind of low-road-density cover big game and Pittman-Robertson-funded wildlife management depend on. Roads and logging degrade the cold, clean headwaters that trout, salmon, and steelhead need, undermining Clean Water Act antidegradation protections (40 CFR §131.12) and, for anadromous fisheries, Magnuson-Stevens Essential Fish Habitat obligations. Whitewater and scenic values on Wild and Scenic-eligible rivers running through these areas are equally at risk. The wildfire justification doesn't hold up either: risk to communities is concentrated in the wildland-urban interface, which the agency can already treat under existing exceptions, not in remote backcountry this rule would newly expose to roads. USDA's own notice admits the "majority sentiment among Tribal governments consulted is opposition," citing threats to sacred sites, subsistence resources, and treaty rights, and admits a failure to fulfill trust and consultation obligations — obligations that carry the "highest responsibility and trust," Seminole Nation v. United States, 316 U.S. 286 (1942). ANILCA §810 requires a subsistence evaluation before, not after, action in Alaska. And procedurally: this comment period is 30 days with zero public hearings, following a truncated 21-day notice period on which 99% of 220,000+ comment letters opposed rescission. The 2001 Rule was built on 600+ hearings and 1.6 million comments. That is not a good-faith effort to hear from the public — it's a box-checking exercise on the way to a predetermined outcome. Withdraw this rule. If site-specific flexibility is genuinely needed, the existing state-petition process (5 U.S.C. §553(e); 7 CFR 1.28) already used by Idaho and Colorado is the right tool — not eliminating baseline protection for 44.7 million acres of the last big wild country left in the National Forest System. Full legal analysis, additional statutory citations (Wild and Scenic Rivers Act, Clean Water Act, Magnuson-Stevens Act, Pittman-Robertson Act, National Trails System Act, NEPA, ESA), and complete source list are provided in the attached comment letter, which I incorporate by reference.

I regularly visit the inventoried roadless areas of the Sam Houston National Forest in Texas (Big Creek, Winters Bayou, Big Woods, Little Lake Creek) and formerly visited the San Bernardino National Forest. I oppose the rescission and comment on both the proposed rule and the Draft EIS. I request a specific response to each numbered item in the Final EIS. 1. The cost-benefit analysis does not support the action The preamble estimates annual recreation losses of about $6.1 million against $5.2-11.4 million a year in Treasury and Forest Service revenue, a figure assuming harvest across every operable acre, which the Department calls unlikely. It states these against a $6.9 billion road maintenance backlog, and concedes impacts could exceed $100 million. The FEIS should state plainly whether the projected timber revenue exceeds the lifecycle maintenance cost of the roads required to obtain it. If it does not, the economic rationale fails. 2. The wildfire rationale is contradicted by the Rule's text 36 C.F.R. § 294.13(b)(1)(ii) already permits cutting generally small diameter timber to maintain or restore ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects. Section 294.12(b) permits roads for public health and safety. Nothing restricts prescribed fire, managed wildfire, hand thinning, or mastication. Small diameter material is what fuels reduction targets; the Rule restricts commercial removal of large trees, which is not fuels reduction. The preamble concedes that greater public access can increase human caused ignition potential. The Department cites the Rule's statement that such cutting "is expected to be infrequent," but that states an expectation, not an operative limit: it sets no cap and adds no approval condition. I therefore request that the FEIS identify, by project name, forest, and year, each hazardous fuels project in the last ten years a responsible official could not implement solely because of the 2001 Rule. Without this list, the stated purpose lacks record support under Motor Vehicle Mfrs. Ass'n v. State Farm, 463 U.S. 29 (1983). 3. The treatment statistic does not establish causation The low treatment rate in high hazard roadless acreage since 2014 is equally consistent with appropriation limits, workforce capacity, and WUI prioritization. The preamble itself says budget and physical constraints will limit road construction after rescission, conceding the constraint is fiscal. The FEIS must analyze these rather than assume the Rule is the cause. 4. Reliance interests are unaddressed The Department invites comment on reliance interests. Reversing a twenty five year policy requires more detailed justification where serious reliance interests exist (FCC v. Fox Television, 556 U.S. 502 (2009); Encino Motorcars, 579 U.S. 211 (2016)). Land management plans were revised against this backdrop and allocated timber production elsewhere; recreation businesses, outfitters, and water providers invested on the same assumption. The proposal analyzes none of it. 5. "This rule authorizes nothing" does not excuse NEPA analysis The Department justifies rescission by its expected effects while failing to analyze them. Its own figures, permanent roads newly permissible across 18.2 million acres and temporary across 11.3 million, are foreseeable consequences NEPA requires it to examine. The FEIS must quantify sediment and drinking water impacts, ESA effects and § 7 status, and cumulative effects with the reinstated Alaska Roadless Rule and E.O. 14225 timber targets. 6. The range of alternatives is inadequate The DEIS carries forward only three alternatives: no action and two rescission variants. No intermediate conservation alternative was analyzed in detail, including those Tribes requested. The FEIS must analyze: (a) retaining the Rule while broadening and streamlining the § 294.13(b)(1)(ii) fuels exception near the WUI, with mandatory temporary-road decommissioning (b) a state and Tribal petition process (c) delegating exception approval to forest supervisors, with deadlines (d) geographically limited rescission supported by unit-level evidence 7. The process is inadequate The Department allows 30 days for a proposed rule, three volume Draft EIS, and cost benefit analysis governing 58.5 million acres, with hearings only in Alaska under ANILCA § 810. Of 64 Tribal consultation requests, 29 have been held, and the Department acknowledges majority Tribal sentiment opposes the rescission. I request a comment period of no fewer than 90 days, hearings in each affected state, and completed tribal consultation before any final action. Requested action: withdraw the proposal and retain 36 C.F.R. Part 294, Subpart B. Alternatively, extend the comment period, hold hearings outside Alaska, complete consultation, and analyze the item 6 alternatives. Respectfully submitted, an anonymous member of the public