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I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. My name is Dawson Autry and I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

I heavily oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would result in the destruction of America's public lands. It would undermine the protections we have in place for these forests, clean water, and wildlife refuges. And, it would severely impact recreational opportunities that enrich the lives of millions of Americans. As an American who takes great pride in the beauty of nature we have managed to protect thus far, I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in The Colony, Texas. While this rule does not affect my daily life at home, it does affect millions of Americans, trees, and wildlife who depend on the areas that this rule protects. These areas have countless benefits and reasons to keep them protected under federal roadless rule, whether it be protection of clean drinking water, protection of animal habitats, economic benefits from tourism, or improved mental health benefits by providing recreational forested areas. The pride that the American people have in a government that protects its forests cannot be understated. These are areas I travel to often to visit in Washington, Oregon, and California. There are many more states, parks, and forests I wish to visit in my lifetime, precisely because they are protected and cared for by rules like the Roadless Area Conservation Rule. I sincerely hope that my children and all future generations of Americans would get that same opportunity. Short term benefits are not worth sacrificing these areas for, these areas must be protected with everything we have. On January 12, 2001, the Forest Service promulgated the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System. The stated "Rationale for the Proposal" does not at all adequately install proper protections for these areas in equal to what the Roadless Area Conservation Rule provides at a federal level. To quantify a single case, under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections. That is one state losing protection for over 1 million acres. When you widen the impact of removing this rule to other states as well, the impact is truly massive and truly horrifying. The Summary of Potential Impacts section states some benefits to the removal of the Roadless Area Conservation Rules. Namely, items such as: 1. "Rescinding the 2001 Roadless Rule would increase opportunities for hazardous fuel treatments in the wildland-urban interface, where 9.8 million acres (or 24 percent) overlap with inventoried roadless areas, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure." 2. "This expansion could increase road-based recreation and accessibility improvements..." 3. "Management Flexibility" 4. Economic gains like increased timber and "access for minerals or energy uses" While I can understand that there may have been some good intention behind the proposal, I want to stress the importance that the broad removal of a federal protection is not the way to achieve these goals. Loss of federal protection will simply result in the gradual erasure of the 18.2 million acres that this rule protects. That is natural land that will either be sold away to corporations or cut-through and paved over with roads. That is natural land that America and the wildlife who inhabited it will never get back. Your proposal has already mentioned several of the environmental and economic impacts that the removal of this rule can cause. It also places a price on these impacts. I urge you to look beyond the bottom line and the immediate price these actions may cause, because the ramifications of removing protections on such a broad scale are much, much greater, and the effects will be felt each and every year from the day they are removed. This is an action that will affect all future generations of Americans. By removing this rule, we would potentially be sacrificing their futures to enjoy the beautiful lands of the United States of America. America is beautiful and deserves to be protected. Once again I strongly urge you to reconsider. Fully or partially removing the Roadless Area Conservation Rule would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

The 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244) should remain in place. The proposed new rule would be extremely harmful to our national forest - all ~ 47 million acres. I object to the prposed new regulation.

Re: Special Area; Roadless Area Conservation Docket No. FS-2025-0001 RIN 0596-AD66 I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule because its claimed wildfire management benefits do not justify the environmental, recreational, and fiscal costs. I am a native New Hampshirite and hike or backpack in the White Mountain National Forest (WMNF) once or twice a month. Some of its wildest areas - like Lincoln Woods, the Sandwich Range and Mount Chocorua, and areas surrounding the Pemigewasset Wilderness - lie within the 235,000 acres of Inventoried Roadless Areas (IRA) in the WMNF [1]. These landscapes help draw roughly six million people annually [2]. The rescission of the Rule places them at risk from commercial timber harvesting. I argue three points against this proposed rescission: 1. Wildfire Management Benefits are not Proportional to Environmental Risks The Rule already allows substantial wildfire risk management, so the Forest Service’s rationale that a full repeal is needed for wildfire mitigation is flawed. Under 36 C.F.R. § 294.13(b)(1), small-diameter timber may be cut or removed to maintain or restore ecosystems, including to “reduce the risk of uncharacteristic wildfire effects.” The Forest Service also stated that “hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule, so long as road construction or reconstruction is not necessary.” 66 Fed. Reg. 3244, 3258 (Jan. 12, 2001). The Rule separately permits road construction when necessary to protect public health and safety from an imminent threat of fire or another catastrophic event. 36 C.F.R. § 294.12(b)(1). I concede that rescission would provide managers more flexibility, but that does not justify eliminating nationwide protections. New roads fragment habitat, increase erosion and sedimentation, and increase human access; the proposed rule itself acknowledges that “greater public access can increase human-caused ignition potential.” 91 Fed. Reg. 53829 (2026). If additional access is needed in particular high-risk forest, “especially in the Western United States,” the Forest Service should adopt targeted exceptions instead of repealing the Rule nationwide. 2. Harm to Scenic Value and Recreation Beyond environmental significance, the WMNF is the crown jewel among NH’s natural assets that support major tourism and outdoor recreation activity. This activity supports 30,000 jobs and contributes $4 billion to the state’s economy annually [2]. The Forest Service acknowledges that rescission could cause “noise, visible infrastructure, and temporary closures” and reduce opportunities for “quiet, remote and self-reliant recreation.” What’s more, the estimated $6.1 million in annual lost recreation is likely an underestimate because the analysis relies heavily on assumptions and admits substantial uncertainty about what and where development would actually occur. In a heavily visited forest like the WMNF, those losses deserve substantial weight. Commercial access that degrades remote landscapes should not be expanded absent a demonstrated public benefit. 3. New Roads are Difficult to Justify Amid a $6.9 Billion Maintenance Backlog The Forest Service already faces a multi-billion dollar backlog of deferred maintenance for its existing roads. 91 Fed. Reg. 53829. It acknowledges that timber harvest and vegetation management would likely create the greatest demand for new roads, and that expected timber-efficiency gains would be “incremental” and constrained by road costs, maintenance funding gaps, and the $6.9 billion backlog. It is fiscally irresponsible to open areas to taxpayer-funded road expansion for the benefit of private timber harvesters when the agency can’t afford to maintain existing infrastructure. Limited Forest Service resources would be better directed toward maintaining existing infrastructure than opening currently roadless lands to additional development. In sum, I request that USDA withdraw the proposed rescission and retain the 2001 Roadless Rule. If the agency concludes that additional management flexibility is necessary for wildfire risk reduction in particular regions or circumstances, it should pursue narrowly tailored amendments that preserve the Rule's nationwide baseline protection while addressing demonstrated management needs. Stripping all protections is an unnecessary excuse to open these delicate ecosystems to extractive industrial activities. [1] https://newhampshirebulletin.com/2026/09/14/repub/unique-stretch-of-new-england-forest-under-threat-after-proposed-rollback-of-roadless-rule/ [2] https://www.unh.edu/news/whos-visiting-new-hampshires-white-mountains

Please DO NOT rescind the Roadless Area Conservation Rule (66 FR 3244) at 36 CFR 294 Subpart B!!!!!!!!!!!!!!!!!!!!!!!!!!!!! This is a terrible idea that will lead to wholesale destruction and development of millions of acres of wilderness, destroying ecosystems and critical habitat for plants and animals for whom that landscape is HOME. It's not a negotiable commodity subject to prerogative management, it is their food and shelter and their survival depends upon keeping it intact. Furthermore, research shows that increased roads and human accessed areas actually INCREASES wildfire risk, as the vast majority of wildfires are human caused. As someone who lives in an area increasingly ravaged by catastrophic fires, doing anything to heighten that risk is not only poor management, it's outright reckless and incompetent. I'm so tired of politicians and corportations seeing natural landscapes as something on a commodities balance sheet. Roadless places are not unused or empty, they are being used by the thousands of plants, animals, and insects that have called them home for eons longer than humans have even been around. The idea that we are somehow set apart from nature and do not rely on keeping this places intact is sheer hubris, ignorance, and arrogance. We destroy wild places to not only their peril, but our own. I vehemently oppose rescinding the Roadless Rule, as do the vast majority of Americans. Please do your job and represent OUR voices, not those of corporations who stand to profit from the destruction of some of the last remaining intact wild places we have.

The continental United States is very large, but has very few wilderness areas. Consequently those that do exist, particularly those in the densely populated part of the country that lies to the East of the Mississippi river, have outsized ecological and recreational value. The proposal to rescind the Roadless Area Conservation Rule (66 FR 3244) has the potential to render the United States more domesticated and more European in character. This would dramatically decrease my enjoyment of the few wilderness areas I have access to, including the Pemigewasset wilderness in New Hampshire's White Mountain National Forest. I would encourage the Forest Service to reconsider the proposed rescission of 66 FR 3244 and maintain the Roadless Area Conservation Rule in its current form.

The natural beauty of this country should not only be celebrated. It should be honored, and it should be protected. These places are a gift, and they are our responsibility. On that understanding, I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The procedural record behind that rule is itself a statement about how seriously the public takes these lands. The agency held more than 600 public meetings and received 1.6 million comments to write it. It has held none to undo it. That asymmetry alone deserves acknowledgment, and the substantive problems in the proposal compound it. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). This asks the public to comment on something the agency has already declined to analyze. Plan amendments are a foreseeable and stated consequence of rescission. They are not hypothetical. Treating them as outside the scope of this action while simultaneously soliciting comment on them is not a coherent procedure. I ask that the agency analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action, and explain in the record why it was originally excluded. The carbon question receives the same incomplete treatment. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. That figure is presented and then set aside. The DEIS concludes that these lands will continue to sequester and store carbon, but it offers no analysis of what happens to storage and sequestration under the alternatives that permit harvest and road construction. Stating a number and drawing a conclusion without connecting them is not analysis. I ask that the agency quantify the projected change in carbon storage and sequestration under each alternative before finalizing this action. On the core legal question, The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule. An agency is entitled to change its position. It is not entitled to reverse a factual finding without explaining what changed and why the prior evidence no longer holds. Nothing in the proposal identifies the evidence supporting the reversal or engages with the agency's own prior finding. The agency must do that, and must do it in the record. Finally, the economic treatment of recreation and small business is internally contradictory. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The certification reaches its conclusion by distributing loss across every small firm in the sector nationally, not by examining the outfitters and guides actually holding permits in the areas at issue. Some of those firms may lose the receipts that sustain them entirely. Spreading a concentrated loss across a national average firm obscures rather than analyzes the impact. The certification should be withdrawn and replaced with an assessment of the small entities actually operating in the potentially affected roadless areas. These places are a gift and they are our responsibility. The children who will inherit them deserve a decision built on complete analysis, honest accounting of what is being given up, and a procedural record proportionate to what is at stake. This proposal does not yet meet that standard.

RE: Docket FS-2025-0001, RIN 0596-AD66, Roadless Area Conservation proposed rule Introduction My family has held a recreation residence permit on a national forest since the 1930s. Wildlife has been one of the great gifts of our time there: elk and deer, birds, trout in the creek, and the occasional sign that something larger passed through at night. Those animals are there because large, unbroken country still surrounds us. I am commenting on how rescinding 36 CFR part 294, subpart B would affect fish and wildlife habitat. What I am addressing My comment concerns the environmental analysis of habitat fragmentation and effects on threatened, endangered, and sensitive species. Analysis Roads break up habitat. Wildlife research has documented for decades that roads increase disturbance and mortality, spread invasive weeds, raise poaching and harassment, and create barriers for animals moving between seasonal ranges. Elk, bears, and many other species avoid roaded areas. Fish suffer when road sediment fills the gravel they need for spawning. The value of a roadless area for wildlife is not only the acres inside it but the connections between them. Roadless areas often serve as refuges during drought and fire and as sources from which animals recolonize nearby land. As conditions change, wildlife will need large, connected landscapes even more. The 2001 rule covered 58.5 million acres of inventoried roadless areas (66 Fed. Reg. 3244, Jan. 12, 2001), and the current proposal would remove protection from more than 44 million acres. A change of that size affects habitat for many listed and sensitive species. The public needs a full, area-by-area accounting of those effects. A general statement that future projects will be reviewed individually is not enough, because cumulative fragmentation happens one project at a time and is rarely assessed as a whole. Recommendations 1. Retain 36 CFR part 294, subpart B and select the no-action alternative. 2. Complete and publish formal consultation under the Endangered Species Act on the rescission as a whole, not only on later site-specific projects. 3. Include in the final analysis a cumulative habitat fragmentation assessment, including effects on wildlife movement corridors and native fish strongholds. 4. Identify the roadless areas that function as refuges for listed species and explain how they would be protected if the rule is removed. Conclusion Once a road divides habitat, that habitat does not recover on any timeline that matters to the animals living there. Please keep the 2001 Roadless Rule.

RE: Docket FS-2025-0001, RIN 0596-AD66, proposed rescission of 36 CFR part 294, subpart B Introduction My family has held a Forest Service recreation residence permit since the 1930s. Our cabin is on one national forest, but I see the Roadless Rule as larger than any single place. I am commenting on the agency's stated goal of prioritizing local decision-making over a uniform national rule. Background USDA has said the rescission would "prioritize local agency decision-making over regulatory rules that are the same across the country." My comment addresses whether that rationale holds up, given how the 2001 rule actually works. Analysis The 2001 rule is not a rigid ban. It allows roads to protect public health and safety in cases of imminent threat of flood, fire, or other catastrophic event (36 CFR 294.12(b)(1)). It allows cutting of generally small-diameter timber to improve habitat or reduce wildfire risk (36 CFR 294.13(b)(1)). It respects existing rights. Local forest managers have used these provisions for twenty-five years. The rule sets a baseline and leaves real room for local judgment. Without a national baseline, each roadless area will be defended one project or forest plan at a time. That shifts a heavy burden onto the public, who must track and comment on many separate local decisions, often with little notice. Some areas will be lost simply because no one had the time or resources to respond to a particular proposal. A national rule exists so the public does not have to fight the same question in every forest. The values at stake are national. The 2001 rule found that roadless areas include 354 municipal watersheds contributing drinking water to millions of people (66 Fed. Reg. 3244, Jan. 12, 2001). They store large amounts of carbon in mature and old forests. They include places such as Alaska's Tongass, among the most intact temperate rainforests on Earth. People in every state rely on these lands for water, wildlife, and recreation, whether or not they live near them. I also ask the agency to explain which specific local management needs the current rule has prevented, with examples. If the existing exceptions have been enough, then the local decision-making rationale does not justify rescission. Recommendations 1. Retain 36 CFR part 294, subpart B as the national baseline and select the no-action alternative. 2. If particular forests face specific needs, address them through targeted, site-specific changes with full public notice, rather than removing protection nationwide. 3. Publish examples of local management actions the rule has actually blocked since 2001. Conclusion The current rule already balances national protection with local flexibility. Please withdraw this proposal and keep the 2001 Roadless Rule.

RE: Docket FS-2025-0001, RIN 0596-AD66, Special Areas; Roadless Area Conservation Introduction I am in my forties, which means I am among the people who will live longest with the outcome of this rulemaking. My family has held a recreation residence permit on a national forest since the 1930s. The cabin and the forest around it have been passed through the generations before me, and I hope to pass the experience of that forest on to the generations after me. I am commenting on how the proposed rescission of 36 CFR part 294, subpart B shifts costs onto future generations. What I am commenting on My comment addresses the cost and benefit analysis, especially the long-term costs that would fall on future taxpayers and forest users. Analysis My generation is inheriting many bills: aging infrastructure, more severe fire seasons, and growing pressure on water supplies. This proposal would add to them. In 2001 the Forest Service reported a backlog of about $8.4 billion in deferred maintenance and reconstruction on more than 386,000 miles of existing roads (66 Fed. Reg. 3244, Jan. 12, 2001). Every new road becomes a maintenance obligation for decades, long after any timber revenue has been spent. Those future costs should be counted in today's analysis, not left for later budgets. At the same time, roadless areas are among the best long-term assets the public owns. They supply clean water without treatment plants, store carbon at no cost to taxpayers, shelter fish and wildlife, and give people somewhere to get away from the noise of everyday life. These benefits continue year after year. A road, by contrast, is a one-way door. Once an area is roaded and logged, it does not return to its earlier condition in my lifetime or my children's. The existing rule already allows the agency to fight fires, reduce fuels, and build roads where public safety requires it (36 CFR 294.12(b)(1) and 294.13(b)(1)). Rescinding it does not give the agency a tool it lacks. It only removes the safeguard. I ask the agency to use a long time horizon in its analysis. A short horizon makes timber revenue look large and long-term losses look small. A fifty-year view would show the true balance. Recommendations 1. Select the no-action alternative and retain 36 CFR part 294, subpart B. 2. Evaluate costs and benefits over at least fifty years, including road maintenance, water treatment, fire suppression, and lost recreation value. 3. Disclose who will pay the long-term maintenance costs for any new roads and how those costs will be funded. Conclusion I want the people who come after me to have the same chance I had: to walk into a forest that is still whole. Please keep the 2001 Roadless Rule.

I am opposed to the proposed rule that would rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244), which prohibits road construction, road reconstruction, and timber harvesting in inventoried roadless areas, with limited exceptions. Roadless areas protect clean water sources, wildlife corridors & habitat all resources that hunters, anglers, outfitters and millions of Americans value - and also oppose rescinding 2001 Roadless Area.

I strongly oppose the proposed administrative rescission of the 2001 Roadless Area Conservation Rule (66 FR 3244). Repealing these protections will not provide the benefits cited as the rationale for this action and will deeply undercut the economic, environmental, and cultural assets of this land. FULL COMMENT ATTACHED

The Forest Service cannot allow the roadless rule to be rescinded. It’s time for FS leadership to step up and protect our public lands from those who want to exploit it for their own personal gain. The roadless rule is more important than ever for both humans and wildlife, as our natural resources dwindle and climate change impacts the globe. Counter to what the current administration claims, we don’t need to “maximize the development and production of the natural resources located on both Federal and State lands…”. Our public lands deserve protection. Though the administration states the RR had been the “subject of extensive litigation”, it had, and has, strong bipartisan support. Years of work and analysis were put into passing the roadless rule; in fact, this effort had some of the greatest public participation in history. As you know, there were over 600 public meetings across 36 states, over 1.6 million public comments made, overwhelmingly in its favor. The rule offers consistent land management across states to avoid incremental loss of the “ecological characteristics and social values” of roadless areas. It provides lasting protection for roadless areas to preserve wildlife habitat, protect water quality, and provide recreational opportunities, among other benefits. The RR moved policy away from developing the FS road system to managing it in an environmentally and financially responsible way, reasons that still resonate today. It directs funds into roads that best provide access for current and anticipated management objectives as well as public uses of FS land. It emphasizes reconstruction and maintenance of needed roads, instead of putting funds into new roads that may not be adequately maintained. The current administration doesn’t offer much of an argument for rescinding the roadless rule. They say it’s to reduce regulatory burden and bring decisions down to the forest level. Decisions have always been made at the forest level with national guidance and over site. This is an appropriate strategy as public land is held as a national asset for all Americans and does not belong to any one state. Americans In Illinois have just as much of a stake in what happens to public land in Utah as those that live in Utah. Regulations are only a burden for those that feel the rules stand in the way of their desired outcome. Many that oppose this rule are looking to increase oil, gas, mining, and timber production, justifying it by declaring a national energy emergency. This action will cause undue harm by by failing to stop roads that have “the greatest likelihood of altering and fragmenting landscapes, resulting in immediate, long-term loss of roadless area values and characteristics” as outlined in 66 FR 3244 - 3245. There is also the claim it’s for wildfire mitigation, removing a one size fits all policy, yet the blanket policy of full suppression is currently an accepted strategy. This strategy goes against findings that full suppression of past wildfires lead to the build up of fuels which increases wildfire severity. The FS also found that a majority of fires are started along FS roads and result in more acres burned, making the addition of more roads counterintuitive if the goal is to increase wildfire mitigation. In 2025 hazardous fuel removal (mechanical and prescribed fire) fell to about half the number of acres treated in 2023 and 2024. Mitigation efforts should begin with reducing fuels in the many areas that do not fall under the roadless rule, rather than adding roads which increase the likelihood of wildfire.

I believe that the Conservation Rule (2001 Roadless Rule) (66 FR 3244), which prohibits road construction, road reconstruction, and timber harvesting in inventoried roadless areas, with limited exceptions should stay in effect and not be rescinded. We don’t need more roads , we need to take care of the roads we have and preserve as much wilderness as possible for the health of our home planet. We need to continue to review and approve only roads as needed. We don’t need to rescind a rule that works towards a seventh generation approach. I ask that you retain the roadless rule as is.

Why do trump and the miserable magats hate our planet? Protect nature. Do NOT rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244), which prohibits road construction, road reconstruction, and timber harvesting in inventoried roadless areas, with limited exceptions.

Re: RIN 0596-AD66, Docket No. FS-2025-0001 — Proposed Rescission of the 2001 Roadless Area Conservation Rule I strongly oppose the proposed rescission and ask the Department to adopt the No Action alternative. I live in Santa Cruz County, California, and have worked in mortgage lending on the Central Coast for 35+ years. I know what wildfire does to communities and home values, and I take the Department's concerns seriously. I have also supported the National Forest Foundation, the Forest Service's chartered partner; my contributions funded nearly 30,000 trees on national forest land. That taught me how slowly a damaged forest recovers, and that protecting intact forest is cheaper than restoring it. Rescission is not needed to address wildfire, and what it gives up cannot be restored. 1. The loss is permanent; the benefit, by the Department's own account, is small. The preamble says management opportunities "would be modest and localized." The projected timber gain (5 to 10 percent more sawtimber; $5.2 to $11.4 million per year) assumes harvest across all 4.8 million operable acres, which the Department calls "unlikely." Against that, it estimates recreation losses of $6.1 million per year and total effects that "could exceed $100 million." Roads are rarely undone, and the agency already carries a $6.9 billion road and bridge maintenance backlog. Once roaded, intact watersheds, habitat, and quiet backcountry do not return. Trading permanent loss for modest, uncertain gain is poor policy. 2. The 2001 Rule already permits the wildfire work the Department cites. The preamble says the prohibitions "removed important management tools." But the Rule expressly allows removal of "generally small diameter timber" to "reduce the risk of uncharacteristic wildfire effects" (36 CFR 294.13(b)(1)(ii)) and road construction "needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event" (§ 294.12(b)(1)). The real complaint is that these exceptions were used in a "limited and inconsistent" way due to reviews and approvals. That is an administrative problem with an administrative fix, not grounds to strip protection from 58.5 million acres. By the Department's figures, the wildland-urban interface covers only 24 percent (9.8 million acres) of the affected lands; three-quarters lies away from the communities the rationale is meant to protect. 3. New roads would add to wildfire risk. Roads bring people, and people start fires. A national study of 1992–2012 records found humans ignited 84 percent of U.S. wildfires and nearly tripled the fire season (Balch et al., PNAS, 2017). The preamble concedes access "can increase human-caused ignition potential." Roads can also open private inholdings to development, as the Alaska petition requests; each new home at the forest edge adds ignition sources, fragments habitat, and adds to what firefighters must defend. 4. Rescission removes the national floor and leaves future development unanalyzed. The proposal authorizes no projects, yet admits later plan amendments "could increase the area where timber harvest and road construction would be allowed," with impacts "beyond those summarized above," and treats them as out of scope. It also adds flexibility for oil, gas, and coal leasing. The analysis measures near-term effects under today's plans while removing the only national limit on tomorrow's. The cumulative effect across 100-plus national forests is not evaluated. 5. Public input would fragment. These lands belong to all Americans. The 2001 Rule followed a national process with about 430 public meetings (66 FR 3244). Under rescission, each area would be decided forest by forest; a Californian would have to follow dozens of proceedings to have the voice available today in one. Tribes agree, citing "the unsustainable burden of project-level review." The process is also rushed: 21 days of comment on the notice of intent, 30 (since extended to 45) on a decision affecting 58.5 million acres, and only 29 of 64 requested Tribal consultations held. Recommended alternative Retain the 2001 Rule. If fuel-reduction work is slowed, fix that narrowly: (a) streamline approval of the existing exceptions within the wildland-urban interface, e.g., by delegating to regional foresters with fixed deadlines; (b) keep using the state petition process (5 U.S.C. 553(e); 7 CFR 1.28), as Idaho and Colorado did. This serves the Department's objectives without stripping protection from the three-quarters of affected land outside the interface. I recognize the needs of timber-dependent communities and the danger of wildfire, but the Department's own numbers show modest, uncertain gains against permanent loss. I respectfully urge withdrawal of this proposal. In closing, this land is largely as nature created it. Whatever one's beliefs about its origin, humans must leave some lands wild and untouched. Respectfully submitted, Forrest Cambell

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The national forests belong to all of us, and to every generation that follows. I am asking the agency to keep the 2001 Roadless Area Conservation Rule in place and to address the specific failures in the record supporting its rescission. I want my children, and all children, to experience freedom in our great national forests and parks. The United States is beautiful because of these places. Tearing them down serves no public purpose I can identify, and the record before the agency does not persuade me otherwise. The agency has been down this road before, and lost. The record here shows that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That language comes from a prior attempt to substitute state-specific management for a single national rule, an attempt the Ninth Circuit rejected. The current proposal rests on the same premise: that local and state-level decision-making can substitute for national protection. The agency must explain, on this record, how the present proposal avoids the precise deficiencies that court identified the last time the agency tried this approach, and it must address its own prior finding that local decision-making can incrementally reduce roadless values of national significance. The proposal also asks the public to comment on consequences the agency has simultaneously placed beyond the reach of its own analysis. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). That is not a coherent analytical process. The agency cannot in good conscience invite public views on a foreseeable outcome while refusing to analyze it. I ask that the agency bring the foreseeable plan-amendment scenario, including the expansion of areas open to timber harvest and road construction, fully within the scope of this action before any final rule is issued. The carbon question is raised and then abandoned. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. Having stated that figure, the analysis does not follow it to its logical conclusion. There is no quantification of what happens to that stored carbon, or to ongoing sequestration, under the alternatives that permit harvest and roading. I care about what these forests hold and what they continue to do. The agency must quantify the projected change in carbon storage and sequestration under each alternative, because the number it cited is meaningless without that comparison. Finally, the agency has reversed a factual finding it made in 2001 without explaining what changed. The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule. An agency is not free to simply announce the opposite of what it previously found. It must identify what evidence or conditions justify the reversal and must engage with what it concluded before. That explanation is absent from the current record, and the agency must supply it. Please manage and care for this land. Nourish it so that it may live on for a hundred more generations of human and animal species alike. These forests are not ours to spend down. They are ours to pass on. Sincerely, Jenna Andrade Cranston, Rhode Island

The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule.

I oppose the rescinding of the Roadless Area Conservation Rule (66 FR 3244). Given the purpose of the rule was to "provide long-term protection of roadless areas across the National Forest System." It should be burdensome to overcome this rule or the protections for these areas are removed. The protections for federal lands should remain in place.

As a lifelong Alaskan and someone who has seen the devastation that the roadless rule has created to the communities in southeast Alaska, I am 100% in favor of rescinding the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244, 36 CFR Subpart B (2001)) The 2001 Roadless Rule was devastating for the communities in Southeast Alaska. Families that had lived in the area for generations were forced to move elsewhere to provide an economic solution for themselves and their children. The rule was unnecessary, ill planned, and didn’t recognize the economic hardship it would create for the people living in the area. The department itself put out a statement saying that they had concluded that the social and economic hardships to Southeast Alaska outweighed the potential long-term ecological benefits. The basis of that statement was that the Tongass Forest plan adequately provided for the ecological sustainability of the Tongass. The USDA made a policy determination in 2003, 2010 and 2020 stating, “Every facet of Southeast Alaska’s economy is important and the potential adverse impacts from application of the roadless rule are not warranted given the abundance of roadless areas and protections already afforded in the Tongass Forest Plan.” The National Forest System is already governed by statutes, regulations, and forest plans that provide meaningful conservation protections. Rescinding this rule would allow for the National Forest Land Management planning processes to function as they were originally intended. Thank you for your consideration.