Read the comments.

To the USDA Roadless Rule Team: As a Coloradan, and a wildlife enthusiast, I believe the 2001 rule is the single most important land management instrument and the threat of its removal is not only catastrophic but infuriating. Every year, I take a fall trip to explore these beautiful mountains and every year I am left with wonder. Seeing new wildlife, a new sunset, a new plant, a riverbed - it never ceases to amaze me. The protection of these ecosystems are imperative for us, but also for all. Being able to backpack through these undisturbed mountains and connect with other life is one of the few things that bring me joy and peace in such a hectic world. Roads end that possibility. Regarding the Mount Antero in the Pike & San Isabel NFs- Alpine and Subalpine Climate Refugia Connectivity — The area spans from 13,600 feet to 14,276 feet across multiple subalpine and alpine ecosystem types—Rocky Mountain subalpine spruce-fir forest, alpine tundra, and bristlecone pine woodland—creating an intact elevational gradient that allows species to shift their ranges as climate conditions change. This vertical connectivity is critical as warming temperatures push suitable habitat upslope; species dependent on cool conditions can only persist if they can move continuously to higher elevations without fragmentation. Road construction fragments this gradient by creating edge effects, altering microclimate through canopy removal, and introducing invasive species along disturbed corridors, which would trap populations in lower-elevation refugia that are becoming increasingly unsuitable. DEIS Narrative Exceeds the 150-Page Statutory Limit With No Extraordinary-Complexity Determination on the Record The Draft EIS exceeds the statutory page limit and contains no determination authorizing it to do so. Volume I of the Draft EIS is 333 pages. Its narrative text runs from the Introduction at page 9 through page 248. References Cited occupies pages 249 through 285, and the List of Appendices and Appendices 1 through 5 occupy pages 286 through 333. Excluding citations and appendices, as the statute directs, the environmental impact statement is therefore approximately 240 pages long. The applicable limit is 150 pages. 42 U.S.C. 4336a, enacted by the Fiscal Responsibility Act of 2023, limits an environmental impact statement to 150 pages excluding citations and appendices, and permits 300 pages only where the proposed agency action is of extraordinary complexity. USDA's NEPA procedures implement the same limits at 7 CFR 1b.7(a) and (i). The Draft EIS expressly adopts those procedures, stating at page 9 that the Forest Service "has prepared this draft environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA) and other relevant laws and regulations," and that "all references to 7 CFR 1b within this document refer to the interim rule." The document therefore exceeds the 150-page limit by approximately 90 pages. The only lawful basis for an environmental impact statement of this length is a determination that the proposed action is of extraordinary complexity. Volume I contains no such determination. The phrases "extraordinary complexity," "page limit," and "Fiscal Responsibility Act" do not appear anywhere in the document, and 42 U.S.C. 4336a is cited nowhere in it. The Draft EIS asserts compliance with "other relevant laws and regulations" while exceeding the one quantitative constraint those laws place on the document itself, and without invoking the exception that would authorize the excess. This is not a matter of formatting. The page limit operates together with 7 CFR 1b.7(i), which directs that issues not of a substantive nature receive the briefest possible discussion. A ceiling of 150 pages applied to a rescission affecting approximately 44.7 million acres of National Forest System lands compels the agency to compress its effects analysis, and the extent of that compression depends directly on which ceiling the responsible official was working to. A document written to 150 pages must omit substantially more analysis than one written to 300. The public reading this Draft EIS cannot tell which constraint shaped it, because the document never says - and the difference is roughly 90 pages of effects analysis across 44.7 million acres. I request that the responsible official make and document the extraordinary-complexity determination required by 42 U.S.C. 4336a and 7 CFR 1b.7(a) as the predicate for a Final EIS exceeding 150 pages, or, if no such determination is made, that the Final EIS text comply with the 150-page limit. Under 7 CFR 1b.7(f)(3), the response to this comment should cite where in the Final EIS or the supporting proposal record that determination is accounted for. A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this. CommentID: RLC-20261006-9WBQV3

I strongly oppose the USDA’s proposal to eliminate, weaken, or alter the Roadless Rule. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. As stated in the Draft Environmental Impact Report (DEIS), the Rationale for the Proposed Rule is to reinstate “….important management tools for key areas where there are needs or opportunities to address overgrown and fuel-loaded national forests.” Essentially, repealing the 2001 Roadless Rule will allow the construction of roads to facilitate management of overgrown and fuel-loaded national forests. However, the Department’s own analysis indicates that it will have the opposite effect. Page 85 of the DEIS states that “Past research and new analyses presented here indicate that more fires, both in absolute numbers and density, originate on other NFS lands compared to IRAs and wilderness areas. The DEIS goes on to state that “The proportion of human-caused fires in IRAs and wilderness is less than half that on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads.” Furthermore, the DEIS states that “the new analysis presented in this DEIS indicates that other NFS lands also have about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates. The number of “actionable” and reportable wildfires may also be generally greater in areas outside of roadless or wilderness areas.” The DEIS fails to analyze the economic benefits and reduced negative impacts of focusing management actions on “other NFS lands” compared to IRAs and wilderness area. As stated on page 26 of the DEIS, “Alternatives analyzed in detail must be technically and economically feasible and meet the purpose and need (NEPA section 102 (2 (c)(iii)), 7 CFR 1b.7(h)). Analyzing increased management of “other NFS lands” is technically and economically feasible and meets the purpose and need of “reducing regulatory burden” and providing “management flexibility”. For these reasons, I believe the Department has failed to comply with NEPA, and the 2001 Roadless Rule should remain in place until an additional alternative (increased management of other NFS lands) is fully analyzed. Sincerely, Jeff Stephens OR

I am a 57 year old Oregonian and CTO of a clearing broker-dealer. Like many of us, I care deeply about the public lands that comprise the American wilderness. I moved here from Texas over 15 years ago in large part due to the natural beauty and the wild outdoors, which are a direct result of our historic conservation and preservation of these spaces. National parks, national forests, state parks and forest, bureau of land management -- I spend as much time as possible in all of these places. They are the very heart and soul of America, and of The West, and we must protect them in every way. I just drove from Portland, OR to Eureka, CA down 101 with a brief stop in the wilderness along the Rogue River halfway between Powers and Agness on Forest Road 33. It is rough and slow going, as challenging and inconvenient as it is inspirational, breathtaking, life-affirming to see untouched wild spaces and vistas as stunning as crossing the Rogue River. Open any of this to development -- topple the first domino -- and complete destruction of our natural environs and wild spaces will proceed in what seems like a blink of an eye. Do this now, my yet-unborn grandchildren -- my kids are 21 -- will lose a birthright that has until now conveyed to all Americans, one of the most valuable and precious things we have. Please do not rescind the roadless rule. P.S. AI didn't write this, and I didn't ask for or receive any help from people or machines. Straight from my head and heart, filled with love and hope, with equal parts concern and conviction. Wilderness Acreage Figures at Page 195 Stated Without Any Citation The Draft Environmental Impact Statement states, at page 195 (Chapter 3, "Recreation Opportunities and Setting," Effects of Alternative 3 – Modified Rule, subsection "Wilderness"): "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation. The sentence is unsourced on its face. The next citation in the subsection, Landres et al. (2015), is attached to a different proposition — the five qualities of wilderness character interpreted from Section 2(a) of the Wilderness Act — and supports nothing about acreage. Nothing in the surrounding text identifies where either number came from, and a reader cannot trace either figure from the text to any entry in the literature cited. These are the two figures by which the Draft EIS characterizes the resource whose treatment under this rulemaking it then analyzes, and they are stated as fact inside the effects analysis for the Modified Rule alternative rather than in an introductory or background passage. National Wilderness Preservation System acreage is not a fixed quantity; it changes with each congressional designation, so a figure stated without a source and without a date cannot be checked by anyone. NEPA requires a "detailed statement" under 42 U.S.C. § 4332(2)(C). The Department's own procedures define substantive information to include information that meaningfully informs "compliance with applicable laws, executive orders, and regulations" (7 CFR 1b.11(a)(53)), and provide for "[m]aking factual corrections" as a response to a substantive comment (7 CFR 1b.7(f)(2)(v)). A headline resource figure that the public cannot trace to any source is not a verifiable element of a detailed statement. The agency cannot answer this concern by citing the passage in which the figures appear, because that passage is the one lacking the source. I request that the Final EIS do one of two things: (1) identify the source of both the 111.9-million-acre National Wilderness Preservation System total and the 36.7-million-acre National Forest System subset, state the date to which each is current, and add that source to the literature cited; or (2) if no source supports the figures as stated, correct them. Under 7 CFR 1b.7(f)(3), the response should cite where in the Final EIS or the supporting proposal record the action taken is accounted for.

My wife and I enjoy hiking, rafting, and the simple joys of bird and wildlife watching in the Chattahoochee-Oconee National Forest. We also make frequent visits to California and Oregon to explore the Redwood and Sequoia Forests. We oppose the rescinding of the Roadless Rule permitting road construction that would result in severe damage to these pristine ecological areas and threaten fish and wildlife species. Allowing roads to be built for logging or mining equipment will have numerous devastating impacts: 1- Roads are the primary cause of the introduction of invasive, non-native species that can overwhelm native wildlife. 2- Roads increase sedimentation that seriously pollutes water quality, affecting not only fish, amphibian, and reptile life in the streams but ultimately groundwater that can impact the natural aquifers from which humans draw their drinking water. 3- Road stream crossings create a barrier to fish movement in national forests and restrict spawning and propagation of trout and other aquatic life. 4- Road construction introduces potential landslides and erosion that destroy established forest roots and slope stability resulting in potential floods and stream sedimentation. 5- The introduction of livestock can cause overgrazing which adversely affects species dependent on grasses for feeding or ground nesting, increasing runoff and soil compaction. 6- Roads can interrupt fires necessary for fire-dependent ecosystems while increasing the possibility of uncontrolled wildfires due to campsites or cigarettes thrown from vehicles. Road construction in roadless areas is the primary cause of ecosystem destruction and endangering wildlife. For these reasons, in addition to the aesthetic loss of our national treasures, we vehemently oppose rescinding the Roadless Rule. Facilitating energy, mineral, and timber production “to the maximum possible extent” on public lands will cost our nation far more in ecological desecration than will be compensated by short-term revenues they generate. We urge you to support H.R. 3930, the Roadless Area Conservation Act, to provide lasting protection for inventoried roadless areas within our treasured National Forest System. The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range — "a 4 to 10 percent increase in total sawtimber harvest" (p. 30) — and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics. I request that the Forest Service supplement the analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and of the resulting sedimentation and fragmentation across the potentially affected environment under each action alternative, at the level of specificity the DEIS applied to the Tongass National Forest at pp. 238-239, and cite in the final EIS where that supplemented analysis is accounted for, as 7 CFR 1b.7(f)(3) provides.

Despite a short comment period, over 625,000 people submitted letters of signed petitions, with the vast majority opposed to rescission of the Roadless Rule. The draft EIS reports public-participation figures derived from a comment-screening process that used a definition of “substantive” that is no longer in effect. Under the definition now in effect, a compliance comment is substantive on its face, with no showing of impacts required. This must be corrected. Because the draft EIS states that comments received “were used to inform the range of alternatives and environmental impact analyses,” a screen that undercounted compliance comments carried forward into the range of alternatives analyzed in this draft EIS. The Forest Service needs to: 1. Correct Appendix 3, footnote 72, and the statement at p. 9 and footnote 1 to state the definition of “substantive” at 7 CFR 1b.11(a)(53), as amended effective April 3, 2026, including the compliance limb, and identify which version governed the screening of each comment record; 2. Re-screen the NOI comment record and the comments on this draft EIS against the operative definition, and disclose in the final EIS the number of comments that are substantive under it but were not substantive under the interim-rule definition, together with any resulting changes to the themes, concerns, and recommendations reported in Appendix 3 and to the range of alternatives those comments informed; and 3. Disclose, with the reported figures, the counting rules that produced them — how a “comment letter” was distinguished from a “submission,” how petition signatures were attributed, and the criteria by which a letter was classified as “generally opposed” or “generally in support” — so that the 99 percent / 1 percent characterization rests on a stated and reviewable basis. Because the reported comment figures and the screening standard behind them bear on the agency’s explanation of its change in position, this concern is addressed to the final rule preamble as well as to the final EIS appendix. Roads kill wildlife. They degrade water quality and habitat. Over 80 percent of wildfires nationwide are human-caused. Repeal of the Roadless Rule is a terrible idea.

I am deeply concerned about the proposed rescission of the Roadless Rule. As someone who lives within Superior National Forest, I spend significant amounts of time hiking, camping, hunting, and fishing in Roadless Areas, both locally and on my journeys through western states. I am deeply concerned that rescinding the Roadless Rule will greatly impact my ability to hunt, fish, gather, travel by non-mechanical means, and recreate on my own public lands. If more of my Forests have roads through them, it greatly reduces the opportunities and access to the land- if there are more and more roads, I have to travel further and further to get away from them. I am additionally concerned about the issues that arise when people in vehicles have increased access to our Forests- significant increases in unintentional wildfires, significant increases in invasive species and aquatic invasive species, and degradation of soil and water quality. I hope the agency will do the right thing and not rescind the Roadless Rule. We have plenty of roads and plenty of access to our public lands as things are currently. The agency’s time and my tax payer dollars would be much better spent improving the hundreds of miles of National Forest roads and hundreds of NF buildings that are currently in disrepair. Additionally, I must point out: Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

To Whom It May Concern: I respectfully request that you do not rescind the Roadless Rule, for many reasons. I will set out just a few here. First, The rationale for the proposed rule is not merely unsupported; it is contradicted by the analysis printed in the document proposing it. I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3). Second, because 36 CFR 294.13(b)(1)(ii) (2001) already authorizes the fire-risk and forest-health treatment the purpose and need in the proposed rule identify, an alternative that retains the 2001 Roadless Rule while streamlining the review and approval process for exceptions under 36 CFR 294.12(b) and 294.13(b) (2001) - including the national tracking of requests, approvals, denials, and processing times whose absence the DEIS concedes at p. 14 - will meet the stated need without rescission. I request that this alternative be developed and evaluated under 7 CFR 1b.7(f)(2)(ii). If it is not carried forward, 7 CFR 1b.7(h)(3) requires the agency to state its reason; a reason that the alternative does not meet the purpose and need is unavailable while the purpose and need rests on the misstatement identified in item 1 and the unsupported causal claim identified in item 3. Because the Rationale for the Proposed Rule is also the agency's explanation for reversing a position it has maintained since 2001, I direct this concern to the final rule preamble as well as to the final environmental impact statement. There are many examples in the proposed rule of unsupported justifications and assertions contradicted by the agency's own data, too many to list here in detail within the character limitations. Important data are missing. Generally, rescission of the roadless rule will change the default from "don't build" to "build roads" on these priceless public lands in a time of significant and worsening climate change and immense habitat loss. Populations of nearly every species of wildlife are in decline. The government has not proved the need to increase roads in these areas. Finally, the public response is overwhelmingly opposed to rescission of the roadless rule. And who is the ultimate owner of these lands? The public. These precious areas must be left as untouched as possible for future generations. Thank you.

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

Dear Secretary Rollins and Chief Schultz: I am writing to express my strong opposition to the recission of the 2001 Roadless Rule. The Roadless Rule is supported by peer reviewed research as well as the Forest Service's own analysis, and I want the land I love spending time to be protected in the future. I am concerned about fire risks associated with expanding roads and the potential impact on water quality, especially for major cities like Los Angeles that get most of their water from the Sierras. The DEIS's Own Tables 14 and 21 Contradict the Rationale's Forest-Health Causal Chain. The Rationale for the Proposed Rule states 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” (DEIS p. 19). The comparative data the DEIS itself publishes contradict each step of that chain, and the FEIS must correct or withdraw the assertion. First, fire. Table 21 (DEIS p. 98) reports ignition density from the Interagency Fire Occurrence Reporting Module for 2014–2024: human-caused ignitions at 3.0 fires per million acres per year within potentially affected IRAs against 22.4 on other NFS lands, and natural ignitions at 8.5 against 16.8. The DEIS’s own text on that page explains why, finding that ignitions “increase in abundance with proximity to roads, supporting the notion that roads facilitate human access” and in turn more human-caused fires. The access the proposed rescission would restore is the variable the agency’s own data associate with a sevenfold higher human ignition rate. Second, the premise that the 2001 Rule produced a lack of active management. The DEIS reports that the Forest Service Activity Tracking System shows “an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs” over the last decade (p. 15). On the same pages it concedes that “There is no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions” (p. 14), and at p. 75 that while “Some of this annual mortality is observed within IRAs,” it is “not possible to characterize the mortality observed on IRAs on a national scale.” The agency thus states that it can measure neither the exceptions actually granted nor the roadless-specific mortality outcome, while asserting a causal relationship running from the first to the second. The rationale is therefore not merely unsupported; it is contradicted by the analysis printed in the same document. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A). Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not pass over a risk the record permits it to analyze). I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3). The Department should not rescind the 2001 Roadless Area Conservation Rule. CommentID: RLC-20261007-FAEAQ6

I implore you not to rescind the Roadless Rule. Having struggled with severe depression all my life, I cannot overstate how important these wild lands are to me. In my lows of loneliness and isolation, the one source of love, of community, of acceptance I could count on has been forests like the ones whose protections you consider removing. In an America without wild, roadless lands, where a person in pain can no longer retreat to the healing solitude of nature, I would have ended my life long ago. It breaks my heart to think of the harm rescission would do to the species who live on these lands, not to mention the people like me who depend on them for solace. The Rationale for the Proposed Rule states 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” (DEIS p. 19). The comparative data the DEIS itself publishes contradict each step of that chain, and the FEIS must correct or withdraw the assertion. First, insect and disease. Table 14 (DEIS p. 75), “Percent of NFS forested acres at risk of tree mortality due to major forest insects and diseases, by land classification,” sets the actively managed lands — NFS ownerships outside designated areas — against inventoried roadless areas in the potentially affected environment. Northern Region: 50.4 percent outside designated areas against 34.2 percent in IRAs. Southwestern: 17.5 against 13.5. Pacific Southwest: 18.9 against 15.2. Pacific Northwest: 34.7 against 23.5. The DEIS states the conclusion in its own words on the same page: “the percent of forests at risk is similar or lower in potentially affected IRAs when compared to NFS forests outside of designated areas.” In the four western regions holding most of the roadless estate, the lands the rule has restricted from vegetation management carry less insect and disease risk than the lands it has not. Second, fire. Table 21 (DEIS p. 98) reports ignition density from the Interagency Fire Occurrence Reporting Module for 2014–2024: human-caused ignitions at 3.0 fires per million acres per year within potentially affected IRAs against 22.4 on other NFS lands, and natural ignitions at 8.5 against 16.8. The DEIS’s own text on that page explains why, finding that ignitions “increase in abundance with proximity to roads, supporting the notion that roads facilitate human access” and in turn more human-caused fires. The access the proposed rescission would restore is the variable the agency’s own data associate with a sevenfold higher human ignition rate. Third, the premise that the 2001 Rule produced a lack of active management. The DEIS reports that the Forest Service Activity Tracking System shows “an average of 500 acres per year of timber harvest and a total of 1.8 million acres of hazardous fuels reduction within IRAs” over the last decade (p. 15). On the same pages it concedes that “There is no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions” (p. 14), and at p. 75 that while “Some of this annual mortality is observed within IRAs,” it is “not possible to characterize the mortality observed on IRAs on a national scale.” The agency thus states that it can measure neither the exceptions actually granted nor the roadless-specific mortality outcome, while asserting a causal relationship running from the first to the second. The rationale is therefore not merely unsupported; it is contradicted by the analysis printed in the same document. An explanation that runs counter to the evidence before the agency is arbitrary and capricious under 5 U.S.C. § 706(2)(A). Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not pass over a risk the record permits it to analyze). I request a factual correction to the Rationale for the Proposed Rule under 7 CFR 1b.7(f)(2)(v), reconciling it with Table 14, Table 21, and the activity figures at pp. 14–15 — either by withdrawing the forest-health causal chain, or by stating, region by region and against those tables, where roadless designation is in fact associated with worse forest-health outcomes than active management. The correction cannot be deferred to project-level NEPA: the assertion is a rule-level justification, it appears in the rule’s rationale rather than in any effects analysis, and it is the premise against which alternatives were eliminated from detailed study as failing the purpose and need. If the FEIS retains the assertion, it should state which acres, in which regions, the tables are said to support it on, and where in the record the agency’s response is accounted for under 7 CFR 1b.7(f)(3).

Please keep the amazing piece of policy, the roadless rule, live and enforced. America is its land, and it's people. I am connected to desolation wilderness in the Tahoe basin. Increased devistation will only result in a less secure climate, resulting in more wildfires and harm done to innocent families that garner no benefit from the destruction and increase to shareholder value. My name is Nathaniel Griffin and I will only suffer if this rule is removed. We must encourage sustainable practices, not allow devastation in our birthright. Thank you Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. Notwithstanding these findings, the DEIS concludes at p. 113 that "the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." No source is cited for that conclusion, and no estimate of the ignition increase appears anywhere in the effects analysis for either action alternative. Its two supporting assumptions are unquantified and uncommitted. At p. 109 the DEIS reasons that "not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." At p. 113 it states that "public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas." Neither alternative commits to any level of access restriction, no proportion of closed roads is estimated, no basis is given for expecting any particular proportion, and the rescission itself transfers that decision to local responsible officials. The analysis thus supplies the mitigating assumption while the rule removes the national requirement that would deliver it. The DEIS states the method for closing this gap and does not perform it. At p. 109: "As discussed in Wildfire Occurrence, past fire occurrence information on NFS lands, inventoried roadless areas, and wilderness can be used to evaluate the potential effects of new road construction." The necessary input is already in the document. Figure 15 (p. 98), "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs," is the ignition-to-road-distance gradient measured inside the affected area itself. Figure 15 appears in the body of the DEIS once, as that caption. No text discusses it and no effects analysis applies it. Because the DEIS announces this analysis, presents the data for it, and then substitutes an uncited qualitative conclusion that runs against its own cited sources, its effects finding for wildfire occurrence is not supported by the record before the agency. An explanation that runs counter to the evidence before the agency does not satisfy reasoned decisionmaking. Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not defer analysis of an effect that is properly assessed at the programmatic scale). This is a challenge to the sufficiency of the agency's explanation under 5 U.S.C. § 706(2)(A), not to the scope or depth of analysis the agency selected. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of ne

Dear Chief: I am a wildlife artist making work about local ecology that I share in educational settings. I rely on research, conversations with biologists and my daily visits to the national forest. Having observed wildlife across a representative cross-section of the inventoried roadless areas in the affected region, I write as a sustained observer to oppose the proposed rescission, the rationale for which the field evidence does not support. My opposition rests on several issues, chief among them fire. I will note ahead of that arguement below, that rescinding the Roadless Rule will fragment habitats and increase road mortality of wildlife. Your analysis, its failure to consistently and adequately address core habitat, as well as improperly aligned data regarding management plans for listed species, fails to address the effects on health, population and distribution of the Southern California population Puma Con Color. I request that it do so. Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire. The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation. If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire. Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom. Do the right thing. DO NOT RECIND THE ROADLESS RULE. All the best, Christian Kasperkovitz

The roadless rule protects essential life including that of humans, animals, and plants-- not to mention the sources that feed that life including water. I am writing this as a newer western NC local. I waited all my life to move here and enjoy the protected sanctuary of our roadless forests. Not only does the roadless rule protect the forests up here in WNC, it also protects the Croatan forest back home in ENC that I grew up enjoying. Rescinding the roadless rule will have divesting effects on the lives of humans, animals, and plants everywhere, not just the surrounding areas by these roadless forests. It could pollute our watershed causing us to have to complete more man made filtering techniques, which means higher costs for everyone; not to mention its effects on the wild life that drinks or lives in our streams and rivers. Our already endangered species may go extinct more quickly than we realize if the rule is rescinded. Another reason is to protect the rich cultural heritage in this area of the Natives. Our country already forced the trail of tears upon the Cherokee, what message would we be sending taking away even more aspects of their culture we promised to protect after the fact. The forest service needs to look into more details considering the effects if the rule were to be rescinded. This includes sediment effects, landslide effects, fragmentation of habitats, and natural carbon repurposment. Data shows the rescinding will not even be profitable. Why destroy for no gain and only loss. Please consider these effects. Exposure Screen Without a Road-Effect Zone and Unbounded Activity Level in the ESA Determinations The DEIS's determinations for ESA-listed species rest on an exposure method its own cited literature shows is too narrow, and on an activity level the document declines to estimate while holding the data needed to bound it. Both defects are internal to the DEIS and both are correctable before the FEIS. **These items are not deferrable to project-level review, and they are not optional.** The DEIS concludes at page 170 that "[a]ll future activities in potentially affected IRAs, regardless of the alternative selected, would require compliance with the ESA prior to implementation." That is correct and does not answer any of the four items. The decision before the agency now is whether to remove a rule that prohibits road construction and reconstruction across the entire potentially affected environment. The exposure method, the projected activity level, the programmatic fragmentation picture and the sediment linkage are attributes of that rule-level decision; no site-specific consultation reaches any of them, and by the time site-specific consultation occurs the resource commitment has been made. Section 7(a)(2) of the Endangered Species Act requires the Forest Service to ensure this action does not jeopardize listed species or adversely modify designated critical habitat, and 7 CFR 1b.7(f)(2)(iii) directs the agency, in response to a substantive comment, to supplement, improve, or modify its analyses. An FEIS that carries forward the page 169 exposure screen and the page 168 disclaimer without addressing items 1 through 4 would rest a "likely to adversely affect" finding for 327 species and 71 designated critical habitats on an analysis the agency's own document shows to be incomplete, and would be arbitrary and capricious under 5 U.S.C. § 706(2)(A).

I live in Washington State. I oppose the rescission of this rule protecting our most fragile ecosystems. I am retired from 34 years of service with the Mt Baker Snoqualmie National Forest. During my tenure the area experienced severe flooding and associated landslides the majority originating from old logging roads. These slides entered salmon streams and were a contributing factor to the decades long decline in Pacific salmon populations. In addition the sediment carried downstream causes erosion and loss of life and property. The roadless rule protects fragile ecosystems from further degradation. Most of the areas designated as roadless do not support timber suitable for sawlogs or any other extractive industry, they have all been tried. Unlike industrial forest land at lower elevations, most of the land designated roadless is more suited to sequestering carbon, and protecting watersheds. RARE II Mapping-Error Rationale Unsupported by the 0.5-Mile Road-Buffer Criterion Actually Applied The DEIS's stated basis for removing roaded inventoried roadless areas under alternative 3 is not the basis the analysis actually applies, and the difference is 11 million acres. At page 24 the DEIS explains why roaded areas sit inside the 2001 inventory: "These roaded areas were included as inventoried roadless areas under the 2001 Roadless Rule because of mapping errors in RARE II and road construction between the time RARE II was completed and the 2001 rule." That sentence states a historical finding - that the acreage is inside the inventory by error or by pre-2001 construction - and it is the DEIS's justification for removing that acreage under alternative 3. The analysis does not support it, for three reasons drawn from the DEIS's own text. 1. The operative criterion is not a mapping-error correction. At page 25 the DEIS states the criterion actually applied: "Roaded inventoried roadless areas were defined as the area within 0.5 miles (either side) of existing roads." That is a proximity buffer run against a current road layer. It performs no comparison to RARE II-era mapping, identifies no specific mapping error, and produces no finding that any particular acre was erroneously inventoried in 2001. 2. The data cannot distinguish the categories the sentence relies on. Footnote 10 at page 25 defines "existing roads" as "National Forest System roads and other authorized public roads." Footnote 20 at page 43 states that "the roads data of September 2025 is used for analyses," drawn from the Forest Service Natural Resource Manager database. A September 2025 road layer records where roads are now. It cannot distinguish a road that existed when RARE II was completed from one built after 2001, and the DEIS's own next sentence at page 24 confirms that post-2001 construction occurred: "some road construction occurred between 2001 and 2010 while the rule was enjoined, or pursuant to the 2001 Roadless Rule's exceptions." A road built lawfully under the Rule's own exceptions is the opposite of a mapping error; it is the Rule operating as designed. On this record no portion of the removed acreage is attributable to RARE II mapping error, because no analysis capable of attributing it was performed. 3. Most of the buffered acreage is not roaded. Land lying within half a mile of a road is not itself roaded. The DEIS removes "6.3 million acres of roaded roadless and 4.7 million acres that are both within the wildland-urban interface and within 0.5 miles of existing roads" (p. 25), and nowhere discloses how much of that 11 million acres contains a road as opposed to lying inside the buffer. The distinction is not academic. Under alternative 3, "roads could not be constructed outside of roaded roadless or wildland-urban interface areas" (p. 88), which means new road construction is permitted inside them. The acreage removed under a "roaded" label is the acreage opened to new roads. These are a factual correction and a supplement to the environmental analysis, within 7 C.F.R. 1b.7(f)(2)(iii) and (v), and the response should cite where in the final EIS each is accounted for under 7 C.F.R. 1b.7(f)(3). The same defect goes to the explanation supporting the proposed rule: if the Department adopts modified inventoried roadless area boundaries on the stated ground that the acreage was inventoried in error, the record must support that ground, and as it stands it does not.

Dear Secretary Rollins and Chief Schultz, Getting away from road noise is exactly what I go to public land for, and the 2001 Rule is a big part of why that's still possible in so many places. Spending time hiking Craggy Mountain is what made me fall in love with Asheville when I first moved here. Being able to quickly get away from the city, into the clean brisk air, seeing the beauty of the Blue Ridge mountains spread out across the skyline is truly an indescribable feeling. I remember sitting at the top of Craggy Gardens, a sea of clouds below us. It was so incredibly peaceful and serene. If the roadless rule is rescinded, I lose the ability to find quiet spaces away from the city. I lose my escape. I lose the ability to connect with nature, to have amazing once in a lifetime experiences with wildlife like this past weekend seeing elk up close in a pristine landscape. The reason I go on hikes is to get away from road noise. To see and experience the undeveloped beauty of our country's incredible landscapes. I should be able to go hiking in Craggy Gardens, camping in Yellowstone, or exploring the Santa Rita Mountains near my grandmother's home, without hearing loud engines, without seeing the desctruction of the healthy ecosystems that make our country America the Beautiful. Allowing clear-cutting of forests on publlc land will greatly reduce the natrual carbon sink that the forests provide. This will have an immediate negative effect on climate warming and biodiversity loss. We know too well the impacts of climate warming in Asheville, after suffering the devastation brought on by Hurricane Helene. The microrefugia have already suffered immense canopy loss due to the hurricane. Rescinding the roadless rule would have truly devastating impacts on the biodiversity of the region. Wilderness Acreage Figures at Page 195 Stated Without Any Citation The Draft Environmental Impact Statement states, at page 195 (Chapter 3, "Recreation Opportunities and Setting," Effects of Alternative 3 – Modified Rule, subsection "Wilderness"): "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure carries a citation. The sentence is unsourced on its face. The next citation in the subsection, Landres et al. (2015), is attached to a different proposition — the five qualities of wilderness character interpreted from Section 2(a) of the Wilderness Act — and supports nothing about acreage. Nothing in the surrounding text identifies where either number came from, and a reader cannot trace either figure from the text to any entry in the literature cited. These are the two figures by which the Draft EIS characterizes the resource whose treatment under this rulemaking it then analyzes, and they are stated as fact inside the effects analysis for the Modified Rule alternative rather than in an introductory or background passage. National Wilderness Preservation System acreage is not a fixed quantity; it changes with each congressional designation, so a figure stated without a source and without a date cannot be checked by anyone. NEPA requires a "detailed statement" under 42 U.S.C. § 4332(2)(C). The Department's own procedures define substantive information to include information that meaningfully informs "compliance with applicable laws, executive orders, and regulations" (7 CFR 1b.11(a)(53)), and provide for "[m]aking factual corrections" as a response to a substantive comment (7 CFR 1b.7(f)(2)(v)). A headline resource figure that the public cannot trace to any source is not a verifiable element of a detailed statement. The agency cannot answer this concern by citing the passage in which the figures appear, because that passage is the one lacking the source. I request that the Final EIS do one of two things: (1) identify the source of both the 111.9-million-acre National Wilderness Preservation System total and the 36.7-million-acre National Forest System subset, state the date to which each is current, and add that source to the literature cited; or (2) if no source supports the figures as stated, correct them. Under 7 CFR 1b.7(f)(3), the response should cite where in the Final EIS or the supporting proposal record the action taken is accounted for. Rescinding protections for roadless areas would be a step backward that I don't think the Department can justify — to the public, to the record, or to the forests themselves. I trust that you will act in the best interest of our forests, wildlife, and people like me, and protect our roadless areas. Thank you for keeping the roadless rule intact. With appreciation, CommentID: RLC-20261006-6GXJTA

I am writing in strong opposition to the U.S. Forest Service's Proposed Rule for Special Areas: Roadless Rule Conservation that proposes to rescind the 2001 Roadless Rule. For 25 years, the Roadless Rule has protected a significant amount of national forest for the benefit of the American people through sustaining forest health and biodiversity, thereby protecting the quality of drinking water sources, cultural resources, public health, economic resources, and recreational opportunities. Rescinding the Roadless Rule would undercut many of these benefits, to the detriment of the American people and our economy. I am a resident of Portland, Oregon and have personally benefited from the roadless rule through getting to hike in beautiful protected wilderness and birdwatching, and for the Rule's protection of forest health including the natural water filtration and storage and water quality of our drinking water sources in the Mt Hood National Forest. Further, the DEIS includes multiple statements that contradict and/or are unsupported by the agency's data and need to be reviewed and corrected. One of the Draft Environmental Impact Statement's primary justifications for the proposed rescission of the Roadless Rule is that the rule limited forest management and contributed to reduced forest health. However, this statement is directly contracted by data in the DEIS, including Table 21 which shows a lower incidence of wildfires starting inside roadless areas compared with other national forest lands. I request that the agency review its conclusions in the final EIS to ensure that they supported by its own data on the lower incidence of wildfire in roadless areas. Furthermore, the Rule already allows hazardous fuels reduction to reduce wildfire risk under an existing exemption. The Rationale for the Proposed Rule states that "while exceptions were available, their use was limited and inconsistent due to associated reviews and approvals to demonstrate consistency with the 2001 Roadless Rule" (DEIS p. 19). However, the agency has not provided the data in the DEIS to back up this claim; on p. 14: "There is no national-level tracking of the review, approval, or implementation of 2001 Roadless Rule exceptions." I therefore request that the agency make a factual correction under 7 CFR 1b.7(f)(2)(v) to the Rationale for the Proposed Rule at p. 19, striking or qualifying the statement that exception use "was limited and inconsistent due to associated reviews and approvals," so that Chapter 1 does not state as established fact a causal conclusion the DEIS concedes at pp. 14 that it cannot support. I request that the U.S. Forest Service review and respond to my comments on the Proposed Rule, and urge the agency not to rescind the Roadless Rule.

Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

Dear Director, I’m writing to oppose the full rescission of the 2001 Roadless Area Conservation Rule and to ask the Forest Service to pursue amendment instead of repeal. [Optional: One or two sentences on personal connection — e.g., “I’ve hiked/hunted/fished in [forest/region] for [X years], and the roadless character of that land is why it still supports [wildlife, clean water, quiet recreation, etc.].”] Amendment is the better tool. The state-specific roadless rules already in place for Idaho (2008) and Colorado (2012) prove the agency can address local management needs through negotiated rulemaking without eliminating baseline protections nationwide. The proposed rule itself notes that states, Tribes, and other parties can petition for tailored roadless provisions under 7 CFR 1.28 — that mechanism should be used instead of a blanket, one-time repeal of 25 years of settled protections across 44.7 million acres. Old-growth and mature forest should be permanently off-limits. These stands cannot be replaced on any human timescale once logged or roaded. They: •Hold the largest, most stable carbon stores of any forest condition class •Provide habitat structure — large snags, downed wood, multi-layered canopy — that younger forest doesn’t have •Protect water quality and intact watersheds far better than roaded, managed stands •Represent some of the least-disturbed land left in the National Forest System, covering just a small fraction of the lower 48 yet supporting a disproportionate share of vulnerable species If the Department’s real goal is wildfire risk reduction near communities, that can be achieved through targeted thinning in overstocked younger stands and wildland-urban interface zones — it does not require opening old growth to logging or new roads. I ask the Forest Service to: 1.Withdraw the proposal to rescind 36 CFR Part 294, Subpart B in its entirety. 2.Pursue amendment through the existing petition process (7 CFR 1.28) to address specific, documented local needs. 3.Write an explicit, durable prohibition on road construction and timber harvest in old-growth and mature forest stands into any amended rule. 4.Retain a nationwide baseline of roadless protection rather than relying solely on individual, more easily revised land management plans. Thank you for considering this comment.

I strongly oppose the rescission of the 2001 Roadless Rule for US National Forests. Rescission of the Roadless Rule would provide numerous harms to human, wildlife, and conservation values across the United States. Road building in forest lands is expensive and timber sales have never repaid the costs of building roads in our National Forests. Rescission of the Roadless Rule would not only cost US citizens enormously in terms of lost recreation and lost benefits of conserving forests, it would cost us financially. Rescission provides no benefit to most Americans. Among the many benefits of the Roadless Rule, it is critical to reducing severe wildfire. The majority of wildfires are started by people. Building roads into currently roadless areas makes these areas more vulnerable to wildfire. The DEIS contains multiple errors and inaccuracies in its analysis of wildfire risk that must be corrected. One critical error is that the DEIS clearly demonstrates the relationship between roads and wildfire but fails to apply this relationship to cost-benefit accounting. The DEIS finds at p. 94 that "[t]he incidence of human-caused fires generally increases with proximity to roads," and at p. 98 that "these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." Table 21 puts numbers to it: human-caused ignition density of 22.4 fires per million acres per year on other National Forest System lands against 3.0 in the potentially affected inventoried roadless areas. Figure 15 plots reported ignition density by distance to roads within those same areas. The Economic Analysis supplies the exposure distribution at p. 18: 51.5 percent of affected roadless acreage lies within one mile of a road, and 30.8 percent within a half mile. The DEIS contains a measured roaded-versus-roadless ignition differential, and the acreage distribution against which either could be applied. It applies none of them. In the Alternative 2 effects analysis the finding is restated and then set aside: "Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001). However, not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." However, the DEIS nowhere states what share of roads constructed under Alternative 2 would be closed to public motor vehicle use, so no determination can be made about the effects of those closures. The cost-benefit analysis does not account for increased wildfire ignition despite claiming that it accounts for maximum costs. The Economic Analysis states at p. 26 that "[w]ith increased road construction, there could be increased hazard (which carries a cost) from human-caused ignitions," and that "[i]f there is an increase in public road access, the number and frequency of wildfires could rise." Having identified the cost, the analysis excludes it from the accounting. The Net Present Value at p. 29 is described as using "maximum potential costs and benefits," yet it carries no line for the ignition hazard. That is a factual error, independent of whether the excluded category can be monetized. Three corrections are required, all possible without new data collection. First, the Alternative 2 effects analysis must either apply Figure 15's ignition-density function and Table 21's differential to the road construction reasonably foreseeable under the alternative, or explain why the agency declines to do so. Under 7 CFR 1b.7(f)(1) the agency must analyze substantive issues, and the roads-to-ignitions relationship is an issue within 7 CFR 1b.11(a)(23) by the DEIS's own statement of the cause-and-effect relationship at p. 98. This is not deferrable to site-specific decisions: the rule-level decision removes the prohibition that presently prevents the roads, and the ignition exposure follows from the rule-level acreage, not from any single project. Second, the DEIS must disclose what proportion of roads constructed under Alternative 2 is assumed to be closed to public motor vehicle use, identify what in the proposed rule text secures that closure, and, if nothing does, withdraw the conclusion that depends on it. Third, the Net Present Value presentation at Economic Analysis p. 29 must disclose that it excludes the increased human-caused ignition cost identified at p. 26, or that cost must be included. I do not ask the agency to reach any particular conclusion about wildfire. I ask that the analysis either use the data it has assembled or say plainly that it has not, so that the record shows which. Thank you.

As a Washington State resident who understands firsthand what the Roadless Rule protects where I live, I oppose this rescission. I have hiked and camped in roadless areas across the Olympic National Forest, including Quilcene, and have studied the history of previous deforestation in the area. Rescinding the Rule would impact trails and natural features like Mt Townsend, where road construction is currently illegal, and timber harvest on those roads. The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range ("a 4 to 10 percent increase in total sawtimber harvest" (p. 30)) and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics. This is not a limit of the analytical method, because the DEIS performs the quantified work for one forest. It states that "[t]he environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while the 2020 Alaska Roadless Rule FEIS "provides more specific, localized effects analysis for the Tongass National Forest affected environment, which supplement the broader nation-wide analysis" (p. 238). Carrying that analysis forward, the DEIS reports "an estimated 49 miles more of potential new road constriction [sic] within the Tongass compared to leaving the Roadless Rule in place" and an average road density of 0.23 miles per square mile (p. 239). By the DEIS's own accounting the Tongass is "nearly 1/4 of the potentially affected inventoried roadless area acreage" (p. 238). One quarter of the analysis area therefore receives a projected road-mile figure and the remaining 30.8 million acres receive none. The omission cannot be deferred to project-level review, because the DEIS's own statement of need rests on quantified national targets. At p. 79 the DEIS relies on Executive Order 14225 and on the One Big Beautiful Bill Act section 50301, which "directs the Forest Service to sell at least 250 million board feet more each year for the next 10 years," and on the National Active Forest Management Strategy's goal of "an increase in timber production nationally by 25 percent." At p. 40 the DEIS says the amounts and locations are uncertain because "the rulemaking would not compel, require, or authorize any sitespecific activities." Both positions cannot hold. If the rescission is needed to meet a quantified national harvest target, then the harvest and the road construction required to reach that target are reasonably foreseeable effects of the rescission, and 42 U.S.C. 4332(2)(C) requires "a detailed statement... on... reasonably foreseeable environmental effects of the proposed agency action." If they are not reasonably foreseeable, the stated need for the rescission is unsupported, and every alternative eliminated for failing to meet that purpose was eliminated against a purpose the agency has not substantiated. The Forest Service should supplement analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and resulting sedimentation and fragmentation across the potentially affected environment under each action alternative, at the level of specificity the DEIS applied to the Tongass National Forest at pp. 238-239, and cite in the final EIS where that supplemented analysis is accounted for, as 7 CFR 1b.7(f)(3) provides.