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Ketchikan Indian Community formally submits its comments on on the Proposed Rescission of the 2001 Roadless Area Conservation Rule and Draft Environmental Impact Statement, 91 Fed. Reg. 53,827 (Aug. 20, 2026), comment period extended, 91 Fed. Reg. 57,841 (Sept. 11,2026); RIN 0596-AD66; Docket No. FS-2025-0001. The comments are attached as a compressed pdf file in full and uncompressed: Part 1 and Part 2.

I am an angler and camper from North Carolina, and I regularly travel to across the United States of America to fish, camp, and enjoy our national forests. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I support responsible forest management, including appropriate efforts to reduce hazardous fuels and wildfire risk. The Forest Service’s own proposal acknowledges that the Roadless Rule does not prohibit and has not entirely prevented hazardous-fuel-reduction activities and that agency records do not show that the absence of roads has prevented fire-prevention or fire-protection measures. See Special Areas; Roadless Area Conservation, 91 Fed. Reg. 53,827, 53,832 (Aug. 20, 2026). The case for rescission should therefore not rest on the assumption that roadless protections make responsible forest management impossible. Additionally, the effects of more roads should not be treated as one-directional. A 2026 peer-reviewed analysis of Forest Service wildfire data from 1992–2024 found substantially higher wildfire-ignition density within 50 meters of roads than in Inventoried Roadless Areas. Gregory H. Aplet, Phil Hartger & Matthew S. Dietz, Three-Decade Record of Contiguous-U.S. National Forest Wildfires Indicates Increased Density of Ignitions Near Roads, 22 Fire Ecology 8 (2026). I believe public lands should provide both reasonable access and places where fish, wildlife, watersheds, and relatively undeveloped recreational opportunities can remain intact. The Forest Service can address site-specific management needs without eliminating the nationwide Roadless Rule. As an angler, I also value roadless areas for the protection they provide to intact watersheds and fish habitat. Trout Unlimited reports, based on Forest Service-supported research, that within the current range of native trout and salmon, those species are 40 percent more common in roadless areas than in roaded forest lands. Chris Wood, Testimony Before the H. Comm. on Natural Res. (May 21, 2026). The Forest Service should factor in the value of maintaining unique biodiversity in its decision. I respectfully ask the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule. Environmental decisions made today can echo for generations. Once a landscape is fragmented by roads and development, what is lost may not be recoverable in our lifetimes. I hope the Forest Service will preserve these places so that future generations can still fish, camp, and experience the American wild as we do today. Thank you for considering my comment.

RE: Comments of the Organized Village of Kake on the Proposed Rule and Draft Environmental Impact Statement, Special Areas; Roadless Area Conservation, Rescission of the 2001 Roadless Area Conservation Rule, 91 Fed. Reg. 53,827 (Aug. 20, 2026); Docket No. FS-2025-0001; RIN 0596-AD66; and Renewed Request for Government-to- Government Consultation

Please accept and fully consider the attached comment letter on the U.S. Department of Agriculture’s (USDA) Proposed Rule Rescinding the 2001 Roadless Area Conservation Rule (Roadless Rule), 91 Fed. Reg. 53,827 (August 20, 2026) (Proposed Rule), submitted on behalf of the following organizations: National Wildlife Federation, Connecticut Forest & Park Association, Conservation Coalition of Oklahoma, Conservation Council for Hawai'i, Conservation Federation of Missouri, Florida Wildlife Federation, Georgia Wildlife Federation, Indiana Wildlife Federation, Kentucky Waterways Alliance, Montana Wildlife Federation, Natural Resources Council of Maine, New Hampshire Audubon, Planning and Conservation League, Prairie Rivers Network, Sociedad Ornitológica Puertorriqueña, Inc., South Carolina Wildlife Federation, Southeast Alaska Conservation Council, Texas Conservation Alliance, Vermont Natural Resources Council, Virginia Conservation Network, West Virginia Rivers Coalition, and Wisconsin Wildlife Federation. We urge USDA to retain the Roadless Rule, which fosters multiple-use management of National Forest System lands while providing flexibility for the U.S. Forest Service to address public health and safety concerns such as wildfire risk. The rule has conserved inventoried roadless areas (IRAs) for a quarter of a century, providing clean water to tens-of-millions of Americans, protecting irreplaceable fish and wildlife habitat, and increasing outdoor recreation opportunities. As USDA’s own analysis shows, removing the protections of the Roadless Rule would severely impact the ability of National Forest System lands to continue to provide these benefits. It would also be inconsistent with the Forest Service’s statutory obligations for managing these lands and their resources.

Please find attached comments of the Southern Environmental Law Center ("SELC") et al. opposing rescission of the Roadless Rule. Enclosed with these comments is a List of Attachments as well as confirmations of previous submissions containing our attachments. Our previous submissions included the following text: Please refer to the 10/02/2026 letter from the Southern Environmental Law Center submitted with confirmation #mur-5suc-54st, for information regarding our attachments in support of our comments. The Southern Environmental Law Center (“SELC”) is submitting these and other documents as attachments to our forthcoming comments on the Proposed Rule, Draft Environmental Impact Statement, Cost Benefit Analysis, and other rulemaking documents related to the Forest Service’s proposed rescission of the Roadless Area Conservation Rule (FS–2025–0001/RIN 0596–AD66; 91 Fed. Reg. 53,827 (Aug. 20, 2026); 91 Fed. Reg. 57,841 (Sept. 11, 2026)). Our comments will explain the relevance of these and all other attachments. Regarding our first documents, the Forest Service has failed to disclose and address its own prior factual findings and judgments regarding the Rule’s importance. These documents are relevant to those prior findings and judgments and form part of the record the agency should consider in evaluating its proposal and responding to public comments.

Please find an additional attachment for the recently-submitted comments of the Southern Environmental Law Center ("SELC") et al. opposing rescission of the Roadless Rule (Comment Tracking Number: mux-6bsw-j95t). Our previous submissions included the following text: Please refer to the 10/02/2026 letter from the Southern Environmental Law Center submitted with confirmation #mur-5suc-54st, for information regarding our attachments in support of our comments. The Southern Environmental Law Center (“SELC”) is submitting these and other documents as attachments to our forthcoming comments on the Proposed Rule, Draft Environmental Impact Statement, Cost Benefit Analysis, and other rulemaking documents related to the Forest Service’s proposed rescission of the Roadless Area Conservation Rule (FS–2025–0001/RIN 0596–AD66; 91 Fed. Reg. 53,827 (Aug. 20, 2026); 91 Fed. Reg. 57,841 (Sept. 11, 2026)). Our comments will explain the relevance of these and all other attachments.

Attached please find Prime Mover Institute’s Comment on Special Areas; Roadless Area Conservation, 91 Fed. Reg. 53,827 (Aug. 20, 2026).

Please refer to the 10/02/2026 letter from the Southern Environmental Law Center submitted with confirmation #mur-5suc-54st: The Southern Environmental Law Center (“SELC”) is submitting these and other documents as attachments to our forthcoming comments on the Proposed Rule, Draft Environmental Impact Statement, Cost Benefit Analysis, and other rulemaking documents related to the Forest Service’s proposed rescission of the Roadless Area Conservation Rule (FS–2025–0001/RIN 0596–AD66; 91 Fed. Reg. 53,827 (Aug. 20, 2026); 91 Fed. Reg. 57,841 (Sept. 11, 2026)). Our comments will explain the relevance of these and all other attachments.

I oppose rescission of the 2001 Roadless Area Conservation Rule. The proposal would remove the national baseline protecting approximately 44.7 million acres of inventoried roadless lands. The record does not establish that eliminating this protection is justified by the best available science, fiscal evidence, or analysis of cumulative effects. 1. THE WILDFIRE JUSTIFICATION IS NOT SUPPORTED BY THE FOREST SERVICE’S OWN RESEARCH. The Forest Service’s peer-reviewed analysis of nearly 20 years of monitoring found that fuel-management activities occurred in roadless areas at higher rates per square kilometer than elsewhere in the National Forest System, and that forests with and without roads had burned at similar rates after adoption of the Rule. It concluded that speculation that eliminating road prohibitions would improve forest health was not supported by the monitoring data. It also found non-native plants were twice as common within 500 feet of roads. (Healey, U.S. Forest Service, 2020, Environmental Research Letters 15:104023.) That evidence directly undermines any categorical assertion that more roads are necessary to address wildfire risk. The agency should identify what evidence has changed and explain why it now reaches a contrary conclusion. 2. RESCISSION IS NOT A MERE ADMINISTRATIVE CHANGE. The proposal itself estimates that, where existing forest plans allow, permanent roads could become possible across approximately 18.2 million acres now protected by the Rule, while active-management opportunities could expand across approximately 4.8 million forested acres. (USDA Forest Service, Proposed Rule, 91 Fed. Reg. 53,827 (Aug. 20, 2026).) Those figures demonstrate the practical significance of rescission. Removing the national baseline changes the starting point for future decisions from protection subject to defined exceptions to project-by-project discretion. The final EIS should therefore analyze the consequences of removing the national protection itself—not merely assume that later project-level NEPA review will capture landscape-scale effects. 3. CUMULATIVE ROAD IMPACTS CANNOT BE DISMISSED AS PROJECT-SPECIFIC. Roads can fragment habitat, alter drainage, facilitate invasive species, increase human access, and affect water quality. A 2025 USGS study found a significant positive relationship between road density and fine sediment in stream habitats and a significant negative relationship between road density and median particle size. (Al-Chokhachy et al., USGS, 2025, Journal of the American Water Resources Association 61:e70006.) These effects can accumulate as road density increases. The final EIS should quantify cumulative changes in road density, habitat fragmentation, watershed condition, sediment, invasive species, and wildlife connectivity. 4. THE FISCAL ANALYSIS MUST ACCOUNT FOR LONG-TERM ROAD OBLIGATIONS. The Forest Service reported approximately $10.8 billion in deferred infrastructure maintenance as of the first quarter of FY2025, including $5.98 billion for roads and $987 million for road bridges. (USDA Forest Service, FY2026 Congressional Budget Justification, 2025.) Before expanding road-building opportunities, the agency should demonstrate that the federal government can afford the construction, maintenance, repair, and eventual decommissioning obligations associated with additional roads. Economic benefits should not be counted without accounting for those public costs. 5. THE AGENCY MUST EXPLAIN THIS POLICY CHANGE WITH PARTICULAR CARE. Under FCC v. Fox Television Stations, Inc., 556 U.S. 502, 515 (2009), an agency changing policy must display awareness that it is changing position and show good reasons for the new policy. Here, the Forest Service is removing a longstanding national conservation standard after decades of additional scientific evidence. The final rule should explain what material evidence has changed, why the agency’s own roadless-area monitoring no longer supports the 2001 approach, why existing exceptions are inadequate, and how cumulative and irreversible consequences were evaluated. The Forest Service should not remove the Roadless Rule first and leave the environmental consequences of that decision to be determined piece by piece through future project approvals. The agency must assess now the reasonably foreseeable consequences of eliminating the protection-including the cumulative effects of roads and development across previously protected landscapes-and determine whether those impacts can be avoided through less sweeping alternatives. I instead urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Area Conservation Rule. Sincerely, Ainsley

The Southern Environmental Law Center (“SELC”) is submitting these and other documents as attachments to our forthcoming comments on the Proposed Rule, Draft Environmental Impact Statement, Cost Benefit Analysis, and other rulemaking documents related to the Forest Service’s proposed rescission of the Roadless Area Conservation Rule (FS–2025–0001/RIN 0596–AD66; 91 Fed. Reg. 53,827 (Aug. 20, 2026); 91 Fed. Reg. 57,841 (Sept. 11, 2026)). Our comments will explain the relevance of these and all other attachments. Regarding our first documents, the Forest Service has failed to disclose and address its own prior factual findings and judgments regarding the Rule’s importance. These documents are relevant to those prior findings and judgments and form part of the record the agency should consider in evaluating its proposal and responding to public comments.

I live in the mountains of western North Carolina, near the Pisgah National Forest, where these forests are part of my everyday life. I urge USDA to retain the 2001 Roadless Area Conservation Rule. I understand USDA’s stated reasons for seeking greater local management flexibility, including wildfire, forest health, and vegetation management. I also understand that rescission would not itself authorize a particular road or timber project. My concern is that removing the Rule eliminates an important safeguard without adequately accounting for the long-term fiscal, economic, recreational, and ecological value of keeping these lands roadless. According to the Forest Service’s own North Carolina Inventoried Roadless Areas map, approximately 173,000 acres of National Forest System land in North Carolina are Inventoried Roadless Areas. Approximately 142,000 acres are in a category where the underlying forest-plan designation allows road construction or reconstruction, making the Roadless Rule a meaningful additional protection. Before removing that protection, I ask USDA to address the following: Who will pay for additional roads over their entire lifetimes? The proposed rule itself acknowledges a $6.9 billion deferred-maintenance backlog for National Forest System roads and bridges. The Forest Service’s 2012 Pisgah National Forest Transportation Analysis estimated that operating and maintaining its suggested road system to standard would require approximately $3.4 million annually. Although that figure is historical, it documents the longstanding difficulty and expense of maintaining mountain roads. Before facilitating additional roads, USDA should calculate their full lifecycle costs: construction, drainage, inspection, maintenance, storm repair, reconstruction, bridges and culverts, and eventual decommissioning. Those costs should be weighed against the economic benefits USDA expects from additional timber harvesting or other activities. What will additional roads cost our watersheds? Forest Service research in the Southern Appalachians has identified forest roads as potentially important sources of erosion and sediment, with consequences for stream water quality. This is especially important in western North Carolina’s steep, wet terrain. USDA should analyze the cumulative effects of reasonably foreseeable additional roads on erosion, sedimentation, headwater streams, aquatic habitat, and downstream water quality. What is the economic value of remaining roadless? Western North Carolina’s forests already produce economic value. People travel here to hike, camp, fish, hunt, paddle, watch wildlife, and experience scenery, solitude, and relatively undeveloped landscapes. Their spending supports lodging, restaurants, retailers, guides, outfitters, and other small businesses in our mountain communities. USDA’s own proposed rule acknowledges that additional roads could reduce opportunities for “quiet, remote and self-reliant recreation” and result in lost economic benefits. Those losses should be evaluated specifically for western North Carolina and the Southern Appalachians, not merely as national averages. There is also an important asymmetry in this decision. Leaving a place roadless today preserves the option for future generations to reconsider its management. Building a road changes the landscape and creates continuing consequences and maintenance obligations. Finally, I ask USDA to explain why complete nationwide rescission is necessary. If particular areas require intervention for wildfire protection, public safety, or forest health, could carefully tailored exceptions address those needs without eliminating the general protection? Before adopting a final rule, USDA should disclose for North Carolina the acreage that would actually lose protections; reasonably foreseeable additional road mileage; lifecycle costs and who pays them; effects on water, wildlife, recreation, and scenic character; economic effects on recreation and tourism; and how those public costs compare with the economic benefits anticipated from rescission. A standing forest has economic value. Clean water has economic value. Roadless watersheds, wildlife habitat, recreation, tourism, and avoiding unnecessary infrastructure liabilities all have economic value. I am not asking the Forest Service to abandon responsible forest management. I am asking USDA to recognize that keeping some places roadless is itself a legitimate and valuable management choice. For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule. Sources: USDA Forest Service, Proposed Rule, 91 Fed. Reg. 53,827 (Aug. 20, 2026), Docket FS-2025-0001; USDA Forest Service, North Carolina Inventoried Roadless Areas map; USDA Forest Service, Pisgah National Forest Transportation Analysis Process Report (2012)USDA Forest Service Southern Research Station research on forest roads, erosion, sediment, and water quality in the Southern Appalachians.

1. Introduction I respectfully submit this comment in opposition to the U.S. Department of Agriculture’s proposal to rescind the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select the No Action Alternative and retain the nationwide protections against road construction, road reconstruction, and most commercial timber harvest in inventoried roadless areas. I am a California resident, educator, and taxpayer. My work with young people makes the intergenerational consequences of public decisions especially concrete to me. Public lands should be managed for durable public benefits—including clean water, intact wildlife habitat, climate resilience, and quiet recreation—not opened to avoidable roadbuilding and commercial extraction whose costs can outlast any short-term revenue. This perspective distinguishes my comment: I am asking the agency to evaluate the proposal not only as a change in management procedure, but as a decision about what ecological inheritance today’s students and future generations will receive. 2. Background and Part of the Regulation Addressed The proposal published at 91 Fed. Reg. 53,827 on August 20, 2026 would remove and reserve 36 C.F.R. part 294, subpart B, thereby rescinding the 2001 Roadless Rule’s nationwide prohibitions. The proposal would leave the separate Idaho and Colorado roadless rules in place, but for other covered national forests it would return decisions about roads and timber harvest to individual forest plans and later site-specific review. The 2001 Rule was adopted to provide lasting national protection for approximately 58.5 million acres of inventoried roadless areas because roads and timber harvest are especially likely to fragment landscapes, impair watersheds, and incrementally erode roadless values. [1][2] My comment specifically opposes the proposed removal of subpart B. I also challenge the proposal’s stated rationale that complete rescission is needed to provide local flexibility for wildfire response, vegetation management, rural economic opportunity, or other place-based needs. The existing Rule is not an absolute prohibition on management. It permits roads needed to protect public health and safety from an imminent catastrophic threat and allows limited tree cutting for ecological restoration, habitat improvement, reduction of uncharacteristic wildfire effects, fire-line construction, and other defined purposes. [2] The agency therefore has narrower tools available than nationwide rescission.