Read the comments.

Dear USDA Leadership: As a scientist, I submit that the ecological findings embedded in the 2001 Roadless Area Conservation Rule reflect the best available science of that period and have been substantially corroborated by subsequent research — a point the rescission proposal does not engage. Florida is my home, the species that live here are my relative. Removing the roadless rule puts the things I love at risk of extinction Removing roadless protections from the Farles Prairie IRA, Ocala National Forest, is a federal action that may affect 15 listed or proposed species by enabling road construction, habitat fragmentation, increased sedimentation, and human access into previously protected habitat. ESA Section 7 requires the agency to consult on every listed or proposed species that the action may affect. The DEIS must disclose the status of consultation for all 15 species documented in the Farles Prairie IRA, Ocala National Forest, and provide species-by-species effects determinations. "Executive Order 11988 requires agencies to avoid, to the extent possible, the long- and short-term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative. Each agency shall provide leadership and shall take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and welfare, and to restore and preserve the natural and beneficial values served by floodplains in carrying out its responsibilities for (1) acquiring, managing, and disposing of Federal lands, and facilities; (2) providing federally undertaken, financed, or assisted construction and improvements; and (3) conducting Federal activities and programs affecting land use. Before taking an action, each agency shall determine whether the proposed action will occur in a floodplain — for major Federal actions significantly affecting the quality of the human environment, the evaluation required below will be included in any statement prepared under Section 102(2)(C) of the National Environmental Policy Act." — Federal Interagency Floodplain Management Task Force / Water Resources Council No adequate justification for rescission appears in the rulemaking record; the Department should decline to proceed. Most respectfully, CommentID: RLC-20261006-WHOB5W

To the U.S. Forest Service: I am writing as someone who cares deeply about the health of my community, our country, our planet, wildlife, and the environment. We have a responsibility to care for and protect the precious natural resources and wildlife habitats. As a science teacher, one of the first units I taught my students was about the interconnectedness of living and non-living aspects of the environment, specifically the importance of salmon and the factors contributing to their declining populations. One of the studies we looked at the correlation between stormwater runoff and the number of salmon eggs that were able to survive and hatch. Removing the roadless protections will surely lead to greater water pollution and cause even more harm to salmon populations, which will affect the ecosystem and humans who rely on salmon as well as clean air and water. Regarding the Tolmie Creek in the Mt Baker-Snoqualmie National Forest, Washington: The Tolmie Creek IRA in Mt Baker-Snoqualmie National Forest drains into downstream floodplains where road-generated increases in impervious surface, runoff volume, and peak flows trigger the flood hazard evaluation mandate of Executive Order 11988. Road construction in the Tolmie Creek IRA, Mt Baker-Snoqualmie National Forest, converts permeable forest soils to compacted and paved surfaces, increasing impervious area, accelerating runoff concentration, and elevating peak flows in downstream floodplains. For the Tolmie Creek IRA, Mt Baker-Snoqualmie National Forest, the DEIS must demonstrate compliance with Executive Order 11988 by evaluating how road construction alters watershed hydrology, increases peak discharge, and affects flood hazard potential for downstream communities and infrastructure. "Completed and proposed activities have resulted in or would result in the temporary discharge of dredged and/or fill material into 39,203 linear feet (8.2688 acres) of streams and 13.6957 acres of wetlands, the temporary discharge of dredged and/or fill material into 3.7690 acres of PFO and PSS wetlands resulting in a permanent conversion of these PFO and PSS to PEM wetlands, and the permanent discharge of dredged and/or fill material into 2,207 linear feet (0.3494 acre) of streams and 0.4288 acre of wetlands. The Mountain Valley Pipeline Section 404 permit authorized a total of 35,554 linear feet of temporary stream impacts and 1,145 linear feet of permanent stream impacts across 620 resource crossings." — U.S. Army Corps of Engineers (Huntington, Pittsburgh, Norfolk Districts) These lands weren't developed for a reason. Keep it that way. Warm regards, CommentID: RLC-20261005-NE57EU

To Whom it May Concern at the US Forest Service: As a WNC native, I respectfully submit that the Department's proposed rescission does not adequately consider the interests of communities whose geographic location makes them the primary bearers of any negative consequences arising from changes to roadless area management. Western North Carolina's drinking water, along with all community water supplies with origins in our National forests, would be harmed by rescinding the roadless rule. Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: The Craggy Mountain IRA in Pisgah National Forest drains into downstream floodplains where road-generated increases in impervious surface, runoff volume, and peak flows trigger the flood hazard evaluation mandate of Executive Order 11988. Road construction in the Craggy Mountain IRA, Pisgah National Forest, converts permeable forest soils to compacted and paved surfaces, increasing impervious area, accelerating runoff concentration, and elevating peak flows in downstream floodplains. Executive Order 11988 requires the agency to assess flood hazard before authorizing road construction. The DEIS must quantify the increase in impervious surface, runoff volume, and peak flow resulting from road construction in the Craggy Mountain IRA, Pisgah National Forest, and evaluate downstream flood risk. "Executive Order 11988 requires agencies to avoid, to the extent possible, the long- and short-term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative. Each agency shall provide leadership and shall take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and welfare, and to restore and preserve the natural and beneficial values served by floodplains in carrying out its responsibilities for (1) acquiring, managing, and disposing of Federal lands, and facilities; (2) providing federally undertaken, financed, or assisted construction and improvements; and (3) conducting Federal activities and programs affecting land use. Before taking an action, each agency shall determine whether the proposed action will occur in a floodplain — for major Federal actions significantly affecting the quality of the human environment, the evaluation required below will be included in any statement prepared under Section 102(2)(C) of the National Environmental Policy Act." — Federal Interagency Floodplain Management Task Force / Water Resources Council Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. I'm asking you to keep the 2001 Roadless Rule in place. See the attachment for the full comment with supporting information. Thank you, CommentID: RLC-20261005-C1M8CY

Brooke L. Rollins and Tom Schultz, I'm one of the many people who spend as much time as they can on public lands — not one specific activity, just out there — and I can tell you the roadless parts are what make the rest of it hold together. I have been getting out into roadless areas for as long as I can remember. These moments are my most cherished memories and there is nothing that makes me feel more proud to be an American than being in the unique places that are innately American. If we loose access to this untouched land, we lose what it means to be American. That connection to the land is precisely what the 2001 Roadless Area Conservation Rule was designed to protect, and what the present proposal would place in permanent jeopardy. Regarding the Three Ridges in the George Washington National Forest, Virginia: The Three Ridges IRA in George Washington National Forest drains into downstream floodplains where road-generated increases in impervious surface, runoff volume, and peak flows trigger the flood hazard evaluation mandate of Executive Order 11988. Road construction in the Three Ridges IRA, George Washington National Forest, converts permeable forest soils to compacted and paved surfaces, increasing impervious area, accelerating runoff concentration, and elevating peak flows in downstream floodplains. The DEIS must evaluate the flood hazard potential of road construction in the Three Ridges IRA, George Washington National Forest, as required by Executive Order 11988, including analysis of increased impervious surface, altered runoff patterns, and downstream flood risk. "Road construction is one of the largest potential sources of forest activity-produced sediment (Megahan, 1980). Road networks can be hydrologically connected to stream networks where road surface runoff is delivered directly to stream channels at stream crossings or via ditches or gullies that direct flow off of the road and then to a stream, and where road cuts transform subsurface flow into surface flow in road ditches or on road surfaces that delivers sediment and water to streams much more quickly than without a road present and increases the risk of mass wasting (Jones and Grant, 1996; Montgomery, 1994; Wemple et al., 1996). The combined effects of these drainage network connections are increased sedimentation and peak flows that are higher and arrive more quickly after storms." — U.S. Environmental Protection Agency Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Research - Fire Safety” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Research - Fire Safety” I respectfully ask the Department to end this rulemaking without disturbing the existing Rule. Yours in conservation, CommentID: RLC-20260831-PS1KCM

As someone who grew up in the majestic Sierra Nevada forests of Lake Tahoe, I'm asking the Department to recognize that what this rule protects is both real and irreplaceable. In Lake Tahoe, we always had the most clean, fresh water directly to our homes. We are proud of it and protected it with care. Fire was always a threat, but one that we protectively reduced the risk using proven strategies. We felt safe, healthy, and proud of being a place where we can, without fear, drink from the faucet. The Rule has, for nearly twenty-five years, preserved the character of places like Lake Tahoe, and similarly the natural ecosystems within my new home of Florida. Rescinding it would be an irreversible administrative act with irreversible consequences on the ground. Hiking in and finding some of the most majestic lakes, seeing the gentle animals living there, and experiencing a place where the stars shine brighter than anywhere is an experience not many people in the world have access to. I've learned that as an adult traveling to over 70 countries. Having access to clean water directly in our homes, access to safe places to view the stars, and the ability to quietly see how we share lands with wildlife is a privilege that every future American should have access to. America the Beautiful is real, and must remain accessible and safe for future Americans as well. There are two examples from the North Fork American River that I believe relevant proof of the danger building roads will bring. As a teenager, I rafted down this river, an experience I hope future generations will be able to have. Example 1: Road construction in the North Fork American River IRA, Tahoe National Forest, creates impervious surfaces that increase runoff volume and peak flows, directly implicating the flood hazard evaluation requirements of Executive Order 11988. Example 2: In the North Fork American River IRA, Tahoe National Forest, road surfaces, cut slopes, and drainage ditches intercept subsurface flow and convert it to rapid surface runoff, increasing both the volume and peak rate of stormwater delivery to downstream floodplains. In Florida, Farles Prairie sits directly above the Surficial Aquifer System, the primary freshwater source for the region. The flat terrain and sandy soils mean that precipitation infiltrates rapidly into groundwater; the intact vegetation and soil structure of the roadless area maintain this recharge function and filter contaminants before water reaches the aquifer. The area's lakes and wetlands — Farles Lake, Sellers Lake, and the wet prairie — are hydrologically connected to this aquifer system. Road construction would disrupt soil infiltration capacity and introduce sedimentation and pollutants into recharge zones, degrading water quality for both aquatic species and human water supplies. This takes Florida in the wrong direction. Road construction on Farles Prairie's flat, sandy terrain requires cut slopes and fill areas that expose bare soil to rainfall and runoff. The sandy soils of this landscape are highly erodible; erosion from road cuts and the road surface itself would generate continuous sediment transport into the headwater wetlands and lakes. This sediment would degrade water clarity and smother the benthic substrates—mud and organic matter—that support the apple snails hunted by the federally endangered Everglade snail kite. Sediment also clogs the fine-scale pore spaces in sandy soils, reducing infiltration into the Surficial Aquifer and forcing more runoff into surface waters, which increases nutrient loading and algal growth that degrades habitat for the Eastern black rail and other wetland species. First, don't hurt apple snails! Second, we do not need more algal growth. We've seen enough toxic blooms! I've traveled to African countries where even the rich must drink water from small sachets sold on the side of the road. General municipal water is not safe there. They have never known free access to clean drinking water. They get sick often. I do not want to see that in the future for my fellow Americans and our next generation. The Rule has served the national forest system for more than two decades, protecting the drinking water of Americans. The Department should not undo that without justification that the current record does not provide. Mary Palm Harbor, FL

To the U.S. Department of Agriculture: Reading the proposed rescission against the body of federal climate assessment, I find no rationale in the Department's notice sufficient to justify the loss of contributions to forest carbon and watershed integrity that the Rule has performed across nearly a quarter century. I'm a forest landowner in North Carolina. The public interest expressed above is precisely the interest the Rule has served for twenty-five years. Regarding the Catfish Lake North in the Croatan National Forest, North Carolina: Pocosin Wetland Integrity and Rare Plant Habitat — The Catfish Lake North area protects one of the Southeast's most specialized wetland ecosystems—pocosins and low pocosins—which depend on the area's current hydrological isolation to maintain their naturally acidic conditions (pH < 4.0). Th… Every stream crossing required for road construction in the Catfish Lake North IRA, Croatan National Forest, involves placement of fill material — culverts, bridge footings, approach fills — into jurisdictional waters, constituting discharge under Clean Water Act Section 404. The DEIS must identify every stream crossing in the Catfish Lake North IRA, Croatan National Forest, that would require discharge of fill material into jurisdictional waters and demonstrate how Clean Water Act Section 404 compliance is achieved for each crossing. "Inventoried roadless areas provide large, relatively undisturbed blocks of habitat for a variety of terrestrial and aquatic wildlife and plants, including hundreds of threatened, endangered, or sensitive species. Many inventoried roadless areas function as biological strongholds and refuges for a number of species, and they play a key role in maintaining native plant and animal communities and biological diversity." — USDA Forest Service “Modeled erosion estimates at forestry stream crossings ranged from less than 0.1 to 381.4 Mg ha-1 y-1. USDA NRCS cites a road construction site erosion rate of 897 Mg ha-1 y-1. Soil erosion rates at forestry stream crossings can be significantly reduced through the implementation of BMPs. Maximum erosion values for haul roads were 191.9 Mg ha-1 y-1, similar to maximum erosion rates observed in legacy road studies. — Journal of Soil and Water Conservation, 2022 (https://doi.org/10.2489/jswc.2022.00110)” “Decreased habitat connectivity has numerous well-documented effects on freshwater fish populations and communities and is recognized as a leading cause of declining freshwater diversity. The cumulative effects of small barriers such as culverts may collectively far exceed those of dams. Januchowski-Hartley and others (2013) and Diebel and others (2015) documented a ratio of 38 times and 24 times more culverts than dams in two separate North American watersheds. — U.S. Geological Survey Scientific Investigations Report, 2024 (https://doi.org/10.3133/sir20235132)” “Warming trends were prevalent during summer and early fall months in recent 20- and 40-year periods (0.18–0.35°C per decade during 1996–2015 and 0.14–0.27°C per decade during 1976–2015). Future warming of 1–3°C would reduce thermally suitable riverine trout habitats by 8–31% while causing their upstream shift. — USDA Forest Service, Rocky Mountain Research Station, 2018 (https://doi.org/10.1002/tafs.10059)” “Executive Order 11988 requires agencies to avoid, to the extent possible, the long- and short-term adverse impacts associated with the occupancy and modification of floodplains and to avoid direct or indirect support of floodplain development wherever there is a practicable alternative. Each agency shall provide leadership and shall take action to reduce the risk of flood loss, to minimize the impact of floods on human safety, health and welfare, and to restore and preserve the natural and beneficial values served by floodplains in carrying out its responsibilities for (1) acquiring, managing, and disposing of Federal lands, and facilities; (2) providing federally undertaken, financed, or assisted construction and improvements; and (3) conducting Federal activities and programs affecting land use. Before taking an action, each agency shall determine whether the proposed action will occur in a floodplain — for major Federal actions significantly affecting the quality of the human environment, the evaluation required below will be included in any statement prepared under Section 102(2)(C) of the National Environmental Policy Act. — Federal Interagency Floodplain Management Task Force / Water Resources Council (https://asfpm-library.s3-us-west-2.amazonaws.com/General/Implementing_Guidelines_for_EO11988_13690_08_Oct15_508.pdf)” The Rule should be retained; no adequate basis for rescission appears in this record. With gratitude,

To the U.S. Department of Agriculture: In my work as an expedition guide, I have spoken with enough guests to know that what they come to Alaska and pristine quiet places for is precisely the character of land that the 2001 Rule has protected. I have spent the past 5 years up in Alaska taking clients to see the beauty and the productivity of an isolated roadless place. I have passed bears and other animals on the trail who do not threaten me because they have an abundance of food and nutrients and we are just passing by together. One visit made that connection concrete. Just last week, we were taking guests along a river bed near Port Althorp and getting to show them what a productive salmon run looks like. We showed them how the dead salmon end up in the forest and return nutrients back to the forest from the water. We passed a bear who was readily on their way to the salmon, wanting nothing to do with us. These guests came back with countless stories and pictures and an understanding of what the world looks like when it is untouched and protected. This is exactly the experience they come looking for when they come travel here. The story recounted and the relationship underlying it are both, in the relevant sense, products of what twenty-five years of roadless protection has made possible; rescission would begin to unwind both. Regarding the Chichagof in the Tongass National Forest, Alaska: Headwater Networks Supporting Pacific Salmon Fisheries — The Chichagof IRA contains the headwaters of the Pelican Creek, Lisianski River, Kadashan River, Neka River, and other major drainages that support world-class salmon populations. These watersheds are classified as "Properly Functioning". Roads authorized by rescission in the Chichagof IRA, Tongass National Forest, alter natural drainage patterns by concentrating and redirecting surface flows, increasing runoff velocity, and delivering higher peak discharges to downstream flood-prone areas. The DEIS must evaluate the flood hazard potential of road construction in the Chichagof IRA, Tongass National Forest, as required by Executive Order 11988, including analysis of increased impervious surface, altered runoff patterns, and downstream flood risk. "Just as development and approval of forest plans must conform to existing laws and regulations, new laws or regulations, including this rule, can supersede existing forest plan management direction. This rulemaking process does not require amendments or revisions to forest plans. The NFMA reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). Together with other applicable laws, the NFMA authorizes the Secretary of Agriculture to promulgate regulations governing the administration and management of the National Forest Transportation System (16 U.S.C. 1608)." — USDA Forest Service This comment joins the record in opposition to the proposed rescission action. With concern, CommentID: RLC-20260824-UUV9QX

Dear USDA Leadership: For a researcher, an analysis that reaches only the conclusions that support its preferred action, and doesn't acknowledge the evidence pointing the other way, isn't analysis — it's justification. I grew up hunting, fishing, hiking, and playing in the woods - and that led me to a career working to protect and care for our forests and other wild landscapes. Once road access is permitted and extraction proceeds, the conditions that sustain connections of this kind cannot be administratively restored; the Department should treat that irreversibility as a dispositive consideration. Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan: Executive Order 11988 requires federal agencies to evaluate flood hazard potential before taking actions that alter floodplain hydrology. Road construction in the Bear Swamp IRA, Huron-Manistee National Forest, increases impervious surface area, accelerates stormwater runoff, and elevates peak discharge. Road construction in the Bear Swamp IRA, Huron-Manistee National Forest, converts permeable forest soils to compacted and paved surfaces, increasing impervious area, accelerating runoff concentration, and elevating peak flows in downstream floodplains. Executive Order 11988 requires the agency to assess flood hazard before authorizing road construction. The DEIS must quantify the increase in impervious surface, runoff volume, and peak flow resulting from road construction in the Bear Swamp IRA, Huron-Manistee National Forest, and evaluate downstream flood risk. "Any discharge of dredged and/or fill material into waters of the U.S. incidental to any of the exempt activities must have a permit if it is part of an activity whose purpose is to convert an area of a water of the U.S. into a use to which it was not previously subject, where the flow or circulation of waters of the U.S. may be impaired or the reach of such waters be reduced (Recapture Provision, Section 404(f)(2))." — U.S. Army Corps of Engineers, Sacramento District The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. “When a party argues that an agency action was arbitrary and capricious due to a deficiency in an EIS, the reviewing court must account for the fact that NEPA is a purely procedural statute. Under NEPA, an agency's only obligation is to prepare an adequate report. Judicial review is typically conducted under the Administrative Procedure Act's deferential arbitrary-and-capricious standard. Under that standard, a court asks not whether it agrees with the agency decision, but rather only whether the agency action was reasonable and reasonably explained. Agencies must take a 'hard look' at the environmental consequences of their actions in the context of projects under consideration. — Supreme Court of the United States (https://www.supremecourt.gov/opinions/24pdf/23-975_m648.pdf)” Sustaining the Rule is the outcome consistent with the Department's rulemaking history, its statutory responsibilities, and the record before it. In solidarity,

To the U.S. Department of Agriculture: In my work as an expedition guide, I have spoken with enough guests to know that what they come to Alaska and pristine quiet places for is precisely the character of land that the 2001 Rule has protected. I have spent the past 5 years up in Alaska taking clients to see the beauty and the productivity of an isolated roadless place. I have passed bears and other animals on the trail who do not threaten me because they have an abundance of food and nutrients and we are just passing by together. Just last week, we were taking guests along a river bed near Port Althorp and getting to show them what a productive salmon run looks like. We showed them how the dead salmon end up in the forest and return nutrients back to the forest from the water. We passed a bear who was readily on their way to the salmon, wanting nothing to do with us. These guests came back with countless stories and pictures and an understanding of what the world looks like when it is untouched and protected. This is exactly the experience they come looking for when they come travel here. The story recounted and the relationship underlying it are both, in the relevant sense, products of what twenty-five years of roadless protection has made possible; rescission would begin to unwind both. Regarding the Chichagof in the Tongass National Forest, Alaska: Headwater Networks Supporting Pacific Salmon Fisheries — The Chichagof IRA contains the headwaters of the Pelican Creek, Lisianski River, Kadashan River, Neka River, and other major drainages that support world-class salmon populations. These watersheds are classified as "Properly Functioning". Roads authorized by rescission in the Chichagof IRA, Tongass National Forest, alter natural drainage patterns by concentrating and redirecting surface flows, increasing runoff velocity, and delivering higher peak discharges to downstream flood-prone areas. The DEIS must evaluate the flood hazard potential of road construction in the Chichagof IRA, Tongass National Forest, as required by Executive Order 11988, including analysis of increased impervious surface, altered runoff patterns, and downstream flood risk. "Just as development and approval of forest plans must conform to existing laws and regulations, new laws or regulations, including this rule, can supersede existing forest plan management direction. This rulemaking process does not require amendments or revisions to forest plans. The NFMA reaffirmed multiple-use and sustained-yield as the guiding principles for land management planning of National Forest System lands (16 U.S.C. 1600, 1604). Together with other applicable laws, the NFMA authorizes the Secretary of Agriculture to promulgate regulations governing the administration and management of the National Forest Transportation System (16 U.S.C. 1608)." — USDA Forest Service This comment joins the record in opposition to the proposed rescission action. With concern, CommentID: RLC-20260824-UUV9QX

To the U.S. Forest Service Roadless Rule Docket: As a rural resident, I want to offer the Department a perspective that doesn't often make it into these comment periods: the people most directly affected by this rule are mostly not the ones asking for rescission. I can see Freel from my front window. We were already impacted by the Caldor fire Fire Ecology - Aplet, Hartger, Dietz 2026 - showed a 32 years of wildfire data proving roadless area fires are considerably lower than fires within 50m of roads. Plus 84% of wildfires are caused by humans - Balch el al 2017 and Smokey Bear. And most humans are too lazy to enter roadless areas, those that do want to protect it. Among many days in these forests, one has stayed with me. Wildfire and water clarity are super important to me. Water clarity is what keeps visitors coming here, providing tourism dollars our town relies on. The Department is respectfully requested to treat that account as what it is — a demonstration of the concrete, non-speculative harm that rescission of the Roadless Area Conservation Rule would produce. Regarding the Freel in the Lake Tahoe Basin Management Unit, California: Road construction in the Freel IRA, Lake Tahoe Basin Management Unit, creates impervious surfaces that increase runoff volume and peak flows, directly implicating the flood hazard evaluation requirements of Executive Order 11988. Roads authorized by rescission in the Freel IRA, Lake Tahoe Basin Management Unit, alter natural drainage patterns by concentrating and redirecting surface flows, increasing runoff velocity, and delivering higher peak discharges to downstream flood-prone areas. Executive Order 11988 requires the agency to assess flood hazard before authorizing road construction. The DEIS must quantify the increase in impervious surface, runoff volume, and peak flow resulting from road construction in the Freel IRA, Lake Tahoe Basin Management Unit, and evaluate downstream flood risk. "In a study in three headwater watersheds in the mountains of central Idaho, 70 percent of sediment deposition from roads constructed on the watersheds, where the slope ranged from 15 to 40 percent, occurred during the first year after construction, and one-fourth of this deposition occurred during road construction (Ketcheson and Megahan, 1996). Sediment generally traveled less than 100 m from its source. Average sediment travel distances from fills, rock drains, berm drains, and landings were between 4 m and 20 m, while that from cross drains was 50 m. The maximum travel distance from some cross drains was more than 250 m." — U.S. Environmental Protection Agency Allowing the Rule to remain in effect is consistent with the Department's obligations under the Multiple-Use Sustained-Yield Act and the National Forest Management Act. Yours truly, CommentID: RLC-20260823-6QPFS3