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FORMAL PUBLIC COMMENT — PROPOSED RESCISSION OF 2001 ROADLESS RULE Docket Number: 2026-18648 October 6, 2026 TO THE U.S. FOREST SERVICE AND DEPARTMENT OF AGRICULTURE: I, Lionel P. Trepanier (lioneltrepanier@gmail.com, Palm Desert, CA 92211), submit this comment in strong opposition to rescission of the 2001 Roadless Area Conservation Rule. I am a 25-year participant in Forest Service rulemaking, having submitted comments on 100+ USFS projects including the Roadless Rule and Spotted Owl EIS. VIOLATION OF LAW This rescission violates the Administrative Procedure Act, National Environmental Policy Act, Endangered Species Act, and Federal Indian Law on multiple independent grounds: 1. APA VIOLATION—Arbitrary and Capricious: The agency's own Draft EIS states: "Road density is linked to human-caused wildfires, and as density of roads increases so does probability, number, and frequency of wildfire ignitions." The proposed rescission contradicts this by authorizing new roads to mitigate wildfire risk. This is arbitrary and capricious disregard of agency's own science in violation of 5 U.S.C. § 706(2)(A). 2. FISCAL IRRATIONALITY: USFS deferred maintenance backlog exceeds $8.6-10.8 billion, with $6.4-6.9 billion tied to 370,000 miles of existing roads built 60+ years ago. Proposing new road construction while systematically underfunding existing infrastructure violates APA rational basis requirements. 3. PROCEDURAL INADEQUACY: Comment period is 53 days total (21 initial + 32 days). Original 2001 Roadless Rule: 129 days + 600 meetings. 2005 Bush rescission attempt: 182 days. This truncated process violates APA's requirement for meaningful public participation. 99% of initial public comments opposed rescission. 4. NEPA VIOLATION: DEIS fails to adequately analyze cumulative environmental impacts on 58.5 million acres, including degradation of municipal watersheds, loss of carbon sinks, habitat fragmentation, salmon spawning habitat destruction, and old-growth ecosystem loss. Fails hard-look review under Motor Vehicle Mfrs. v. State Farm, 463 U.S. 29 (1983). 5. ESA VIOLATION: Sweeping rescission across ranges of threatened/endangered species (marbled murrelet, northern spotted owl, salmon populations) without completed ESA Section 7 consultations violates 16 U.S.C. § 1536. Grounds for injunctive relief. 6. FEDERAL INDIAN LAW VIOLATION: Rescission breaches federal trust responsibility to tribes, violates Executive Order 13175 requiring government-to-government consultation, and endangers treaty-protected hunting, fishing, and gathering rights on ancestral lands. Industrial roadbuilding violates federal obligations to sovereign tribes. DEMAND I demand the Forest Service: - WITHDRAW the proposed rescission immediately - MAINTAIN the 2001 Roadless Rule in entirety - COMPLETE mandatory ESA Section 7 consultations - Provide 120-day comment period for any future rulemaking The 2001 Roadless Rule—enacted with broad bipartisan support and defended by federal courts—represents 25 years of successful policy protecting one-third of undeveloped National Forest System lands. This unlawful rescission will be challenged vigorously in federal court. A comprehensive detailed comment with full legal analysis is attached. Respectfully submitted, Lionel P. Trepanier Palm Desert, California 92211 lioneltrepanier@gmail.com October 6, 2026 --- [ATTACH FULL COMMENT DOCUMENT WITH COMPLETE ANALYSIS]

FORMAL PUBLIC COMMENT — PROPOSED RESCISSION OF 2001 ROADLESS RULE Docket Number: 2026-18648 October 6, 2026 TO THE U.S. FOREST SERVICE AND DEPARTMENT OF AGRICULTURE: I, Lionel P. Trepanier (lioneltrepanier@gmail.com, Palm Desert, CA 92211), submit this comment, behalf Utah Tar Sands Resistance, an organization with a long history of advocating for and physically protecting public lands in Utah, including in the National Forests. We write in strong opposition to rescission of the 2001 Roadless Area Conservation Rule. VIOLATION OF LAW This rescission violates the Administrative Procedure Act, National Environmental Policy Act, Endangered Species Act, and Federal Indian Law on multiple independent grounds: 1. APA VIOLATION—Arbitrary and Capricious: The agency's own Draft EIS states: "Road density is linked to human-caused wildfires, and as density of roads increases so does probability, number, and frequency of wildfire ignitions." The proposed rescission contradicts this by authorizing new roads to mitigate wildfire risk. This is arbitrary and capricious disregard of agency's own science in violation of 5 U.S.C. § 706(2)(A). 2. FISCAL IRRATIONALITY: USFS deferred maintenance backlog exceeds $8.6-10.8 billion, with $6.4-6.9 billion tied to 370,000 miles of existing roads built 60+ years ago. Proposing new road construction while systematically underfunding existing infrastructure violates APA rational basis requirements. 3. PROCEDURAL INADEQUACY: Comment period is 53 days total (21 initial + 32 days). Original 2001 Roadless Rule: 129 days + 600 meetings. 2005 Bush rescission attempt: 182 days. This truncated process violates APA's requirement for meaningful public participation. 99% of initial public comments opposed rescission. 4. NEPA VIOLATION: DEIS fails to adequately analyze cumulative environmental impacts on 58.5 million acres, including degradation of municipal watersheds, loss of carbon sinks, habitat fragmentation, salmon spawning habitat destruction, and old-growth ecosystem loss. Fails hard-look review under Motor Vehicle Mfrs. v. State Farm, 463 U.S. 29 (1983). 5. ESA VIOLATION: Sweeping rescission across ranges of threatened/endangered species (marbled murrelet, northern spotted owl, salmon populations) without completed ESA Section 7 consultations violates 16 U.S.C. § 1536. Grounds for injunctive relief. 6. FEDERAL INDIAN LAW VIOLATION: Rescission breaches federal trust responsibility to tribes, violates Executive Order 13175 requiring government-to-government consultation, and endangers treaty-protected hunting, fishing, and gathering rights on ancestral lands. Industrial roadbuilding violates federal obligations to sovereign tribes. DEMAND I demand the Forest Service: - WITHDRAW the proposed rescission immediately - MAINTAIN the 2001 Roadless Rule in entirety - COMPLETE mandatory ESA Section 7 consultations - Provide 120-day comment period for any future rulemaking The 2001 Roadless Rule—enacted with broad bipartisan support and defended by federal courts—represents 25 years of successful policy protecting one-third of undeveloped National Forest System lands. Respectfully submitted, Lionel P. Trepanier, personally and as Director Utah Tar Sands Resistance Palm Desert, California 92211 utahtarsandsresistance@gmail.com October 6, 2026 -

I write today in support of the “no action” alternative and to keep the 2001 Roadless Rule intact. The Roadless Rule successfully safeguards the critical streams and rivers that provide clean drinking water for millions of Americans, preserves vital wildlife migration paths, and protects mature forests that serve as critical carbon sinks—an environmental buffer that is uniquely vital in light of increasingly hotter and drier weather trends here in Utah. Complete rescission of the rule is a flawed approach to wildfire mitigation. Particular notes of concern regarding the proposed changes: Watershed Protection: Across the country, roadless forests feed watersheds that supply clean drinking water to about 24 million Americans. The agency's own DEIS indicates that a full repeal risks severe environmental degradation, including increased erosion, localized landslides, and heavy sediment loads introduced directly into these municipal water supplies. Biodiversity: The DEIS also notes that shifting away from national roadless protections may adversely affect up to 327 threatened and endangered species by fragmenting critical habitats and disrupting migration corridors. Tribal Sovereignty: Tribal nations overwhelmingly oppose the repeal of the Roadless Rule, citing direct threats to sacred sites and treaty-protected hunting and fishing rights. Notably, the Secretary of Agriculture and the USDA announced the proposed rule- a large-scale, sweeping shift in environmental policy- without the mandatory advance consultation of affected tribal governments, bypassing Executive Order 13175, the Administrative Procedure Act, and the USDA's own Departmental Regulation 1350-002. Attempting retroactive consultation during an open public comment window fails the legal standard for "prior" or "meaningful" government-to-government consultation. Disrupting these vast, intact ecosystems will impact human communities far beyond what appears in the short term. A full repeal of the 2001 Roadless Rule strips all environmental protections and bypasses the collaborative, state-specific approach previously achieved in places like Idaho and Colorado. The cutting of mature trees will disrupt local water cycles, destabilize forest ecosystems, and fragment critical habitats. Introducing new road networks into these pristine spaces creates greater opportunities for human and machine caused ignitions. The 2001 Roadless Rule already allows for the proactive thinning of small-diameter trees to reduce wildfire risk; therefore, this total rescission is unnecessary for public safety and disregards the cumulative ecological damage that will be incurred. I strongly encourage the USDA to consult with a balanced, independent panel of conservation biologists, ecologists, forest management specialists, and local tribal leaders to fully grasp the long term impacts of this measure. Furthermore, as established in NCAI Resolution #SEA-25-102, Tribal governments need to be treated as cooperating agencies, ensuring they have equitable standing with states in determining management priorities for areas that directly affect Tribal resources, treaty rights, and cultural landscapes. If the rule is rescinded contrary to my primary recommendation, I urge the agency to implement a "Restoration Only" framework as the sole allowable policy direction. Limit road infrastructure to temporary networks permitted solely for urgent forest health and public safety, while prohibiting commercial logging. Restrict all cutting to sub-merchantable fuels using strict, science-based diameter caps. Codify ecological priority zones. Utilize non-commercial stewardship and continuous maintenance contracts focused solely on removing small-diameter ladder fuels while maintaining the closed canopy of ancient trees. Thank you

I urge you to rescind the proposal discussed in FS-2025-0001-223869, Special Areas: Roadless Area Conservation, because of the irrevocable devastation it would cause. Once roads are built, there is no way to undo the damage. According to the analysis in the DEIS, elimination of the Roadless Rule across 45 million acres nationwide would result in a loss of up to $9 million a year from lowered visitor spending, especially hurting local communities, 327 ESA-listed species and 71 critical habitats would be negatively impacted, threaten Tribal sacred and archeological sites, exacerbate the Forest Service’s estimated maintenance backlog of over $8.6 billion covering the existing 370,000 miles of roads, and could actually increase fire risk. More roads will result in more human-caused fires in the backcountry. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. Agencies already have authority to manage fuels and fight fires in roadless areas, including the construction of roads for emergency situations. There is no reason to repeal the Roadless Rule. To repeal the Roadless Rule without early, meaningful, government-to-government consultation with affected Tribes would be a violation of the Constitution, Federal law, treaty obligations, Tribal sovereignty, and religious rights. Roadless areas sustain ecosystems Tribal Nations have relied on for generations and are critical to food security for many indigenous communities as well as for sustaining cultural practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts. Roadless areas also include sacred sites and ancestral homelands, such as in the Tongass National Forest for the Tlingit, Haida, and Tsimshian peoples. The DEIS does analyze Tribal rights and interests. The defect is in what that analysis contains, and the DEIS says so itself. This comment is directed at the Tribal Rights and Interests section, pp. 205–210, and at the compliance representation Table 52 rests on it (p. 247). I request that the FEIS supplement the Tribal Rights and Interests analysis to do what the DEIS presently does not: for each tribe whose treaty-reserved rights the record identifies — including at minimum the Swinomish Indian Tribal Community, the Confederated Salish and Kootenai Tribes of the Flathead Nation, and the Shoshone-Bannock Tribes — (1) identify the treaty and the rights reserved; (2) map the inventoried roadless acreage lying within the ceded territory, usual-and-accustomed area, or identified subsistence use area to which those rights attach; (3) state, by alternative, the acres of that overlap in which road construction and timber harvest would become permissible; and (4) analyze the effect of that change on the quantity, quality, and ecological integrity of the treaty resources on which, by the DEIS's own statement at p. 210, the usability of the right depends. Where a boundary is confidential under the authorities the DEIS cites at footnote 65, the acreage can be reported in aggregate without disclosing the boundary, and the FEIS should report it that way and say so rather than omit the analysis. Until that analysis exists, the DEIS cannot support a comparison of alternatives for this resource, and the sections Table 52 identifies cannot document compliance with E.O. 13175. Given the widespread multifaceted harms repealing the Roadless Rule would cause it is imperative that it be improved by: Eliminating the logging loopholes. Logging does not improve anything - it only causes degradation. Instead of the 2000 EIS estimated ~ 1,400 acres of logging in roadless areas across the nation annually, on average from 2008-2018, there has been 3,200 acres of inventoried roadless logging annually in Montana alone. The majority of which was from using Roadless Rule loopholes. Eliminating livestock grazing in our inventoried roadless areas. Livestock grazing spreads invasive grasses that exacerbate wildfires, displaces wildlife, destroys habitat, and pollutes clean water. Despite being only four percent of livestock production in this nation, livestock grazing is pervasive on nearly 250 million acres of our public lands. The Forest Service is clandestinely restocking vacant grazing allotments with cattle, including in roadless areas and Wilderness, without public knowledge or participation. Restricting motorized and mechanized use in our inventoried roadless areas. Research shows that motorized and mechanized access (on roads, trails, or over the snow) harm wildlife, from elk to grizzly bears. Extend the provisions of this strengthened national rule to Idaho and Colorado, which currently have less protective rules. Thank you

Special Areas: Roadless Area Conservation; Proposed Rule RIN 0596-AD66 Docket number FS-2025-0001-223869 My name is Karla Ward, a registered voter living in Whatcom County, Washington. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, documented in the Federal Register on August 20, 2026 (FR Doc. 2026-16965, Docket No. FS-2025-0001, RIN 0596-AD66). The proposed rescission is a violation of treaty rights, trust responsibilities, and federal law (see USDA Departmental Regulation 1350-002, Executive Order 13175, and the Federal government’s trust responsibility to Tribal Governments). The proposed rescission is an unacceptable and illegal Indigenous-erasure-forward and ethnic-cleansing policy statement. The EIS, cost-benefit analysis, and draft Biological Assessments available under Docket No. FS-2025-0001 are as clear as the water flowing from a protected and pristine watershed. It ain’t broke. Don’t fix it. The DEIS analyzes three alternatives. The only alternative acceptable to this voter is Alternative 1 (No Action), retaining roadless policy on 44.7 million acres of inventoried areas, including 9.3 million acres on the Tongans National Forest. The proposed rule reveals that the rescission “would have substantial direct effects on Indian Tribes”, and “warrants consultation under E.O. 13175”. The DEIS itself concedes: “Timber harvest and road construction in inventoried roadless areas could significantly alter Tribal access to treaty-reserved resources, sacred sites, and other culturally significant areas.” Both action alternatives acknowledge these activities “could have long-term negative effects on Tribal rights and interests.” Every alternative that Tribal governments put forward in good faith during scoping was screened out of detailed analysis in the DEIS. Government-to-Government consultation is the standard, not a one-off. Re-defining ‘consultation’ to nothing more than a public comment option is dismissive and illegal. Tribal consultation is NOT advisory, nor is it just another check-off box item. Substantive, formal, robust and inclusive Tribal and Nation consultation and accordance-as understood by the Tribes-is non-negotiable and must not be diminished, period. Roadless spaces preserve food security-such as salmon stocks and gathering territories-for many Indigenous communities. Roadless spaces sustain Indigenous cultural practices observed and protected for thousands of years. This artificially accelerated rescission will undermine existing co-management and co-stewardship agreements and Memorandums of Understanding between the USFS and many Indigenous governments. Case in point, proximate to me, the Roadless Rule protects 19,200 acres of the Mt. Baker-Snoqualmie National Forest, which includes at least 19 local areas that could be adversely affected by the proposed rescission. Every acre is traditional Indigenous homeland to multiple recognized Tribes and Nations, and has been since time immemorial. The accelerated process coded in the proposed rescission of the Roadless Rule favors extraction over protection. What’s the reason for the hurry? Three words: GREED, POWER and CONTROL. Ecosystems providing clean drinking water to 60 million US residents and 354 municipal watersheds, and wildlife habitats and foundational biodiversity, will be irrevocably and significantly compromised by incursions from motorized vehicles, expanded logging, drilling, fracking, mining, refining and distribution activities. Keystone species contributing to sustainability for all of us will certainly be harmed by invasive incursions and additional wildfire risk, as documented in the EIS that the rescission proposes to ignore. The existing rule provides for management flexibility, including wildfire risk reduction and public safety response. The proposed rescission enshrines the ‘wildfire risk’ red herring. By increasing human activity in currently-protected roadless areas, wildfire risk is enhanced, not diminished. Concerns for wildfire in roadless areas are best addressed with robust USFS wildfire mitigation funding and interjurisdictional-including Tribal-involvement. The American people overwhelmingly supported the establishment of the Roadless Rule and the values therein encoded, have opposed rescission during the intent process, and will continue to insist on its intact preservation during the DEIS process. The Federal Land Policy and Management Act of 1976 states ‘public lands are to be protected for future generations’. The federal government is responsible to manage these lands for ALL citizens, for the long-term, not for the benefit of short-term, exploitative, commercial interests. The USFS was constituted for public service, not to enable outright, illegal corporate capture of public lands. Adopt Alternative 1(No Action).

I write to oppose the proposed removal of 36 CFR part 294, Subpart B, and to urge the Department to adopt the No Action alternative. First, the Department's own analysis undercuts its rationale. The preamble concedes that management opportunities from rescission "would be modest and localized." It projects $5.2 to $11.4 million in annual revenue to the Treasury and Forest Service against an estimated $6.1 million in lost recreation benefits. It does this while the agency carries a $6.9 billion deferred maintenance backlog for roads and bridges. Adding roads to a system the agency cannot maintain is not stewardship. It shifts a liability onto future budgets and onto the watersheds that unmaintained roads degrade. Second, the wildfire justification does not require rescission. The 2001 Rule already permits cutting generally small-diameter timber to reduce the risk of uncharacteristic wildfire (§ 294.13(b)(1)). It also permits road construction needed to protect public health and safety (§ 294.12(b)(1)). If those exceptions have been applied inconsistently, the remedy is clearer guidance, not the elimination of protections across 58.5 million acres. The preamble itself acknowledges that new access increases the potential for human-caused ignitions. Third, the proposal disregards the weight of Tribal input. By the Department's own summary, most Tribal governments consulted oppose rescission as a threat to sacred sites, subsistence resources, and water quality. Only 29 of 64 requested consultations had been held. Finalizing this rule before consultation is complete would be inconsistent with the federal trust responsibility under E.O. 13175. Fourth, "local flexibility" here means forest-by-forest uncertainty. A national rule gives states, Tribes, communities, and businesses a stable baseline. The Idaho and Colorado rules show that tailored state approaches are already available by petition without dismantling the national floor. Finally, these areas supply clean drinking water, intact habitat, and remote recreation that cannot be restored once they are roaded. Irreversible losses should not be traded for modest and speculative gains. I respectfully urge the Department to withdraw the proposed rule.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge USDA to withdraw it and adopt the No Action alternative. The preamble's own findings do not support the stated purpose and need, and the record fails to analyze costs the agency itself acknowledges. I live in Arizona and Vermont, and have seen firsthand the ecological and economic benefits of the rule. In addition to using public lands for recreation, these lands protect our nation's heritage, and natural resources we will rely on into the future. As Arizona is currently in a water crisis due to decreased Colorado River flows, intact national forests that ensure clean water supply and aquifer recharge are essential--and any change to this rule can be read as disrespect for the citizens of that state. Near Tucson, where I live, the The Upper Rincon and Santa Rita IRAs on the Coronado National Forest protect sky island headwaters above the Tucson basin, and the Arizona National Scenic Trail crosses both. USDA should analyze the rescission's effects on these watersheds and on recreation along the trail. The agency's findings undercut its rationale. USDA justifies rescission by citing wildfire, insects, and forest health (91 FR 53828), yet concedes management opportunities would be "modest and localized" (53829). Projected timber gains assume harvest across all 4.8 million operable acres, which USDA calls "unlikely" (53829). Speculative benefits cannot rationally justify removing protections from tens of millions of acres. Under Motor Vehicle Mfrs. Ass'n v. State Farm (1983), the agency must show a rational connection between the facts found and the choice made. It has not. Drinking water impacts are unanalyzed. The preamble acknowledges roadless areas at high risk of intense fire that threatens "drinking water sources" (53829) and records Tribal concern for water quality (53832), but quantifies no effect of new roads, harvest, or leasable mineral development on sediment, turbidity, or treatment costs for downstream utilities. USDA should identify affected public water systems by watershed and quantify these effects before any final action. USDA admits the rule will raise human-caused ignition risk. The preamble states greater public access "can increase human-caused ignition potential" (53829). The fire benefit it cites, fuel treatment in the wildland-urban interface, involves 9.8 million acres, about 24 percent of affected areas (53829), and the 2001 Rule already permits cutting small-diameter timber to reduce uncharacteristic wildfire effects (36 CFR 294.13(b)(1)). A narrower alternative exists: clarify that exception for WUI fuels work while keeping protections elsewhere. USDA must explain why it rejected that option. Economic costs are understated and fall on small entities. USDA estimates $6.1 million per year in lost recreation benefits, plus closures, noise, user conflicts, and trade-offs for tourism (53829-30), and says impacts could exceed $100 million (53830). Outfitters, guides, and tourism operators are largely small businesses, yet USDA certifies no significant impact on small entities (53831). That certification conflicts with its own findings. New roads would also add to a $6.9 billion deferred maintenance backlog (53829) that the analysis does not cost out. Wildlife and subsistence analysis is incomplete. The preamble lists threatened and endangered species and plant and animal diversity among the values at stake (53828), notes possible long-term effects on commercial fisheries (53830), and defers ANILCA Section 810 subsistence hearings to a later notice (53830). Finalizing before that analysis is complete would be premature. Tribal consultation is incomplete. USDA concedes the rescission has substantial direct effects on Tribes, that most Tribes consulted oppose it, and that only 29 of 64 requested consultations have been held (53831-32). The final Tribal impact statement will appear only with the final rule. Proceeding first is inconsistent with E.O. 13175 and the federal trust responsibility. Reliance interests must be weighed. USDA invites comment on reliance interests (53830). Under DHS v. Regents (2020), an agency changing course must consider them. Water utilities, recreation businesses, Tribes, and communities have relied on these protections for 25 years. I request you withdraw the proposed rule and adopt No Action. The USDA justifications for changing this rule are contradicted within its own documents. This increases new fire risk, decreases water quality, and disproportionately affects the economies of smaller towns and rural America. This cannot be justified and cannot go through.

My name is Audrey McGaughey, and I serve as the Tribal Historic Preservation Officer for the Modoc Nation. Our ancestral homelands in northeastern California and south-central Oregon include lands now managed as National Forest, and our people remain connected to those places today. The Modoc Nation wants to work with the Forest Service. We say that first because it is the heart of this comment. We understand why changes to the Roadless Rule are being considered. Many of our national forests are overgrown, and that overgrowth puts forests, wildlife, and communities at risk. Our people have always understood that land needs people. For generations, our ancestors tended these landscapes, and that relationship between people and the land is what kept them healthy. Active management, and the access it sometimes requires, can be part of restoring that relationship. We do not come in opposition to caring for the forest. What we ask is that this work be done in good faith, and with us. Roadless areas are some of the least surveyed lands in the National Forest System. They hold cultural sites, burials, and traditional use areas that have never been recorded. A road built without talking to us first can destroy something that cannot be replaced. A road planned with us can often go around it. That is the kind of practical problem-solving we want to do together. We respectfully ask that the final rule and Record of Decision guarantee the following: Meaningful government-to-government consultation with affected tribal nations before any road construction or ground disturbance is approved in a current roadless area. We mean real meetings, held early, where tribal input can still shape the route and design of a project, consistent with Section 106 of the National Historic Preservation Act (36 CFR Part 800) and Executive Order 13175. A commitment to avoidance first. Where a cultural site is identified, the agency and the tribe work together to route around it or find a better way before any other option is considered. Tribal cultural monitors present during ground-disturbing work, when a tribe requests them. Reporting and treatment of artifacts, sites, and ancestral remains in the way the affected tribe directs. Tribes know how we wish our ancestors and our places to be respected, and those protocols should guide the work, alongside NAGPRA and ARPA. Cultural surveys completed before decisions are made, with sensitive site locations kept confidential. Please do not be afraid to reach out. We are willing to talk, we are willing to meet, and we want to get things done. It is an honor to work alongside our federal partners, and we would much rather build that partnership than stand on opposite sides. Good consultation makes for better projects, healthier forests, and stronger relationships for everyone. Sepk'eec'a, Audrey McGaughey Tribal Historic Preservation Officer, Modoc Nation

Over the last 13 years in particular I have seen and dealt with the significant impacts of humans on our National Forest and Wilderness areas. The areas most trashed, most harmed, most affected are those accessible by roads. I also know anecdotally and from reporting that the majority of wildfires are human caused and that the majority of them are started in places accessible to roads. So the argument that we need to recind the roadless rule for wildfire management holds little water for me. I am weary of picking up human shit, dispersing fire evidence in places where none are allowed and/or where common sense seems to fly out the window. I'm tired of the resource damage. Over the last couple decades it is also apparent that our practices of resource extraction, reliance on fossil fuels, and so on - all the things that are undeniably causing the climate change in ways that are inarguable anymore - are putting us on a path to our own extinction. We live on an exquisite planet. Spend a time in the woods near where I live and learn how precious and amazing it all is. We have much to learn from this place starting with how to stop thinking we are the king of the mountain. We need to do more than just "consult" with the tribes but perhaps get curious about how they lived here sustainably for thousands of years. And then there is the practicality of what is being proposed. We can not and do not maintain the Forest Service Roads we currently have. And even if we could we also do not have the manpower to manage more. Where will the money come from? Where will the employees come from. You have already gutted it. And in just a few minutes of research it's clear y'all simple do not know what you are doing, talking about and lack any kind of cogent plan. Additionally, the full gambit of folks who access National Forest Lands are opposed to this. Listen. Do what is right for generations to come. Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates 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. Thirty of Sixty-Four Tribal Consultation Requests Undisposed in the Section Designated as the EO 13175 Compliance Record Re: Consultation accounting, Draft EIS Vol. I p. 17 — thirty of sixty-four tribal consultation requests are unaccounted for in the only section the Draft EIS designates as its Executive Order 13175 compliance record. 1. The Draft EIS's own figures. At Vol. I p. 17, under the heading "Consultation with Federally Recognized Tribes and Alaska Native Corporations," the Draft EIS states: "The Forest Service received 64 requests for consultation, 29 consultations have been held, and an additional 5 scheduled." Thirty of the 64 requests — 47 percent — are therefore neither held nor scheduled.

I oppose the proposal to remove and reserve 36 CFR part 294, Subpart B (§§ 294.10–294.18). USDA should adopt the No Action alternative. At a minimum, it should keep roadless protections on the Tongass National Forest. My name is Amamsa Bremner, I was born in raised in the Tongass, I am an enrolled member of the Yakutat Tlingit Tribe 1. The impacts analysis leaves out carbon. The "Summary of Potential Impacts" covers roads, timber, wildfire, recreation, fishing, and minerals, but not carbon or climate. For the Tongass, that is a major gap. A peer-reviewed study (DellaSala et al., 2022, Land 11(5):717) estimated that the Tongass stores about 2.7 billion metric tons of carbon, roughly 20% of all forest carbon in the National Forest System. Inventoried roadless areas hold just over half of it. Logging old-growth rainforest releases carbon that takes centuries to recover. USDA's own Tribal input summary notes that Tribes raised the forest's "global climate significance" as a carbon sink, but the proposal never responds to that point. Recommended change: The final EIS and cost-benefit analysis should quantify carbon losses forest by forest, including for the Tongass, before any final decision. 2. The wildfire rationale does not apply to the Tongass. The "Rationale" section justifies rescission with drought, wildfire, and fuel-loaded forests, "especially in the Western United States." The Tongass is a temperate rainforest where large fires are rare. Conditions in other forests should not be used to remove protections from one where they don't exist. Recommended change: Exclude the Tongass from any rescission. 3. Forest plans do not give equivalent protection. The proposal claims that land management plans address "similar conservation objectives" as the 2001 Rule. Yet it also admits that later plan amendments "could increase the area where timber harvest and road construction would be allowed." A protection that can be amended away is not equivalent to a rule. The Tongass has been exempted and restored repeatedly since 2003, which shows how fragile protection is without a durable rule. 4. Stewardship should be led by Tribes, not shifted onto them. The proposal says local decisions would be "informed by Tribes." USDA's own summary, however, reports three things. Most consulted Tribal governments oppose rescission. Tribes warn that it shifts the burden of project-level review onto their limited resources. And Tribes asked for co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent. Tribal guardian programs in Southeast Alaska, such ans Kake, Yakutat annd others, are the right stewards for any thinning, restoration, or forest management in Tongass roadless areas. That work should not be opened to commercial timber sales and road building. Recommended change: Keep Subpart B and develop a co-stewardship framework with Tribes on the Tongass, consistent with the federal trust responsibility under E.O. 13175. 5. Subsistence review must come first. The proposal says ANILCA Section 810 subsistence hearings will be announced later. USDA should not finalize any rule until those hearings are held in Southeast Alaska communities and a full 810 analysis is complete. That analysis should include effects on salmon watersheds. The proposal's conclusion that commercial fishing would not be significantly affected has not been examined for the Tongass specifically. For these reasons, I urge USDA to withdraw the proposed rescission and retain the 2001 Roadless Rule.

I oppose the proposal to remove and reserve 36 CFR part 294, Subpart B (§§ 294.10–294.18). USDA should adopt the No Action alternative. At a minimum, it should keep roadless protections on the Tongass National Forest. [1–2 sentences about who you are and your connection to the Tongass.] 1. The impacts analysis leaves out carbon. The "Summary of Potential Impacts" covers roads, timber, wildfire, recreation, fishing, and minerals, but not carbon or climate. For the Tongass, that is a major gap. A peer-reviewed study (DellaSala et al., 2022, Land 11(5):717) estimated that the Tongass stores about 2.7 billion metric tons of carbon, roughly 20% of all forest carbon in the National Forest System. Inventoried roadless areas hold just over half of it. Logging old-growth rainforest releases carbon that takes centuries to recover. USDA's own Tribal input summary notes that Tribes raised the forest's "global climate significance" as a carbon sink, but the proposal never responds to that point. Recommended change: The final EIS and cost-benefit analysis should quantify carbon losses forest by forest, including for the Tongass, before any final decision. 2. The wildfire rationale does not apply to the Tongass. The "Rationale" section justifies rescission with drought, wildfire, and fuel-loaded forests, "especially in the Western United States." The Tongass is a temperate rainforest where large fires are rare. Conditions in other forests should not be used to remove protections from one where they don't exist. Recommended change: Exclude the Tongass from any rescission. 3. Forest plans do not give equivalent protection. The proposal claims that land management plans address "similar conservation objectives" as the 2001 Rule. Yet it also admits that later plan amendments "could increase the area where timber harvest and road construction would be allowed." A protection that can be amended away is not equivalent to a rule. The Tongass has been exempted and restored repeatedly since 2003, which shows how fragile protection is without a durable rule. 4. Stewardship should be led by Tribes, not shifted onto them. The proposal says local decisions would be "informed by Tribes." USDA's own summary, however, reports three things. Most consulted Tribal governments oppose rescission. Tribes warn that it shifts the burden of project-level review onto their limited resources. And Tribes asked for co-stewardship alternatives built on Traditional Ecological Knowledge and Tribal consent. Tribal guardian programs in Southeast Alaska [name specific programs if you can] are the right stewards for any thinning, restoration, or forest management in Tongass roadless areas. That work should not be opened to commercial timber sales and road building. Recommended change: Keep Subpart B and develop a co-stewardship framework with Tribes on the Tongass, consistent with the federal trust responsibility under E.O. 13175. 5. Subsistence review must come first. The proposal says ANILCA Section 810 subsistence hearings will be announced later. USDA should not finalize any rule until those hearings are held in Southeast Alaska communities and a full 810 analysis is complete. That analysis should include effects on salmon watersheds. The proposal's conclusion that commercial fishing would not be significantly affected has not been examined for the Tongass specifically. For these reasons, I urge USDA to withdraw the proposed rescission and retain the 2001 Roadless Rule.

Dear Secretary Rollins, I am writing to express my disapproval of rescinding the 2001 Roadless Rule. This is a betrayal of the American public and the antithesis of responsible land, water, and wildlife management. It is also an egregious breach of U.S. Tribal Nations' treaty rights. Rescinding the rule ignores treaty agreements with Tribal Nations and circumvents Tribal Historic Preservation protection of sacred sites and ancestral remains (under federal law and Executive Order 13175). This is also an infringement of Treaty & ANILCA Title VIII Rights (for Alaska Tribal members), as well as the Endangered Species Act (ESA), the Federal Land Policy and Management Act (FLPMA), the National Environmental Policy Act (NEPA), and the Clean Water Act. It will do immeasurable harm to public landscapes. Roadless areas are vital to watersheds, habitat, and wildlife connectivity. Fish, wildlife, and people all depend on intact forests for many vital reasonswater storage, habitat, clean air, and carbon storage. Wildlands health is important to us all, and for future generations of Montanans. Rescinding the Roadless Rule creates even more threats of wildfire, bringing more traffic into remote placeshuman-caused fires are the most common and often occur within one mile of an existing road. Building roads into intact ecosystems increases the opportunities for fires to start. Rescission of the Roadless Rule would create undue pressures on both the private sector and taxpayers. The outdoor industry relies on roadless areas and intact ecosystems, bringing in revenue to Montana, providing jobs and equipping hunters, anglers, and outdoor enthusiasts. Taxpayers will be stuck with construction costs for roads and an expensive long-term backlog of maintenance. In addition to outdoor jobs, money from responsible recreation also flows to state and federal governments in the form of entrance fees to parks, hunting and fishing licenses, lodging, and campsite fees. Rescinding the rule will shrink important sources of revenue and funding. The Roadless Rule rescission is fiscally irresponsible and illegal. It demonstrates this administrations penchant for deregulation, contempt for public interests, and disregard for Tribal rights. Removing the rule also subverts public wil; the rule is popular with both political parties and has been supported by millions of tax payers/voters. Rescinding this rule is a fast money scheme for a few elitists, not for the benefit of the American public or for our future generations. I urge you to keep the 2001 Roadless Rule. The federal government bears the responsibility to protect the public trust, the law, public lands, and Tribal sovereignty. Rescinding the rule is a land scheme, theft from the American taxpaying voter and an outrageous attack on our waters, lands, and wildlife.

I am writing to urge you NOT to rescind the 2001 Roadless Rule. Doing so would be a betrayal of the American public and the antithesis of responsible land, water, and wildlife management. It is also an egregious breach of U.S. Tribal Nations' treaty rights. Removing the rule subverts public will—the 2011 rule is popular with both political parties and has been supported by millions of public comments. Upending this rule is a get-rich-quick scheme for a few individuals, not for the benefit of the American public or for our future generations. It will do immeasurable harm to public land. Roadless areas are vital to watersheds, habitat, and migratory corridors. Fish, wildlife, and people all depend on intact forests for many vital reasons—water storage, habitat, clean air, and carbon storage. Their health is imperative to us all. Rescinding the Roadless Rule would create even more threats of wildfire, bringing more traffic into remote places—human-caused fires are the most common and cause the most damage. By building roads into intact ecosystems, opportunities to start fires increase. Legally, it flouts agreements with Tribal Nations and circumvents Tribal Historic Preservation protection of sacred sites and ancestral remains (under federal law and Executive Order 13175). This is also an infringement of Treaty & ANILCA Title VIII Rights (for Alaska Tribal members), as well as the Endangered Species Act (ESA), the Federal Land Policy and Management Act (FLPMA), the National Environmental Policy Act (NEPA), and the Clean Water Act. I urge you to keep the 2001 Roadless Rule in place. The federal government bears the responsibility to protect the public trust, the law, public lands, and Tribal sovereignty. Overturning the rule is theft from the American public and an outrageous attack on our waters, lands, and wildlife. I urge you to uphold the 2001 Roadless Rule.

September 18, 2026 Joshua White Acting Director, Ecosystem Management Coordination U.S. Forest Service, USDA 201 14th Street SW Washington, DC 20250-1124 SUBMITTED VIA REGULATIONS.GOV Docket No. FS-2025-0001 / RIN 0596-AD66 Re: NCAI Comments on Proposed Rule and Draft Environmental Impact Statement—Special Areas; Roadless Area Conservation Dear Acting Director White: On behalf of the National Congress of American Indians (NCAI), I submit the enclosed comments on USDA's proposed rescission of the 2001 Roadless Area Conservation Rule. NCAI strongly urges USDA to select the No-Action Alternative and retain the existing Roadless Rule. The rule provides an important nationwide baseline for protecting Tribal ancestral homelands, treaty-reserved resources, subsistence areas, sacred places, cultural landscapes, watersheds, and fish and wildlife habitat. NCAI's position is grounded in resolutions adopted through its membership, including Resolutions #MEM-26-040, #SEA-25-102, #AK-21-010, and #ABQ-19-029. These resolutions reflect the view of Tribal Nations participating in NCAI's process that removing these protections would impose an unreasonable burden on affected Tribal governments to monitor and respond to numerous future forest-planning and project-level decisions affecting their homelands and resources. The enclosed comments explain NCAI's concerns regarding the adequacy of Tribal consultation to date, the need to protect treaty and subsistence rights, and the importance of meaningful Tribal co-stewardship. They also identify specific recommendations for USDA should the agency proceed with changes to the current rule. We respectfully request that USDA fully consider these comments and include this letter and the enclosed submission in the administrative record for Docket No. FS-2025-0001, and that USDA treat this submission as preserving NCAI's position for purposes of administrative and judicial review. NCAI urges USDA to ensure that all affected federally recognized Tribal Nations receive a full, timely, and meaningful pre-decisional opportunity for government-to-government consultation, consistent with Executive Order 13175 and USDA Departmental Regulation 1350-002, before any final decision is made. Sincerely, Viswatej Attili Policy Associate National Congress of American Indians Enclosure: NCAI Comment Letter on Special Areas; Roadless Area Conservation

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). I request that USDA specifically address each point below in the final rule and response-to-comments, as required for reasoned decisionmaking under the Administrative Procedure Act, 5 U.S.C. 706(2)(A). ## 1. The draft EIS's alternatives analysis must not be a formality The preamble states that Tribal consultees requested specific alternatives, including a "No Action" alternative, a "Strengthened Roadless Rule Alternative," and a "Traditional Homelands Conservation Rule" incorporating Tribal co-stewardship and consent (Tribal Input Received section). It also records that Tribal participants "noted the global climate significance of the forest as a critical carbon sink," referring to the Tongass National Forest (same section). I request that the final EIS include a full, good-faith analysis of each requested alternative and disclose the carbon-sink and cumulative landscape-level effects of removing the national prohibition across all 58.5 million acres at once, not merely note that these concerns were raised. ## 2. The rule's own cost-benefit findings do not support the action The preamble states that only about 4.8 million acres (16 percent of forested inventoried roadless areas) meet both operability and plan criteria for expanded timber harvest, and that even full harvest of those areas — called "unlikely due to budgets, unforeseen limits on operability, and market conditions" — would yield only a 5 to 10 percent increase in national sawtimber harvest and $5.2–11.4 million per year in Treasury/Forest Service revenue. Against this, the same preamble estimates recreation and tourism losses of $6.1 million annually and states total additional impacts "could exceed $100 million" per year. The proposed rule does not explain why this tradeoff — modest, uncertain gains against agency-estimated costs exceeding $100 million annually — justifies rescinding a 25-year-old national protection. I request the final rule reconcile this discrepancy directly rather than restate general deregulatory policy goals. ## 3. Tribal consultation is incomplete, and majority opposition is already documented The preamble states the Forest Service received 64 requests for Tribal consultation, of which only 29 have been held, and that consultations "will be ongoing throughout the rulemaking process" — meaning the record shows consultation is incomplete as of this proposal. It also states that "the majority sentiment among Tribal governments consulted is opposition to the proposed rescission," citing threats to "inherent rights, Tribal sovereignty, cultural survival, and the ecological health of ancestral homelands." The preamble itself concludes this rescission "would have substantial direct effects on Indian Tribes ... and therefore warrants consultation under E.O. 13175." Given that determination, USDA should not finalize this rule until consultation is complete for all 64 requesting Tribes and the required ANILCA Section 810 subsistence hearings for Alaska — currently undated, with details "announced in a subsequent notice" — are held and incorporated into the record. ## Conclusion Each point above is drawn directly from USDA's own proposed rule. I request that the final rule and response-to-comments specifically address each one, consistent with the agency's obligation to engage in reasoned decisionmaking and respond to significant comments in the rulemaking record.

To Secretary Rollins and the U.S. Forest Service: I oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. The Rule protects roughly 58–60 million acres of Inventoried Roadless Areas (IRAs) across 38 states, and the record shows it delivers measurable benefits in watersheds, biodiversity, climate, wildfire, recreation, and tribal relations — benefits a rescission would put at risk. 1. Roadless areas protect drinking water. Roads are a documented source of sediment pollution in forested watersheds; even small road-disturbed areas can generate a disproportionate share of a watershed's erosion, and road densities above roughly one mile per square mile correlate with aquatic ecosystem degradation (Geos Institute, 2011, citing Durgin et al. 1989 and Henjum et al. 1994). A 2026 peer-reviewed PLOS Water study found IRAs provide outsized value for river protection, clean water, and aquatic biodiversity nationwide. Pew Charitable Trusts notes roadless areas alone hold 354 municipal watersheds supplying drinking water to millions (Pew, 2026). 2. Roadless areas are irreplaceable for biodiversity and connectivity. A peer-reviewed U.S. Forest Service/Wilderness Society analysis found IRAs increase the effective size of, and reduce isolation between, protected areas like national parks and wilderness (Belote et al., 2020). A 2021 Science of the Total Environment study found unprotected IRAs are important habitat for species of conservation concern, with lasting biodiversity effects if lost (Loucks et al., cited therein). Regional studies in the Klamath-Siskiyou and northern Rockies found roadless areas capture vegetation types under-protected elsewhere. 3. Roadless areas are a significant climate solution. Undisturbed forest soils and old growth store substantial carbon. Belote et al. (2020) found IRAs capture significant carbon annually relative to already-protected lands. The Tongass and Chugach hold a disproportionate share of national forest tree carbon, critical to climate goals (Law et al., 2023). Logging and road-building would release stored carbon and reduce future sequestration. 4. The claim that the Rule worsens wildfire risk is not supported. USDA cites roadless designations as a "barrier to wildfire risk reduction." Peer-reviewed research says otherwise: a 2026 Fire Ecology study (Aplet et al.) found ignitions up to four times more likely within 50 meters of a forest road than in roadless areas. This also undercuts the premise directly — the Rule already permits fuel-reduction treatments, and no fire-mitigation project under it is known to have been denied recently. In short, the tool the agency claims it lacks already exists. Roads are a documented source of human ignitions, so new roads would likely increase, not decrease, fire risk. 5. Rescission threatens recreation access and rural economies. IRAs sustain hunting, fishing, and backcountry recreation that many rural economies depend on. A 2026 Trout Unlimited report notes recreational fishing on national forests generates over $2.2 billion annually through gear, guiding, travel, and licenses (Gillespie et al., USFS PNW Research Station) — value tied to the clean-water habitat roadless areas protect. Meanwhile the National Forest System carries a $10.8 billion road-maintenance backlog; new roads add to that liability rather than reducing it. 6. The process has not met tribal consultation obligations. USDA's own August 2026 docket states most Tribal governments consulted oppose the rescission, citing threats to treaty rights, sovereignty, and ancestral homelands, and identify inadequate government-to-government consultation, as required under Executive Order 13175, as a central concern. The Affiliated Tribes of Northwest Indians and National Congress of American Indians have called for a minimum 120-day consultation period and cooperating-agency status under NEPA; that has not occurred. 7. Procedural and legal concerns. The 30-day window is short given the scope — the 2001 rule drew 1.6 million comments after 600 public hearings, with the large majority in support. This round has had no hearings outside Alaska. The rescission is also legally vulnerable: agencies must justify departing from 25 years of contrary findings, and NEPA requires a genuine range of alternatives, which the draft EIS does not appear to provide. I join calls to extend the comment period and hold hearings in affected states. I'll be direct: I'm angry that a policy with this much scientific and public backing is being unwound through a rushed process. This isn't a partisan issue — a February 2026 national poll found 76% of likely voters support the Rule, and groups like Backcountry Hunters & Anglers oppose this rescission for the same reasons conservationists do. I am watching this process closely, and I will not let a decision of this scale go unanswered. Thank you for considering my comment.

I am writing to express my strong opposition to the U.S. Department of Agriculture’s (USDA) proposed rule to remove 36 CFR Part 294 Subpart B, which rescinds the 2001 Roadless Area Conservation Rule. Nationwide prohibitions on road construction and timber harvesting in Inventoried Roadless Areas (IRAs) provide essential protections for 58.5 million acres of National Forest System lands. Scrapping national protections for fragmented, forest-by-forest planning fails to ensure sustainable resource management. I urge the USDA to select the No Action Alternative and retain the 2001 Rule. 1. Flawed Rationale on Wildfire Risk & Active Management The preamble claims national prohibitions constrain necessary fuels management and wildfire response. This misstates the existing rule's provisions. Under 36 CFR 294.13(b), the 2001 Rule already allows timber cutting and fuel reduction to reduce wildfire risk, clear hazardous fuels in the Wildland-Urban Interface (WUI), and control insect or disease outbreaks. Furthermore, industrial road building opens contiguous forest canopies, dries out forest floor fuels, and introduces invasive plants that carry higher fire frequencies. The preamble acknowledges that increased road access elevates human-caused ignition risks. Rescinding the rule will likely compound wildfire hazards rather than mitigate them. 2. Fiscal Inefficiency & Road Maintenance Backlog The Forest Service faces an estimated $6.9 billion deferred maintenance backlog for existing roads and bridges. Expanding permanent or temporary road networks into remote areas creates long-term financial liabilities the agency cannot support. Economically, the USDA’s analysis estimates potential timber revenue gains of $5.2 to $11.4 million per year, while acknowledging annual losses of $6.1 million to the outdoor recreation economy in operable areas alone. Negligible timber gains do not justify permanent damage to recreation, outfitters, guides, and local tourism economies reliant on unsegmented public lands. 3. Inadequate Assessment of Cumulative Impacts Under NEPA Delegating roadless management entirely to 192 individual forest planning processes violates landscape-level conservation standards: Habitat Fragmentation: IRAs serve as core habitat buffers and migration corridors for threatened, endangered, and sensitive species. Evaluating impacts piecemeal across individual forest units ignores cumulative, landscape-scale ecological degradation. Drinking Water Protection: Over 60 million Americans rely on National Forest lands for clean drinking water. Removing baseline protections risks sedimentation, soil erosion, and water degradation in headwater streams across critical watersheds. 4. Failure to Uphold Tribal Trust Responsibilities The majority of Tribal governments consulted oppose this rescission. Shifting from a protective nationwide standard to unit-by-unit planning forces an unsustainable administrative burden onto Tribal resources to repeatedly contest individual project proposals that threaten sacred sites, traditional gathering areas, and treaty-reserved rights. Proceeding despite widespread Tribal opposition undermines the Federal Government’s trust responsibilities and Executive Order 13175. Requested Action The 2001 Roadless Rule provides a stable, ecologically vital framework for managing national forests. Returning to fragmented management will increase litigation, inflate maintenance costs, and permanently degrade public lands. I respectfully request that the Department: 1. Reject the proposed rescission (RIN 0596-AD66). 2. Adopt the No Action Alternative in the Final EIS. 3. Preserve 36 CFR Part 294 Subpart B to safeguard Inventoried Roadless Areas. Respectfully submitted, DiMari D’Agostino Massachusetts State Constituent Swampscott, MA 01907 (845) 492-6268

I am writing in support of the U.S. Department of Agriculture’s proposed rule to rescind the 2001 Roadless Area Conservation Rule (36 CFR Part 294, Subpart B) and restore decision-making authority to local Forest Service line officers under the National Forest Management Act of 1976 (NFMA). A rigid, national "one-size-fits-all" restriction limits the agency’s ability to address localized forest health crises. Over 40% of inventoried roadless areas face high or very high wildfire hazard potential, yet restrictive federal rules have hindered mechanical thinning and hazardous fuel reduction efforts needed to protect neighboring communities, critical infrastructure, and municipal watersheds. Returning authority to local land management plans—guided by NEPA, the Endangered Species Act, and NFMA—allows for agile, science-based management tailored to specific landscape conditions. However, as the Department moves to finalize this rescission, it must ensure full compliance with Executive Order 13175 (Consultation and Coordination with Indian Tribal Governments) and fulfill its federal trust responsibilities. Shifting decisions to the local forest plan level must not compromise meaningful, government-to-government Tribal consultation. To ensure the final rule and subsequent local planning efforts are legally robust and respectful of Tribal sovereignty, I urge the Department to incorporate the following procedural safeguards: Mandatory Government-to-Government Consultation: Require Forest Supervisors to initiate early, formal consultation with affected federally recognized Tribes prior to approving any project or plan amendment within former inventoried roadless areas. Integration of Traditional Ecological Knowledge (TEK): Explicitly direct local decision-makers to incorporate TEK and co-stewardship opportunities into forest management plans to protect sacred sites, cultural resources, and traditional gathering rights. Comprehensive Subsistence Protections: Ensure that local forest planning frameworks, particularly in regions subject to statutory subsistence mandates like ANILCA Section 810, fully evaluate and protect Tribal subsistence access and natural resources. By combining local management flexibility with rigorous, formal Tribal consultation, the Department can achieve proactive forest stewardship while upholding its federal trust responsibilities. I urge the Department to finalize the rescission with these critical procedural protections included.

I am submitting this comment in strong opposition to rescinding the USDA Roadless Rule. As a Tribal member of the Pit River Nation, whose ancestral homelands span Shasta, Lassen, Siskiyou, and Modoc Counties, this rescission would directly harm our cultural resources, watersheds, and forest ecosystems. Removing the Roadless Rule would eliminate meaningful Tribal consultation, violating Executive Order 13175, which requires government‑to‑government engagement when federal actions affect Tribal Nations. It also conflicts with Executive Order 12898 by increasing environmental burdens on Indigenous communities without Tribal input. Roadless areas in the Shasta‑Trinity, Lassen, and Modoc National Forests contain our sacred sites, gathering areas, and traditional food and medicine resources. Opening these areas to road building and development will fragment habitat, damage watersheds, and threaten places our people have protected since time immemorial. The Pit River Nation is actively working toward the development of a Tribal Indigenous Forest Plan grounded in Pit River Nation ecological knowledge. Rescinding the Roadless Rule undermines this effort by removing protections and excluding Tribal voices from decisions affecting our homelands. I urge USDA to retain the Roadless Rule, uphold federal trust responsibilities, and ensure the Pit River Nation continues to have a formal role in managing and protecting our ancestral territories. Ida M. Riggins, Enrolled Tribal Member of Pit River Tribe idamriggins@gmail.com A longer formal letter referencing NEPA, NHPA Section 106, and trust responsibility A version tailored to Ajumawi or Atsugewi Bands A version that expands on the Indigenous Forest Plan and co‑management principles Just tell me what direction you want next.

I am very concerned about the proposed rescinding of the Roadless Rule. Through my professional research, I understand how important the protections of our natural wild areas are to the future survival of species, including humans, on this planet. I am particularly alarmed at how little this proposed plan seems to take into account the crucial role wild forest lands play in mitigating climate change. I am also concerned about the dire effects on sensitive species the repeal of the roadless protections would cause. My work includes monitoring salmon runs, a very important keystone species, whose decline would puts a whole web of interrelated species into peril. Ultimately our quality of life, our livelihoods, and likely our very survival, depend on us using our intelligence and knowledge to protect what is left of our wild lands. Nothing can replace the clean water, clean air and habitat that require these protections. Do not allow short term foolishness to destroy the heritage of health we must pass to future generations. I have read and agree with the below concerns about the Draft Environmental Impact Statement about the Roadless Rule. Please address my concerns and provide a proposal that does not sell out our future. Thank you, Caroline Phillips One-Sided Purpose and Need Omitting Countervailing Conservation Values [challenge-022] The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values. I request that the Forest Service reverify the roads-mileage figure against current transportation-system records, disclose the results, and either update the DEIS or justify continued reliance on the older data. I request the agency apply changed-circumstances data specifically to roadless areas and explain, on the record, why it rejects its own contrary ignition-density findings. I request a revised, balanced Purpose and Need section addressing Conservation values. I request the agency complete government-to-government consultation consistent with E.O. 13175 before any final rule, and document in the record how Tribal input altered the proposal. No Action Alternative Fails to Quantify Environmental Benefits of Retention [compliance-025] The No Action alternative's treatment fails to quantify the environmental benefits of retaining the 2001 Roadless Rule's protections. The Purpose and Need section (pp. 18-19) describes only that the Department clarified the proposed action and used literature "to inform analysis," without presenting any quantified baseline of unfragmented habitat acreage, watershed protection metrics, or wilderness/recreation values attributable to continued retention. This is a status-quo narrative, not the comparative analysis NEPA requires: 42 U.S.C. § 4332(2)(C)(iii) mandates "an analysis of any negative environmental impacts of not implementing the proposed agency action," which necessarily requires quantifying what would be lost, not merely describing the decision process. No figure here approaches the rigor of the acreage, harvest-volume, and operability projections built for the action alternatives. Given documented links between road construction, habitat fragmentation, and invasive species spread, the agency should quantify habitat connectivity, watershed protection, and recreation/wilderness values under No Action with comparable specificity before finalizing this EIS. I request that the agency add a dedicated analysis quantifying the added maintenance burden and environmental risk of proposed new roads given this documented, unresolved funding shortfall before finalizing the decision. Given documented links between road construction, habitat fragmentation, and invasive species spread, the agency should quantify habitat connectivity, watershed protection, and recreation/wilderness values under No Action with comparable specificity before finalizing this EIS. DO NOT SELL OUT OUR FUTURE!