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Dear Secretary Rollins, For a parent, the fact that this rule has held across multiple administrations isn't bureaucratic trivia — it's evidence that it represents something durable enough to keep. As I walk through the woods with my children I point out the names of things, their uniqueness and beauty, and I am always proud when the facts I've imparted come back to me in conversations with them. Without exposure to wild and natural areas, we don't value them and forget that we share the planet with many ecosystems, plants and animals that are interconnected with us. The planet's health is our health. I've heard migratory birds (like the Cerulean Warbler cited below) in roadless forests that I hear nowhere else, felt quiet and peace that no urban park can provide. The record should reflect that the experiences just described are not anomalous but representative of what the 2001 Rule makes possible. Regarding the East Fork in the Ozark-St. Francis National Forest, Arkansas: Invasive Species Colonization Along Road Corridors — Road construction creates a linear disturbance corridor of bare soil, compacted earth, and altered light conditions that invasive plant species exploit for establishment and spread. These invasive species are a major threat to the survival of native species. The roadless condition of the East Fork IRA, Ozark-St. Francis National Forest, maintains contiguous interior forest canopy that shields Cerulean Warbler (Setophaga cerulea) nests from edge predators and Brown-headed Cowbird parasitism. This intact condition is itself the protection — once a road fragments the canopy, the edge effects are permanent and cumulative. Without site-specific analysis of how road construction in the East Fork IRA fragments interior forest breeding habitat for Cerulean Warbler (Setophaga cerulea, G4), the DEIS does not meet the requirements of the MBTA and EO 13186. The agency cannot lawfully proceed on an incomplete record. "Although most forest interior nesting species did not appear to avoid edge habitat along paved or unpaved forest road corridors, there were differential rates of nest predation and brood parasitism along varying widths of road corridors, suggesting that some corridors, particularly wider corridors with mowed edges, may be creating ecological traps for some migratory species of forest interior nesting songbirds." — USDA Forest Service, Gallatin National Forest Travel Plan FEIS - Issue 14: Migratory Birds, 2006 The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. “Road and trail corridors through continuous forest habitat can lead to increased nest predation rates since smaller forest patches may be easier for predators to penetrate, and roads and trails provide travel corridors for predators to access forest interior from nearby open habitat. Forest interior migratory bird species tend to be vulnerable to predation and parasitism because they often have open cup nest structures, poorly developed defense mechanisms, nest close to the ground and typically only produce a single, relatively small clutch each breeding season. — USDA Forest Service, Gallatin National Forest Travel Plan FEIS - Issue 14: Migratory Birds, 2006 (https://www.fs.usda.gov/media/53140)” The Rule is sound; the proposed rescission is not; the Department should act accordingly. With appreciation, Ms. Ashley Harper CommentID: RLC-20260902-9F3V2T

Dear Secretary and Chief: As a conservationist, I write to note that the Department's characterization of the Rule as having produced management inefficiencies is unsupported by the Forest Service's own implementation record, which the Department has not cited in support of this claim. While my career has been short in duration it is long in struggle with fighting for protection of wildlands. Americans are responsible for our land and protecting its inherent value. Keeping the land pure and unaltered with unnecessary construction. We have a duty to protect wildlands and I have worked tirelessly to convince not just the general public, but now the US Government of its value. Why are you fighting against your constituents? No one wants this. Visiting Alexander Springs for the first time I was awe stricken of the birds and ecology. If you have never taken the time to walk into the forest until you no longer hear the road. No car horns muffling the birds, no bright street lights blocking the stars. I encourage you to do so. You will learn the value of protecting those spaces from destruction. I turn to the specific grounds for my opposition to rescission. Regarding the Alexander Springs Creek in the Ocala National Forest, Florida: The Migratory Bird Treaty Act and Executive Order 13186 impose affirmative federal obligations to protect migratory bird habitat. The Alexander Springs Creek IRA, Ocala National Forest, supports Atlantic Flyway breeding habitat for 1 neotropical migratory songbird species that are globally vulnerable or state-imperiled: Bachman's Sparrow, (G3, S3 in Florida). These obligations attach to every one of them. Every road built through the Alexander Springs Creek IRA, Ocala National Forest, converts interior forest to edge habitat on both sides of the corridor. The 1 neotropical migratory songbird species breeding in this Atlantic Flyway forest are all interior-nesting specialists. Edge creation does not affect them selectively — it degrades nesting conditions for the entire assemblage at once. Executive Order 13186 requires federal agencies to develop and implement a Memorandum of Understanding with the U.S. Fish and Wildlife Service to promote the conservation of migratory bird populations. The DEIS for rescission of roadless protections in the Alexander Springs Creek IRA, Ocala National Forest, must demonstrate compliance with this directive as it applies to 1 Atlantic Flyway breeding songbird species. The MBTA protects every one of them. "More than half of migratory bird species in North America are experiencing population declines. Habitat loss and the resulting fragmentation on the breeding grounds are strongly correlated with observed population declines for the Connecticut warbler, which has experienced a total population decline of 62% since 1966 and declined by −8.99% per year between 2000 and 2017. Land-use practices that retain large, forested patches within landscapes will likely benefit breeding populations of this declining songbird." — PMC / Proceedings of the Royal Society B, 2021 The Department's own history with this Rule — through administrations of both parties — argues for leaving it in place. Very truly yours, Emily Gunther CommentID: RLC-20260823-MWNB9I