Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The humpback whales we watched around Baranof Island brought me to this fight. I want those waters protected, and I want to know exactly how logging the Port Alexander and North Baranof roadless areas, covering 120,681 acres and 314,089 acres respectively in the Tongass National Forest, will affect the humpback whales who frequent those waters. The Tongass is the largest intact temperate rainforest left on Earth, holding over 12,930 miles of salmon-producing streams. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. I oppose that outcome completely. I also paddle parts of the Teanaway River, which flows through the Teanaway roadless area in Wenatchee National Forest. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Washington State is currently in the fourth consecutive year of drought and in a drought emergency. Our rivers have remained free flowing. How will rescission affect the volume of water and sediment load in the Naches, Tieton, and Yakima rivers and all their tributaries on the east side of the Cascades? Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, in habitat the DEIS identifies as Essential Fish Habitat and critical habitat managed by NMFS. I want to know what the effect on local salmon runs will be, and I ask the agency to answer that question squarely in the final record. We have visited Hyder, Alaska the last two summers and enjoyed watching the bears fishing at the USFS Fish Creek Wildlife Observation Site. The DEIS quotes the federal grizzly recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. How will rescission affect the number of bears and salmon that come to that observation site? The agency must address this. The national forests of Washington state already show scars from previous National Forest roads that remain in place, many of those roads receiving no maintenance. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. What will happen to the service level on current National Forest roads if the roadless rule is repealed and additional roads are built? How much will that cost taxpayers? The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. The agency's own record also states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on wildfire and fuels management grounds. Those two positions cannot both be right. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. Sincerely, Margaret Van Cleve Selah, WA

I do not support repealing the Roadless Rule, nor do I support Executive Order 14192, Unleashing Prosperity Through Deregulation, Executive Order 14225, Immediate Expansion of American Timber Production, Executive Order 14154, Unleashing American Energy, and Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential. This administration has been very transparent that it only values our environmental resources for what can be extracted from them. Natural resources require a holistic approach, especially when we are in a GLOBAL CLIMATE CRISIS, and I haven't heard any support for science-backed decisions regarding this matter. The proposal reads like an attempt to return jurisdiction to local decision-makers and to mitigate forest fires, but in concert with the map and executive orders, it reads as an incredibly transparent ploy to remove a roadblock from plundering our forests for timber. Forest fires are four times more likely to be started next to roads; and our large ancient trees do a vastly better job of removing carbon from our atmosphere. Money will not save the future of humanity; plundering our magnificent ancient forests seems shockingly shortsighted. Until this administration acknowledges actual environmental experts on issues like these, it will not have the trust of much of the American people.

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tongass has shaped my life in Sitka in ways I am still learning to name. In two years here it has molded how I move through the landscape, what I am grateful for, how I eat, what I notice. The sheer grandeur of an intact temperate rainforest does that. It is hard not to be enamored, and even harder not to feel grateful for what the Tongass is: a main pillar of subsistence, culture, recreation, and ecosystem in Southeast Alaska. The Tongass makes life whole here. As someone who lives inside that wholeness, I submit these comments opposing the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The forest I am writing from is the largest intact temperate rainforest left on Earth. It holds 110 inventoried roadless areas totaling 9,339,575 acres, more than 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by United States national forests. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. That means the salmon streams, the Sitka black-tailed deer, the brown bear, the wolves, the bald eagle, and the five species of Pacific salmon that anchor subsistence life here are all subject to what follows from that zero. The nine municipal watersheds named in DEIS Table 2, including Sitka, are also subject to it. I ask the agency to explain in specific terms what protection, if any, replaces the rule for those watersheds and that wildlife. The agency's own Tribal consultation record makes the procedural posture of this rescission indefensible. "The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule." Tribal governments proposed alternatives, among them a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analyzed. I find it deplorable that the summary of that consultation arrives only after the comment period closes. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule is issued. The economic case for rescission is not established by the agency's own numbers. The agency acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal contribution, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and the road system this rescission would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with that record and explain how an action whose own analysis cannot establish a net benefit is justified. The legal foundation here is also troubled. The agency's record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The proposal argues that state-specific approaches can substitute for a national rule. The Ninth Circuit already reviewed that argument the last time the agency replaced the national rule with a state-by-state approach and found it wanting. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids those same deficiencies. Finally, the DEIS itself quantifies a consequence it does not then apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record. No projection across the 40.1 million acres of potentially affected environment follows from it. The agency should apply its own cited finding at the scale of the action it is proposing. I implore policymakers to visit Southeast Alaska, bring your kids, show them what an intact temperate rainforest looks like, gaze upon it with gratitude for all the life it supports, be humbled. A logged stand grows back. The agency should say plainly what does not. Sincerely, Zia NoiseCat Sitka, AK

The proposed rule change says: "In 2001, the Roadless Area Conservation Rule established a single, nationwide set of prohibitions intended to provide lasting protection for inventoried roadless areas within the National Forest System in the context of multiple-use management." It goes on to say: "this deregulatory action advances the policy objectives of Executive Order 14192, Unleashing Prosperity Through Deregulation [...]. In Executive Order 14225, Immediate Expansion of American Timber Production, the President declared that “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” In Executive Order 14154, Unleashing American Energy, the President likewise declared that “it is in the national interest to unleash America's affordable and reliable energy and natural resources.” In Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, the President declared that “it is the policy of the United States to fully avail itself of Alaska's vast lands and resources” and “maximize the development and production of the natural resources located on both Federal and State lands within Alaska.”" It goes on to say that even without protection of the Roadless Rule, NFMA requires that areas adopt land management plans that "addresses similar conservation objectives as the 2001 Roadless Rule was intended to address, such as ecological integrity, sources of public drinking water, diversity of plant and animal communities, sustainable recreation, scenic character, and protection of cultural and historic resources." It adds: "In 2001, USDA and the Forest Service asserted that a national prohibition was the best means to reduce conflict and potential for incremental impacts to the ecological and social values of these areas." It adds: "Where plans allow, rescission of the 2001 Roadless Rule could increase management flexibility for access (roads), vegetation management, targeted fuels treatments, and access for minerals or energy uses." My comments: In the summary of key considerations it says that near-term permanent road additions would be likely on 45.5% of affected lands and temporary roads are likely on 28.3% of affected lands, totaling 73.8% of the currently roadless areas. It says timber harvesting would likely increase on 16% of affected areas, estimating a maximum of approximately $11.4M in revenue for the US govt. It says that 24% of the affected areas are in the wildland-urban interface and would improve the ability to suppress forest fires in those areas. It estimates $6.1M losses in economic benefits for recreation (reducing the net maximum revenue for the US govt to $5.1M, which appears to also be independent of the costs of road construction, which seem likely to exceed $5.1M--therefore, this rule does not project net increase in revenue for the US govt as a result of this rule change). It claims that there would not "likely" be a net increase in mineral development, despite also stating above that this rule change would further the goals of Executive Order 14154, Unleashing American Energy. Those claims appear to be in conflict with each other. I support the original goals of the roadless rule, which is to preserve pristine wilderness areas from encroaching "incremental" deterioration. The stated description and justification for the rule attempt to have it both ways -- it says that the rule change would pave the way for paving, timber harvesting, mining, and resource extraction, but also that we don't need to worry because maybe local officials might not decide to do those things. It cites legitimate-sounding needs for wildfire mitigation and prevention, but officials could have submitted a narrower rule change limited to the wildland-urban interface areas; or suggested broadening the allowed exceptions to enable effective wildfire prevention and response without also opening the areas to more harvesting and encroachment. Instead they have proposed a rule change that their summary estimates will in the near-term be likely to result in impacts to 73.8% of affected lands currently protected as pristine roadless areas. Its summary also does not project a net profit for the US govt from these rule changes, once their maximum projected revenues are compared against their projected costs and reasonable plausible road construction costs. The Forest Service has a multi-use mandate, but this does not mean that every parcel of land is or should be expected to be multi-use, and it is necessary to protect these lands at the national level from incremental impact. These rare lands that remain pristine and wild should be protected and preserved as the unique and valuable receptacles of ecological habitat, natural wonder, and irreplaceable history. Once they are gone they cannot be brought back.

To Whom It May Concern: My name is Clara Hildman, and I live in Loveland, Colorado. I am writing as an individual to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I’m writing to specifically address the section of the proposal regarding Purpose and Need for Action where there is a paragraph that speaks about resource use in certain areas. “Specifically, this deregulatory action advances the policy objectives of Executive Order 14192, Unleashing Prosperity Through Deregulation, to alleviate unnecessary regulatory burdens. In Executive Order 14225, Immediate Expansion of American Timber Production, the President declared that “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” In Executive Order 14154, Unleashing American Energy, the President likewise declared that “it is in the national interest to unleash America's affordable and reliable energy and natural resources.” In Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, the President declared that “it is the policy of the United States to fully avail itself of Alaska's vast lands and resources” and “maximize the development and production of the natural resources located on both Federal and State lands within Alaska.” Consistent with this policy, Executive Order 14153 directed the Secretary of Agriculture to reinstate the 2020 Alaska Roadless Rule that exempted the Tongass National Forest in Alaska from the 2001 Roadless Rule. This proposed rescission does not mandate timber cutting or road construction but would relieve regulatory burden relative to management of National Forest System lands.” I would like to highlight this last sentence in contrast to the previous language of what came before it. It seems to slightly contradict the previous phrasing of things like “...maximize the development…” and “...fully avail itself of Alaska's vast lands and resources”. I believe this proposed action requires adjustment because the current rule that is in place has been shown to improve the wilderness character, opportunities for solitude, a noticeable lessen in pollution, and protects our forests. For example, in my community, I have seen how the presence of trucks close to the wilderness area can affect the environment near said road. To improve this rule and better serve the public, I recommend that the agency: Find a alternative to rescinding the rule completely If the rule does get rescinded, to find restrictions and a type of strict management with the absence of this rule Thank you for the opportunity to share my perspective on this important matter and for your time in reviewing substantive public feedback. Sincerely, Clara Hildman

The proposed rule change says: "In 2001, the Roadless Area Conservation Rule established a single, nationwide set of prohibitions intended to provide lasting protection for inventoried roadless areas within the National Forest System in the context of multiple-use management." It goes on to say: "this deregulatory action advances the policy objectives of Executive Order 14192, Unleashing Prosperity Through Deregulation [...]. In Executive Order 14225, Immediate Expansion of American Timber Production, the President declared that “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” In Executive Order 14154, Unleashing American Energy, the President likewise declared that “it is in the national interest to unleash America's affordable and reliable energy and natural resources.” In Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, the President declared that “it is the policy of the United States to fully avail itself of Alaska's vast lands and resources” and “maximize the development and production of the natural resources located on both Federal and State In the summary of key considerations it says that near-term permanent road additions would be likely on 45.5% of affected lands and temporary roads are likely on 28.3% of affected lands, totaling 73.8% of the currently roadless areas. It says timber harvesting would likely increase on 16% of affected areas, estimating a maximum of approximately $11.4M in revenue for the US govt. It says that 24% of the affected areas are in the wildland-urban interface and would improve the ability to suppress forest fires in those areas. It estimates $6.1M losses in economic benefits for recreation (reducing the net maximum revenue for the US govt to $5.1M, which appears to also be independent of the costs of road construction, which seem likely to exceed $5.1M--therefore, this rule does not project net increase in revenue for the US govt as a result of this rule change). It claims that there would not "likely" be a net increase in mineral development, despite also stating above that this rule change would further the goals of Executive Order 14154, Unleashing American Energy. Those claims appear to be in conflict with each other. I support the original goals of the roadless rule, which is to preserve pristine wilderness areas from encroaching "incremental" deterioration. The stated description and justification for the rule attempt to have it both ways -- it says that the rule change would pave the way for paving, timber harvesting, mining, and resource extraction, but also that we don't need to worry because maybe local officials might not decide to do those things. It cites legitimate-sounding needs for wildfire mitigation and prevention, but officials could have submitted a narrower rule change limited to the wildland-urban interface areas; or suggested broadening the allowed exceptions to enable effective wildfire prevention and response without also opening the areas to more harvesting and encroachment. Instead they have proposed a rule change that their summary estimates will in the near-term be likely to result in impacts to 73.8% of affected lands currently protected as pristine roadless areas. Its summary also does not project a net profit for the US govt from these rule changes, once their maximum projected revenues are compared against their projected costs and reasonable plausible road construction costs. The Forest Service has a multi-use mandate, but this does not mean that every parcel of land is or should be expected to be multi-use, and it is necessary to protect these lands at the national level from incremental impact. These rare lands that remain pristine and wild should be protected and preserved as the unique and valuable receptacles of ecological habitat, natural wonder, and irreplaceable history. Once they are gone they cannot be brought back.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The largest intact temperate rainforest left on Earth is my backyard. I grew up as a lifelong Alaskan, and since my parents bought land near Petersburg, the Tongass National Forest has been the wild place I explored and returned to. I have stood next to massive Sitka spruce trees and walked vast stretches of muskeg. I camp there with my family on our property in summer, just a few hundred feet from the forest boundary. Alaska is not the last frontier if it is not wild, and this rescission takes that character away. The Tongass holds 9,339,575 acres across 110 inventoried roadless areas, over 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by US national forests. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives, the Tongass keeps zero acres of roadless protection. The fish I catch in summer from roadless watersheds are vital for the livelihoods of Alaskans, and the fishing, hunting, and tourism industries that my fellow Alaskans depend on are renewable only as long as the land stays wild. The agency's own numbers cannot justify this action. The record before the agency states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. I ask the agency to reconcile the proposal with its own Cost Benefit Analysis and explain how an action that cannot establish a net benefit in its own record justifies what follows. The Sitka black-tailed deer I see in this forest face documented harm from road construction. The agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations in Alaska by preserving old-growth winter shelter. The DEIS cites research finding that roads built for extraction may have altered mule deer migration routes and increased their movement speed, and that the danger is disrupted migration and lost unroaded security. Bears face a parallel threat. The DEIS quotes the federal grizzly recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. These are the agency's own cited findings, applied to animals I share this forest with. The agency must explain, with specificity, what equivalent protection replaces the rule for these populations in the Tongass after the exclusion takes effect. The DEIS also acknowledges that "habitat fragmentation reduces biodiversity by 13 to 75 percent," that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter. Wide-ranging mammals have, in the agency's own words, "suffered habitat loss and the extirpation or fragmentation of their populations." The wolves and bald eagles of the Tongass are not abstractions to me. They are part of what makes this place worth protecting. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and enter those projections into the record. The drinking water question is equally unresolved. The agency states that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Petersburg is among the nine municipal watersheds named in the DEIS. The agency also acknowledges that "skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity," yet no projection of sediment delivery to those intakes follows. The agency must quantify projected sediment delivery to those municipal intakes and identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for the watersheds that will lose roadless protection. This forest is not an abstraction or a statistic. It is where I am from. I oppose this rescission and expect these questions answered in the final record. Sincerely, Joseph Ransdell-Green Fairbanks, AK

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Born and raised in Alaska, the Tongass National Forest is near and dear to my heart, and I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The Tongass is the largest intact temperate rainforest left on Earth. It holds 110 inventoried roadless areas totaling 9,339,575 acres, over 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by US national forests. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives, the Tongass keeps zero acres of roadless protection. That is not a reform. That is a permanent transformation of a place that cannot be rebuilt once it is gone. I work for our National Scenic Trails, which includes the Continental Divide Trail. Thru-hikers, hunters, and day users depend on the landscapes and watersheds that the Roadless Rule currently protects. The potential impact of logging would be detrimental to drinking water for many Americans in states where protections do not currently match the Roadless Rule. Having lived near fast-spreading wildfires, I know the impact is hard on communities where homes and livelihoods are lost. National forests that are easily accessible by the public should be managed for forest health in ways that reduce wildfire risk and support the communities around them. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Sincerely, Sarah Wilson Lakewood, CO 80215

As an individual, a Coloradan, and an American, I am concerned by the proposed repeal of the Roadless Area Conservation Rule, which would open the door to misuse of public lands. The truth cleverly told is the biggest lie of all. Secretary of Agriculture Brooke Rollins and Forest Service Chief Tom Schultz have presented this rescission as a boon to forest management and wildfire risk reduction. They claim that 40% of roadless territory is at high wildfire risk, and that fire reduction treatment is long overdue. They assert that redirecting oversight from federal purview to local hands will improve outcomes. And doesn't it make sense? A one-size-fits-all federal rule couldn't possibly allow the flexible management necessary for individual forests and communities, right? But the messenger is the message. Rollins has little expertise in forest management but plenty in economics and agricultural development, and Schultz has a long history in logging for profit. The USDA's press release on August 18th fixated more on the Roadless Rule's hindrance of partisan administration objectives than strategically reducing wildfire risks and promoting wilderness health. The USDA stated, "The rescission aligns with Executive Order 14192, Unleashing Prosperity Through Deregulation, to alleviate unnecessary regulatory burdens, Executive Order 14225, Immediate Expansion of American Timber Production, Executive Order 14154, Unleashing American Energy, and Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential." Removing the Roadless Rule is a paramount step in allowing private industry to access wilderness spaces, which is expressly against the wishes of the American public. Extractive industry-interested parties insist on pursuing the Rule's destruction, and the forest service appears to be acquiescing to their desires. Their continual refusal to hold open public hearings is a slap in the face of voters. The forest service manages eight times more miles of road than the entire US highway system. We can't manage the roads we do have, made clear by a maintenance backlog worth $6 billion. An astonishing number of fires in forests are due to human driven consequences - 80% of which are within a half mile of a road. The problem doesn't seem to be lack of roads so much as lack of resources to deal with fires when they arise, and if our money is going towards more roads it certainly isn't going towards fighting fires by the roads we already have. And while less than 5 percent of our land is roadless or wilderness, the outdoor recreation economy represents almost 2.4 percent of the entire U.S. GDP, and hunting generates a total economic output of over $107 billion. These activities rely on remoteness and land teeming with natural flora and fauna. They cultivate an appreciation for our American heritage as well promote our economy. Rashly endangering a healthy portion of our economy and environment for extractive corporate interests hardly seems wise. At some point in time, we will need to reevaluate the Roadless Rule. There should be exemptions and processes to allow the safe management of our lands when there are no other options or when local interests truly misalign with federal oversight. But the complete abolishment of a key stopgap for unbridled private industry is telling. There has been no discussion of how we will preserve wilderness spaces should roads need to be built. There is this assumption, it seems, that the details will pleasantly work themselves out, or that the profits from logging and oil will satisfy everyone to such an extent that we will not mind that our greatest national treasures have been overrun by corporate interests. The damage to delicate ecosystems could be generationally devastating. In conclusion, repealing the Roadless Rule in this hasty and simply profit-minded way is against the American spirit of things. A nostalgic fervor is gripping the regulatory agencies in question, and it biases them towards methods of the past. While true that we have used our natural resources mightily, and to such great effect that we reap the benefits of our forefather's actions today, it is not because their actions were eternally and universally applicable and effective. It is because they were gripped by the needs of their day. They were not looking back to how their grandparents did business. They looked forward to how they would be doing business. The actions which made us will not continue making us. It is a new day, and we need to sustain a new generation whose needs and desires seem to be ever more intertwined with the preservation of public lands, and protections of our environment, and industry that incorporates both of those goals. Until there is a concrete and publicly favorable plan to deal with wilderness areas that need roads, and protect those lands even after those roads are built, the overarching Roadless Area Conservation Rule needs to remain intact and in force.

U.S. Department of Agriculture, I am writing to oppose the proposal to rescind the 2001 Roadless Area Conservation Rule (docket number FS-2025-0001). Maintaining the roadless rule as a federal rule is essential for ensuring all states benefit from a shared baseline to protect to their natural resources. I am concerned that the expansion of timber production as proposed in Executive Order 14225 and extracting natural resources in Alaska as proposed in Executive Order 14153 will not be adequately balanced with ecosystem restoration and maintenance. Opening more of our forests for timber production or to extract gas, oil, and other minerals, destroys the balance of a fragile ecosystem. These environments are inherently valuable, but they also help support us by providing wildlife habitat, clear air and water, sequestering carbon, and unparalleled recreation areas. I am concerned rescinding the Roadless Rule will encourage more frequent depletion of natural resources and increased negative impacts on our environment. While the proposal cites changing insect and disease pressures as potential reasons for rescinding the rule, I believe more targeted screening approaches to avoid initial introductions would be more effective. Devastating invasive pests and pathogens, such as the emerald ash borer and Phytophthora ramorum, the causal agent of Sudden Oak Death, are primarily introduced through the foreign importation of plants primarily via the nursery and timber trades (Sun et al. 2024, Grünwald et al. 2012). The USDA should evaluate whether it would be more cost-effective to manage these pests and pathogens by screening for them at ports of entry and supporting local USDA and Forest Service professionals in routine surveying efforts. In the case of Sudden Oak Death, research has shown disease management solutions are most effective and cheaper when deployed earlier in an outbreak (Cunniffe et al. 2016). I have greatly benefited from the roadless rule through my hiking, kayaking, and camping experiences across the US but particularly in North Carolina’s Pisgah and Nantahala National Forests. As a biologist who has studied the movement of pathogens in forested areas, I think conservation efforts focused on early mitigation efforts are more effective at preventing outbreaks. Rescinding the federal rule puts the health of natural ecosystems in jeopardy for an unconvincing purpose. Thank you for considering these comments. References Cunniffe, N. J., Cobb, R. C., Meentemeyer, R. K., Rizzo, D. M., & Gilligan, C. A. (2016). Modeling when, where, and how to manage a forest epidemic, motivated by sudden oak death in California. Proceedings of the National Academy of Sciences, 113(20), 5640-5645. Grünwald, N. J., Garbelotto, M., Goss, E. M., Heungens, K., & Prospero, S. (2012). Emergence of the sudden oak death pathogen Phytophthora ramorum. Trends in microbiology, 20(3), 131-138. Sun, J., Koski, T. M., Wickham, J. D., Baranchikov, Y. N., & Bushley, K. E. (2024). Emerald ash borer management and research: decades of damage and still expanding. Annual Review of Entomology, 69(1), 239-258.

Hello, I am commenting to say that I, like many other americans, wish to keep the Roadless Rule in place and unchanged. The Roadless Rule is detrimental to preserving soil, water, and air. It helps keep our drinking water clean with less run off from vehicles. It preserves the diversity of plants and animals by not cutting through ecosystems. Many habitats, endandered wildlife, and sensitive species require undisturbed land to thrive. The Roadless Rule has been a boon to human activity as well, creating beautiful undisturbed backcountry for recreation use and enjoyment. The proposal reasoning for recission are shoddy at best. The executive orders signed by Trump are unlawful. I greatly oppose executive order 14192. We need regulations to keep corporations in check from greedily taking more than they should and also for more responsible land management. We need regulations to keep our air, soil, and water clean. I oppose executive order 14225 for logging expansion. Our forests have dwindled enough. We should be looking into more sustainable options than lumber for our paper and wood use. Bamboo, hemp, and other plant materials grow faster with less water and land used. We need to pivot from our addiction to timber production. I oppose executive order 14154 for rescinding restrictions on coal and gas. Again, not sustainable for the long term. We should be shifting to nuclear, wind, geothermal, and of course solar. These alternatives don't create the same level of pollution and long term destruction of land for short term gain. I oppose executive order 14153 for opening up Alaska for drilling and timber sales. These wildlife areas are extremely detrimental to millions of birds, both migratory and fixed populations. It would affect game animals, predators and prey animals both, all the way up the food chain. We want to keep this land natural and preserve it for generations to come. Oil is a dying energy, switch to sustainable alternatives already! I greatly oppose the National Active Forest Management Strategy and the One Big Beautiful Bill Act 50301 for the increase of timber production by 25%, we can NOT sustain that. The amount of roads put in to harvest would also cost more than the timber production. We need to harvest less wood, and switch to alternatives mentioned above. We do NOT need more roads. Roads start more fires than they put out, by around seven times more. Putting in the roads would only increase access by around 3% total. The agency Roads cost money and the DEIS states it costs $80k to $100k per mile at the minimum, plus $5k to $50k per mile for yearly maintainace. The projected logging revenue gain from opening the logging areas is only $4 to $12 million a year nation wide. The DEIS does not show these numbers side by side, but when you do the math, the cost for the amount of roads needed would far outspend the amount being made. We already can't afford the roads we have, with a $7 to $8.4 billion dollar backlog for the Forest Service's own figures for road maintainance. There is no plan for maintaining these, as well as all the new roads being proposed. There has also been the finding by the agency's own analysis, showing “detrimental effects on ecosystem health including watershed health, forest health, and biodiversity.” In the biological assessment of the rescission shows it “may affect, and is likely to adversely affect” 327 endangered listed species, as well as critical designated habitats. That alone should be the reason to stop trying to rescind the roadless rule. I wish to close with the following comments. I see nothing but short term greed that will have dire longterm consequences. If you care for the future of this planet, if at least for your children's sake, you will not support the rescission of the roadless rule as well. We share this planet, not just with our fellow man, but with all the nature of this world that keeps us alive. We will thrive as a species working together with nature rather than trying to control and extort nature. Have a care for this world instead of money. Do not disappoint the people, we all will be watching.

Rescission of the 2001 Roadless Rule aligns with President Trump’s Executive Order 14192, Unleashing Prosperity Through Deregulation to get rid of overcomplicated, burdensome barriers that hamper American business and innovation. It also supports Executive Order 14153, Unleashing Alaska’s Extraordinary Resource Potential which directs the Forest Service to exempt the Tongass National Forest from the 2001 Roadless Rule. The 2001 Roadless Rule prohibitions are unnecessary in places like the Tongass which can be adequately protected through the normal national forest land management process as intended by Congress in 1976 when it enacted the National Forest Management Act. Congress enacted over 6.6 million acres of Wilderness and other restrictive land use categories prior to the promulgation of the Roadless Rule on the Tongass. The remaining areas, which the Roadless Rule restricts access to, were passed over so they could support local employment, including year-around timber manufacturing jobs in a region where there are minimal state or private timberlands available to the mills. Application of the 2001 Roadless Rule has severely impacted the social and economic fabric of Southeast Alaska communities and violates the Alaska National Interest Lands Conservation Act and the Tongass Timber Reform Act. It has devastated the timber industry where sustainable harvests have plummeted and employment is now a fraction of what it was prior to enactment of the rule. Under the 2001 Roadless Rule, road access to mineral claims has been made reliant on the subjective response to a project by Forest Service officials. The Tongass is a highly mineralized, 16.9-million-acre Volcanic Mass Sulfide (VMS) mining district that contains critical and rare earth minerals which are needed for national security. There are over 200 potential hydropower sites in Southeast Alaska. The Roadless Rule is a barrier to road access to mining claims, exploration, and development and hydropower development because the “reasonable access” the Rule provides does not necessarily mean road access. The Forest Supervisor can specify expensive helicopter access (even though there were no helicopters when the Mining Act of 1872 was enacted). Leaving what is reasonable access up to the responsible Forest Service official to determine what is “reasonable access’ or when a road is “needed” is subjective and does not adequately protect access rights. Rescission of the Roadless Rule would only make an additional 186,000 acres of the 16.9-million-acre Tongass National Forest available for timber harvest, roughly 1%. Thank You, Ben Schulman 907-632-5393

To the U.S. Forest Service: I write in strong support of rescinding the 2001 Roadless Area Conservation Rule, particularly as it applies to the Tongass National Forest. [Personal line, e.g.: "As a lifelong Alaskan who has worked for decades on resource development in this state, I have seen firsthand what this rule has cost Southeast Alaska communities."] Rescission is consistent with Executive Order 14192, Unleashing Prosperity Through Deregulation, which directs agencies to remove overly complicated and burdensome barriers to American business and innovation. It also implements Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, which specifically directs the Forest Service to exempt the Tongass from the Roadless Rule. The Roadless Rule's blanket prohibitions were never necessary on the Tongass. When Congress enacted the National Forest Management Act in 1976, it established a forest planning process designed to weigh conservation and use on a forest-by-forest basis. That process is fully capable of protecting the Tongass's important ecological values without a one-size-fits-all national rule. Congress has also already struck the balance on the Tongass. Before the Roadless Rule was adopted, Congress designated more than 6.6 million acres of the forest as Wilderness and other restrictive land use categories through the Alaska National Interest Lands Conservation Act (ANILCA) and the Tongass Timber Reform Act (TTRA). The lands Congress left out of those designations were left out deliberately, so they could support local employment, including year-round timber manufacturing jobs in a region where almost no state or private timberland is available to supply the mills. The Roadless Rule effectively overrode that congressional judgment, and in doing so it conflicts with both ANILCA and TTRA. The consequences have been severe. Sustainable timber harvests on the Tongass have plummeted, and timber employment in Southeast Alaska is now a fraction of what it was before the rule took effect. The loss of these jobs has damaged the social and economic fabric of communities that have few alternatives for year-round work. The rule also stands in the way of mineral and energy development that matters to the entire nation. The Tongass is highly mineralized, including volcanogenic massive sulfide deposits that contain critical and rare earth minerals needed for national security. Southeast Alaska also has more than 200 potential hydropower sites that could provide clean, affordable, renewable power to the region. Under the Roadless Rule, access to these resources depends on the subjective judgment of individual Forest Service officials. The "reasonable access" the rule guarantees to mining claims does not necessarily mean road access. A Forest Supervisor can instead require costly helicopter access, an outcome that the authors of the Mining Act of 1872 could never have contemplated. Leaving it to an individual official to decide what access is "reasonable," or when a road is "needed," creates uncertainty that discourages investment and fails to protect access rights established in law. Finally, the practical footprint of rescission is modest. Rescinding the rule would make only about 186,000 additional acres of the 16.9-million-acre Tongass available for timber harvest, roughly 1 percent of the forest. That is a small and reasonable change that would restore the balance Congress intended and give Southeast Alaska communities a real chance at economic stability. I urge the Forest Service to finalize rescission of the 2001 Roadless Rule. Sincerely, Sarah Ward Anchorage, AK

Roadless Rule Dear Secretary Rollins, I am writing in opposition to rescinding the 2001 Roadless Rule. I support Alternative 1, no action. Undeveloped roadless areas and Wilderness are part of what defines Montana and other western states. They are what makes our state the envy of people from all over our nation and the world. Without them Montana would be just another place. Unroaded areas contain areas of unique special qualities but are not protected by wilderness designation. Many areas are wilderness study areas (WSA) but have been repeatedly blocked from gaining wilderness status by conservative legislatures. Unroaded areas often provide a buffer zone around our wilderness areas and National Parks and Monuments. Imagine if clearcuts or open mines were allowed around the perimeter of Glacier National Park. It has been stated that the purpose of rescinding the 2001 Roadless Rule is to give control back to the local forests and reduce the burden of Washington’s over regulation. But in the body of the Roadless DEIS the following executive orders are found (pages 19-20 I believe): 1.Executive Order 14192: Unleashing Prosperity Through Deregulation 2.Executive Order 14225: Immediate Expansion of American Timber Production 3.Executive Order 14154: Unleashing American Energy 4.Executive Order 14153: Unleashing Alaska’s Extraordinary Resource Potential To me this sounds like an expansion of top-down management rather than bottom-up especially considering other actions we have seen from the current administration. Lastly, some bullet points to ponder: •The Bitterroot National Forest where I live has 2,246 miles of FS roads. For comparison the county, Ravalli, which is surrounded by the forest only has 1,450 miles of road. •Last spring after winter storms closed FS roads with fallen trees, local citizens opened some roads because the Forest Service lacks the resources to do so. •Forest roads are costly to maintain. That is why many are gated and others are in poor condition. Adding more roads will add to the maintenance cost in addition to the initial cost of construction. •Roads contribute to man-made forest fires, the spread of invasive plants, and can have negative effects on sensitive wildlife. Whenever I walk the forest roads in my area I see many invasive plants competing against native species and spreading outward into the forest. •Logging and mining can and does have negative effects on stream and river quality. •Roads are detrimental to recovering animal species such as Grizzly Bears, Lynx, and Wolverines. Roadless areas provide corridors for these animals to move about and expand their range.

The attached, following section the proposed rule is what I am for. I firmly believe local authorities and the public who live in sensitive areas, should have the deciding power. Corporations take over way too much of our natural lands. When they do, even if started in a small way, or for money making purposes, our country loses precious natural environments and ancestral history that is very important to the character of this nation. Most importantly, if we encroach upon every last piece of open land to build imposing, modern roads for the purpose of corporate enrichment , we are helping to destroy the last vestiges of our natural environment. Look into the future and envision what America will become. It’s not ultimately to our advantage. “Rescinding the 2001 Roadless Rule is intended to return decision-making for road construction, road reconstruction, and timber harvest in inventoried roadless areas to local officials, in conjunction with Forest-level land management planning. As directed by Executive Order 14153: Unleashing Alaska’s “Extraordinary Resource Potential, the proposed rule will expressly exclude the Tongass National Forest from the 2001 Roadless Rule.”

I am writing in support of maintaining the 2001 Roadless Rule, and strongly oppose Executive order 14153. Written with strong public support, and bipartisan congressional support, the Roadless Rule is a beneficial legislation which protects 58 million acres of National Forestland. It serves to protect public lands from new road building, industrial logging, & commercial development, in order to manage human impact pristine and undeveloped public lands, to safeguard critical wildlife habitat, preserve watershed supply for clean municipal water, and to maintain habitat connectivity for preservation of migrational areas & corridors of up to 220 threatened and endangered species. The Roadless Rule prevents degradation of not only forests, but downstream lands and waterways from industrial sediment, construction chemicals, and soil erosion. It also reduces risk of human-caused wildfires, which have been commonly associated with roadside starts. Additionally, the Roadless Rule maintains outdoor economics, back country heritage, and vast possibilities for learning and research. We cannot fall short of our responsibilities to preserve public land for generations to come. We must remember that public lands have always been intended for the use of citizens, not commercial uses. We must not be so short sites as to view our pristine lands as “resource potential”, as the President’s executive order implies. Undeveloped lands are more than potential resources. They are already serving so many important purposes for the health of Earth and Humans. Only in vast, clean, undeveloped areas can water be filtered by the land, can carbon be pulled from the air, and can soil regenerate healthy minerals. In summary, I am urging to maintain the Roadless Rule to preserve the integrity of public lands, and request strong opposition to Executive order 14153. Thank you for your time and consideration. Lynette Griffin Lifelong US Resident and outdoor enthusiast

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Eight years on the Deschutes National Forest left marks on me that do not fade. I hiked it, camped in it, fought fire across it, canoed it, skied it, and spent years helping manage it. I know what the Roadless Rule means to that land, and I know what losing it would mean. That is why I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The agency's own fire science should stop this proposal before it goes any further. The draft environmental impact statement contains the agency's finding that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The Deschutes holds 11 inventoried roadless areas totaling 136,446 acres, home to bull trout, Oregon spotted frog, northern spotted owl, white-headed woodpecker, redband trout, and elk. Opening that landscape to new roads in the name of fuels management contradicts the agency's own ignition data. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with the fire density data reported in DEIS Table 21. The economic case for rescission is equally hollow. The agency's own record shows that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile that fact with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how any action whose own numbers cannot demonstrate a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. My sister lives near Olympic National Forest and depends on the water, recreation, and resources that forest provides. She and the communities around her are precisely the people that figure disappears for in the ledger this proposal pretends is favorable. The Tongass National Forest alone exposes how far the agency is willing to go. It is the largest intact temperate rainforest left on Earth, holding 110 inventoried roadless areas totaling 9,339,575 acres, with over 12,930 miles of salmon-producing streams and roughly 44 percent of all the carbon stored by United States national forests. Under both action alternatives the Tongass keeps zero acres of roadless protection, a result the agency acknowledges is driven directly by Executive Order 14153. Nine municipal watersheds are named in DEIS Table 2. I will not accept the framing that opening this ecosystem to oil companies represents sound stewardship, and the agency must explain how that outcome serves the public interest it is charged to protect. This is not the first time the agency has tried to dismantle the national rule by substituting state-by-state approaches. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That attempt failed, and courts found it wanting. Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres, including the High Uintas country I have hiked, camped, photographed, and explored. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The State of Utah should not be permitted to destroy this wilderness, and a patchwork of state-level substitutes offers no assurance it will not. The agency must address how this proposal avoids the deficiencies the Ninth Circuit identified when the national rule was last dismantled this way. Finally, the agency cannot credibly claim the 2001 rule exceeded its statutory authority. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court upheld the agency's authority under the Organic Act and the Multiple-Use Sustained-Yield Act and found no de facto wilderness designation. The agency must explain, squarely and specifically, the legal basis for any position to the contrary. Don't let this happen! Sincerely, A couple from: Oregon, Utah, Colorado

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The bald eagle is one reason I watch birds in the Tongass National Forest, and it is one reason I am filing this comment. The Tongass is the largest intact temperate rainforest left on Earth, holding 110 inventoried roadless areas totaling 9,339,575 acres, more than 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by United States national forests. Executive Order 14153 directs the agency to exclude the Tongass expressly from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives, the Tongass keeps zero acres of roadless protection. I am asking this agency to reconsider, and to answer the specific questions below on the record. Our public lands should be preserved for future generations and managed so we can take pride in the country we live in. Is nothing sacred anymore? Is all of this for short-term gain and pillaging? The small pockets of intact land that remain should stay beautiful and free of industrial development, and the decision now before this agency will determine whether that is possible. I urge the agency to weigh that obligation in its response to each issue I raise here. On the matter of birds: the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The Tongass supports verified populations of bald eagles and marbled murrelets, among others. Opening 9,339,575 acres of currently protected rainforest habitat to road construction is not a minor adjustment; it is a landscape-scale change whose documented consequences for avian communities appear in the agency's own environmental record. I ask the agency to explain what weight it gave those findings when it decided the benefits of rescission outweigh the harm to bird populations in the Tongass and elsewhere. On fire: the agency's own record states, "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless advances wildfire and fuels management as partial justification for rescission. I ask that the agency explain how the proposal departs from those prior findings and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. On economics: the agency's own analysis shows that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Clean water is crucial for our survival, and we need water, not more roads. The agency's cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning negative $92 million to positive $199 million. The agency must reconcile the proposal with a cost-benefit analysis that cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest. On the legal history of state-by-state approaches: the agency's record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That approach was already tested and litigated. The agency should address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values. On statutory authority: the proposal argues the 2001 rule exceeded what Congress granted. The Tenth Circuit held otherwise, stating: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency should address the Tenth Circuit's conclusion that the 2001 rule fell within authority granted by the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and state plainly what legal basis supports a contrary reading now. Future generations will inherit what we decide today. They deserve an answer to each of these questions before this rule is rescinded. Sincerely, Brooke Thompson Juneau, Alaska

Each named Executive Order identified in the Purpose and Need for Action given for rescinding the Roadless Rule specifies the extraction of natural resources. In Executive Order 14225, Immediate Expansion of American Timber Production, President Donald Trump declared that “the United States has an abundance of timber resources that are more than adequate to meet our domestic timber production needs, but heavy-handed Federal policies have prevented full utilization of these resources.” In Executive Order 14154, Unleashing American Energy, the President likewise declared that “it is in the national interest to unleash America's affordable and reliable energy and natural resources.” In Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, the President declared that “it is the policy of the United States to fully avail itself of Alaska's vast lands and resources” and “maximize the development and production of the natural resources located on both Federal and State lands within Alaska.” Given the current Administration’s priorities, it appears that the primary motivation to rescind the Roadless Rule is to better access natural resources for their extraction. In its rationale, the current proposal identifies the hurdle to accomplishing this as “the limited number of roads within inventoried roadless areas and the inability to reconstruct or build new roads to provide the needed access”. A secondary reason to rescind the rule is to enable more effective forest management to reduce wildfire risk for “community protection in the wildland-urban interface” (WUI). However, there is significant disagreement about how much of the inventoried roadless area is within or one mile from WUI. In the August 2025 proposal to rescind the rule, the National Forest Service stated that this area constitutes approximately 35% (15 million acres) of roadless acreage which falls under the Roadless Rule. This was refuted by The Wilderness Society’s 2025 testimony, stating that its GIS analysis found that less than 5% (2.8 million acres) of roadless area fell in or within one mile of WUI. Even if the roadless area acreage affecting WUI is as high as 35%, that does not justify rescinding the Roadless Rule for the remaining majority of inventoried roadless areas. In 2007, my husband and I hiked from Mexico to Canada along the Pacific Crest Trail. We lived in and walked across our national forests for five months. Since the birth of our son in 2010, we have gone on multiple backpacking trips of 100+ miles traversing National Forest Wilderness Areas in California, Oregon and Washington. As a family, we have witnessed the pristine natural beauty of places that can only be reached on foot or by horseback. We have also seen how easily forest roads can be used for unsanctioned vehicle access to restricted areas where people car camp and significantly increase the risk of fire to us all. In President Theodore Roosevelt’s New Nationalism speech of 1910 he said: “I recognize the right and duty of this generation to develop and use the natural resources of our land; but I do not recognize the right to waste them, or to rob, by wasteful use, the generations that come after us. […] Of all the questions which can come before this nation, short of the actual preservation of its existence in a great war, there is none which compares in importance with the great central task of leaving this land even a better land for our descendants than it is for us”. By rescinding the Roadless Rule we would compromise our country’s limited, remaining wilderness for the purpose of short-term economic gain. Moreover, by building roads across these areas, we would increase access to and thereby increase the risk of forest fire rather than mitigating and protecting against it. For more than a century, Americans have intentionally sought to conserve this natural legacy. Rescinding the Roadless Rule signals the clear intention to access and incrementally dismantle the remainder of our country’s wilderness areas. We cannot afford to compromise this American treasure. It is our duty to preserve it today and for generations to come.

The U.S. Department of Agriculture is initiating rulemaking concerning management of inventoried roadless areas on approximately 44.7 million acres of National Forest System lands, including in Alaska. The proposed rule would rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule) (66 FR 3244), which prohibits road construction, road reconstruction, and timber harvesting in inventoried roadless areas, with limited exceptions. State-specific roadless rules for Idaho and Colorado at 36 CFR 294 subparts C and D will be retained. Rescinding the 2001 Roadless Rule is intended to return decision-making for road construction, road reconstruction, and timber harvest in inventoried roadless areas to local officials, in conjunction with Forest-level land management planning. As directed by Executive Order 14153: Unleashing Alaska’s Extraordinary Resource Potential, the proposed rule will expressly exclude the Tongass National Forest from the 2001 Roadless Rule. I live in a forested area which has many logging roads. I understand logging is important. It might help in forest health and in the natural resources our forests supply. I am writing today to express my concern about opening more forest areas by creating roads into areas that are wilderness areas and areas previously untouched and should be protected. I am firmly against more roads into areas our forests! What can , will we leave for future generations? Why can’t our wild animals have areas in which are left untouched by creating more roads? The present govt administration is hell bent on cutting down our forests, eliminating animals that thrive in their natural environments, spray documented cancer causing poisons on our forests and generally destroy our wilderness! Hands off our forests!