Read the comments.

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.

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.

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.

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.

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.

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.

KEEP THE 2001 ROADLESS RULE! BACKGROUND In October 1999, then-President Clinton announced an effort to address the 58.5 million acres of Inventoried Roadless Areas (IRAs) in our national forests. The proposed Roadless Rule would limit road construction and timber harvest, address the deferred maintenance backlog, and provide lasting protection for these areas. Over the next year, the Forest Service held over 600 public hearings across the nation. Over 1.6 million comments were submitted, nearly 97% in favor of the rule. Now the USFS is proposing to rescind the rule with a totally inadequate 21-day “predecisional” comment period and 47-day comment period for the Draft Environmental Impact Statement (DEIS). Any attempt to revoke the rule should provide at least as much opportunity for public comment as when the original rule was proposed. FLAWED RATIONALE The DEIS claims Roadless Rule rescission is needed for “management flexibility” and to promote “decisionmaking by local Forest Service officials” (p10). It also claims rescission is needed to “allow for active management to respond to changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface.” Yet as explained in the DEIS, all these activities are already allowed under the current rule. The DEIS (p12) disparages the rule for being “one size fits all”. However, Executive Order 14225 (“Immediate Expansion of American Timber Production”) arbitrarily requires the national forests to increase their harvest levels by 25%, while EO14154 arbitrarily directs them to accommodate the wishes of the fossil fuel industry. It is highly disingenuous for the current administration to claim the Roadless Rule precludes local decision making while issuing blanket executive orders that allow for no local input. Indeed the DEIS (p10-11) all but states that the proposed rescission is aimed at ramping up road building and timber harvest in IRAs. Under Alternative 3 two types of land would be removed from IRAs - non-national forest system lands included under the rule due to mapping errors, and Congressionally designated areas, which have more restrictive and permanent mandates than the Roadless Rule. As pointed out in Table 2 though, boundary modification can be accomplished through rulemaking, without revoking the Roadless Rule. ROADS According to the DEIS: “…less than 10 percent of paved roads and less than 30 percent of gravel roads are in good condition.” (p40) “…typical costs for annual road maintenance can range from $5,000 to $50,000 per mile. A review of route decommissioning costs..indicated [costs] from as low as $2,000 per mile for minor treatments...to an excess of $50,000 per mile for more complex treatments”(p41). “…the Forest Service received approximately $270 million in fiscal year 2023, or less than 20 percent of the estimated funding needed to maintain its existing road infrastructure.”(p42). “Annual appropriations for construction, improvement and maintenance of the road system have drastically declined” from $234 million in 2004 to $73 million 2024 (p43). “In 2001, the deferred maintenance backlog was estimated at $8.4 billion for all maintenance levels of roads.” (p43). This has increased to over $10.8 billion in 2025 (USDA-FS. FY2025, Q2 Deferred Maintenance Needs). “The Forest Service has a significant road maintenance backlog; however, it is assumed that some new road construction and additional maintenance would result from any action alternative.”(p45) These are all compelling reasons for MAINTAINING THE CURRENT ROADLESS RULE, not revoking it. As stated in the DEIS, decommissioning costs are comparable to a year of maintenance, so decommissioning is far more cost-effective than maintaining unneeded roads. FIRE The USFS erroneously claims that rescinding the Roadless Rule and allowing road building in IRAs will reduce wildfire risk. A recent study of the impacts of roads on wildfire ignition density across all 8 contiguous USFS regions (Aplet et al 2026. Fire Ecology 22, article 8) found that from 1992 to 2024, ignition density was lowest in designated wilderness areas (1.75 fires/1000 ha), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha).The highest ignition density was on lands within 50 m of roads (7.99 fires/1000 ha), and the second highest density was on other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). Lands between 0 and 250 m from roads averaged 6 ignitions/1000 ha, while lands over 2000 m from roads averaged fewer than 2 ignitions/1000 ha. CONCLUSION The 2001 Roadless Rule has worked well for 25 years. Alternative 1 (“No Action”) is clearly the most environmentally and fiscally responsible alternative. Please choose Alternative 1 and keep the Roadless Rule.

Dear Director, My name is Birgit Graf, and I am writing in response to the proposed rescission of the Roadless Area Conservation Rule (Docket No. FS-2025-0001). I have lived in Montana for decades, and feel very fortunate having had the opportunity to spend time in places like the Bob Marshall and Great Bear Wilderness, the Swan Range and the Badger-Two Medicine Area. I have enjoyed the beauty and serenity of these undisturbed, quiet places, which make Montana unique, as large intact connected landscapes are increasingly hard to find. I am very concerned about the future impacts of the proposed rescission of the Roadless Rule. Whereas Glacier Park, the Great Bear Wilderness, the Bob Marshalls enjoy protections from industrial development due to congressional designations, the integrity of places like the Badger-Two Medicine, the Swan Range or the Crazy Mountains is only protected by the Roadless Rule. Without that protection the likelihood of industrial development with accompanying negative impacts is very high. Therefore I strongly support the "No Action" alternative (Alternative !). !.The negative ecological impacts resulting from road building include wildlife habitat loss and fragmentation, loss of important migratory corridors, decrease in species diversity, soil erosion and stream pollution, harm to threatened and endangered species, increase in invasive insects and weeds, also a significant increase in noise and air pollution. 2. The economic consequences include loss of revenue due to declining tourism, as many out-of-staters visit the State esp. because of its magnificent scenery and wild beauty, as do many Montanans (like me), who enjoy hiking, boating, fishing and other recreational activities, which support local businesses like outfitters, guides, tour operators etc. 3. While the proposal for rescission does not mandate road-building and timber production and other industrial activities, according to the USDA, it is alligning with Executive Order 14225 "Immediate Expansion of American Timber Production" and EO 14154 "Unleashing American Energy" of 2025. Considering the 2025 congressional OBB Act, which mandates yearly increases of timber production on USFS administrated land as well as on Bureau of Land Management land, the quota can only be met by industrial-scale operations, and road building in the currently inventoried roadless areas seems inevitable. Besides moving the USFS Wildland Fire Operations over to the Department of the Interior, creating a new US Wildland Fire Service, and proposing more widespread budget cuts and the elimination of several offices (like the Collaborative Forest Landscape Restoration Program), the released USDA FS proposed budget for FY 2027 seeks to refocus the Forest Service on its core land and ressource management mission through timber production. This goal is reflected in the fact that the line item for forest products is more than quadrupled. The result is very limited room for multi-use. 4. A major reason for the rescission of RR is, according to the USDA, that the rule prevents efforts to improve forest health, by aiding over grown forests, and to effectively deal with increasingly severe and long lasting wildfire seasons. It has been well established that roads actually increase the likelihood of wildfires. According to the National Park Service almost 85% of wildfires are human- caused, and ignite in close proximity to roads. The challenges of community protection in the wildland-urban interface, fuel reduction, and strengthening the resilience of forest ecosystems can be and has been successfully met within the framework of the Roadless Rule. Furthermore, it is difficult for me to understand how the aim of improving the federal response to wildfires, as stated in 2025, can be achieved, considering the major budget cuts and reductions in wildfire-certified staff and other essential workers in the same year. 5. In 2024, a group of Montana researchers found that the common quick suppression of low and modest intensity wildfires actually leads to larger more intense fires. These scientific findings are in line with tradidional tribal fire management practices, based on the knowledge that frequent, low intensity fires on the landscape are not just important to reducing the risk of catastrophic wildfires, but are essential for forest health and resiliency. I am encouraged by the over 60 co-stewardships that were signed in 2024 between Tribal Nations and National Forests. Also in 2024 the Forest Service published a draft amandment to the Northwest Forest Plan, which manages 245 million acres across California, Oregon and Washington. Over half of the amendment involved tribal stewardship. I hope very much that the new Wildland Fire Service at the BLM builds on these partnerships. And as we have great responsibilities, I pray that decisions will be made with the well being of the future generations in mind. Thank you!

I live in Belfair, Wa and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, camping, fishing, trail volunteering, camping, wildlife watching, and living near a National Forest community. Natural unspoiled ecosystems like deep forests are key to the survival of all creatures and peoples, they are tied to the health of our air and water and can never be replaced. Mount Zion is one place that has shaped my views on this proposal. It is within the Mount Zion Inventoried Roadless Area in Olympic National Forest. All of these are sacred natural spaces they are bastions for the health of our species, a legacy we leave to our children and their children. I am concerned about the cost of expanding the National Forest road system. We cannot maintain the roads we have and it will ruin these sacred places. I am concerned about wildlife habitat and landscape connectivity. They provide large connected habitats that are increasingly difficult to find. I am concerned about clean water and healthy watersheds. Maintaining untouched wilderness is key for healthy unpolluted natural water sources. Roadless areas matter to me for recreation and the experiences they provide. These lands cannot be replaced, our unconscious souls are tied to these places. I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. Why is the existing rule not enough? I believe maintaining a national conservation baseline matters. The administrative priorities are backwards and greed will kill our species and every other species if this goes unchecked. The Roadless Rule is essential for wildlife corridors. It protects future generation's access to pristine nature. It protects 44.7 acres of forest roads. What you are proposing will create gateways for extractive industries. I strongly oppose removing the Roadless Rule and ask for the Forest Service to adopt a no action alternative" to keep the Rule intact. Wildfires are 4x more likely to start near roads. Roadless areas are carbon vaults. Many of these areas are the foundation of pristine watersheds that cities rely on. Road maintenance is significantly more costly than no roads! Before rescinding the national rule, I would like USDA to answer this question: How would USDA ensure that roadless values are protected through individual forest plans and project-level decisions if the national rule is removed? It’s written on your own USDA website… “The proposed rescission reflects the administration’s commitment to return authority to local line officers and ensure they have the tools needed to restore forest health and productivity. 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.” Telling us your plans to sell our public lands to private timber companies and mining companies. For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments. Sincerely, Laura. A mother, teacher, and musician

The USFS should stop the rule making process to rescind time 2001 Roadless Rule (66FR3244). Preserving forests means protecting them not only from fire, but from the political and corporate interests that continuously seek to monetize public lands. The USFS's own research (Long-term forest health implications of roadlessness, 2020, Sean P. Healey Environmental Research Letters. 15: 104023.) has shown that human-caused wildland fire occurs at higher rates near roads than in roadless areas. While more rapid response to fire, facilitated by roads, may decrease the size the fire, this is offset be the increased fire frequency. Studies have shown time and time again, if you want to protect homes in the wildland urban interface you need to fire proof the structure not cut down all the trees. In addition, the rescinding of the roadless rule implies that wildfire risk will be reduced by thinning. This may be true for the short term but, without follow-up maintenance or prescribed burns, thinned forests often experience dense spurts of sapling and brush regrowth, which can recreate high fuel loads in less than 10 years. Analysis from the same study cited above showed that roads are strongly associated with the spread of invasive plant species in national forests. Non-native plants are twice as common within 500 feet of a road as farther away. The study concludes that based on 20 years of monitoring data rescinding the roadless rule road prohibitions would not improve forest health or reduce wildfire risk. Invasive plant species degrade the land for wildlife and livestock. Adding roads and increasing road density will also fragment the habitat, which has been shown to have a negative effect on forest plants and animals, and increase human/wildlife conflict. Roadless areas are important to the survival and well being of threatened and endangered species. Most roadless areas are located remotely at the top of pristine watersheds. Road building, development and resource extraction will have a negative impact on the watershed's water quality and quantity, which impacts all downstream users. One of USFS goals in the rescinding the Roadless Rule is to increase local control. This goal conflicts with current policy and executive orders (Executive Order 14192, Unleashing Prosperity Through Deregulation, Executive Order 14225, Immediate Expansion of American Timber Production, and Executive Order 14154, Unleashing American Energy). The current policy combined with these executive orders will increase non-local development and resource extraction. Plus, the USFS's increased weakening of NEPA combined categorical exclusions will further erode the already limited local public input. In Montana, where I live, polls indicate that 80% of the state favors keeping roadless areas as they are. Part of the reason we favor it is for recreation, which is a big contributor to the state's economy. But it is more than that, it is also the solitude and stress relief people get from being out in nature. The USFS asks for viable alternatives to rescinding the Roadless Rule. I say, do nothing. Keep roadless areas as they are. If you are looking for economic justification, how about all the below cost timber sales on USFS lands we could avoid? That money saved for doing nothing should be enough justification. If not, you can include the clean up costs the government ends up stuck with to clean up after mining companies that go bust. Finally, the loss of recreation dollars that are spent visiting the untrampled roadless areas.

I strongly oppose the USDA’s proposal to rescind the permanent 2001 Roadless Area Conservation Rule because the stated Purpose and Need for Action is invalid given its basis in Executive Orders (EOs), as opposed to constitutionally legitimate law. The four EOs are: -EO 14153, Unleashing Alaska's Extraordinary Resource Potential -EO 14154, Unleashing American Energy -EO 14192, Unleashing Prosperity Through Deregulation -EO 14225, Immediate Expansion of American Timber Production Theses EOs are not an appropriate basis for rescinding a permanent Conservation Rule for two reasons: 1 - Whereas the President of the United States has the authority to issue EOs under Article II of the US Constitution, that authority comes with a specific duty: to make sure the laws be faithfully executed. In contrast, these four EOs add up to rescinding—not executing—a permanent rule and are therefore outside the scope of Article II of the Constitution. 2 - Donald Trump, who issued these orders, does not own these resources entrusted to the USDA and the USFS. Rather, the citizens of the United States own them. Therefore, the matter of changing a permanent Rule (or not changing it, given that it’s permanent) should be left to Congress to consider on behalf of their constituents, with thoughtful input from scientists and data-driven studies that formed the rationale for the 2001 Roadless Area Conservation Rule in the first place.

I oppose the rescission of the Roadless Rule because removing federal protections from these lands will open them to commercial exploitation by so-called local land managers. Rescission will threaten vital backcountry ecosystems, clean drinking water sources, and wildlife habitats (for salmon, elk, grizzly bears and others), as well as thousands of miles of public trails. The USDA says “The rescission removes national designation of roadless areas but does not mandate timber cutting or road construction. The action removes regulatory burden and sends decisions about roadless areas to the local national forest managers.” National forests require national oversight, not the short-sighted drive for profit at the expense of a livable ecosystem. “Active forest management to mitigate wildfire risk” the reasoning used by the USDA in favor of the rescission can be undertaken under current policy on more than a quarter of these lands—11.3 million acres— which are already near existing roads. The fact that 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, tells us something important: the current Administration is not interested in wildfire prevention or keeping wild lands protected for all species, including humans. Their intent and desire is for profit only. No rescission of the Roadless Rule!!

The proposed rule has some justifications that are good (wildfire management, etc.) though I question whether additional roads will actually help very much with that without data to back it up. The main problem I have with this proposed rule is that while it does bring up some good points it is very clear that the main goal is not those justifications, it is simply to increase resource extraction possibilities: > 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.” I also don't see how "you can't build roads here to harvest timber" is more onerous regulation than "well depending on where you are in the country you may or may not be able to build a road here to harvest timber". Also 58.5 million acres is tiny in the grand scheme of the United States. Why break down protections for a relatively small pieces of the US forest system in order to get a benefit that is, according to your own analysis, on the order of $100 million? We spend that much on a couple days of the Iran war. Sums larger than that get lost every year by the Department of Defense that can't even pass a simple audit. Hire more people for the IRS and audit rich tax dodgers and you'll make more than this per year. Not every bit of the forest should be easy to access. The ability of Americans to get far out into nature and reset themselves is more important than a timber company making 0.5% extra revenue on their balance sheet. Jason

I am writing to implore you to preserve and protect our most sacred resource, our wild and roadless lands, by upholding the Roadless Rule. Although the government has said that rescinding the rule would serve to prevent forest fires that is a clear and easily detected lie as 85% of forest fires are started by humans and most of them near roads! It is obvious that the intent of rescinding the Roadless Rule is to extract resources. Trump himself said so on National TV. Clearly, rescinding the Roadless Rule would only facilitate Trumps Executive orders: 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", at the expense of the forests, valleys, mountains, rivers and animals that Americans hold so dear. For the love of God do not allow this.

I am a lifelong resident of New York and a mother with an advanced degree in public policy, concentrating in environmental policy. I am writing with strong objection to the proposal to rescind the "roadless rule." As I raise my child, I look forward to introducing him to the beauty of our nation, including Alaska, Arizona, California, Montana, Nevada, New Mexico, Oregon, Utah, Washington, and Wyoming -- lands that will be impacted by this careless action, should it come to be. As a policy expert, I commend efforts to ensure that those with the most familiarity with the land, local land managers, have the ability and resources needed to care for the vibrant and invaluable ecosystems that we entrust them to conserve. I also commend efforts to directly deal with the climate change-related risks that we face, including wildfire. Repealing the "roadless rule" does neither. Local land managers are not afforded more resources if this rule is erased. Instead, pressures of development and resource extraction will compete with the interests of conservation. In fact, that seems to be the point of this proposal rather than the stated objectives of local autonomy and forest fire prevention. The purpose of the proposal is to open the way to extracting natural resources for profit as is made clear by the explicit call-outs in the USDA press release to alignment with 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. It is in the interest of our nation and our children to protect federal lands from extraction and development, and it must be a priority of the Forest Service.

In August 2025, I and thousands of other people submitted comments on the proposal from USDA to rescind the Roadless Rule. Analysis of this publicly available data showed that 99% of those comments were in opposition of removing the Roadless Rule. Despite this overwhelming opposition and mountains of evidence to support the clear benefits of the Roadless Rule, I am here again in 2026 writing to keep the 2001 Roadless Rule in place as it is. Below are my main concerns with the current proposal 91 FR 53827: 1) EO 14225 is listed as a reason to support rescinding the Roadless Rule and states that the US has enough timber for domestic demand, but fails to provide any evidence for this claim. The logging industry is complex, and the US does not have enough lumber mills in order to justify destroying our public lands in the name of profit. In order to ramp up US-based lumber mill output we would need to invest into significant upgrades to existing mills as they would not be capable of handling old-growth forest logs. Current economic policy and tariffs cause this option to be untenable due to increased costs. American forests are also primarily pine, which is a very soft wood not ideal for building and as such we are reliant on hardwoods grown in colder climates like Canada. In order to address our lumber needs, we should instead address the harms of current economic/tariff policy. 2) Rescinding the Roadless Rule would open up public land for harmful resource depletion. EO 14154 is fundamentally flawed as it fails to account for our most abundant renewable energy sources such as water, wind, and solar. Oil, coal, and natural gas are not reliable energy sources as they are not renewable; once it is gone, all we are left with is a devastated landscape filled with pollutants that harm the American public. Reliance on fossil fuels is short-sighted and leads to increased costs for American consumers; under current policy, we are now experiencing record high diesel prices which is projected to lead to devastating effects downstream in the supply chain for necessities like food, medicines, and other goods. There is an argument that utilizing American oil will reduce reliance on crude oil from other countries, but US oil is sweet crude oil which our refineries are not equipped to process efficiently, so even if we do ruin our public lands to extract oil from them, we will see little to no benefit. As seen with logging, the costs associated with upgrading refineries is likely too steep to justify doing this. As I have family in West Virginia, I have seen the devastating effects of fracking and coal production firsthand and support phasing these modalities of energy production out entirely in order to protect our communities from cancer and devastating toxic environmental pollution. The future-oriented, evidence based solution to our energy concerns is diversification into renewable energy which will benefit the American public through providing renewable options for domestic energy while also protecting their health and their public lands. It will also allow American businesses to innovate and create new renewable energy products, benefiting the economy as a whole. 3) This proposal is devastating to the environment and all who enjoy it. Deforestation will destroy our public lands and harm critical wildlife. The National Forest Service currently cares for over 300,000 miles of road, of which there is a large maintenance backlog. Why is it imperative to add more roads to protected public land when we cannot take care of the existing ones? Additionally, more public access via new roads will increase wildfire risk. Irreversible loss of nature and important tribal lands aside, the $1.3 trillion dollar outdoor recreation economy supports millions of jobs throughout the country; destroying public lands and jobs for hard-working Americans for a projected $4-10 million in revenue is inherently a lose-lose scenario.The simple solution to the problems the National Forest Service currently faces in regards to land stewardship is not to rescind the Roadless Rule, but to adequately staff and fund the National Forest Service so their needs can be properly addressed. In summary, I strongly oppose the current proposal to rescind the Roadless Rule as it is based on flawed assumptions and data, would cause irreparable damage to protected ecosystems and native wildlife, and would devastate rural economies that depend on outdoor recreation. Public lands are not for sale, and the 2001 Roadless Rule should remain as it is today. Alternative unbiased evidence based solutions as described above should be considered to benefit our nation and protect what makes our country great for generations to come. I will be supporting any legislation and litigation that will keep the 2001 Roadless Rule intact, and will advise my fellow outdoorsman to do the same.

As a child growing up in the south, I spent a lot of time exploring the wilderness of Appalachia, including Cherokee National Forest. My family has spent extensive time enjoying these wildlands every Summer for the last 25 years — my entire life. We’ve hosted extended family reunions in the mountains of Gatlinburg, TN many times. Being able to share the land I grew up in with my friends, cousins, and their children is an experience unlike any other. Seeing the joy and awe on their faces as they watch a bobcat meander along the tree line or a family of elk stop to drink from a creek in which we cool off is nothing short of magical. With the repeal of this Rule, the very land on which these memories were made is at great risk, including thousands of acres of Cherokee National Forest. Mary O’Malley, your public affairs specialist, in a statement to WBIR-TV Knoxville, TN, stated that the rescission aims to improve access to wildfires for professionals. According to Kristin Gendzier, a Senior Attorney with the Southern Environmental Law Center, however, wildfires are more likely near roads. In fact, the Draft Environmental Impact Statement (ELMS Project #302690) published in August of this year by the Forest Service states that ignition density is four times greater on Forest Service lands other than Inventoried Roadless Areas. It also states that exceptions already exist within the Rule for “public health and safety” and to “prevent resource damage or address safety hazards.” In addition, the Forest Service’s August 18th Press Release refers to four Executive Orders, three of which clearly call for profit at the expense of our wildlands as according to the Federal Register: Executive Order 14225 (Immediate Expansion of Timber Production), Executive Order 14154 (Unleashing American Energy), and Executive Order 14153 (Unleashing Alaska’s Extraordinary Resource Potential). During the Release, Montana Governor Greg Gianforte called upon the restoration of “common sense” to active forest management. Common sense, however, allows one to see that this rescission, as do the Executive Orders, have ulterior motive: to subject our forested land to destruction in the name of profit. Again, I urge the Forest Service to reconsider the rescission of the 2001 Roadless Rule. Preserve the tenets of the North American Model of Wildlife Conservation, especially the Rule of Law. Hear the people and speak for us.

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and to urge the Department of Agriculture to retain the rule by selecting the No Action alternative. My name is Katie Uberti and I live in the greater Seattle area in Washington state. Washington contains 830 trails encompassing 4,000 miles that are currently protected by the Roadless Rule. These include acres in the North Cascades, sections of the Pacific Crest Trail and Lake Quinault and the surrounding rain forest. These places have provided my family some of our best days together and I want to see these sacred areas preserved. The rescission is justified as a wildfire measure, but the record does not support that. The agency's own analysis shows only about 5 percent of high hazard roadless areas have received fuels treatment since 2014, which reflects a budget and staffing shortfall, not a barrier created by the rule. The proposed rule also concedes that greater access can increase human caused ignition potential, and most wildfires on Forest Service land are started by people. Removing road protections is more likely to raise fire risk than lower it. Roadless areas also include rivers and watersheds that supply clean drinking water to 354 municipal watersheds. A 2026 University of Washington study, in partnership with Conservation Science Partners, found that the roadless rule protects drinking water for about 25 million Americans. The city of Port Townsend, WA, for example, could be particularly impacted by any new construction or logging because they rely on water that comes exclusively from roadless areas. Repealing the Roadless Rule also doesn’t make sense financially. The Forest Service already carries a deferred maintenance backlog of roughly 6.9 billion dollars for its roads and bridges, and it is funded to maintain only about a fifth of the more than 370,000 miles of road it already manages. This rescission opens up to 18.2 million acres to new road construction the rule currently prohibits. Building more roads the agency cannot afford to maintain is fiscally reckless and shifts the long term cost onto taxpayers. Finally, this rescission would make it far easier to route powerlines, pipelines, and water conveyance through roadless corridors by removing the road construction barrier that has kept most such infrastructure out. The Department cites Executive Order 14154 on energy as a reason for the action. The public deserves a full analysis of the industrial infrastructure this could enable, not an assurance that the effects would be modest. For these reasons, I ask the Department to: retain the 2001 Roadless Area Conservation Rule by selecting the No Action alternative; fully analyze the fiscal, wildfire, water, wildlife, and infrastructure effects described above; and complete meaningful Tribal consultation before any decision is made. These areas deserve our protection and reverence, not a bulldozer. I hope to see this administration listen to its constituents and retain the Roadless Area Conservation Rule. Thank you.