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.

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.

When I was little my favorite children's book was called The Dead Tree by Alvin Tresselt. It is a story about a long lived oak tree that gives life and resources to all the other species as it lives and dies. While it is alive it is a shelter to the birds in its branches, the chipmunks in its trunk, the fox in its roots; it lives over a hundred years, longer than any human lifespan. When it eventually falls to wind and old age it is decomposed by small creatures like termites, who eat it and break it down and as they do the mother skunk can raise her babies in the hollowed out log. When the remains of the tree eventually become part of the soil they provide nutrients that the acorns it dropped on its way down use to grow strong, so that they can take the dead tree's place in the cycle of things. I am a student of environmental science and policy and it is stories like this that fueled my love and wonder for the natural world and my desire to understand and protect it. I will be commenting on the rescission of the roadless rule’s threats to biodiversity, like that seen in the story of The Dead Tree, as well as its needs in regards to wildfire management, timber production and rural job opportunities. The Roadless Rule protects old growth ecosystems throughout the United States and territories. Rescinding it will result in a loss of biodiversity in these places through increased logging, which is explicitly a goal of the rule's rescission in alignment with Executive Order 14225, Immediate Expansion of American Timber Production. Increased deforestation is known to reduce biodiversity of species through loss of habitat and old growth forests are home to some of the highest biodiversity of any terrestrial ecosystem (8,9). With timber production being a goal of the proposed rescission, old growth forests that are already fire resilient will be the target of this logging instead of areas that are prone to wildfire because the lumber in at-risk areas is usually small and not economically valuable for timber production (6). This means that the long-lasting trees in these robust and biodiverse forests will be the first to go, increasing habitat loss and therefore species loss. A main motivator behind executive order 14225 is that importing timber goods exports timber related jobs to other countries instead of adding jobs into our rural communities. However this rescission will put opportunities into new road creation when our Forest Service already has a backlog of $6 billion in road maintenance needs, while being understaffed and underfunded from recent cuts (6,7). Instead of opening up valuable and threatened environments to the possibility of habitat and biodiversity loss we should be focusing on maintaining the roads we already have which provide access to our already established timber operations. Additionally, the rescission claims to support increased flexibility for wildfire risk management options within roadless areas. However we do not need to open up these roadless areas to engage in proper wildfire management and in doing so we will not decrease fire risk. Roadless areas can already be managed to reduce fire risk without adding new roads and there are already exceptions written into the rule that allow fire risk management for “unnaturally intense wildfires”(5). Roads themselves additionally correlate with increased rates of fire ignitions due to increased human activity (3). Human activity increases the rates of fire ignition and although not all of these ignitions cause widespread wildfires, the increased frequency means that the benefits of greater access to prevent wildfire actually increase the potential fires. References: https://www.fs.usda.gov/managing-land/planning/roadless https://www.usda.gov/about-usda/news/press-releases/2026/08/18/usda-acts-remove-roadless-rule-restrictions-exacerbate-rising-wildfire-risk https://link.springer.com/article/10.1186/s42408-026-00450-2 https://research.fs.usda.gov/treesearch/61251 https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa https://www.eenews.net/articles/economic-realities-cut-into-trump-timber-plans/ https://www.pnt.org/roadless-rule-how-you-can-help/ https://www.sciencedirect.com/science/article/pii/S0006320723002276 https://www.sierraclub.org/massachusetts/importance-old-growth-forests https://www.govinfo.gov/content/pkg/DCPD-202500316/pdf/DCPD-202500316.pdf

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.

Pertaining to the text on page 53828 (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.’’), I disagree whole heartedly that rescinding the roadless area conservation rule would have enough economic, social, and cultural impact to justify fragmenting the land that was set aside "to provide long-term protection for 58.5 million acres of inventoried roadless areas across the National Forest System." We already have enough Forest Service land that has been fragmented and opened to logging and other intensive activities that keeping these already protected lands off limits provides much more benefit than the potential destruction of it. Opening the already protected lands would not only harm the environment, increase the infestation of invasive species, increase erosion, increase human/animal encounters, but the economic impacts would be dwarfed by the loss of what exists there today. DO NOT ENACT THIS RULE CHANGE. I, and all those I have talked to, DO NOT SUPPORT THIS AT ALL.

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.

Hi, my name is Thomas Fleming. I’m a frequent hiker who has enjoyed many national forests. I make regular trips to and through Allegheny National Forest, Green Mountain National Forest, and White Mountain National Forest. And this year I also made trips that led me on hikes in Mount Hood National Forest. All places that include inventoried roadless areas. I’m again stating that I am against the rescinding of the Roadless Rule. Despite the stated aim of this rescission being to restore local control, it is also in line with Executive Order 14192, regarding deregulation, and Executive Order 14225, regarding expanding timber production. These are goals that serve a broader vision of favoring extractive industries and disfavoring the recreational industries that me and many others who engage with these areas highly value. Protection of natural areas is never and has never been a default. That is why protections like this are important, and given the executive vision, I simply cannot trust at this time that this rescission will align with what I value about these spaces.

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.

As a Washington State resident who understands firsthand what the Roadless Rule protects where I live, I oppose this rescission. I have hiked and camped in roadless areas across the Olympic National Forest, including Quilcene, and have studied the history of previous deforestation in the area. Rescinding the Rule would impact trails and natural features like Mt Townsend, where road construction is currently illegal, and timber harvest on those roads. The Draft EIS states the purpose of the proposed rescission in terms of "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" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range ("a 4 to 10 percent increase in total sawtimber harvest" (p. 30)) and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics. This is not a limit of the analytical method, because the DEIS performs the quantified work for one forest. It states that "[t]he environmental impacts presented in the other sections of the DEIS are programmatic and nationwide in nature," while the 2020 Alaska Roadless Rule FEIS "provides more specific, localized effects analysis for the Tongass National Forest affected environment, which supplement the broader nation-wide analysis" (p. 238). Carrying that analysis forward, the DEIS reports "an estimated 49 miles more of potential new road constriction [sic] within the Tongass compared to leaving the Roadless Rule in place" and an average road density of 0.23 miles per square mile (p. 239). By the DEIS's own accounting the Tongass is "nearly 1/4 of the potentially affected inventoried roadless area acreage" (p. 238). One quarter of the analysis area therefore receives a projected road-mile figure and the remaining 30.8 million acres receive none. The omission cannot be deferred to project-level review, because the DEIS's own statement of need rests on quantified national targets. At p. 79 the DEIS relies on Executive Order 14225 and on the One Big Beautiful Bill Act section 50301, which "directs the Forest Service to sell at least 250 million board feet more each year for the next 10 years," and on the National Active Forest Management Strategy's goal of "an increase in timber production nationally by 25 percent." At p. 40 the DEIS says the amounts and locations are uncertain because "the rulemaking would not compel, require, or authorize any sitespecific activities." Both positions cannot hold. If the rescission is needed to meet a quantified national harvest target, then the harvest and the road construction required to reach that target are reasonably foreseeable effects of the rescission, and 42 U.S.C. 4332(2)(C) requires "a detailed statement... on... reasonably foreseeable environmental effects of the proposed agency action." If they are not reasonably foreseeable, the stated need for the rescission is unsupported, and every alternative eliminated for failing to meet that purpose was eliminated against a purpose the agency has not substantiated. The Forest Service should supplement analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and resulting sedimentation and fragmentation across the potentially affected environment under each action alternative, at the level of specificity the DEIS applied to the Tongass National Forest at pp. 238-239, and cite in the final EIS where that supplemented analysis is accounted for, as 7 CFR 1b.7(f)(3) provides.

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

On behalf of the Klamath-Siskiyou Wildlands Center, we submit the following comments and endorsements from supporters as attachments. KS Wild opposes the rollback of the 2001 Roadless Area Conservation Rule as outlined in the DEIS, and so do our network of supporters. The one-size-fits-all-approach to rolling back the Roadless Rule is does not offer the flexibility to local land managers that the US Forest Service lays out. In fact, by citing the need to rollback regulations based on the President's Executive Order 14225, the agency is making it clear this is a political decision and not one guided by science or ecological integrity.

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 am a college student in Washington state passionate about maintaining and conserving public lands for their intrinsic value. I strongly urge you not to repeal the Roadless Rule. As the original Roadless Rule identified, some characteristics of roadless areas include diversity of plant and animal communities, undisturbed soil, water, and air, and habitat for a range of sensitive species who depend on undisturbed land (USDA Forest Service, 2026). These variables are incredibly important to me, and more importantly, they are incredibly important to the species who reside in them. Roadless areas are home to over 77 bird species of conservation concern (National Audubon Society, 2026), something I care about very much. As a board member of my local Audubon Society chapter, I have worked hard to advocate for birds and their habitat. This Roadless Rule recission is set up to do the exact opposite. The Forest Service should be focusing on how roadless areas can be best managed for habitat improvement and wildfire mitigation, rather than highlighting its extrinsic value by road-building and timber harvesting. I do agree that management of these forests can be left up to local decision-makers, but I think the national protections should stay in place. “In Executive Order 14225 ... 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.’” The timber resources may be able to be put to use by humans, but they are not ours to take. These public lands are one thing that makes our nation so special. We must protect them.

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.