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I am writing as a lifelong Pennsylvanian, a resident of Cumberland County, a former state park ranger, and a land protection professional, submitting this comment in my personal capacity. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and ask the Department to retain it. My concern centers on the roughly 25,000 inventoried roadless acres in Pennsylvania's Allegheny National Forest, including Hearts Content National Scenic Area and the area surrounding Minister Creek. The Allegheny is Pennsylvania's only national forest, and though it sits across the state from me, its roadless acres are the commonwealth's share of this rule. These are old, wet hemlock and hardwood stands and headwater streams that support native brook trout and the Eastern hellbender, Pennsylvania's state amphibian. The other ninety-five percent of the Allegheny is already open to logging and drilling under a forest plan written by the local professionals who manage it. What this rescission reaches is the last five percent that plan was never allowed to touch: forest that spent a century recovering from being cut to the ground. At its plainest, the Roadless Rule is a rule against cutting roads back into forest that has spent a hundred years coming back. I ask the Department to address the following in the final rule and EIS: 1. Wildfire. The stated rationale is wildfire risk, but the fire profile of eastern roadless areas is not that of the West. Hearts Content and Minister Creek are wet ground where fire risk is low and the risk to streams from road construction is not. How does the DEIS analyze fire risk for eastern inventoried roadless areas specifically, and how does it reconcile a national rescission with federal fire records showing that only a small fraction of wildfires start in roadless areas, while most ignite along roads? 2. Local control. The 2001 rule already contains the mechanism the Department says it wants: any state may petition for its own roadless rule, Idaho and Colorado did, and this proposal retains both. If returning decisions to local officials is the goal, why is national rescission necessary rather than the existing state petition process? What have the officials responsible for the Allegheny actually requested? 3. Water. What analysis has the Department conducted of road construction impacts on headwater stream sedimentation and the aquatic species that depend on cold, clean water in eastern forests, particularly now that the rescission of the Endangered Species Act harm definition has removed the regulatory backstop for habitat? 4. The record. The 2001 rule followed six hundred public meetings and 1.6 million comments. This rescission has had roughly two months of comment across two windows and no public meetings, and the agency's own scoping summary shows that the overwhelming majority of more than 600,000 comments opposed rescission. How will the final rule respond to that record? At minimum, the Department should adopt an alternative that retains roadless protections in eastern national forests, where the wildfire rationale does not apply. Pennsylvania has one national forest. Its roadless acres are a promise a quarter century old, and I ask the Department to keep it. Jared Abell Carlisle, Pennsylvania

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My career in stream restoration has taught me something that seems lost on the agency proposing this rescission: damage to intact headwater systems is expensive and irreversible. I have had to seek federal funding to restore streams in urban and rural landscapes, including Cuyahoga Valley National Park. I know what erosion and sedimentation cost counties, states, tribes, landowners, federal agencies, and taxpayers long after the roads that caused them have served their purpose. Opening new roads into the roadless areas that protect the last unfragmented headwaters strikes me not as management but as the deliberate manufacture of future problems. These areas are a national treasure and hold the key to our shared future on Earth, in the context of our twin crises of climate change and biodiversity loss. I often travel to natural areas to watch birds, recreate, and find peace. I have hiked and worked across public lands in Utah, Idaho, Nevada, California, Oregon, and Washington since 2004. Annually, my family travels from Ohio to Allegheny National Forest and Pisgah National Forest to hike and bike. The 18 inventoried roadless areas of Pisgah, totaling 99,369 acres, include headwaters of the Atlantic and the Gulf, habitat for cerulean warblers, northern long-eared bats, hellbenders, brook trout, and more than 30 endemic salamander species found nowhere else on Earth. The agency's own record acknowledges that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency has this finding in its own DEIS and has chosen not to treat it as decisive. I ask the agency to explain how that finding is outweighed by the justifications offered for rescission. Public lands should be managed to promote biodiversity and climate resiliency, protecting habitat for rare and listed species, reducing habitat fragmentation, and sustaining ecosystem services including clean air and water. The Pisgah and Nantahala roadless areas, combined with Utah's 4,013,529 acres across 222 inventoried roadless areas and the lands I have walked in six western states, represent the core of what remains of unfragmented forested habitat at national scale. Rescinding the 2001 rule trades that permanence for benefits the agency's own cost-benefit analysis cannot confirm. I ask the agency to reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and to explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. My tax dollars should support conservation and habitat protection, not the degradation of the last contiguous habitats protecting many listed and rare species. The wildfire rationale offered for this rescission sits in direct tension with the agency's own findings. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Our western forests need adequate management to reduce the risk of widespread wildfire, and I support that goal, but deforestation is not the answer and neither is a road network that, by the agency's own data, elevates ignition risk. The agency must explain why the proposal departs from these findings and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I commented on this rescission in 2025 and received no response. I feel that legislators are not listening to or representing the interests of their constituents and are bowing to corporate interests aimed at gutting our shared natural resources. I want these places preserved and protected for other visitors and future generations. This docket deserves an answer to each of the points raised above. Sincerely, Ann Gilmore, Kent, Ohio 44240

To the U.S. Forest Service: These areas have been where I have found peace in a world that never feels still. The most beautiful peaceful grounding times in my life have taken place in these areas. I come from generations who have enjoyed, worked, vacationed, and more in these areas and believe wholeheartedly that rescinding the Rule will do irreparable damage. I'm not a climate scientist. I just read what the climate scientists publish. The 2001 Rule does measurable carbon work. Keep it. Regarding the Minister Valley in the Allegheny National Forest, Pennsylvania: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Rescinding the Roadless Rule would open the Minister Valley, Allegheny National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. “Focal species, which define the habitat identity, proved to be very helpful in discriminating between habitat types and zones, as they actually exhibited higher abundances or frequencies within a habitat type, relative to other habitats. The detailed analysis of focal species abundance and turnover can be used as a short-term alert of plant community disruption, before the effects of disturbance become fully evident. Plant communities or vegetation types represent a key approach for biodiversity conservation above the species level and have been increasingly used as crucial units for inventory, planning and monitoring as they are good indicators of overall biodiversity. — AoB Plants / PMC, 2016 (https://doi.org/10.1093/aobpla/plw040)” “Skid trails extended road edge effects on plant biodiversity up to 60 m into forest stands, serving as conduits for non-forest species and removing interior forest species. The addition of lime and clay substrates from road construction modified pH, nutrient content, soil moisture and bulk density, promoting roadside establishment of exotic and nitrophilous species. Limestone gravel damaged acidophilic species on roads and into stands, and the road effect was more damaging to forest species and less-competitive species on skid trails. — ScienceDirect / Biological Conservation, 2013 (https://doi.org/10.1016/j.biocon.2012.10.008)” “Long-term drying associated with drainage and road construction resulted in a two to fourfold increase in total biomass in three of four fen sites, but this came at the expense of ground-layer mosses and understory species. Drainage induced a shift toward a drier peatland regime, favoring increased canopy and vascular plant density while decreasing moss cover and productivity. Within ground-layer communities, drainage favored dry-adapted hummock moss and lichen species over wet-adapted but desiccation-prone species typical of low-lying lawns and hollows. — Springer Nature / Wetlands Ecology and Management, 2015 (https://doi.org/10.1007/s11273-015-9423-5)” “Road construction permanently occupied 73% of the total construction areas. Soil structure is fully destroyed and land productivity is lost in permanently occupied areas. The soil organic matter of pre-construction road was 3.57 times higher than post-construction, and soil bulk density in post-construction was greater than pre-construction by 10.3%. Topsoil formation proceeds very slowly — 1 cm of topsoil is formed under natural conditions every 300–400 years, yet it can be eroded in only one year on construction sites. — International Journal of Environmental Research and Public Health / PMC, 2022 (https://doi.org/10.3390/ijerph192316046)” Draft EIS Discloses No Irreversible or Irretrievable Commitment of Resources for Any Alternative Please please continue to uphold the Rule, continue to protect these lands, continue to allow future generations to experience a version of the world that is preserved naturally. Thank you.

I am writing to express my strong opposition to the proposal to fully or partially rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. I am an arborist, mountain biker, hiker, and river paddler living in Kent Ohio. National forests and inventoried roadless areas matter deeply to me because the forest lands I love to learn and recreate in like Allegheny National Forest located just 2 hr drive from Kent. The ANF contains Hearts Content, a beautiful natural area that’s great for quiet connection to nature. Fully or partially rescinding the Roadless Rule would threaten unfragmented backcountry landscapes, wildlife habitats, and clean water sources. Roads fragment ecosystems in ways that cause long-term ecological harm, and dismantling these protections undermines the natural integrity of our public lands. I urge the Forest Service to drop the proposed rescission and instead support Alternative 1 (the No Action alternative) to maintain full, permanent protections for all currently designated inventoried roadless areas. Thank you for the opportunity to comment on this important issue. Sincerely, Rick Denbeau Kent Ohio 44240 Rickdenbeau@gmail.com

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The trail at Jake's Rocks runs through a forest that still holds some of the rarest ground in the eastern United States. I bike there because the Allegheny National Forest is a beautiful natural area with abundant wildlife, and it should stay that way. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens that, and I oppose it. Pennsylvania holds 7 inventoried roadless areas totaling 24,866 acres. The areas I know and care about, including Clarion River, Minister Valley, Hearts Content, and Allegheny Front, are part of that inventory. There is only 1% of old growth forest left in the eastern United States. Wildlife depends on these areas for survival, and once that ground is opened to roads and the disturbance that follows, it does not come back. I ask the agency to explain in its final record what it finds insufficient about the protections these specific areas currently receive. The agency's own prior findings on wildfire should stop this proposal in its tracks. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency now proposes to open roadless areas in the name of fuels management, it must explain why it is departing from that conclusion, and it must reconcile the rescission with its own ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The current roads in the Allegheny are not properly maintained. It makes no sense to build more roads through this area when the existing ones are neglected. The agency's own record makes the same point in economic terms: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." A road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year cannot absorb new miles in exchange for returns that small. I ask the agency to reconcile the proposal with its own Cost Benefit Analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning a range the analysis itself cannot resolve in favor of the action. These roadless areas feed 7,000 municipal water intakes, and the agency's own data report that about 24 million Americans drink water that starts there. Across the Eastern region, which includes Pennsylvania, 286 municipal water intakes sit in watersheds containing affected roadless areas. Fewer than 12% of those watersheds have impaired streams today, and the agency's own analysis finds that roads and their facilities can produce up to 90% of the sediment from a timber sale. Do not disturb this natural balance. The agency must address what opening these watersheds to road construction does to that sediment load and to the communities downstream who depend on water that begins in places like Clarion River and Minister Valley. The regulatory flexibility analysis accompanying this proposal certifies no significant impact on small entities, yet "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification is reached by spreading losses across every small firm in the sector nationally, not by assessing the guides and outfitters who actually hold permits in the affected areas. The agency should withdraw the certification and assess the impact on the businesses operating in the roadless areas themselves. Finally, "the proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This comment is one such interest. I have planned my recreation, my sense of what this forest is, and my expectations of its future around protections that have been in place for more than two decades. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any further action. Sincerely, Paula Adams Pittsburgh, PA

As a professional ecologist, researcher and educator, I am writing to most strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). I urge the Forest Service to retain the current Roadless Rule by selecting Alternative 1 and for the Forest Service to reject the proposed nationwide rescission under Alternative 2 as well as any alternative that substantially weakens protections. I am deeply concerned about the false claim that removing the Roadless Rule is necessary to reduce wildfire risk. On the contrary, 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). It is clear that more roads mean more fires, and my studies of areas opened to roads show that among other things, all of this equipment being brought in spreads non-native plants which have no part in the ecosystem to manage them, which takeover and suffocate the diversity of native flora and create massive amounts of highly flammable ground fuels. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of pristine, roadless wildlands. I am also very concerned about the proposed rescission emphasizing greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning process to maintain ecological, cultural, and public values of roadless areas to an adequate level across the National system. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. Returning these decisions to entirely local planning processes should not be treated as a substitute for consistent nationwide protection measurements. Putting these forests under local control would have immense impact on the land managers' ability to protect undeveloped wildlands put wildlife habitat and connectivity, biodiversity, endangered and threatened species and clean water which emerges from the headwaters in many of these roadless areas at grave risk. We must keep all roadless wildlands under protection at the National level. As a researcher on biodiversity preservation on National Forest lands, I have an intimate knowledge of roadless areas in the Flathead National Forest as well as the Allegheny National Forest and have conducted biodiversity surveys in both locations as well as in non-roadless areas on both these National Forests. It is profoundly clear from all the studies that the the way lands are managed in non-roadless areas results in a far less biodiverse ecosystem that includes huge numbers and in some areas, monocultures of invasive, shallow rooted flora which create highly flammable ground fuels, decreasing water retention in dry soils, increasing wildfire risk and suffocating the diversity of native flora which support the entire ecosystem of flora, fauna and fungi. The 2001 Roadless Area Conservation Rule should be kept intact as is with no changes whatsoever. We cannot afford to lose any more of the scant amount of pristine wildlands we have remaining to hold ecosystems intact - for the wellbeing and sustenance of nature and therefore humankind.

I urge the U.S. Forest Service to retain the 2001 Roadless Area Conservation Rule and reject the proposed repeal. As an Eagle Scout and an eighteen-year-old who spends time hiking, camping, and biking on public lands, protecting our forests matters deeply to me. Scouting taught me to leave places better than I found them and to consider how my actions affect those who come after me. I believe those same principles should guide how we manage our national forests. Through Scouting and winter backpacking trips in Allegheny National Forest, I have learned how much spending time outdoors can teach a young person about responsibility, leadership, and looking after others. These experiences have also given me an appreciation for places where nature feels larger than the demands of everyday life. I want future generations to have those opportunities. I oppose removing the Roadless Rule’s restrictions on road construction and timber harvesting. I am concerned that doing so would put intact forests, wildlife habitat, and watersheds at greater risk of lasting damage. Please fully evaluate the cumulative effects of additional roads and logging, including habitat fragmentation, erosion, and the loss of opportunities for quiet recreation. I recognize that wildfire protection and forest management are serious responsibilities. However, I ask the Forest Service to explain why those goals cannot be achieved while retaining the rule and using its existing exceptions, rather than repealing these protections broadly. Our public forests belong to future generations as well as those of us alive today. As a young person, I will live with the consequences of this decision for decades. Please retain the Roadless Area Conservation Rule and protect the forests we still have the opportunity to preserve.

I am writing on behalf of Friends of Allegheny Wilderness, a Warren, Pennsylvania-based non-profit organization dedicated to protecting wilderness under the Wilderness Act of 1964 here in the Allegheny National Forest. We and our hundreds of thousands of supporters strongly oppose rescinding the 2001 Roadless Area Conservation Rule. This landmark directive has helped to protect roadless areas, and adjacent designated wilderness areas, on national forest lands for a quarter-century now. If anything is to be done with the Roadless Rule, it should be strengthened to eliminate logging and roadbuilding loopholes, and to provide better protection to roadless areas and adjacent designated wilderness areas. Roads fragment wildlife habitat, dividing contiguous ecosystems and creating harsh 'edge effects' that introduce invasive species and human disturbance. Existing roadless areas preserve large, uninterrupted tracts of high-quality interior forest habitat essential for sensitive, threatened, and endangered native species. By maintaining unbroken habitat, roadless areas serve as vital migration corridors, allowing wildlife to safely travel, forage, and adapt across broader natural landscapes. Roads threaten streams and rivers. Dirt and sediment that runs off roads impairs habitat for fish and other aquatic wildlife, and roads in steep, rugged country increase the risk of landslides that suffocate streams and rivers. Over long periods, as normal background amounts of soil and rock naturally break down and travel downstream, hydraulic abrasion wears down sharp edges. The particles become smoothed, rounded, and sorted by size over decades and centuries. By stark contrast, logging roads and other forest roads are built by crushing bedrock and exposing fresh, unweathered parent material. Traffic grinds this rock into fine dust, and storm runoff washes it into nearby streams. Because these particles have not undergone long-term aquatic transport, they are characterized by extremely sharp, angular, jagged edges. Fish breathe by drawing water across delicate filaments and lamellae in their gills. Rounded natural sediments simply slide off or cause minimal friction. Angular logging road particles act like microscopic shards of glass—scratching the gill tissues, causing lacerations, triggering excessive mucus production, and prompting cellular thickening. This drastically reduces the fish's ability to absorb oxygen and filter out waste. Beyond the sharp shape, logging roads generate an overwhelming volume of fine sediment. In natural stream systems, rounded gravel creates interstitial spaces where aquatic insects live and fish lay eggs. High-volume logging road runoff fills these gaps with fine, sharp silt, suffocating fish eggs and burying macroinvertebrates. One of the most glaring falsehoods surrounding efforts to rescind the Roadless Rule is the claim that we need to build more roads into roadless areas in order to prevent forest fires. In fact, more roads will result in more human-caused fires. Research shows that more than 60 percent of human-caused fires in national forests in the lower forty-eight states are ignited within one-eighth of a mile of the nearest road, and 95 percent are ignited within one-half of mile. You punch roads into a roadless area, you are going to wind up with more fires, not fewer. Roads bring people in their vehicles, and these people inevitably bring fire. Roadless areas provide for recreation like camping, hiking and backpacking, hunting and angling, wildlife viewing and photography, and other activities. Large sections of the North Country, Continental Divide, Pacific Crest, and Appalachian National Scenic trails cross protected roadless areas. With more than 380,000 miles of existing roads—a vast network that dwarfs America's entire highway system—the U.S. Forest Service faces a deferred maintenance backlog exceeding $8.6 billion. Rather than cavalierly expanding upon this costly footprint, the focus should be on closing and decommissioning roads wherever possible, in order to restore natural landscapes and ensure fiscal responsibility. In the Allegheny National Forest, we have about 25,000 roadless acres, including the largest inventoried roadless area on federal public lands in the Commonwealth — the 9,705-acre proposed Tracy Ridge Wilderness Area. We must retain protections brought by the Roadless Rule for all 25,000 roadless acres in the Allegheny National Forest to help protect these last special areas here in what is otherwise the most densely-roaded national forest in the country. We must continue to grow America's 111 million-acre National Wilderness Preservation System. An important component of doing that is to keep all national forest roadless areas completely intact, so that with time they too may all ultimately be designated as wilderness areas under the Wilderness Act of 1964. Kirk Johnson, Executive Director Friends of Allegheny Wilderness

I'm writing to comment in opposition to the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). I'm based in Juneau, Alaska, and regularly recreate within roadless areas here in the Tongass National Forest. In Alaska,, I most often recreate in the following roadless areas: Taku-Snettisham, Juneau-Skagway Icefield, Juneau Urban, and Douglas Island. Additionally, I have recreated on roadless areas in several states including but not limited to: Allegheny National Forest, PA, Monoghaela National Forest in West Virginia, White Mountian National Forest in New Hampshire, Jefferson National Forest in Virginia, Ocala National Forest in Florida, Chattahooche National Forest in South Carolina, Pisgah National Forest in North Carolina, Olympic National Forst and Gifford Pinchot National Forest in Washington. When recreating, I often seek out roadless areas and feel that protections for these areas are critical to ensuring future generations can enjoy these lands as I have. I believe the rule is well written, and the language allows for a variety of exemptions (timber harvest, wildfire fighting, roadbuilding, resource access, thinning, etc.). Most importantly, local Forest Service officials already have the authority to review and approve these exemptions. Roadless areas provide critical habitat for wildlife and serve as an important natural protection, helping ensure communities across the country have clean drinking water. Here in Alaska, I’m most concerned with the potential impacts that new subsidized road development for the timber industry would have on salmon habitat. Local economic engines have been designed around roadless areas. Just this summer, I paid a rafting company to raft through a roadless area, and a climbing guide to access a local crag via roadless-area trails. Here in Alaska, over 2 million cruise ship passengers will sail through the inside passage, marveling at our intact forest. Repealing the rule could put this billion-dollar industry at risk. The rule was originally designed to save taxpayers' money and allow the USFS to prioritize the maintenance backlog. Rolling back the rule could result in spending US Taxpayer dollars on road subsidies and a return to a time when the US government subsidized the Timber Industry. I find the "Purpose and Need for Action" for FS-2025-0001-223869 frivolous. I'd like to encourage the USDA to move away from a top-down, DC-driven approach. Roadless Rule protections have been in place for more than two decades; they are working, and the rule is serving the American public well. Again, I oppose the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule. I'll continue to raise my voice so my nieces and nephews have the same opportunities I've had to bike, hike, ski, raft in roadless areas. Thanks for your time and consideratio

Dear Ms. Rollins: As a parent, I submit these comments in opposition to a proposed rescission that, in my assessment, inverts the appropriate relationship between short-term economic rationale and long-term ecological obligation. Water is a precious resource for all humans. I want this resource to be valued above all else and my children will need this resource and so will their children. To destroy watersheds now, for short term profits, is incredibly short sighted and does not benefits Americans. Regarding the Allegheny Front in the Allegheny National Forest, Pennsylvania: Waters of the United States flow through the Allegheny Front IRA, Allegheny National Forest, establishing Clean Water Act Section 404 jurisdiction over any activity involving discharge of fill material into these streams. "NEPA is a success — it has made agencies take a hard look at the potential environmental consequences of their actions, and it has brought the public into the agency decision-making process like no other statute. Congress envisioned that federal agencies would use NEPA as a planning tool to integrate environmental, social, and economic concerns directly into projects and programs. However, during the first 25 years of NEPA, application has focused on decisions related to site-specific construction, development, or resource extraction projects. Perhaps the most significant environmental impacts result from the combination of existing stresses on the environment with the individually minor, but cumulatively major, effects of multiple actions over time." — Council on Environmental Quality, Executive Office of the President Every stream crossing required for road construction in the Allegheny Front IRA, Allegheny National Forest, involves placement of fill material — culverts, bridge footings, approach fills — into jurisdictional waters, constituting discharge under Clean Water Act Section 404. Do not rescind the Roadless Act! The Forest Service and U.S Government seems to be focused on short term profit and not the health and wellness of ALL Americans. Very truly yours, Elizabeth Darling CommentID: RLC-20261005-UE9ZOO

Dear Forest Service Leadership: Regarding the Minister Valley in the Allegheny National Forest, Pennsylvania: Minister Valley is one of my favorite hikes in the world and means a lot as a place I backpacked with my mom. That forest is like a holy place. Walking in it you can feel how long it took to form. A forest is more than just trees, it's our history and our heritage. Roadless areas function as corridors that let wide-ranging wildlife and aquatic species move between habitat patches as landscapes change. Rescinding the Roadless Rule would open the Minister Valley, Allegheny National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. Rescission of the 2001 Rule is not in the public interest; the Department should decline to proceed. In earnest, Marisha Sullivan CommentID: RLC-20261005-2TVK56

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The areas with roads are not wilderness. That distinction is what I am asking this agency to defend before it eliminates the protection that makes it meaningful. Pennsylvania holds 7 inventoried roadless areas totaling 24,866 acres. The Clarion River, Minister Valley, and Tracy Ridge units in the Allegheny National Forest are among them, and they are where I hike in the wild. Rescinding the 2001 Roadless Area Conservation Rule would expose those 24,866 acres to road construction and the industrial access roads bring with them. Before that happens, the agency owes a coherent legal and factual record. What follows identifies where that record falls short. The agency justifies rescission in part on permitting and administrative burden, yet its own rule text already provides for the situations it cites as problems. The rule as written "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions for existing mineral leases, community wildfire protection, and public health and safety are already in the rule. The agency has not identified which specific burdens fall outside those existing exceptions or placed any quantification of the residual burden on the record. I ask the agency to do exactly that: name each claimed burden, explain why the rule's existing exceptions do not resolve it, and support that explanation with figures. The regulatory flexibility analysis reaches its no-significant-impact certification by averaging the projected expenditure loss across every small firm in the sector nationally, rather than examining the outfitters, guides, and tour operators who actually hold permits in the affected areas. The agency's own cost-benefit work undercuts that move. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." A certification resting on a national average, while the agency's own analysis identifies a specific affected class and a floor on lost receipts, does not satisfy the Regulatory Flexibility Act. The agency should withdraw the certification and produce an analysis limited to the firms actually operating in the potentially affected roadless areas. The agency has also invited reliance comments it has not committed to weigh. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." This letter is one such reliance interest. I hike in the wild because areas with roads are not wilderness, and I rely on the 2001 rule to keep the Clarion River, Minister Valley, and Tracy Ridge units in a condition that makes them worth going to. An agency changing course is required to assess the reliance interests its prior policy created. The Cost Benefit Analysis as it stands does not do that. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before any final action. Finally, the agency's own fire data contradicts the wildfire rationale for rescission. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself concedes that road access could increase the number and frequency of wildfires. The agency cannot simultaneously cite fire risk as a reason to open these areas to roads and decline to quantify what new roads will do to ignition rates. What is the projected increase in human-caused ignitions from new road access in the affected areas, and how does that figure weigh against the claimed reduction in wildfire hazard? The record does not say. The Eastern region, which includes Pennsylvania, has 286 municipal water intakes sitting in watersheds that contain affected roadless areas. The people drinking that water, and the people hiking in the wild because roaded land is something else entirely, are owed a record that honestly accounts for what rescission costs. This one does not yet do that.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. Water from national forest country in the Eastern Region of the Allegheny National forest reaches as many as 3,819,600 people downstream, by the agency’s own data. I am one of them. Fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. Again, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the U.S. Forest Service to select Alternative 1 (the No Action alternative) in the draft Environmental Impact Statement and keep the 2001 Roadless Rule fully intact. Thank you.

My name is Devney, I am a student in Washington DC and I'm from Ohio. I grew up camping and fishing in the allegheny national forest. We would catch crawfish and climb trees and felt like kings of the forest. It taught my siblings and I to care for the land because it cared for us. It built our fires and provided our entertainment. There is no reason I should have to fight the same fight that my grandparents and my parents all have to preserve our land. My kids deserve a childhood in nature and science backs that up. Kids who grow up near national forests or other accessible public lands are on average more literate and better communicators. In the literacy crisis today we should be doing all we can to help youth learn to read and enjoy reading, and believe it or not, public lands play a big role in that. For the sake of the future generations m, the Roadless Rule should not be rescinded.

As a former US Forest Service employee with extensive experience in and adjacent to Roadless Areas, I strongly object to rescission of the the Roadless Area rule. I worked on the Mt baker Snoqualmie National Forest from 1980 through 1991. I worked on the Nez Perce National Forest in 1978 I worked on the Silver Fire Recovery Forest in the Siskiyou National Forest in 1987. I worked on the Hurricane Hugo Watershed Recovery Project in the El Yunque National Forest in 1989 I currently live in PA and have traveled and recreated in the Allegheny National Forest. I lived in Alaska in 2010 and traveled in Se Alaska in 1982 and throughout Alaska during my work for the Alaska Center for the Blind and Visually Impaired. Many of the roadless areas especially on the Mt Baker Snoqualmie National Forest were in areas not well suited to timber harvest. They occupied steep landscapes in the Silver Fir zone, areas that did not recover well from timber harvest and were often subject to landslides in zero order drain ages and due to failure of roads in the steep unstable terrain. Timber removal in these landscapes resulted in negative impacts on salmon habitat, wildlife habitat and yielded relatively little value for the timber harvested with the cost of harvest. I dispute that removing the roadless area rule would return decision making for the management of inventoried roadless areas to the land management planning process at the individual national forest level.Each National Forest and Ranger District has been under timber harvest goals set at higher organizations, not because of the true ability of the land to withstand the impacts of road construction and timber harvest. The Darrington Ranger District of the Mt Baker Snoqualmie National Forest where I worked for nearly a decade is a prime example. Areas open to timber harvest had excessive road construction, often poorly maintained and subject to slope failures. Once the levels of timber harvest were reduced in Darrington and Monte Cristo the local economy developed more reliance and infrastructure to support recreation that utilized back country and front country resources. The areas proposed to be removed from the Roadless Area Rule in the Darrington Ranger District are generally adjacent to wilderness, on lands not well suited to road construction and timber harvest. They are far more valuable and suited for back country recreation, protection of fisheries and wildlife habitat. The Roadless Areas of the Nez Perce Clearwater National Forest Striking a balance between recreational enjoyment and the well-being of our wildlife is crucial for ensuring the long-term health of the Nez Perce-Clearwater National Forest. Roadless areas are designated for increased ATV, motorcycle, and snowmachine use, which will displace essential wildlife such as wolverines, mountain goats, grizzly bears, and elk. The absence of specific written directions in the plan to protect wildlife from increased motorized recreation raises questions about the sustainability of such expansion. Most named wildlife require extensive habitat. the absence of defined limits on the extent of motorized trails or riding areas leaves these critical zones vulnerable to an unlimited influx of motorized recreation. The roadless areas of the Nez Perce Clearwater like the Chugach Tongass and Mt Baker Snoqualmie National Forests are far more valuable for protection of salmon habitat than they are for timber harvest. The Chugach National Forest Roadless areas are located in areas not well suited to timber harvest. Much of the landscapes steep sloped areas with soil that is destabilized by road construction, posing a risk to the highly valuable fisheries resource. The Tongass National Forest in Alaska is well suited to insure the long term protection of the salmon and other fisheries, and wildlife. The Tongass not unlike the Higher elevation roadless areas on the Mt Baker Snoqualmie and Siskiyou National Forests does not support timber harvest and regrowth to justify the cost and environmental impact of that harvest. The EL Yunque National Forest has roadless areas. They are a vital resource for protecting critical wildlife habitat and watershed resources. There are ample areas of the El Yunque National Forest to serve the needs of the casual tourist. The Allegheny National Forest is a precious resource to Pennsylvanians. Opening up current Roadless areas to road construction and energy development would degrade the wildlife habitat and diminish precious backcountry recreation. The Roadless areas are adjacent to the Allegheny River, The Clarion Wild and Scenic River, within the Allegheny National Recreation Area and the Hickory Creek Wilderness. I strongly object to rescission of the Roadless Area Rule. These roadless areas are a unique and irreplaceable resource belonging the people of the United States. They are part of our heritage and should be retained in current condition.

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.

Do not rescind the Roadless Rule. The USDA’s draft environmental impact statement (DEIS) points to economic and environmental harm happening to undeveloped backcountry forests, wildlife, water resources, and communities, if the rule is rescinded while also not improving wildfire risk reduction. The DEIS also suggests maintenance costs will increase. For fire mitigation the USDA should lean on the environmental wisdom of sovereign tribes and respect treaty rights. The lands that the Roadless Rule protects are a common good and belong to the American people. They are vital resources for economic and physical health and often communities have grown or been created around tourist opportunities. Here in Pennsylvania, this is threatening the Allegheny National Forest. There is already access for hikers and ATVs. What is needed, in Alleghany and elsewhere, is pristine wilderness, untouched and unthreatened by commerce, construction, and cars. Leave the Roadless Rule in place. You asked in 2025 and Americans responded with more than 600,000 comments demanding our forest be left alone. It is our heritage and our land and deserves better than being open to bureaucratic abuse. Leave the Roadless Rule unaltered.

To the U.S. Forest Service and Department of Agriculture, I am writing to express my strong opposition to the proposal to rescind or weaken the 2001 Roadless Area Conservation Rule. I am an outdoor enthusiast and outdoor educator based in Chardon Ohio, and public lands are an important part of both my personal life and my work. I hike extensively in national forests and regularly lead youth groups on outdoor experiences in the Allegheny National Forest, White Mountain National Forest, and Monongahela National Forest. These forests provide opportunities not only for recreation, but also for young people to develop a deeper understanding of the natural world and their responsibility to care for it. From my experience spending significant time in these forests, I value the opportunity to experience large, relatively undeveloped landscapes where people can hike, explore, and learn without the presence of extensive roads and development. Roadless areas also provide important habitat and help protect watersheds and the quality of our water. Expanding roads into these areas would fragment intact landscapes, affect wildlife habitat, and create long-term infrastructure and maintenance costs. The remaining roadless areas in our national forests are a valuable and limited public resource. Once roads and other development are introduced into these places, their character is difficult or impossible to restore. I urge the Forest Service to withdraw this proposal and maintain the protections provided by the 2001 Roadless Area Conservation Rule. Sincerely, Tatiana Yudovina Chardon, Ohio Sent from my iPhone

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Andrew Moore, I live in Pittsburgh, Pennsylvania, I am an environmental journalist and the author of two books of natural history, The Beasts of the East: The Fall and Rise of America’s Eastern Wilderness (Mariner Books, 2026) and Pawpaw: In Search of America’s Forgotten Fruit (Chelsea Green, 2015); and I am a member of the Pennsylvania Native Plant Society and the Wild Ones Western Pennsylvania Area Chapter. In my personal life, I am also an outdoor enthusiast and frequent Roadless Areas in both Pennsylvania and West Virginia. Areas that are especially important to me include the Clarion River Inventoried Roadless Area and the Hearts Content Inventoried Roadless Area, within the Allegheny National Forest; and the numerous and irreplaceable Roadless Areas of West Virginia, including Canaan Loop, Cheat Mountain, Cranberry Glades Botanical Area, Dolly Sods Roaring Plain, Gauley Mountain, and the Seneca Creek Inventoried Roadless Area, among so many others. I have also visited and backpacked in Roadless Areas in the Sierra Mountains of California, and I credit experiences in those wild, roadless mountains for teaching me about the vastness and the irreplaceable beauty and biological heritage of the United States of America. Furthermore, I place immense value on roadless areas in the West and other parts of the United States, places I may not have been to yet, but which I had planned to visit in the near future. The preservation of these landscapes by previous generations of Americans are among our most noble national achievements. We must honor that work and maintain our Inventoried Roadless Areas. I am also the father of a six-year-old boy, a Tiger Cub in Scouting America, and I look forward to taking my son into Roadless Areas so that he, too, can experience the value and wonder of a wild, roadless America. And it is my hope that in the preservation of these Inventoried Roadless Areas, future generations of Americans will be inspired to become the land stewards we so desperately need. Roadless Areas are our National Heritage and Must Be Preserved From Alaska’s vast Tongass to the red spruce forests of the West Virginia highlands, our national forests are an invaluable inheritance, providing innumerable benefits: Habitat for wildlife, including threatened and endangered species; safeguarding the water of farms, aquatic wildlife, and human communities; and unmatched and irreplaceable opportunities for hunters, anglers, hikers, and other appreciators of nature. The 58 million acres within inventoried roadless areas provide these opportunities and services like no other landscapes, while also supporting millions of visitors each year. These places unite all Americans who value the natural world, across the political spectrum. For more than two decades, inventoried roadless areas have helped the U.S. Forest Service meet its statutory mandate to “improve and protect the forest[s]” under its control. The Forest Service introduced the Roadless Rule in 2001 to implement a National Forest System management approach that would allow it to consider the "whole picture" of landscapes across the country, in order to protect the nationally significant ecological and social values of roadless areas. The Forest Service has previously warned that managing inventoried roadless areas on a forest-by-forest basis could allow incremental road construction and timber harvest, leading to the erosion of roadless qualities nationwide, while increasing the agency’s maintenance, and fiscal burdens. As such, the Roadless Rule advances essential goals of forest management: protecting wildlife, preserving clean water, and preventing wildfires. Opening inventoried roadless areas to development jeopardizes our natural heritage without providing the means to address potential harm. Road construction scars forest ecosystems: as Forest Service ranger Elers Koch has said, “Roads are such final and irretrievable facts.” When roads cause contribute to the local extinction of wildlife, those species may never return. When roads increase sedimentation in our waterways, they may remain “dirty” indefinitely. Roads can induce wildfires, and when those road-attributed fires burn through our national forests, old-growth trees, which have grown for thousands of years, can be destroyed in flash. And as we’ve seen, forest roads can only be removed with heavy machinery—and even decommissioned roads can persist for decades, or indefinitely. The protections inherent to the Roadless Rule are more pressing than ever: Megafires, accelerating habitat loss, and diminishing water supplies have heightened the need for coordinated forest management across the national forest system and increased the value of inventoried roadless areas. (COMMENT CONTINUED IN ATTACHED FILE)

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Clarion River corridor in the Allegheny National Forest, the Northern Massanutten in George Washington National Forest, and Big Schloss along the Virginia and West Virginia border are places I care about, and the proposed rescission of the 2001 Roadless Area Conservation Rule threatens all three. I oppose this rescission and ask the agency to address the specific failures of analysis described below. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That figure is striking and then abandoned. The document does not carry it forward into any projection of how much sediment would actually reach waterways downstream of the 3,821 acres at the Clarion River, the 9,444 acres at Northern Massanutten, or the 8,375 acres at Big Schloss, let alone downstream of affected roadless areas across the broader landscape. Pennsylvania alone holds 7 inventoried roadless areas totaling 24,866 acres, and across the Eastern region, which includes Pennsylvania, 286 municipal water intakes sit in watersheds containing affected roadless areas. The agency cites the risk and walks away from the math. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before any final action is taken. On drinking water more broadly, the DEIS states that Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The agency then asserts that existing forest plans adequately protect those sources, but identifies no enforceable provision in any plan that carries the equivalent protective force of 36 CFR 294.12 and 294.13. An assertion is not a substitute for a showing. The agency must identify, forest by forest, which plan provisions perform the same protective function as those regulations for the municipal watersheds affected, and must do so with enough specificity that the public can evaluate the claim. The fragmentation analysis suffers the same pattern of citation without application. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range, presented without qualification, is substantial. Yet no projection follows it across the 40.1 million acres of potentially affected environment. The places I have named, the Clarion River corridor among them, support wildlife that depends on the interior conditions that roadless designation preserves. A finding of that magnitude deserves more than a footnote. The agency should apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what the results mean for species within the affected landscape. The regulatory flexibility analysis compounds these problems by reaching a conclusion that cannot be reconciled with the document sitting beside it. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The certification is achieved by spreading an annual expenditure loss across every small firm in the relevant sector nationally, diluting the impact to invisibility, rather than examining the outfitters and guides who actually hold permits in the affected areas. The DEIS concedes some firms may lose these receipts. That concession alone should have triggered a harder look. The agency must withdraw the certification and perform the analysis on the small entities actually operating in and around the potentially affected roadless areas, not on the average national firm in a category. These are not peripheral objections. Each involves a number the agency chose to include and then declined to use. The Clarion River corridor, Northern Massanutten, and Big Schloss deserve an analysis equal to what the agency's own data makes possible. I urge the agency to address each of these points in the record and to maintain the 2001 rule. Sincerely, Maurice E Chioda Dallastown, PA