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I have hiked and mountain biked for years in the Angeles National Forest (specifically in the Strawberry Peak and Arroyo Seco roadless areas) and hope to explore other National Forests soon. These protected public lands are our national treasures, and they must be preserved—with exactly the kind of protections the Roadless Rule provides. Rescinding this rule and opening these protected lands to road building and logging would dramatically harm them, irrevocably damaging sensitive ecosystems that in many cases are not protected elsewhere (within the National Park System, for example). The Roadless Rule is a sound, common-sense regulation. It does not prohibit multi-use activities within the areas it protects—it simply ensures damaging roads are not built. We must be good stewards of our public lands and ensure they remain healthy, thriving, and undeveloped for future generations. Please keep the Roadless Rule intact.

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting since I was 10 years old has connected me to the cycle of life, to my food, to how it is processed and where it comes from. The national parks and forests have been my refuge in hectic times, my place of peace. I have been a trail guide in 5 states, led hikes through the Angeles National Forest and San Gabriel wilderness, through the Cascade Mountains, climbed Mount Rainier, and led hunting trips through the Alaskan wilderness. I have photographed Big Horn Mine, the surrounding mountains, and the San Gabriel wilderness. I want my children to have the same opportunities I had to explore and appreciate these lands. I oppose rescission of the 2001 Roadless Area Conservation Rule. The agency's own data 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." I have lived through several major wildfires, some that nearly took our home. I know that mismanagement of forests leads to disastrous fires, which then cause sudden flash floods when it rains. The agency is now proposing to open roadless areas in the name of fire management while its own record shows that roading those areas increases ignition risk. I ask the agency to explain why this proposal departs from its own prior findings and to reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not add up, and where my tax dollars go matters to me. The record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, and the net present value of the proposal spans -$92 million to +$199 million. The agency cannot establish a net benefit, yet it proposes expanding a road system already carrying a $6.9 billion maintenance backlog on a road budget of about $73 million a year. Building new roads into country that has none, while existing roads crumble, is not a responsible use of public funds. The agency must reconcile this proposal with those numbers and explain on the record how that arithmetic serves the public interest. One of my first memories of fishing is on the American River that flows through Sacramento, pulling salmon in almost as big as me at the time. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, reducing egg survival, rearing densities and growth of coho salmon in areas that include Essential Fish Habitat and critical habitats managed by NMFS. The Cucamonga A unit of 1,249 acres in the Angeles National Forest and the Cucamonga C unit of 4,106 acres in the San Bernardino National Forest sit in this landscape. Clean water is not a policy preference. We as humans require it. Our wildlife and forests need it. I want the agency to tell me, specifically, how it intends to protect those 1,034 intake watersheds if this rule falls. On the question of statutory authority, the Tenth Circuit spoke plainly: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court held the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency owes the public a specific, on-the-record explanation of its basis for any contrary legal position. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Our lands should be kept and managed for future generations. Their loss will have an unimaginable impact on us all. Sincerely, John Benge Chino, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public land should be managed for wildlife diversity, conservation, and to be enjoyed by future generations. The proposal before the agency fails all three of those purposes, and it fails them using the agency's own record. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. That is not a peripheral finding. It is in the agency's own draft environmental impact statement, and it speaks directly to the kind of habitat that keeps Arroyo Seco and Magic Mountain worth entering. These areas sit within Angeles National Forest, part of a state that holds 381 inventoried roadless areas totaling 4,389,760 acres. The birds I photograph are sensitive to exactly the disturbance that roads introduce. The agency must explain how opening these landscapes to road construction is consistent with the bird abundance and species-avoidance data already in its record. On wildfire, the agency's own text states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on fuels and fire management grounds. That justification runs directly into the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain on the record why the proposal departs from its own prior findings on fire occurrence and reconcile the rescission with those numbers. Clean water is a universal human right. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer roads mean cleaner source water. That relationship is not speculative; it is in the agency's own data. The agency must address that relationship directly, and state plainly how the rescission protects, rather than degrades, the source water those intakes depend on. The economic case does not hold together either. The agency's record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal extraction volumes, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million. The road system already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with an analysis that cannot establish a net benefit and explain how expanding a deficit-carrying road network is justified by figures this small. The proposal also argues that state-specific approaches can substitute for one national rule, and invokes what it describes as a preference for flexibility over uniformity. The agency's own record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already examined a state-by-state replacement and found it wanting. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies identified in that litigation. Finally, the proposal questions whether the 2001 rule exceeded statutory authority. A court already answered that. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and concluded it did not create de facto wilderness. The agency must state the legal basis for any position to the contrary, and explain why that holding does not govern here. Sincerely, Kaitlin Callahan North Hollywood , Ca

I’m writing in strong support of the roadless rule. I believe we actually need more roadless areas within our country and that rescinding the rule would be a travesty for the people of this country, our precious ecology and for future generations. I live within walking distance from the Angeles National Forest. It is a place of refuge, solace, and inspiration for myself, my family, and our friends. We hike in the forest at least four days a week. The hiking helps us stay fit and healthy and provides us a chance to bond as a family. Being immersed in the smells, clean air, fresh streams and incredible diversity of plant and animal life is something we all look forward to every week. As a baby, some of my daughter’s first words were the plants she would see along the rustic mountain trails. This connection to nature is how we are meant to live and many of us in the U.S. have become separated from it. Many of our country’s modern plagues are rooted in this disconnection from nature – obesity, depression, chronic diseases, cancers, etc. We are grateful for this proximity of the Angeles National Forest, and some of our most treasured places are in roadless areas. There is an area along the San Gabriel River boarding a roadless area where my friends and I would spend summers decompressing and enjoying the river. The water would be crystal blue. And it was an escape from the urban density in which we all lived. Living adjacent to the ANF, wildfires are also a huge concern of ours. Countless studies, including ones from the US Dept of Fish and Wildlife, have shown that the presence of roads significantly increases the risk of wildfires. Most wildfires are human-caused. With more roads, come more people and more opportunities for fires to spark. In addition, roads are known to increase the presence of invasive species, most of which grow quickly and then dry out, creating the worst kind of fuels and kindling for wildfires. In addition to our personal issues with rescinding the roadless rule, we know roads fragment, disturb and pollute wild areas. Our nation needs natural, intact, wilderness areas with thriving ecosystems. While humans have temporarily created our own systems to feed and support ourselves, these intact ecosystems have been the backbone of life on this planet for its entire history. If our human-made systems fail, our only life-line is the natural ones. We need to preserve them for means of human and national security. Even with flourishing human systems, intact natural areas are imperative to our health. They keep the air and water clean. And are even a trove of natural knowledge for ourselves and future generations. For example, there is a plant that grows near me in the ANF, Yerb Santa (eriodictyon crassifolium), which has been known for generations as a healing plant. Scientists at the Salk Institute are currently studying it and found a compound within the plant that shows promise as a drug for Alzheimer’s. Intact ecosystems protect plants like this. If it’s not self-evident, wild areas are valuable in their own right. Maybe you see them as the creations and gifts of divinity or maybe as the result of thousands of generations of various organisms evolving together. I believe every cell, every heart-beat, every flower of every species has the right to flourish. We have a moral imperative to respect the natural world, and protect the diversity of life on this planet. The roadless rule is a step toward that. Many of the Roadless areas are in biodiversity hot spots. Places that need protection so that myriad forms of life can continue to flourish like they have through the ages. Let us not lose sight of the important things in life and what makes our country great. We need to protect roadless areas for ourselves and for future generations. Roadless areas have lower risk of fire ignition, they provide beauty and recreation that inspire life and connection to nature and among people, they help keep our nation healthy through clean air, water, and they help protect the natural world, a gift of innate value which we must protect at all costs.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Angeles National Forest is where I spend my weekends. The Inyo is where my bucket list trips point. These places are sacred, and they are meant to be enjoyed as they are, without development and without roads cutting into country that has none. The agency's own record undermines its wildfire rationale for rescission. The 2001 rule is being dismantled in part on the grounds that roadless areas need road access for fuels management and fire response. But the agency found, in its own prior analysis: "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." I came to this comment with the same concern from a different direction: forests with roads face a measurably higher fire risk, and fighting those fires drains taxpayer dollars in ways that are avoidable. The agency must explain why the current proposal departs from its own prior findings, and must reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not support rescission either. The agency has already found that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." That is the return on offer. Against it sits a road system already carrying a $6.9 billion maintenance backlog, funded at roughly $73 million a year. Opening new roads into the Angeles, the Inyo, and every other affected forest to capture a share of less than half a percent of national timber output is a waste of resources and money. The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already in that condition. The agency has also been down the road of replacing national protection with a state-by-state approach, and the courts rejected it. Rather than reproducing the agency's own language on that history, I will state the point plainly: the record shows that local decision-making can incrementally erode nationally significant roadless values in ways that aggregate into large and irreversible loss. The agency must address how this proposal avoids the deficiencies the Ninth Circuit identified the last time a state-specific framework was substituted for the national rule, and it must answer that question directly rather than treating the prior litigation as settled against the rule's supporters. On statutory authority, the courts that examined the question did not find the 2001 rule unlawful. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and found it did not create de facto wilderness. The agency's current proposal rests in part on an authority argument the Tenth Circuit already rejected. What is the legal basis for a contrary position, and where in this record does the agency address that holding? These lands are meant to be protected. The agency has not shown that rescission serves the public that uses them. Sincerely, Whitney San Diego, CA

I am a native Californian, and I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I am lucky to have grown up in a rural area near Auburn, CA with many roadless areas just up the hill in the Tahoe and El Dorado National Forests. These roadless areas protect our access to clean water that comes largely from the mountains. The North Fork American River Inventoried Roadless Area (IRA) and the North Fork Middle Fork American River IRA both protect areas upstream from my home from soil erosion, landslide risk, and sediment pollution - negative impacts that will increase if the Roadless Rule is repealed, according to the Draft Environmental Impact Statement (DEIS) (p 101). These rivers run into Folsom Lake, a reservoir that provides drinking water to hundreds of thousands of residents in Sacramento and the surrounding foothills. Of course, this pattern is repeated across the entire United States, where the Roadless Rule protects drinking water for about 24 million Americans (p 121). I have recreated in and formed deep connections to 63 roadless areas in California, Oregon, and Washington while hiking the length of the Pacific Crest Trail (PCT). The PCT is a designated National Scenic Trail, one of the crown jewels of the system of trails in the United States, and attracts thousands of hikers from around the world every single year, year after year. This is a boon to the local economies of the rural towns the trail passes by, but the attraction of the trail depends on the quality of nature along it, including the 10% of the trail that goes through IRAs. The US Forest Service’s own economists agree that rescinding the Roadless Rule would cost nearby communities up to 9 million dollars per year in visitor spending, as laid out in the Draft Environmental Impact Statement (DEIS) (p 223-224). This could negatively impact Julian, CA near Caliente IRA in the Cleveland National Forest; like many PCT hikers I ate several times at Mom’s Pies and stayed at the Julian Gold Rush Hotel when I passed through. Idyllwild, CA near the Pyramid Peak A IRA in the San Bernardino NF was my refuge when a storm system swept through the mountains bringing snow in April; I stayed two nights at the Fireside Inn to dry out my gear and wait out the storm which also meant splurging on breakfast, lunch and dinner at local restaurants. Big Bear, CA benefits from visitors to several nearby roadless areas including one of my favorites, Deep Creek, which has a natural hot springs that is beloved by hikers and locals alike. The Roadless Rule keeps the creek clean and the canyon it runs through intact. Wrightwood, CA is another destination for recreation, including for PCT hikers, that is nearby several roadless areas in the Angeles NF including Sheep Mountain and Pleasant View, and stands to suffer losses to its economy if the Roadless Rule is rescinded. They have an excellent general store that gets a lot of business from hikers and the summit of Mount Baden-Powell is both in their backyard and part of the Sheep Mountain IRA. Baden-Powell offers a challenge, and immersion in nature, draws day-trippers from Los Angeles, and would be severely degraded if it were logged. Green Valley, CA, near the Tule and Fish Canyon IRAs, benefits from hikers who shop at their local market and eat at the wonderful Green Valley Smokehouse. I could keep going, since I hiked through, as stated above, 63 IRAs throughout the three states. All are local treasures that draw people from around the world looking for world-class recreation in nature, and who spend on dining, lodging, guiding, equipment and more in the surrounding communities. The eastern Sierra Nevada has a number of IRAs that are near and dear to me, not just as a hiker, but as a climber as well. I climb to connect with nature, explore my physical and mental limits, experience solitude and beauty. According to the DEIS, rolling back the Roadless Rule will degrade scenery and backcountry access (p 25, 192). This could be true, for example, in the Coyote North IRA where the climbing area Little Egypt is located. I’ve been climbing and hiking in and around Bishop for 16 years now. I’ve also explored the Birch Creek IRA on trails among the ancient bristlecone pine trees. The Birch Creek IRA contains not just the oldest living trees but the world’s oldest living non-clonal organism, which is a Great Basin bristlecone pine tree that is 4858 years old. I am in awe of the natural world when I go to this place, and believe it must be protected for everyone, including future generations. When the Roadless Rule was put in place in 2001, our country was overwhelmingly in favor of the Roadless Rule. We still are. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative.

I have hiked most of the Pacific Crest Trail (PCT) which passes through 63 Inventoried Roadless Areas (IRAs) along 288 of its 2653 miles. I write to strongly oppose the proposal to eliminate protections in these and other IRAs around the nation. The administration falsely claims that road building in IRAs will help to prevent wildfires. In reality, and as numerous studies have shown, the presence of roads greatly increases the chances of ignition from passing vehicles, carelessness, or deliberate arson. Consider the Angeles National Forest that has seen one human-caused fire after another. Now almost no large trees are left. The 2009 Station Fire that burned 160,000 acres was started by an arsonist who used Highway 2 to gain access to the forest near mileage marker 29. The huge network of USDA Forest Service roads that penetrate our national forests have likewise been the source of countless ignitions. Indeed the past century of Forest Service mismanagement has had a devastating effect on these lands, mismanagement that is closely connected with roads. Secretary of Agriculture Brooke Rollins is not going to get away with her lies about real sources of most wildfire. And the mismanagement does not end with fires. Forest Service roads are poorly maintained, eroding the landscape and posing hazards to people that use them. The Forest Service is in no position to expand its road network further; instead it must remove roads and restore our lands. Such a positive activity would protect and enhance trails such as the PCT. Since the Forest Service has almost entirely given up maintaining trails, this work is largely conducted by dedicated volunteers. Removing protections for IRAs such as the extensive ones found in the Klamath Mountains or Los Padres National Forest would be a slap in the face to the volunteers like me who have worked to cover for the failings of the Forest Service. How dare the administration consider doing this! Of course we know the reason for this proposal: It is all about serving Mammon, about "getting the cut out" and "getting the oil out." In reality outdoor recreation is a true and enduring source of economic activity -- one that does not devastate the land. The outdoor recreation economy generates $730 billion annually, far more than timber sales. IRAs store 20% of all carbon in U.S. national forests. And IRAs are crucial habitat for 1,600+ threatened species. The greed and dishonesty of the administration will be its undoing.

Re: Special Areas; Roadless Area Conservation - proposed rescission, 91 FR 53827 (Aug. 20, 2026) | RIN 0596-AD66 | Docket FS-2025-0001 I oppose rescinding the 2001 Roadless Rule and ask that the Department withdraw the proposed rule, or at minimum adopt an alternative that retains the national baseline and requires site-specific NEPA before any road construction or commercial harvest in inventoried roadless areas. I am a U.S. military veteran and an America the Beautiful Military Lifetime Pass holder. I live in San Francisco, and these areas are where I actually spend my time - the San Gorgonio Wilderness (San Bernardino NF), the Cucamonga Wilderness and the San Gabriel high country around Mount Baldy (Angeles NF), the Mount Pinos country in Los Padres NF, and the eastern Sierra out of Mammoth. The reason those places are still quiet is the 2001 rule. I also drive SR-38 to the Vivian Creek trailhead, which has washed out repeatedly since the 2020 El Dorado Fire - a reminder of what these steep headwater drainages do after fire, and why road density and ground disturbance in them matter. Four specific comments: 1. The stated problem does not require this remedy. USDA keeps the Idaho (subpart C) and Colorado (subpart D) roadless rules and notes that any state, tribe, or entity may petition under 5 U.S.C. 553(e) for tailored management. If place-based roadless rules are workable - and USDA is retaining two - then "one-size-fits-all" is not a justification for repealing the baseline everywhere else. The Department already has the mechanism it says it needs. 2. "Returning decisions to land management plans" is a plan of absence. The notice states the rule "does not require or compel the amendment or revision of any land management plan." For forests whose plans do not independently prohibit road construction and harvest in roadless areas, rescission leaves a gap with no protection until a plan is revised - years, for many units. The final EIS should state, acre by acre, how much of the 58.5 million acres retains equivalent protection on day one and how much does not. The notice asserts effects are "bounded by existing land management plan direction" without demonstrating what that direction is. 3. The economics are close to a wash; the losses are not. USDA's own figures: timber-industry gain of $4.6-10.6M/yr, recreation loss estimated at $6.1M/yr - against a $6.9 billion deferred-maintenance backlog on the existing forest road network. Building new roads you cannot afford to maintain, for revenue the same order as the recreation value displaced, is not a net-benefit case. The road-maintenance liability of new permanent roads is missing from the analysis. 4. Wildfire. The notice concedes greater access "can increase human-caused ignition potential." If road construction is justified as fire-risk treatment, the EIS should quantify treatment acreage actually achievable within operability and budget over ten years, and compare it against the acres each new road puts at higher ignition risk. The 9.8 million WUI acres overlapping roadless areas deserve a spatially explicit alternative, not blanket repeal. Alternative I support: No Action, or a targeted-WUI-treatment alternative permitting fuels reduction and temporary access within a defined distance of at-risk communities while retaining the prohibition on new permanent roads and commercial harvest in the interior of inventoried roadless areas. As a veteran, I value these lands for the quiet, self-reliant recreation they provide, and I ask the Department to keep the protection that makes them what they are. Please withdraw the proposed rule. Brian Mauck - San Francisco, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The place I return to is Angeles National Forest. I go there to reconnect to myself and to those around me, and to maintain respect and a sense of awe for our natural world. The roadless areas within that forest, including Strawberry Peak, Arroyo Seco, and San Gabriel Add, are part of what makes that possible. The 2001 Roadless Area Conservation Rule protects them. I oppose rescinding it. The agency's own record destroys the wildfire rationale for this proposal. The agency found that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding sits in the agency's own draft environmental impact statement alongside ignition data showing far higher fire density on roaded land than inside inventoried roadless areas. Angeles National Forest, where I hike at Strawberry Peak and along Arroyo Seco, is exactly the kind of fire-prone landscape that finding describes. I ask the agency to reconcile this proposal with DEIS Table 21 and explain why its current position departs from its own prior findings on fire occurrence in roadless areas. The economics do not hold up either. The agency's own analysis shows that the total timber volume affected by the rule at issue is less than 0.5 percent of total United States production, and the oil and gas production from all National Forest System lands is about 0.4 percent of national production. Those are not numbers that justify dismantling protections for the roadless areas I visit in California, a state holding 381 inventoried roadless areas totaling 4,389,760 acres. The agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. It establishes uncertainty. And it does not account for the fact that the existing road system already carries a $6.9 billion maintenance backlog. How does adding more roads to that backlog serve the public interest? The agency should answer that question directly before this proposal moves any further. The proposal also argues that state-by-state management can replace a single national rule. The record shows the agency has tried that before. It "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That state-petition approach was challenged in court, and the agency lost. The Ninth Circuit identified specific deficiencies in that approach, including the agency's own prior finding that local, incremental decision-making erodes nationally significant roadless values over time. The 1,034 municipal water intakes in the Pacific Southwest region sitting in watersheds containing affected roadless areas illustrate what is at stake when those values erode piece by piece. The agency should explain how this proposal avoids repeating the same legal deficiencies the court identified before. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. That argument has already been tested. The Tenth Circuit exercised jurisdiction pursuant to 28 U.S.C. Section 1291, reversed the district court's order granting declaratory relief and issuing a permanent injunction, and remanded the case for the district court to vacate the injunction. The court found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and that it did not create de facto wilderness. The agency owes the public a clear, on-the-record explanation of the legal basis for any position that contradicts that holding. I visit Angeles National Forest to feel awe. That feeling depends on places that remain whole. These areas deserve the protection the 2001 rule provides. Sincerely, Evangeline Stout Los Angeles, CA

Dear Chief: I am a wildlife artist making work about local ecology that I share in educational settings. I rely on research, conversations with biologists and my daily visits to the national forest. Having observed wildlife across a representative cross-section of the inventoried roadless areas in the affected region, I write as a sustained observer to oppose the proposed rescission, the rationale for which the field evidence does not support. My opposition rests on several issues, chief among them fire. I will note ahead of that arguement below, that rescinding the Roadless Rule will fragment habitats and increase road mortality of wildlife. Your analysis, its failure to consistently and adequately address core habitat, as well as improperly aligned data regarding management plans for listed species, fails to address the effects on health, population and distribution of the Southern California population Puma Con Color. I request that it do so. Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire. The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation. If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire. Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom. Do the right thing. DO NOT RECIND THE ROADLESS RULE. All the best, Christian Kasperkovitz

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Angeles National Forest is where I go to hear running water and birdsong and to clear my head. I also lived in Utah for a time and came to love the Utah backcountry. Both of those places are shaped by the 2001 Roadless Area Conservation Rule. I oppose its rescission under Docket FS-2025-0001. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres. As a westerner, I am concerned about water conservation as temperatures and drought continue to increase. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule places those watersheds under real and quantifiable pressure. The agency's own analysis documents that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer unroaded areas means more sediment, more impaired streams, and less reliable water for the people and communities downstream. I ask that the agency explain, with specificity, how removing protections from roadless watersheds across the Intermountain region is consistent with any credible commitment to water quality and drought resilience. The proposal justifies rescission partly on wildfire and fuels management grounds. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The Angeles and the Utah backcountry I care about are both fire-prone landscapes. Opening roadless areas to road construction does not reduce ignition risk; the agency's own data say the opposite. The agency must explain why the proposal departs from these prior findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The proposal also cites permitting and administrative burden as justification. But the rule as written already accommodates the agency's stated concerns. The agency's own text notes that the rule "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)." If the existing exceptions for health, safety, and reserved rights are insufficient, the agency has not shown where they fall short or put numbers to the gap. It should identify, specifically and by category, which burdens the current exceptions do not already address, and quantify those burdens. I want future generations to have access to the outdoors and to the health benefits of spending time outside. The Forest Service held more than 600 public meetings and received 1.6 million comments before writing this rule. It has held none before undoing it. The Utah backcountry and the forests near Los Angeles that I value were protected by a process that was extensive and public. The rescission process has been neither. The agency's own analysis concedes that its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year, and names outfitters, guides, and tour operators as affected parties, 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 rather than assessing the businesses actually holding permits in affected areas. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have organized my relationship to these landscapes around the assumption that they would remain protected. An agency changing course is obligated to assess the reliance its prior policy created, not simply invite comment and then ignore what it receives. The agency must identify and genuinely weigh the reliance interests described in the comments it collects, including this one. Sincerely, Zak Breckenridge Long Beach, CA

To the Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). I haven been an avid hike for almost 20 years, hiking several times a week (or more). This includes national parks and national forests including the following: • Angeles National Forest • Arapaho National Forest • Carson National Forest • Cleveland National Forest • Inyo National Forest • Lassen National Forest • Pike National Forest • Rio Grande National Forest • Roosevelt National Forest • Routt National Forest • San Bernardino National Forest • White River National Forest Hiking is important to both my physical and mental health and has played an important role in my volunteer work to help veterans reintegrate following their service and find community. Taking them on hikes has been a powerful way to bolster their health and wellness. The 2001 Rule protects roughly 58.5 million acres of inventoried roadless areas by generally prohibiting road construction, road reconstruction, and timber harvesting, with limited exceptions. Rescinding it removes that protection nationwide. The notice states that the rescission does not itself mandate timber cutting or road building. But it removes the rule that currently prevents them, and the agency should be candid that this makes road construction and logging in these areas possible where they are now generally prohibited. For hikers, the value of these areas is that they are undeveloped. A trail through a roadless area offers quiet, solitude, and a sense of remoteness that cannot be rebuilt once a road is cut through. Opening the door to new roads and logging puts those experiences at risk, and the loss would be permanent in a way that is very hard to undo. The Department's stated reasons for the proposal are to reduce regulatory burden and to return decisions to local Forest Service officials. I ask the agency to address the following in the final rule and EIS: How will recreation be weighed? If decisions move to the local level, what required standard will ensure that the value of undeveloped backcountry for hiking and other dispersed recreation is considered, rather than left to discretion project by project? What is the burden being relieved? Please identify the specific, documented costs of the 2001 Rule, and show that they outweigh the benefits of keeping a consistent nationwide protection. Why rescind rather than amend? If there are specific problems with the rule, why does the Department propose eliminating it entirely instead of a narrower fix? How will the public be involved? Under the proposal, how would hikers and other recreation users learn of and comment on future decisions affecting individual roadless areas? I also ask that the Department give the public adequate time to review a proposal of this size. The rescission was issued alongside a draft environmental impact statement and a cost-benefit analysis, with an original 30-day comment period. I urge the Department to withdraw the proposed rescission and keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Laura W. Fort Collins, CO

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The East and West Fork of the San Gabriel Rivers are not wilderness by any formal designation, but they hold landlocked coastal steelhead, and they are close enough to Los Angeles that people who love them share the water with people who abuse it. I have watched gold miners dig out whole sides of the stream, sending sediment downriver and destroying the natural habitat those fish depend on. I have seen illegal camping all up and down the river creating public health hazards with elevated E. coli. Rescinding the 2001 Roadless Area Conservation Rule for the Angeles National Forest will not reduce that pressure. It will increase it, and it will do so while the agency's own science documents exactly what new roads cost a river. The agency's document states: "The DEIS: 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 number appears in the record and then vanishes. No projection follows it. Removing riparian vegetation raises stream temperatures beyond what suits cold-water species, and warmer temperatures reduce egg survival, rearing densities and growth of coho salmon. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS. If the agency knows roads and their facilities can produce up to 90 percent of the sediment from a timber sale, it must quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. I am asking for that calculation. The drinking water question is not abstract. The agency's own record states: "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." Water is limited already. Clean drinking water is more limited still. Many of these watersheds feed into aquifers and aqueducts that sustain cities and communities, and the current impairment rate is low precisely because the roadless rule has been holding. The DEIS asserts that forest plans address municipal water sources without identifying a single enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds, and that it do so specifically, not by category. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. A federal appellate court reviewed that question directly and held otherwise: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. I ask that the agency explain the basis for any position contrary to that holding, and that it address that court's reasoning directly. On the economics, the proposal rests in part on timber and energy arguments. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." With a $73 million annual road budget and a $6.9 billion maintenance backlog already in place, spending more to open country that has no roads is a poor decision that goes against any serious principle of avoiding government waste. I also value the Inyo National Forest for its remoteness and high altitude, qualities that exist because development has not reached them. The agency must reconcile this proposal with its own Cost Benefit Analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest. I oppose rescission of the 2001 Roadless Area Conservation Rule. The agency has quantified the harm and declined to follow it to its conclusions. That is not a reasoned decision. The record requires answers, and the public deserves them. Sincerely, Dorothy Dai Los Angeles, CA

My name is Lyndsey Nolan and I live in Los Angeles, where I visit the Angeles National Forest and any other park/forest as often as possible. I am commenting on the USDA Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule. Adding road will cause damage to forests, not protect them. Section 294.14 already permits tree thinning and emergency fire access. Repealing these protections will benefit corporate logging interests at the expense of taxpayers and intact ecosystems. I ask that the Forest Service choose the No Action Alternative and keep the 2001 Roadless Rule intact.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet I go looking for in Jefferson National Forest, in the Sawtooth Mountains in Idaho, and in national forests and BLM land across Arizona, Utah, Washington, and Oregon is already hard to find. It is harder every decade. I have hiked and camped in these places since childhood, going there for quiet, to escape light pollution, and to see and hear the wildlife. I have sat by a river in the Sawtooth Mountains and watched a bald eagle sweep out of the sky and take a fish from the water. That is not a small thing. Rescinding the Roadless Area Conservation Rule puts that kind of experience, and the places that make it possible, at permanent risk. Brush Mountain in Jefferson National Forest is supposed to be protected from the ills that have already devastated much of Appalachia: mountaintop removal, deforestation, displacement of wildlife, contamination of the water table. It is supposed to be a place for nature to recover and thrive. Angeles National Forest is not only essential for wildlife like the mountain lion that need uninterrupted space to roam and hunt, but for the residents of the Los Angeles metropolitan area who need relief from constant noise, light, and traffic. A road into either place means more noise, more pollution, a total corruption of the environment for people, animals, plants, and water. The agency owes the public a direct explanation of how opening these 6,002 and 7,245 acres, respectively, to road-building serves a purpose commensurate with what would be destroyed. The agency's own record addresses bird abundance in roadless areas, and the findings are unambiguous. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The bald eagles, the countless other birds I go to these places to find: the science on what roads do to them is already in the record. The agency must explain why it is proceeding anyway. The wildfire justification offered for this rescission is contradicted by 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." I lived through multiple fire seasons in California. I saw Angeles National Forest burn. I was affected by smoke and road closures, and was evacuated from work sites because of forest fires. Friends lost access to their homes. The agency must reconcile this proposal with the ignition data in its own DEIS, which shows far higher fire density on roaded land. As a taxpayer, I object to what this proposal represents financially. The road maintenance backlog already stands at $6.9 billion. The agency's own economic analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The record also states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must explain how a cost-benefit analysis that cannot establish a net benefit justifies expanding a road system already in this condition. Drinking water is already a serious problem across this country, from Flint, Michigan to Appalachia. With 24 million Americans' drinking water coming from roadless areas, and with the agency's own analysis showing that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, the risk to those watersheds is not speculative. Across the Southwestern region alone, 739 municipal water intakes sit in watersheds containing affected roadless areas. The agency should state plainly what its plan is to protect those intakes. The forests themselves are the resource. A home for plants and wildlife, and a place for humans to rest and recharge. Not something to extract for commodities. We have so few of these spaces left. The Native Americans believe we must consider the impact our decisions will have on the next seven generations, and this rescission would rob future Americans of places that are, as the agency's own record implies, invaluable and irreplaceable. I urge the agency to withdraw this proposal. Sincerely, Rose Shawhan Blacksburg, VA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Escaping to isolated sections of forest is a major part of my recreation, and it is extremely important and valuable to me. I photograph the natural sites that inspire me: forest-covered hills and mountain peaks that are untouched, places that recall the way the land looked for thousands of years before people altered the large majority of it. The areas I am most concerned about include Sespe-Frazier in Los Padres National Forest, where I carry many fond memories of hiking and backpacking in my twenties and which is wonderful for how accessible it remains from the greater LA area; the rugged landscapes of the San Gabriel Add and Arroyo Seco units in Angeles National Forest, which provide an important escape from the nearby sprawl of LA; Pyramid in Eldorado National Forest, a wonderful place to hike and experience beauty and solitude; and Tioga Lake in Inyo National Forest, a place of immense natural beauty. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and these places represent what remains. We cannot restore a landscape once it is destroyed. So little is left already, and we must save what is left for our children and further descendants. Preserving natural beauty and places of solitude should have a higher priority than wealth extraction. That is the principle I ask this agency to apply in reviewing this proposal. The agency offers wildfire management as part of the justification for rescission, but its own findings contradict that rationale. 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." The places I hike and photograph, these untouched forest-covered hills, carry value precisely because they have remained unroaded. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale fares no better on examination. The agency's own record acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The solitude I seek in places like Sespe-Frazier and the beauty I photograph at Tioga Lake are not abstract values; they represent the kind of recreation that the agency's own cost-benefit analysis recognizes as carrying real economic weight. The same analysis projects timber revenue to the Forest Service 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 negative $92 million to positive $199 million. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal also argues that state-specific approaches can replace a single national rule, but this ground has been tested before. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." California's 4,389,760 roadless acres, including the watersheds that supply 1,034 municipal water intakes across the Pacific Southwest region, were protected under the national framework precisely because local, incremental decision-making was found to gradually erode nationally significant roadless values. How does this proposal avoid the deficiencies the Ninth Circuit identified the last time the agency substituted a state-by-state approach for the national rule? Finally, the proposal contends that the 2001 rule exceeded statutory authority. But the Tenth Circuit addressed that question directly. The court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state plainly on what legal basis it departs from that holding. The places I have described are finite. The Pyramid roadless area covers 24,347 acres. Sespe-Frazier covers 106,910. These numbers do not grow back once a road goes in. I ask the agency to answer each of the questions raised above before proceeding further. Sincerely, Erik Krumrey San Rafael, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Eaton Fire displaced me from my home for over one year, and I did not return. That experience is inseparable from why I oppose this rescission. Our resources should not be used to deforest our land. They should be directed toward the indigenous communities that have long cared for this land in historically scientific and ecological ways, preserving native wildlife and old growth that protect against fire. Opening roadless areas to roads and the activity that follows moves in exactly the opposite direction. On the wildfire question, the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused or wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Angeles National Forest, one of the many pristine ecosystems at stake here, sits in the middle of this reality. Bobcats to beetles depend on it, and so do the communities whose homes and lives are threatened when fire moves through degraded, roaded terrain. The agency must explain why this proposal departs from those prior findings and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Water is a sacred source, and any damage to our current watersheds will not go unnoticed. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The communities drinking water that starts in these roadless watersheds are not abstractions. The agency should be required to answer, on the record, how it weighs that contamination risk against whatever benefit it projects from opening these areas. The projected benefit is itself difficult to square. The agency's record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those figures, the agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service, recreation losses of at least $6.1 million a year, and a net present value spanning -$92 million to +$199 million. A road system already carrying a $6.9 billion maintenance backlog would be expanded by a proposal whose own numbers cannot establish a net benefit. The agency must reconcile those figures and explain what economic justification supports this action. The proposal also argues for replacing the national rule with state-specific approaches, yet the record itself records that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.'" 70 Fed.Reg. at 25,656. The agency tried that path before. The Ninth Circuit identified deficiencies in the state-by-state approach the last time it was attempted. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values and explain how this proposal avoids the same result. Finally, the proposal argues that the 2001 rule exceeded the agency's statutory authority. The Tenth Circuit already addressed that question and held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not find that it created de facto wilderness. What legal basis does the agency now advance for a contrary position, and how does it distinguish that holding? I hike with my dog, camp in the mountains, and rock climb in places like Angeles National Forest because they are still intact. I oppose this rescission and urge the agency to withdraw it. Sincerely, Rebecca Seman Tujunga CA

Dear Brooke L. Rollins, I am a reproductive surgeon and healthcare sustainability researcher Studies show that natural and green spaces improve the mental and physical health of those who live nearby. Having green spaces in the middle of LA improves access to those who otherwise cannot get out of the city. Repealing the rule reduces health benefits of natural spaces and exposes patients to more traffic related pollution. This increases healthcare costs for all and creates and weakened population. Regarding the Arroyo Seco in the Angeles National Forest, California: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the Arroyo Seco, Angeles 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. Your actions transfer increased health costs to other governmental agencies, for what benefit? This is a formal objection to rescission, entered for the record.

As someone who gauges a place partly by what hasn't reached it yet, I'd say the 2001 Rule has done more to preserve what makes certain public lands worth visiting than any other rule. I make weekly trips into the Angeles National Forest to get away from the people and constantly congested traffic of the Los Angeles basin. This area already attracts people who use the existing roads to dump large trash items, strip stolen vehicles, and engage in illegal activities. It has suffered multiple massive landslides and fires in the last five-plus years. Building more roads into our wild spaces brings more people; often the kind of people who don't respect the environment. More roads will only encourage more dumping, and increase the potential for wildfire ignition. Making our wilderness more accessible to the general public and exploitation inevitably causes more environmental harm. Those of us who visit it regularly appreciate and cherish the escape it offers. Regarding the Strawberry Peak in the Angeles National Forest, California: “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha). Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads. — Fire Ecology (Springer Nature), 2026 (https://doi.org/10.1186/s42408-026-00450-2)” Don't walk away from the protection the Rule provides. We only have one Earth. With thanks, Sarah Fairfield CommentID: RLC-20261002-KVL3B7

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I grew up in are not abstractions. My father took me hunting deer through the Angeles Forest, around Barley Flats and into the backcountry, and what I carried home from those days was not just game but something harder to name: appreciation for the land and its beauty. We may be hunters, but stewardship always comes first. The elk, deer, and bear we hunt need a refuge. We need to be stewards. Now the agency proposes to rescind the 2001 Roadless Area Conservation Rule, and I am filing this comment in opposition to Docket FS-2025-0001 because that decision would open the very ground those animals depend on. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The areas I named in the Angeles National Forest, including Arroyo Seco, Strawberry Peak, Magic Mountain, and San Gabriel Add, and the Tuolumne River area in the Stanislaus, are part of that inventory. I spend weekends and holidays camping and hiking throughout the Angeles, Inyo, Tahoe, and Stanislaus forests to explore the natural beauty of California, and I want to keep experiencing it, others to experience it, and this land protected for the next hundred years and beyond. These mountains are where I photograph wildflowers in spring, deer, and one day a mountain lion. But mountain lions need protected forests and mountains to have a home. Roads are the core threat to that home. The agency's own record states that elk avoid areas near roads and select habitat away from them, that ideal summer elk habitat is unroaded land with cover and forage, and that elk survival rates rose during a road closure and fell again when the gates were removed. The DEIS also cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed, and the rule's own Tribal record credits its protections with the recovery of deer populations in Alaska by preserving old-growth winter shelter. On bears, the DEIS quotes the federal grizzly recovery plan directly: increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation, and food reward all increase with the use of even secondary unpaved roads. I ask that the agency explain, as part of the record before it closes, how rescinding the rule is consistent with these findings, each of which comes from its own documents. The wildfire rationale the proposal offers fares no better on its own terms. The agency's 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." That finding is the agency's own. I ask that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from its own prior findings. The economic case is equally strained. The agency's record concedes: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service 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 ranging from -$92 million to +$199 million. The agency must 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. Across the Pacific Southwest region alone, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, a cost the proposal does not adequately account for. Finally, on statutory authority: a federal appellate court has already answered the question the proposal re-opens. The Tenth Circuit held, "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain, with specificity, the legal basis for any contrary position it now takes. Sincerely, Elizabeth Harris San Jose, CA