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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The suburban sprawl I'm stuck in makes the chance to climb peaks and get away all the more necessary. Roadless areas on the national forests are where that escape is possible. I oppose rescission of the 2001 Roadless Area Conservation Rule and ask the agency to respond to the points below. What we would lose here could never be replaced in my lifetime, nor in many lifetimes. These lands are valuable precisely because they have not been exploited for quarterly earnings. That is not a sentimental argument; it is a factual one about irreversibility. Rescission opens a permanent door. On fire, I have watched fire season grow noticeably longer and worse since I have lived near Boise NF, beginning in 2010. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nevertheless invokes wildfire management as a justification for rescission and the road-building that would follow. The agency must explain why this proposal departs from its own prior findings on fire occurrence, 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. On economics, the agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile this 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 carrying a $6.9 billion maintenance backlog. On the state-by-state rationale, the record shows that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That is the agency quoting itself favorably, but the agency has also found that local decision-making can incrementally erode nationally significant roadless values. The Ninth Circuit has already weighed in on the deficiencies of replacing a national rule with state-by-state management. The agency should explain how this proposal avoids those same deficiencies. On statutory authority, the proposal argues the 2001 rule exceeded what Congress granted. The court record shows 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 held 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. If the agency now holds a contrary position, it must state the legal basis for that position with specificity. The water question should be obvious to anybody paying attention. Fewer than 12 percent of the watersheds fed by roadless areas have impaired streams today. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency has not explained how rescission is consistent with its obligations to the roughly 24 million Americans whose drinking water starts in those watersheds. That explanation is required before this rulemaking can proceed. Sincerely, Graham Hill Boise, Idaho

As a researcher who studies forest ecology, it is vitally important that we limit the amount of fragmentation that occurs in these forests to increase the resilience and ecosystem services our national forests provide. From a citizens standpoint, I have been traveling the U.S. the past few months and have primarily visited national forests including the Ozark NF, Uinta NF, Boise NF, Willamette NF, and Sequoia NF. These are beautiful places that support beautiful and diverse ecosystems that are a treasure for all Americans. Please do not tarnish the beauty and ecology of these places by dismantling the Roadless Area Conservation Rule. We all benefit from this rule, even though the benefits may largely be indirect. We need to think about the sustainability of our public lands and keep this rule intact so future generations can have access to clean air, clean water, and beautiful places to recreate and research. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Boise National Forest is where I go to find what I can only describe as the pristine landscape untouched by human activity. I hike there, I camp there, and I keep my eyes open for any and all critters that come into view. The photographs I take are of a place that looks the way it does precisely because roads have not been pushed through it. The rescission of the 2001 Roadless Area Conservation Rule would end that, and the agency's own documents give me no confidence that it has weighed what it would be giving up. The proposal frames rescission partly in terms of timber and energy economics, yet the record the agency assembled says 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." Those are not figures I computed; they come from the agency itself. Against that marginal production gain, the agency's own cost-benefit work 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 range spanning negative $92 million to positive $199 million, all while the road system already carries a $6.9 billion maintenance backlog. I ask that the agency reconcile its stated economic rationale with those numbers, and explain how opening more roads to produce less than half a percent of national timber volume makes financial sense when its own analysis cannot establish a net benefit. The regulatory flexibility certification compounds the problem. "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." Reaching a no-impact conclusion by averaging losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas, is not an assessment of the entities at risk. The agency should withdraw that certification and conduct a genuine analysis of the small businesses operating specifically inside the potentially affected roadless areas. I rely on the current rule every time I enter the Boise National Forest expecting to find country that has not been opened to mechanized extraction. That reliance is exactly what the agency invites comment on, and then declines to count. "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." Under settled administrative law, an agency changing course must identify and weigh the reliance interests its prior policy created. This comment is one such interest. The agency must now do what it promised and actually weigh the interests it solicited, including the one expressed here. Finally, the fire analysis cuts against the proposal more sharply than the agency acknowledges. Its own effects document states that "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." That is a ratio of more than seven to one. The same document concedes that road access could increase the number and frequency of wildfires. The critters I watch and the landscapes I photograph in the Boise National Forest are already subject to fire pressure. Before the agency claims that new roads reduce wildfire hazard, it must quantify the expected increase in human-caused ignitions that road access brings and place that number alongside whatever suppression benefit it is claiming. It has not done that, and it must. Sincerely, Concerned citizen Boise, Idaho

I and my family are strongly opposed to the Trump administration and the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule. My educational background is a BS in Limnology and Marine Biology (University of Texas, Austin) and a Masters in Civil Engineering (University of Washington, Seattle). I worked at Boeing Aerospace with Supercomputers doing Finite Element Modeling. My work included modeling aeronautics for commercial, space, and military systems. I also worked for Boeing at the Hanford Nuclear Waste Site in Richland WA. The work required groundwater modeling to determine where nuclear waste stored in Basalt caverns would spread over time. For three years, I have been the FIREWISE Captain for our Idaho neighborhood near the Boise National Forest. Every year now we have numerous nearby wildfires that threaten our neighborhoods, agricultural land, forests and for us personally both our Boise and Stanley properties. Various studies show that building roads fragments wildlife habitats, increases soil erosion, releases stored carbon, and elevates the risk of human-caused wildfire ignitions linked to increased access. Eighty percent of the fires in the West are human caused. Careless “practice” shooting of firearms, inappropriate campfires, sparks from vehicle chains or mufflers, tossed cigarettes, lighting of fireworks, and arson will increase if additional roads make access deep into the forest and in dry grasslands possible. Rescinding the Roadless Rule will only increase the number of uncontrolled fires, unprosecuted perpetrators and fire-fighting costs. The Trump administration has severely reduced funding to manage and protect our forests. Numerous knowledgeable public servants (BLM, Forest Service, Fire teams) were fired by the Federal goverment to supposedly cut big government and save money. That was a disastrous strategy as evidenced by the unprecedented 2026 Fire Season in the West and elsewhere. We personally know BLM fire management personnel that were fired then hired back late in the fire season on an expensive temporary basis due to Big Box fire management (not the preferred best practice). Ranchers do not like the Big Box approach as it relies on "back burns” of huge swathes of their private land in an attempt to make a large Box around the fire. This is one example of the funding cut debacle. There was not enough money left after the huge government funding cuts to implement the needed prescribed burns and best practices. Due to the lack of funding to fight the fires with the best practices that are thoroughly proven, the United States is burning. I will not even go into the stupidity of ignoring that Climate Change is scientifically proven and that “boots on the ground” observations regularly prove that reality. A few of the unpleasant Facts related to the Forest Service Roadless Rule Rescission are: •Discretionary Funding: The administration's budget requests have sought dramatic reductions—including a proposed 44% cut to operations and up to a 75% overall reduction in discretionary budget allocations according to analyses like those from Taxpayers for Common Sense. •Research Elimination: The proposals completely eliminate funding for the Forest and Rangeland Research accounts, closing dozens of research stations nationwide. •Shifting Priorities: While operations, research, and non-fire programs face deep reductions, the budget requests significantly boost funding targeted for commercial timber sales and logging programs. With regards to the ” Shifting Priorities” mentioned above - there are no studies that have determined the results on the forests and the potential of increased human caused fires which will follow from such a sudden shift to un-hindered large scale commercial logging. In addition, it appears that the commercial logging will have very few regulations to protect streams, fish, wildlife etc. What will be the restraints on the chosen forests, road locations and the environmental impact? What will be the regulations on the corporations? Please refer me to studies and enforceable regulations that indicate our current Under Secretary of Agriculture for Natural Resources and Environment , Mr. Michael Boren, and the rest of the administration have any plans for the actual long term financial well-being of the country , our safety, and the environmental impacts of this decision. Again to clarify, my family and I strongly OPPOSE the Rescission of the 2001 Roadless Rule and will vote accordingly.

I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. This rule has protected roughly 58–59 million acres of national forest land (nearly one-third of the National Forest System) for 25 years, and repealing it would cause irreversible harm to wildlife, water, and public lands that belong to all Americans. 1. Roadless areas are irreplaceable wildlife habitat. Although inventoried roadless areas make up only about 2% of land in the lower 48 states, they provide habitat for well over half of vulnerable terrestrial wildlife species, including hundreds of plants and animals listed or proposed for listing under the Endangered Species Act. These lands also serve as critical connective corridors between national parks and wilderness areas for wide-ranging species like grizzly bears and elk. Opening them to road construction and logging would fragment habitat that, once developed, cannot be restored. 2. Roads degrade water quality and increase flood/erosion risk. The Forest Service’s own Watershed Condition Framework identifies road density as a key driver of degraded water quality and quantity. Rescinding the rule would allow new road building in the very areas that currently protect clean drinking water for downstream communities. 3. The wildfire-risk justification for this rollback is not well supported. The proposal argues that removing roadless protections is needed to reduce wildfire risk, but recent research shows roadless areas have burned at rates similar to or lower than roaded forests over the past decade. Roads themselves are a leading cause of human-ignited wildfires. If wildfire risk is the real concern, targeted, science-based fuel treatments — not a blanket repeal of protections on tens of millions of acres — is the appropriate tool. 4. This is a wholesale repeal of a rule the public strongly supports. The 2001 Roadless Rule was the product of one of the most extensive public engagement processes in federal rulemaking history, with the overwhelming majority of the more than 1.6 million comments received in support of it. Comments submitted during the 2025 notice of intent to repeal likewise overwhelmingly opposed rescission. Replacing a durable, science-based national standard with ad hoc, forest-by-forest planning removes a consistent baseline of protection and instead exposes these lands to inconsistent management and the political pressures of the moment. 5. “Local flexibility” does not require full repeal. Land managers already have mechanisms to address genuine local needs — including existing exceptions in the 2001 rule itself for activities like fire risk reduction. A full national rescission goes far beyond what is needed to address legitimate local circumstances, and instead removes durable protection for wild, undeveloped forest land across 38 states. For these reasons, I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule in full. The Boise National Forest, which starts not far from where I live, is already protected under Idaho’s own state-specific roadless rule. While I certainly appreciate this, our country’s beautiful forests and public lands deserve federal, not just state, protection.