Read the comments.

Continued: 4. Fire is a part of the ecosystem. To the extent that the rationale is reducing fire, the rationale is wrong, as other commenters have pointed out and as the rationale points out, that more roads lead to more fire activity. But also the entire proposal is misplaced — because the most effective way to address fires of increasing intensity is to address climate change. That is the real national priority that needs to be addressed that the government is completely failing to address. Roads in forests are not a recognized wild-land fire management policy, as other commenters have pointed out. *** Put simply, the repeal of the Roadless Rule is a step backwards in public lands management. It effectively takes public lands out of the hands of the people they are set aside for — the American public — and hands them to special interests who are willing to pay for them. This is not the mandate that the USFS has been given by Congress. The mandate is the manage these lands for multiple uses. Creating new roads in forests prioritizes only one use, timber harvesting, over all others. *** My experience in this comment is drawn from recreating at the following USFS properties: Little Missouri National Grassland; Buffalo Gap National Grassland; BigHorn National Forest; Chequamegon-Nicolet National Forest; Hiawatha National Forest; Ottawa National Forest; Huron-Manistee National Forest; Superior National Forest; Chippewa National Forest; Shoshone National Forest; Custer-Gallatin National Forest; Flathead National Forest; Bridger-Teton National Forest; Caribou-Targhee National Forest; Gifford Pinchot National Forest; Olympic National Forest; Okanogan-Wenatchee National Forest; Mount Baker-Snoqualmie National Forest; Colville National Forest; Medicine Bow-Routt National Forest; Arapaho National Forest; White River National Forest; Black Hills National Forest; Thunder Basin National Grassland; Unit-Wasatch-Cache National Forest; Sierra National Forest; Stanislaus National Forest; Lincoln National Forest; and Shawnee National Forest. My major takeaway from all these experiences is that these Forests already have more roads than most people could explore in a lifetime. There is quite simply no practical or logistical need, from a recreational perspective, for more under the rationales that the USFS has proposed in this rule change.

Dear Secretary Rollins and Chief Schultz: The pollution becomes more deadly. The temperatures continue to rise. Animals are dying as their homes are cut down leading to potential ecosystem collapse. If they go, we go too. As a citizen whose climate worry shapes how I vote, what I read, and now what I comment on, the 2001 Rule keeps a meaningful amount of carbon in trees. That's the version of climate action that does the math. Regarding the Big Island in the Chippewa National Forest, Minnesota: I want to Department to understand the long term effects and the world they are giving their kids and their kids kids. I want them to think of the future. Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Most remaining forest is already fragmented. Globally, 70 percent of remaining forest is within one kilometer of a forest edge — within the zone where edge effects compromise interior conditions. The remaining intact interior, including roadless areas in the National Forest System, has become disproportionately important for sustaining the species and processes that require unfragmented forest (Haddad et al. 2015). — Haddad et al., 2015 (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Big Island, Chippewa 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 proposed action should be withdrawn, and the 2001 Rule allowed to remain operative. With gratitude, CommentID: RLC-20261002-Z54EVT

My name is Mary Grace Lemon and I live in in Minneapolis Minnesota. I have recreated in National Forests all across the United States including several National Forests in Minnesota such as Superior National Forest and Chippewa National Forest and Kisatchie National Forest in my home state of Louisiana. I also have a PhD in hydrology and spent 5 years working for the United States Fish and Wildlife Service as a hydrologist. I am writing to comment on the USDA Forest Service’s proposed rescission of the 2001 Roadless Area Conservation Rule. I am against repealing this rule for several reasons. First, repealing this rule will not help with fires. Rather, the repeal of this rule will likely lead to increased ignitions and fire intensity due to several factors. Second, roadless areas are critical for ecosystems. Habitat fragmentation causes significant harm to wildlife populations. Lastly, this rule change will waste taxpayer money and reduce recreation opportunities. Wildfires are 4x more likely to start near roads (Aplet et al. 2026). Cars can cause sparks and are sources of ignition. In addition, roads are a pathway for fire-prone invasive plant species to invade the forest interior. Roads also cause hydrological changes that can lead to vegetation community changes and reduce soil moisture, increasing the vulnerability of a forest to fire. In fact, I worked for five years on restoration projects that overwhelming involved removing roads within National Wildlife Refuges to restore hydrologic connectivity and increase the water table within forested areas to reduce the vulnerability of the forest to fire. Roads are a major cause of habitat fragmentation, breaking continuous landscapes into smaller, isolated patches. By acting as barriers to movement, roads prevent animals from reaching food, mates, and new territory, while traffic adds direct mortality (Seiler, 2001). Over time, this isolation shrinks populations and limits genetic exchange, making them more vulnerable to local extinction (Forman & Alexander, 1998; Trombulak & Frissell, 2000). A review of 79 studies found that negative effects of roads on animal abundance outnumbered positive effects five to one (Fahrig & Rytwinski, 2009). While working at USFWS, I helped to remove many roads to restore ecosystem function and habitats. All of these roads were built with taxpayer money and then removed with taxpayer money after rarely being used. This represented a massive waste of taxpayer money that could have easily been avoided if large investment decisions were not left to local managers and rather decided at a higher level. In the end taxpayer money was wasted and ecological damage was done because a restored ecosystem takes decades to function as effectively as one that has never been modified. Repealing the roadless rule will lead future wasteful and ecologically damaging uses of taxpayer money that will require additional taxpayer money to be corrected. Roads are some of the most disruptive human modifications that exist for effective ecosystem function. For all of the above reasons and more I strongly oppose rescinding the 2001 Roadless Rule and taking the no action alternative. We should absolutely be doing everything that we can to reduce the number of roads within our federal and managed forests and wilderness areas. Before moving forward, I ask that the agency: 1.Conduct a full environmental review of the impact of rescinding this rule on roadless areas; 2.Commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. comments were considered and concerns addressed. References •Aplet, G.H., Hartger, P., & Dietz, M.S. (2026) Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(8). •Fahrig, L., & Rytwinski, T. (2009). Effects of roads on animal abundance: An empirical review and synthesis. Ecology and Society, 14(1), 21. •Forman, R. T. T., & Alexander, L. E. (1998). Roads and their major ecological effects. Annual Review of Ecology and Systematics, 29, 207–231. •Seiler, A. (2001). Ecological effects of roads: A review (Introductory Research Essay No. 9). Swedish University of Agricultural Sciences, Uppsala. •Trombulak, S. C., & Frissell, C. A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology, 14(1), 18–30.

I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66 / Docket FS-2025-0001). As an outdoor recreation enthusiast and cross-country skier based in the Upper Midwest, I rely on the quiet, unfragmented landscapes protected by the Roadless Rule. In Minnesota, the Superior National Forest and Chippewa National Forest contain critical inventoried roadless areas (IRAs) that provide high-quality backcountry recreation, protect critical watersheds, and preserve contiguous forest ecosystems. Rescinding the Roadless Rule and opening these lands to new industrial road construction and commercial timber harvesting threatens the core values that make our public lands unique: Recreational Quality and Trail Integrity: Cross-country skiing, backcountry touring, and trail recreation depend on unbroken forest canopies, natural snow accumulation, and non-motorized, quiet solitude. Carving roads through currently roadless parcels fragments trails, degrades scenic corridors, accelerates wind scours and snowmelt, and introduces industrial noise and traffic that permanently diminish the winter recreation experience. Ecosystem and Watershed Protection: In northern Minnesota, roadless tracts act as vital buffers for pristine waterways, including watersheds feeding into Lake Superior and the Boundary Waters Canoe Area Wilderness. Road construction is one of the leading causes of soil compaction, erosion, siltation in cold-water streams, and the introduction of invasive species. Fiscal and Maintenance Burden: The Forest Service already faces a multi-billion-dollar maintenance backlog on existing forest roads. Expanding road construction into inventoried roadless areas will only increase long-term taxpayer liability and divert scarce agency maintenance resources away from heavily used trail infrastructure and developed recreation facilities. Failure to Justify Full Rescission: The 2001 Roadless Rule already provides clear exceptions for emergency wildfire management, forest health, and public safety. Complete rescission is an unnecessary overreach that strips durable, nationwide protections in favor of short-term extraction. I urge the U.S. Department of Agriculture and the U.S. Forest Service to withdraw this proposed rule, select Alternative 1 (No Action), and retain the full protections of the 2001 Roadless Area Conservation Rule.

Dear Special Areas: Roadless Area Conservation, To Whom It May Concern in US Forest Service: I am writing to you today to thank you for preserving our precious forests by keeping the Roadless Rule in force. Please do not repeal the Roadless Rule! This rule has protected our forests for generations. Forest protection protects groundwater, recreational businesses, animal habitat(many of them already endangered), and all of us against climate change. Our children deserve and, in truth, require, intact forest space to preserve quality of earth, air, water, and life itself! The Roadless Rule protects all these things from unnecessary development and extraction. It is crucial to our survival! When I was young, my father bought a piece of land outside the Chippewa National Forest. I had the good fortune to spend my summers there, and I learned a deep appreciation for silence where the only sounds are nature, Gods natural temple. The air smelled only of earth and pine, the water clear at 20 feet or more. The undisturbed lakes provided habitat for very kind of fish and fowl, cranberries grew in their wetlands,and a variety of animals made their homes there. Outside the forest boundary, small towns thrived on the sale of canoes,fishing equipment and basic food. These gifts remain today. These many gifts remain in part because of the Roadless Rule which also preserve flyways for migratory birds and drinking water for tens of millions of people.The undisturbed forests are themselves a precious resource to be protected, not an unused space to be exploited! Tens of millions of acres of undisturbed forests will become vulnerable if the Roadless Rule is not kept to protect them. Development of these acres will extract from all of us a precious resource that cannot be replaced, all for a profit for individuals who already have enough, or too much money. All the money in the world cannot replace our forest preserves. I beg you not to destroy protections that benefit all of us for the hope that a few may profit. Instead please collaborate with local groups and the states themselves to provide for changing needs. For the benefit of all of us, you, me, and our children's children, do not repeal this essential Roadless Rule. Sincerely, Sarah Dagg sarah.l.dagg1604@gmail.com Sincerely, Sarah Dagg

I am writing in opposition to rescinding The U.S. Department of Agriculture (USDA or Department) 2001 Roadless Area Conservation Rule (2001 Roadless Rule), which established broad prohibitions on road construction, road reconstruction, and timber harvesting within inventoried roadless areas on National Forest System lands. I have been an annual visitor in the Superior National Forest and Chippewa National Forest for some 45 years. I have enjoyed both the wilderness areas of the BWCA and other national forest land adjacent to the BWCA within the Superior National Forest. These lands are unique to the northern plains, and thankfully to the visionaries before us, have been largely preserved from development, mining and timber extraction all to the benefit of the local ecosystem and economy. There are almost no other places that rival the solitude and pristine nature of these lands. Removing the federal protections will make extraction of resources and destruction of natural landscapes more viable. This would cause irreparable damage to an ever more fragile and threatened wilderness sanctuary. Please do not rescind the 2001 Roadless Area Conservation Rule. Sincerely, Joseph Wild Crea

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet and solitude of the roadless area in the Chippewa National Forest in northern Minnesota is why I go there, often going hiking and camping to get away from the city. I also paddle many of the watersheds in Minnesota. I believe public lands should be managed to sustain wildlife habitat, protect watersheds, and maintain places to recreate. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens all three of those purposes, and the agency's own record does not support the action. Minnesota holds 16 inventoried roadless areas totaling 62,081 acres. Those acres include watersheds I paddle, and across the Eastern region, which includes Minnesota, 286 municipal water intakes sit in watersheds containing affected roadless areas. Rescinding the rule puts that water protection at risk without any demonstrated offsetting benefit, and I ask the agency to explain on the record what specific protections will replace the watershed safeguards the rule currently provides. The agency's economic justification does not hold together. The record before the agency 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's own Cost Benefit Analysis 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 ranging from -$92 million to +$199 million. The road system the agency would be expanding already carries a $6.9 billion maintenance backlog. I ask the agency to reconcile those numbers and explain how an action whose own analysis cannot establish a net benefit justifies adding to that backlog. The regulatory flexibility analysis presents a related problem. The agency certified 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 was reached by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. The analysis itself concedes some firms may lose those receipts. The agency should withdraw the certification and assess the impact on the small entities actually operating inside the potentially affected roadless areas, not the national average. Reliance interests are also unaddressed. "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." I have organized my recreation around the protections this rule has provided. When an agency changes course, it must assess the reliance interests its prior policy created. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Finally, the agency's own fire data undermines the safety 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 claimed reduction in wildfire hazard cannot rest on data showing that roaded land burns at more than seven times the rate of roadless land. The agency should quantify the expected increase in human-caused ignitions from new road access and weigh it against whatever wildfire reduction it claims before this rule moves forward. Sincerely, Rachele Krivichi St. Paul, MN

Dear Secretary Rollins and Chief Schultz, As someone who cares deeply for our planet, it’s wild places and wildlife, as well as its human inhabitants, I have been voicing my care and concern over the ever-increasing threat posed to all of us by climate change for over 20 years. I have been reading and following climate research for over a decade, I know the carbon that is held by intact forests is not a footnote. The 2001 Rule protects a meaningful chunk of it. The roadless rule protects wild spaces that we need to help us mitigate and maybe someday turn back the perils of climate change. I value them for recreation and as a less-stressed home for the wildlife that share these spaces. Being in these places is a sanctuary and a return to Every year my front lawn has a patch of Milkweed that keeps expanding. Living in town, it stands out among mowed lawns. I wait to see Monarchs and hope this little bit helps them survive. That’s why roadless areas here mean so much to me. They are spaces that help these creatures have a better chance. Living near roadless areas like Potato Island in the Chippewa National Forest, I value the habitat it provides to the species I care about, like Monarch Butterflies, Canadian Lynx and Bald Eagles. The story recounted and the relationship underlying it are both, in the relevant sense, products of what twenty-five years of roadless protection has made possible; rescission would begin to unwind both. Regarding the Potato Island in the Chippewa National Forest, Minnesota: ESA Section 7 mandates conference with USFWS whenever a federal action may affect a Proposed Threatened species. Monarch (Danaus plexippus, G4, PT) is documented in the Potato Island IRA, Chippewa National Forest — rescission is the federal action, and the consultation obligation is statutory, not discretionary. The Roadless Rule currently functions as the barrier preventing activities that may affect Monarch (Danaus plexippus, PT) in the Potato Island IRA. Roads are not built because the rule prohibits them. Timber is not harvested because road access is unavailable. Rescission removes that barrier and enables the full suite of habitat-altering activities. The DEIS must include the results of conference with USFWS for Monarch (Danaus plexippus, PT) in the Potato Island IRA, including any biological opinion and incidental take statement. Absent this documentation, the record does not demonstrate compliance with ESA Section 7. "Increased road density and access into remote areas can lead to increased hunting, trapping, fishing, poaching, disturbance to wildlife, trampling and other direct human impacts on biodiversity in forest and aquatic ecosystems. Impacts of roads and linear clearings on tropical forests include elevated tree mortality, altered species composition, invasion of disturbance-adapted species, and reduced understory bird abundance extending hundreds of meters from road edges." — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Laurance et al. 2009, 2009 “Protected areas of natural vegetation effectively cool the land surface temperature, particularly the daily maximum temperature in the tropics, and reduce diurnal and seasonal temperature ranges in boreal and temperate regions. Daily maximum land surface temperature of protected tropical forests is 4.71°C ± 0.06°C lower than that of croplands. The warming rate in protected boreal forests is up to 20% lower than in their surroundings. Nonprotected areas with the same type of vegetation as protected areas show reduced warming buffer capacity, highlighting the importance of conservation to stabilize the local climate and safeguard biodiversity. — Science Advances, 2022 (https://doi.org/10.1126/sciadv.abo0119)” “Changes in human footprint drive changes in species extinction risk. One stark forecast is that 25 million km of new roads will be built globally by 2050, threatening many intact areas. It is clear that many intact forests are under severe and rising pressure, and there is an urgent need for greater conservation efforts. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Di Marco et al. 2018, 2018 (https://doi.org/10.1038/s41467-018-07049-5)” The proposed rescission should not be finalized; the Roadless Area Conservation Rule should remain effective. With resolve, CommentID: RLC-20260824-QZAYC4

Go fuck yourselves. Leave 36 CFR part 294, subpart B in tact. The roadless areas of the Superior National Forest and the Chippewa National Forest are some of the last wild forests we have in Minnesota. They should remain largely undisturbed for posterity, and free from state/industry politics and the corruption of Washington D.C. political appointees.