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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking and hiking through places like Pyramid in the Lake Tahoe Basin and the Paiute roadless area in Inyo National Forest to commune with nature, watch birds, and observe wildlife, I have come to understand what these landscapes hold. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own analysis does not support the step it is proposing to take. I am an avid backpacker and day hiker who lives in Northern California. I have travelled all over the United States to hike and backpack. The impact of roads and off road vehicles on wildlife, the land and the experience being in the “wilderness” is obvious and depressing. Bird watching is not incidental to why I go into roadless areas. It is a central reason. The agency's own record, drawing on research the DEIS cites, documents 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. California already holds 381 inventoried roadless areas totaling 4,389,760 acres, and the birds I go to find depend on the quiet and the unbroken canopy those areas provide. Opening that landscape to road-building does not simply alter the scenery. It restructures the acoustic and ecological conditions that determine whether those species stay or go. I ask the agency to explain, with specificity, how the benefits it claims from rescission can be weighed against documented declines in bird abundance and species presence that its own cited science predicts. The wildfire rationale the agency offers for this rescission conflicts directly with what its own record says. 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." The DEIS further reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency must explain why its proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions from new road access weighed against any claimed reduction in wildfire hazard. The regulatory flexibility certification also cannot stand as written. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading expenditure loss across every small firm in the sector nationally rather than examining the guides and outfitters holding permits in the specific affected areas. The agency concedes some firms may lose those receipts. It should withdraw the certification and assess impact on the small entities actually operating in and permitted for the potentially affected roadless areas. The Chugach National Forest in Alaska is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta within it hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration, including western sandpiper in the millions. Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape at a scale that exists nowhere else in the national forest system. The 2001 rule is the structural protection that has kept those conditions intact. A state-petition process substituted for a national rule creates no guarantee that protection continues, and the agency's own record does not model what happens to that ecosystem if the rule falls. Finally, the proposal itself 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. My years of hiking, birding, and backpacking in California's roadless areas, and my expectation that federal policy would continue to protect them, are exactly the kind of reliance interests the agency invited and then declined to assess. The agency must identify and weigh those interests as part of this proceeding, including what this comment represents. Sincerely, Kristen Sorensen Petaluma, CA

I live in Anchorage, Alaska and the Chugach National Forest is a playground for residents in the area. I can’t imagine allowing any commercial or industrial development on these lands. The same holds true for all public lands that would be affected by the rescission of the Roadless Rule. My wife and I are retired and travel in the winter, we make it a point to visit National Parks, National Forests, National Monuments and National Wildlife Refuges. We enjoy the pristine beauty of all of these National Treasures. Rescinding the Roadless Rule would open the door to development of timber, mining and oil industries in these areas and negatively impact recreation, wildlife habitat and the environment. The old growth trees in these areas are vital to the health of the forests, they are able to survive fires and sow the seeds for new growth. I fear that the timber industry would harvest the old growth and weaken the health of the forests. I am opposed to rescinding the Roadless Rule and encourage no change.

I am opposed to repeal of the roadless rule because I frequently recreate in National Forests that will be effected and recreation with the current amount of roads is completely sufficient to fulfill more than a lifetime of recreation in these places. It is worth noting that I often recreate in my overlanding vehicle, which is a 2021 Chevrolet Silverado 2500 with an AT Overland Atlas camping topper that is specifically designed for overloading, which is exploring backcountry roads (primarily in national forests) and camping. I often string together trips of 2-5 days overloading in various national forests. (I will provide my experience doing so at the end of this comment.) Due to the plethora of road options already available in National Forestland, which is enough to satisfy a lifetime of use, the addition or more roads is not a compelling rationale for this proposal. Specifically, these are the reasons I am opposed to repeal of the roadless rule. 1. Impact on nearby National Parks: National Forests play a critical role in the National Park System by often surrounding National Parks and thus serving as a buffer between pristine parkland and wilderness areas and human activity. This is the case for nearly all the major parks in the park system, including the Crown Jewels of the National Parks Service, which will be directly impacted by the recession of the roadless rule—Yellowstone, Grand Teton, Glacier, Mount Ranier, Yosemite, North Cascades, Olympic, Everglades, Grand Canyon, Rocky Mountain, Sequoia and Kings Canyon, Redwood, Crater Lake, Shenandoah, Wrangell St. Elias, and Great Smokey Mountains. It is additionally the case for lesser known, but still important, national parks such as Theodore Roosevelt, Badlands, Guadalupe Mountains, Lassen, Pinnacles, Voyaguers, Mesa Verde, Black Canyon of the Gunnison, New River Gorge, as well as other national park units such as Pictured Rocks National Lakeshore and Sleeping Bear Dunes National Lakeshore. The impact on the Greater Yellowstone Ecosystem looks particularly acute. The GYE, which includes Yellowstone National Park, Grand Teton National Park, and several impacted National Forests — Custer-Gallatin NF, Shoshone NF, Bridger-Teton NF, Caribou-Targhee NF. Like the other National Parks mentioned above, Yellowstone greatly benefits by being completely surrounded by National Forest land. In fact, also like many of these other National Parks, it is impossible to enter Yellowstone without passing through a National Forest. Simply put — increasing roads and industrial motor vehicle traffic in national forestland will adversely impact the ability of people to get into the parks and will have an adverse effect on nearby wildlife and wilderness areas. 2. Impact on last remaining intact ecosystems Personally, when I camp and backpack, I do it in an intact ecosystem. Whether in/around Yellowstone, Tongass NF, Chugach NF, Superior NF / Boundary Waters, or other roadless wilderness areas, these areas are few and far between and provide solitude that is simply unavailable in forestland that permit roads. The personal benefits to me, my family, and my friends are significant. These areas provide time and space and silence for personal reflection and personal growth. Adding additional roads into roadless areas threatens this recreation. It is also worth noting that these areas are some of the last areas WITHOUT ROADS in the world, so the only areas that permit space for reflection away from modern society. These areas need to be preserved as is for this unique and limited experience. The estimated loss of $6.1M annually is a ridiculous underestimate that completely lacks support. The real total is far greater. 3. No definition of the “regulatory burden” that will allegedly be relieved. There is no real definition of what the exact “regulatory burden” that USFS claims is present. If this is just another way of stating that this current government just doesn’t like the rule, then that is not a persuasive reason to repeal it. Moreover, the rationale is full of vague, undefined justifications that do not hold up to scrutiny: - “Constrains responsible officials from exercising the timely, place-based discretion…” - “Evolving national priorities and changed conditions…” - “Removed important management tools for key areas…” - “Unique ecological, economic, and social needs of their communities…” These are vague, boilerplate terminologies for which no concrete examples are given in the rationale. Indeed, there are no examples given of any local forest service officials expressing desire for more “flexibility to address conservation and resource issues” by repealing the roadless rule. Absent any examples, the rationale for this repeal cannot stand. (To be continued - 1 of 2)

Dear Secretary Rollins: As an outdoor enthusiast, and mother who is doing her best to raise outdoor kids in an indoor world, rescinding the 2001 rule is a fundamental change, and NOT for the better. I have gone on a rafting trip down one of these waterways, and the experience cannot be replicated without the protections from the 2001 Rule. The quality of the water, the icy temperatures even in late summer, the untouched wilderness, all contribute to a life altering experience. These experiences cannot be taken for granted. It cannot be assumed that they can be shared by any similar waterway - these areas are protected because they are unique. I visited this area 3 times in the last 5 years. I first went with my husband and son, when my son was 2 years old. The landscape and environment we experienced was breathtaking. It was so impactful that my son asked to go again, not even a year later. 2 years after that, we came again with my daughter, when she was 2. All visits were in winter, by the way. To travel ten+ hours with young kids is no easy task, but it was worth it to visit an area this pristine. Regarding the Resurrection in the Chugach National Forest, Alaska: The watershed of the Resurrection IRA, Chugach National Forest, functions as a natural water filtration and storage system. Its headwater streams maintain baseflow through dry periods and buffer peak flows during storms — hydrological services that road construction disrupts at the most fundamental level. "Solar insolation in riparian canopy openings increased daily maximum and average temperatures, but did not affect daily minima. During the day, maximum temperatures increased 1.5–2.5°C within the opening. However, just 40 m after the stream returns to forest cover, the residual temperature increase was only about 0.5°C. Streams that experienced the greatest temperature increases within the opening tended to drain smaller watersheds and experienced a large difference in canopy cover when moving from the reference section into the opening." — Hydrological Processes (Wiley/NSF PAR), 2020 Road surfaces in the Resurrection IRA, Chugach National Forest, would function as impervious collectors — compacted, unvegetated surfaces that shed rainfall as overland flow rather than allowing infiltration. Cut slopes expose bare mineral soil that erodes with every rain event. Fill slopes, composed of unconsolidated material pushed downhill during construction, slump and deliver sediment to drainages for decades after construction. Rolling back this rule would devastate this area, along with countless others that are no longer protected. The likelihood of new invasive species could have dramatic effects on plants and wildlife in the area. The environmental impacts of building new roads and the traffic it would bring would absolutely harm the salmon population, not only impacting the bears and therefore the entire food chain in that area, but also decimating livelihoods of those in the wild salmon and tourism industry. The risk is immense, to both animals and humans. The gain is little, to a handful of corporations. It doesn't take much thought to realize these areas should remain protected. Kind regards, CommentID: RLC-20261007-IFCR2F

I oppose the proposal to rescind (fully or partially) the Roadless Area Conservation Rule I live in Alaska (and formerly lived in Idaho), and I work as an outdoor educator and a ski patroller. Public lands are crucial to my work and livelihood. Without robust public lands I don't have a job, or career that I have had for close to two decades. I also recreate on public lands, so they are a large part of every facet of my life. In Alaska several areas will be impacted by rescinding the Roadless Rule. I live close to and work in the Chugach National Forest. I spend time both personally and professionally in the Chugach backpacking, packrafting, mountaineering, and sea kayaking. And I know many other people hunt, fish, and do other recreation in this area. Additionally rescinding the roadless rule will have a negative impact on wildlife and the local ecosystem. As humans we do not live in a silo, and anything we do that negatively impacts the natural world negatively impacts us as well. Protecting large swaths of public lands is crucial for our survival. For the above reasons full or partially rescinding the Roadless Rule under Alternatives 2 and 3 in the EIS draft would be a huge mistake. I oppose the proposal to rescind or alter the Roadless Rule and I support Alternative 1, the No Action alternative. Thank you

As an Alaskan resident, I advocate to maintain Chugach National Forest protection and urge you to uphold the Roadless Rule. Maintaining this rule is critical for several, basic reasons: Drinking water: 60 million Americans rely on national forests for drinking water; intact forests filter water naturally Wildlife habitat: habitat for salmon, trout, elk, and other species that depend on undammed, unlogged streams and connected landscapes Wildfire risk: wildfires are 4x more likely to start near roads; roughly 90% of wildfires start within half a mile of a road — directly rebuts the administration's stated rationale Old growth & carbon storage: contains vast swaths of the country's remaining old-growth forest and significant carbon storage Fiscal responsibility: the existing road network already carries an $8.5+ billion maintenance backlog; building more roads adds to it Thank you for your consideration.

As an Alaskan resident, I support Chugach National Forest protections and urge you to uphold the Roadless Rule, put into effect in 2001 and hailed as one of America's most successful conservation measures. The Roadless Area Conservation Rule protects drinking water sources, wildlife habitat, and world-class recreation opportunities across 58.5 million acres of national forests. I strongly support the roadless rule and oppose the proposed Forest Service action to rescind these protections. Protecting these sensitive environments for future generations is something I care deeply about. Thank you for reading my comment.

I am totally opposed to rescinding the 2001 Roadless Rule. It should not be removed. It is a terrible idea. I am a stakeholder in the Tongass and Chugach National Forest management processes representing public interest. Previous comments regarding this rule have been 90% wanting to retain it nationwide. I have seen no proof that the roadless rule has prevented needed infrastructure in the national forest for community needs. Where is the data on that statement that nothing is allowed in the roadless areas. These areas are the prime habitat for fish and wildlife and human beings. These are special areas to conserve our valuable natural resources of hunting and fishing economies and tourism. They are necessary. And there has been no government to government consultation between the tribes and the Forest Service. Why not? A few subsistence hearing are not a substitute. Rescinding this rule will have a detrimental impact on subsistence resources.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live, work, play, and have a subsistence lifestyle in Alaska. The Tongass National Forest is where a lot of the species that I harvest live and thrive in due to the old growth forests and the pristine forests not interrupted or segmented by roads. The species here that depend on the health of old growth forest is not just mammals, but the salmon runs that return to these areas. Additionally, the Chugach National Forest is where I also recreate and depend on intact, healthy forest not segmented by roads. Already, the forest around Chugach National Forest experience more pressure from more people and infrastructure. Adding roads would increase the pressure and not support a sustainable, subsistence lifestyle and culture. I am oppose of the Roadless Rule act and support Alternative 1, the No Action alternative.

I would like to express my disagreement and disappointment with the U.S. Forest Service proposed rule to rescind in its entirety the National 2001 Roadless Area Conservation Rule. My family and I are avid nature lovers. We would rather be outside than inside. We prefer to experience the wonders of our nation's outdoors in their natural surroundings. We walk, hike, backpack and camp using Leave No Trace ethics. We admire the changes in nature during the 4 seasons: the new life of Spring, the active growth of Summer, the preparations of Fall, the resting time of Winter. I remember seeing more than 2 dozen varieties of wildflowers blooming during the last week of March on a Spring Break camping trip in Hoosier National Forest, IN. During a Summer backpacking trip in Superior National Forest, MN, I watched the emergence of a dragonfly crawling out from its final stage and making its way to a rock, where it rested and dried itself in the sunshine, gaining strength to fly away. Having grown up in the Chicago Metro area, my first trip to Shawnee National Forest in downstate IL was a wonderful awakening to the fact that Illinois is not made up of just farmland and cities...Downstate IL is Forest! My family has traveled throughout all 50 United States. From White Mountain National Forest, NH, across to Sequoia National Forest, CA, up to Chugach National Forest, AK, over to the Forest Reserves of Hawaii, and many forests in between, our National Forests provide us with un-surpassing beauty, solitude, diversity, and peace. The busy National Parks are crowded with tourists visiting the wonders of our country. Many National Forests border these Parks, providing undisturbed habitat and access to the land. Our children, grandchildren, and future generations deserve the opportunity to seek out the amazing wonders of our unique natural spaces in solitude and peace. My husband and I recently spent time camping and hiking in our nation's first National Forest, Gila NF, NM. The strip mining area outside Silver City, NM, is an ugly example of what happens when the forest and land are destroyed. Opening up NF land to the possibility of new roads being built and private business taking over is not in our nation's best interest. We have an unknown number of species that have not yet been discovered and cataloged. Their survival depends on unique characteristics and habitats found only in the small amount of pristine, untouched, old growth forests we have left. When their habitats are destroyed, species we have never observed will be gone from Earth forever. We can't get them back. Please do not rescind the National 2001 Roadless Area Conservation Rule. Thank you

I am a concerned citizen who regularly recreates, hunts, fishes, and forages on the Chugach National Forest and I adamantly oppose the proposed rescission of the 2001 Roadless Rule. I implore Chief Tom Schultz to maintain the status quo and allow the Roadless Rule to continue as written. National Forest Service land is public land which means it should be managed in such a way that it remains a public investment for generations. The roadless rule helps to preserve undeveloped forests and other sensitive ecosystems within National Forest Boundaries. A forest does not have to be logged or mined in order to have inherent value- it has value as habitat for wildlife species deemed desirable for eco-tourism as well as hunting and it has value as land left largely untouched by human hands which is by and far one of the rarest resources left on earth. As for wildfire management- the forests were over managed for many years in the 20th century which led to a catastrophic accumulation of fuels and thus resulted in extremely severe wildfires. This prompted current wildfire mitigation strategies including prescribed burns because there are so many forest types that actually rely on fire regimes to remain healthy. Making an argument for wildfire mitigation and suppression as a reason to rescind the roadless rule is not sensible. Intact forest away from human infrastructure will have a fire regime, not everything on this earth needs to be managed by humans- in fact, as stated previously, there are some ecosystems that are significantly worse off due to over management. Let's focus on fire mitigation in key areas around pre-existing infrastructure. Additionally, opening up more roadways will allow higher levels of access which, based on evidence, will lead to even more wildfires since the predominant cause of wildfires is human (85% according to the National Park Service). Furthermore, the US Forest Service is already critically understaffed and behind on all types of maintenance projects, especially road maintenance. If the USFS is unable to maintain the roads it currently has, it will be impossible to keep up with even more. I think it would be a much more logical use of funding to maintain pre-existing infrastructure and resources. I know that this current administration has a strong focus on timber and mineral extraction, however those needs must be strongly balanced against every other user group. When an area is used for timber extraction or mineral extraction, that effectively cuts off every other user group- no one is able to or wants to go and hunt around an active mine or hike through an area that is being actively logged. Rescinding the Roadless Rule may further the narrow desires of the current administration to address the interests of a small number of user groups but, the general public, the largest user groups by volume have issued a resounding rejection. Roughly 95% of the 1.6 million comments on the original 2001 rule were in support of creating it. Roughly 99% of the over 600,000 comments on the initial notice of proposed recession were in opposition. However, the US Forest Service proceeded anyways, ignoring the voice of the public. The job of the federal government is to represent the public, all of the public, not just the companies that have the most money to throw at policies or the whim of a capricious president. I implore you to listen to us, the 99%, and steward our public lands in a way that will preserve them- intact- for generations to come.

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

I have a Bachelor of Science in Forest Resources from the University of Georgia, I am a former ATCS with the Federal Aviation Administration, and I have taught mathematics in public high schools from the coast of South Carolina to America’s last frontier in Alaska, and then back to the Appalachian Mountains. I have lived adjacent to the Francis Marion National Forest, the Chugach National Forest, and the Nantahala National Forest. I have been hiking, backpacking, and camping in these forests for 54 years. I am 100% against overturning or modifying the Roadless Rule, a much needed protection for our public lands. I feel this entire process is just another first step toward eventually selling off public lands or services to the highest bidder for development or corporate profit, and it will devastate the majesty of our forests. There is absolutely no practical reason to overturn the Roadless Rule in our beautiful national forest, and those that are pushing this change are either blinded by dollar signs and greed, or just extremely short-sighted and apathetic. Please serve the people of our great nation and act in the public’s best interest.

I am a concerned American citizen who has visits Alaska's Chugach National Forest often and I adamantly oppose the proposed rescission of the 2001 Roadless Rule. I implore Chief Tom Schultz to maintain the status quo and allow the Roadless Rule to continue as written. National Forest Service land is public land which means it should be managed in such a way that it remains a public investment for generations. The roadless rule helps to preserve undeveloped forests and other sensitive ecosystems within National Forest Boundaries. A forest does not have to be mined or logged in order to have value- it has value as habitat for wildlife species deemed desirable for eco-tourism as well as hunting. It has value as land left largely untouched by humans which is one of the rarest resources left on earth. In regards to wildfire management, the forests were over managed for many years in the 20th century which led to a catastrophic accumulation of fuels and thus resulted in extremely severe wildfires. This prompted current wildfire mitigation strategies including prescribed burns because there are so many forest types that actually rely on fire regimes to remain healthy. Making an argument for wildfire mitigation and suppression as a reason to rescind the roadless rule is not sensible. Intact forest away from human infrastructure will have a fire regim. Not everything on this earth needs to be managed by humans. As stated previously, there are some ecosystems that are ignificantly worse off due to over management. Let's focus on fire mitigation in key areas around pre-existing infrastructure. Additionally, opening up more roadways will allow higher levels of access which, based on evidence, will lead to even more wildfires since the predominant cause of wildfires is human (85% according to the National Park Service). Furthermore, the US Forest Service is already critically understaffed and behind on all types of maintenance projects, especially road maintenance. If the USFS is unable to maintain the roads it currently has, it will be impossible to keep up with even more. I feel it would be a much better and logical use of funding to maintain pre-existing infrastructure and resources. I understand that this current administration has a strong focus on timber and mineral extraction, however those needs must be strongly balanced against every other user group. When an area is used for timber extraction or mineral extraction, that effectively cuts off every other user group- no one is able to or wants to go and hunt around an active mine or hike through an area that is being actively logged. Rescinding the Roadless Rule may further the narrow desires of the current administration to address the interests of a small number of user groups but, the general public, the largest user groups by volume have issued a resounding rejection. Roughly 95% of the 1.6 million comments on the original 2001 rule were in support of creating it. Roughly 99% of the over 600,000 comments on the initial notice of proposed recession were in opposition. The US Forest Service proceeded anyway, ignoring the voice of the public. The job of the federal government is to represent all of the public, not just the companies that have the most money to throw at policies or the whim of a capricious president. I implore you to listen to us, the 99%, and steward our public lands in a way that will preserve them- intact- for generations to come.

My name is Hillary Hunter. I am vehemently against the repeal of The Roadless Rule. I was born and raised in Petersburg Alaska and now live in Juneau. I have spent the majority of my life living in the Tongass National Forest. I have also hiked the Pacific Crest Trail California to Washington, going through many national forests and wilderness areas. I went to college in Bozeman next to the Gallatin National Forest. I lived up on the Kenai Peninsula for a summer in the Chugach National Forest. This is to say that my experience being an American and my vision of our country is strongly shaped by our national forest system and I have come to this opinion through hands on lived experience. Research conducted by the U.S. Forest Service has shown that nearly two thirds of fires that are human caused begin along roads. Building more roads into deeper wilderness area does the opposite of helping to prevent and fight wildfires. It creates greater swaths of high risk areas. It is also a bad faith argument to say that The Tongass needs roads to access areas of unhealthy forest that need to be logged in order to prevent wildfires. The Tongass is a rainforest and is not at risk of wildfires. It makes me, a local, wonder if the people proposing these decisions for my home are either uneducated on the areas that they manage or attempted to manipulate and lie to people. Creating roads to log The Tongass does not make sense either. It is so logistically difficult to remove logs from the forest, ship them to processing plants and distributors from this archipelago that the cost ends up being higher than the profit. Also healthy forest is essential to our economy. We need our salmon runs to not be disturbed. Damaging waterways where salmon return to spawn is bad for commercial fishing, subsistence fishing, and sport fishing which is an important part of the tourism economy. We have over 1.5 million cruise ship tourists a year with a season that only covers our short summer. This is a lot of people for such a short amount of time. They come here to see the wildlife and vast expanses of wilderness. They do not come here to see roads crisscrossing mountains and bald clear cuts. Retaining wilderness areas with no road access is required for Alaska to retain our majestic landscapes and ecosystems that both locals and visitors love. I have worked at a popular Forest Service sightseeing location on a roadsystem and one that is only accessible by boat, plane, or kayak. They both serve different purposes such as accessibility to the public and education. That is wonderful. It also means that I have seen first-hand how it impacts the health of the ecosystem. The place with no roads has next to no litter and the animals aren't harassed by thousands of people a day. It gives migrating birds to salmon to bears a place to live as they normally would in a world not shaped by humans. Places such as this have inherent value and allow us to avoid the pitfalls of sliding baseline effect. If the original is completely erased how do we know what we have lost. Places that have been heavily logged, such as Prince of Wales, have issues with deer population. The vegetation grows back too dense for deer to be able to have their fawns in the areas they would normally pick. They can't move through clear cuts with downed trees or the thick brush as it grows back. This can result in them having their fawns in locations that leave them exposed to predators and cars. Subsistence is important to people who live near national forests and in Alaska especially. There are many reasons that the Roadless Rule should not be repealed that are environmentally, culturally, and economically sound. Leave our wild places for the next generation and the ones after.

I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in Kenai, Alaska and spend time recreating in nearby Roadless Areas like the Chugach National Forest. I also hope to visit other Roadless Areas across Alaska to hike, camp, fish, forage, and enjoy nature. Under the proposal, Alternative 2 and 3 would eliminate protections for millions of acres of wild, public lands in Alaska. The economics of these attacks on the Roadless Rule do not add up. Building logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely used. According to the DEIS, the Forest Service could build new roads across 18.2 million acres in the short term. This would significantly inflate the deferred maintenance backlog. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. Beyond the economics, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and serve as critical carbon sinks in the fight against a changing climate. The DEIS states that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In Alaska, this includes listed species such as the Chinook salmon, among others that are understudied and therefore not fully understood. How would the agency ensure these populations and their habitats aren’t further degraded without protection of the Roadless Rule? The DEIS also states that “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” Alaska has exceptional water quality, largely due to the protections of the pristine wilderness areas. Roadless Areas would lose protections under both Alternatives 2 and 3. How would the agency ensure that these watersheds remain intact and that water sources are not compromised from increased risk of erosion and sedimentation? Once roads and clearcuts fragment these landscapes, the damage is permanent. In the DEIS, the agency admits that “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” I am concerned that removing Roadless Rule protections would increase fire risk in our nation’s backcountry forests. The DEIS also acknowledges that increased road construction and timber harvest are likely to “introduce and spread invasive plant species due to ground disturbance.” Invasive plants tend to be more flammable, leading to higher wildfire risk, and often outcompete native plant species, further endangering our pristine public lands. The USDA’s decision to pursue this rollback through an abridged and inadequate public comment process is appaling. The original Roadless Rule was created after the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. During the comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with majority opposing the proposed rescission of the rule. During the legally required Tribal consultation process, the agency found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission.” Its analysis concedes that timber harvest and road construction in these areas “could have long-term negative effects on Tribal rights and interests.” Now, the agency is attempting to dismantle these protections through a rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities. This is undemocratic for decisions of such sweeping consequence. The public comment period should be extended to no shorter than a total of 120 days. The American public has already spoken: keep the Roadless Rule in its full form in place. The Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. For the reasons listed above, I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting is an affordable and sustainable way to feed my family. Without it, we have to rely on food shipped from other parts of the world. That dependence is exactly what living in Alaska's wild country protects us from, and this proposed rescission threatens it. The Chugach National Forest holds 40 inventoried roadless areas totaling 5,439,110 acres. Ninety-nine percent of it has never had a road built through it. It is the most roadless national forest in the entire system. That is the country my family depends on. Brown bear, moose, and mountain goat move through it. The Copper River Delta hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration. Salmon run through it. Fishing is already so controlled in Alaska due to the popularity of salmon nationwide, and the watershed integrity that roadless protection provides is part of what keeps those fisheries alive at all. The agency's own record states that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, and that the affected area includes Essential Fish Habitat and critical habitats managed by NMFS. (source: DEIS; Carter 2005). Roads are the mechanism that delivers that damage. I want the agency to explain in plain terms how rescinding the rule protects salmon habitat rather than exposing it. I enjoy exploring the beautiful, wild, uncharted open country of Alaska by backpacking and snowmobiling. Open country stays open when roads stay out. The agency's own analysis 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 wildfire and fuels management grounds. Those two positions cannot both be true at once. I ask that the agency reconcile this rescission with the ignition data in its own draft environmental impact statement, specifically the findings reported in DEIS Table 21, which show far higher fire density on roaded land than inside roadless areas. The agency's own record also states: "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." No population-level effect on big game is projected anywhere in the document. Hunting is how I feed my family. If big game populations and hunter access decline because of increased road pressure, that is a concrete harm to real people, and the agency has not projected it. I ask that the agency project the effects on big game populations and hunter opportunity before this rule is finalized. The agency's own record further states: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That number appears in the document. No projection across the 40.1 million acres of potentially affected environment follows it. A range that wide applied to an area that large demands analysis, not citation and silence. The agency must apply that fragmentation range to the full affected environment and show the projected outcome. In a world where screens and artificial intelligence are becoming the norm for our children, they even more need this undisturbed land to experience real nature. My family loves Alaska for its wild country. Losing that would cause us to lose interest in living there. That is a reliance interest. The agency created it with the 2001 rule, built through more than 600 public meetings and 1.6 million comments. It now proposes rescission without a single public meeting and without assessing what it is undoing. 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. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any further action. Sincerely, Kathryn Reynolds Salcha, AK

This comment is a joint letter from Alaska businesses and environmental organizations addressing concerns for the Chugach National Forest specifically. There are 11 signers:Alaska Alpine Adventures Alaska Environment Alaska Guide Collective LLC Alaska Wilderness League Center for Biological Diversity Chugach Adventures Defenders of Wildlife Earth Justice Girdwood Backcountry Guides Prince William Sound Stewardship Foundation Susitna River Coalition See attached file for comment.

My name is Peter Casey and I live on the outskirts of the Chugach National Forest in Alaska. I oppose the changes to the Roadless Rule and would like to see the regulation remain unchanged. It makes no sense to weaken the roadless rule when the Forest Service doesn't have enough money or personal to maintain the roads that we currently have in our National Forests. Opening up our forests for more road construction will lead to further neglect of existing roads and eventually these new roads will also fall into disrepair. Building more roads in remote forest areas also increase the risk of more wildfires. Wildfires are caused by humans and the most common place for wildfires to start in National Forests is along roads. I want to see our Forests protected and for them to remain unburned. New roads would also interrupt the wilderness areas of the National Forest system. These areas are essential for wildlife, they provide habitat and solitude for large animals, help prevent the spread of invasive species, and give refuge for endangered species. They are also important recreational areas, often wilderness areas support the tourism economy of nearby towns like Ely, Minnesota and Portage, AK. Please keep the Roadless Rule intact to protect our National Forests for many generations to come.

I am writing to oppose the recission of the Roadless Rule, Docket (FS-2025-0001). Every winter I go deer hunting and fishing in Sitka. The food I harvest is directly supported by the healthy old growth forest ecosystem, and would be permanently harmed by mining, timber harvest, and erosion from road construction. This is true for wildlife throughout the Tongass National Forest. So few areas in the world are dedicated to conservation, and the Tongass is the greatest forest our country has left. We must protect it. Additionally, I'm very concerned about the impact this rule recission could have in the Chugach National Forest near Anchorage. I enjoy hiking to areas of solitude just minutes from my office, and do not want the noise, dust, or damage to habitat that roads would create.