Read the comments.

Enclosed are comments presented on behalf of the Cleveland National Forest Foundation.

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from soil erosion, landslide risk, and sediment pollution - negative impacts that will increase if the Roadless Rule is repealed, according to the Draft Environmental Impact Statement (DEIS) (p 101).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 strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I am a resident of California and my immediate family has always enjoyed camping and visiting national forests and parks. We have loved visiting Yosemite, Sequoia, Joshua Tree, Olympic National Forest, Silver Falls State Park, Glacier, and the Cleveland National Forest land just to name a few. My extended family now spans 5 generations. I want our grandchildren, great grandchildren, nieces, nephews, grand nieces and nephews to be able to enjoy protected national lands as we have done. Considering all of our family members we have campers, hikers, backpackers, fishermen, kayakers, hunters, photographers, birdwatchers, and those who just want to unplug and unwind in nature. Conservation of our beautiful lands is crucial. The Roadless Rule provides ecological protection, recreation, and sustainable forest management. It protects clean water sources, wildlife habitat, endangered or sensitive species, and mitigates fire danger. Humans are the source of nearly 90% of wildfire ignitions. Ignition density is nearly 4 times higher within 50 meters of roads. More roads in forests means a higher danger for fires. Most of us in California have much personal experience with wildfires and are very concerned with preventing them. These wild lands are the treasures and jewels of America. We need to be stewards of their protection, not agents of their sale and development. Opening new roads will lead to logging, mining and other commercial endeavors detrimental to our precious forest land. As Joni Mitchell cautioned some 50 years ago, paving paradise and putting up parking lots means our beautiful resources will be gone forever. I ask that the Forest Service listen to the overwhelming public consensus and preserve the 2001 Roadless Area Conservation Rule as it stands. Sincerely, Cathy Leonard Spring Valley Ca

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas near where I live are an escape from the concrete city around us. For many people in this part of Southern California, including those who visit the Ladd roadless area in Cleveland National Forest, these 5,300 acres represent the only outdoor recreation space they have the ability to visit. I oppose rescission of the 2001 Roadless Area Conservation Rule because the agency's own record does not support it, and because the people who depend on these lands deserve better than an analysis built to reach a predetermined conclusion. Public lands need to be managed for public use, not for privatizing and stripping of all natural resources. That approach enriches a few while destroying open spaces for all. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and the question before the agency is whether all of that, including the places closest to densely populated communities with no other realistic access to wildland, should be opened to the roads and extraction that the 2001 rule was written to prevent. Nothing in the record answers that question honestly. Our drinking water is already at risk, and rescission would further strain the resources and agencies involved in delivering drinking water to Southern California residents. The Pacific Southwest region, which includes California, has 1,034 municipal water intakes sitting in watersheds that contain 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. Losing the rule's protection over these watersheds is not an abstraction for communities here. I ask the agency to explain on the record how that sediment loading is consistent with maintaining water supply for the populations those 1,034 intakes serve. The regulatory flexibility analysis does not survive scrutiny. 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 expenditure loss across every small firm in the sector nationally rather than assessing the operators actually holding permits in the affected areas. The agency must withdraw that certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas, not on a national average that obscures the real harm. The agency also invited reliance interests and then ignored them. 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. Communities, recreationists, and small businesses have organized their expectations around the protections the 2001 rule created for more than two decades. This comment is exactly the kind of reliance interest the agency asked to hear about. The agency should identify and weigh those interests, including this one, before any final action is taken. The fire data the agency collected cuts against its own proposal. 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 concedes that road access could increase the number and frequency of wildfires. For communities already living with wildfire risk in Southern California, that is not a minor footnote. The agency must quantify the expected increase in human-caused ignitions from new road access and set that figure honestly against whatever wildfire hazard reduction it claims to offer. Finally, the range of alternatives the agency considered was never real. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose and need statement written entirely around deregulation forecloses the comparison NEPA was designed to require. The agency should restate the purpose and need in terms of actual forest conditions and analyse at least one fully protective alternative before this proceeding goes any further. Sincerely, SR 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

I am writing about the Pine Creek Roadless Area in Cleveland National Forest, California. I urge the Forest Service to keep the 2001 Roadless Area Conservation Rule in place. In a region as developed as Southern California, the roadless areas that remain are among the last places where wildlife, quiet, and intact habitat still exist, and they cannot be replaced once roads are built. I am an avid mountain biker and hiker who rides and hikes public lands in Southern California throughout the year, especially the Cuyamaca and Mount Laguna area. I go to the mountains east of San Diego for quiet, for distance from development, and for the chance to see wildlife living undisturbed. In that area I see deer and a wide variety of birds on nearly every trip. In a county of more than three million people, those encounters are only possible because large areas of habitat remain connected and quiet. Roads bring traffic, noise, and permanent human access into habitat that wildlife now uses undisturbed. The deer and birds I see regularly would be pushed out. Mountain lions are at even greater risk. Southern California's lion populations are already hemmed in by freeways and development, and every new road further fragments the territory they need to hunt, breed, and keep their populations genetically healthy. Roads also mean more wildfire. The large majority of these devastating fires are started by people, and every new road gives more people access to country that is hard to reach and hard to defend. San Diego County's mountains have already burned catastrophically, and adding ignition sources there makes no sense. In addition, land that belongs to everyone would be opened to extraction for private financial gain, while the public absorbs the loss. Once these areas are roaded, logged, or burned, they do not recover in my lifetime. I ask the Forest Service to fully weigh the long-term costs of rescission: increased human-caused wildfire risk, the loss of wildlife habitat and connectivity for species like mountain lions, and the maintenance backlog the agency already cannot fund on its existing road network. The rule should be retained as written.

Hello, my name is Joshua Pierce and I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. Public lands are especially important to me because I have been an active USFS Volunteer on the Cleveland National Forest, Trabuco Ranger District since 2015. Our public lands deserved to be conserved and not opened up to more roads. Again, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule.

Dear Ms. Rollins: As someone who's most treasured and life changing moments have taken place in roadless public land, I'd say this rule has done more for what I value about those places than any other single policy. I want to live and raise my child in a world where there are diverse habitats and life forms where ever we look. I don't want to live in a world that is quiet, devoid of the sounds of bugs or birds. I want to preserve these spaces that can support dwindling wildlife and keep them aloft. I explore the Cleveland National Forest area, and I know it's home to many threatened and endangered species like the California Gnatcatcher or the dwindling arroyo toad. Listening to the sounds of birds on a walk with my daughter we captured a bird call on our Merlin app and saw that it was a California Gnat catcher, a rare and endangered bird. We were ecstatic and felt so bless to have found such an illusive creature. These birds, plants, and ecosystems are barely hanging on with the limited space that we've given them to thrive. The roadless rule allows us to hold on to these wild places, visit them, learn from them, and support not just endangered species, but entire ecosystems that are connected and depend on each other. Regarding the Eagle Peak in the Cleveland National Forest, California: Federal land protections slow habitat loss for imperiled species. Imperiled species lost the least habitat (3.6 percent) on federal lands, compared to more than twice that rate (8.1 percent) on private lands without conservation easements. The Endangered Species Act's protective effect is strongest on federal lands (Eichenwald et al. 2020). — Adam J. Eichenwald, Michael J. Evans, Jacob W. Malcom, 2020 · Frontiers in Ecology and the Environment (https://doi.org/10.1002/fee.2177) My objection is on the record. My request is that the Department take it seriously and preserve the Roadless Rule. Sincerely,

Dear Mr. Schultz, As an outdoor enthusiast, I respectfully submit that the proposed rescission of the 2001 Roadless Area Conservation Rule has not been accompanied by a NEPA analysis commensurate with the scope of the action — specifically, that the environmental consequences of opening 58 million acres to road-building authorization have not been adequately evaluated in the record. As someone who has grown up camping and hiking in Coldwater, it is especially important to me that it remain roadless. Regarding the Coldwater in the Cleveland National Forest, California: Roads, disturbance, and altered ecosystems create invasion pathways that let non-native plants, pathogens, and animals displace native biota. Roads carry invasion effects into forest interiors. Skid trails and forest roads extend road edge effects on plant biodiversity up to 60 meters into adjacent forest stands, serving as conduits for non-forest species and removing interior forest species. The effect is amplified by the lime, clay, and gravel used in road construction (Avon et al. 2013; Dai et al. 2025). — Avon et al., 2013 (https://doi.org/10.1016/j.biocon.2012.10.008); Dai et al., 2025 (https://doi.org/10.1111/ddi.70002); Zhao, 2025 (https://doi.org/10.1111/ddi.70002) Rescinding the Roadless Rule would open the Coldwater, Cleveland 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. Roadless areas are home to some of the most precious, and fragile ecosystems that would certainly be disturbed or destroyed by the presence of roads. Keep roadless areas roadless. Hopefully, CommentID: RLC-20261006-JXKXPI

The reason why over 1 million Americans, including myself, oppose this move to rescind the Roadless Rule is simple, it is a direct threat to our health. “Undeveloped” land does not mean unproductive. These protected lands ensure we have legacy and old growth forests that clean our water and air, and provide habitat for millions of species. These ecosystems are directly tied to our wellbeing. A study conducted by the Forest Service itself and published on August 19, 2026 showed that repealing the roadless rule would increase wildfire risk and increase harm to our communities directly tied to the roads themselves. As a Californian constituent, I am aware of the cost of wildfires. NBC Los Angeles reported the City of LA spent 31.74 million dollars on the Palisades fire of 2025. That was for the fire itself. The reported cost does not include the cost communities spent to rebuild or the emotional cost of losing everything. It does not include the number of lives lost or the amount of land destroyed. Repealing the Roadless Rule opens various vast spaces across the US to loss. Loss of life both human and animal, loss of clean air, and especially loss of clean water. The U.S. Forest Service itself estimates that Roadless Areas clean and provide water to approximately 25 million Americans. Fresh water is our most precious resource. We would be remiss to continue to allow and pass policies that risk our drinking water. Trees are important contributors to our climate and ecosystems. We are dependent on them for our air, water, and land stability. At this stage of climate change, it is important that was protect our trees as they are an important buffer to keeping our climate livable. The Roadless Rule protects both of these assets as well as the living beings who depend upon them. The magnanimity of our forest should be protected for generations to come. Once they are gone, they cannot simply be replaced. Trees do not grow quickly, a new sapling does not have the same productivity as a thousand year old tree. In our fast paced, single use, throw away culture, it is increasingly important to stand for places worth protecting and increasingly important to recognize the value in leaving protected land as it is. For these reasons as well as a personal love for all the forests I’ve been privileged enough to visit: Yosemite, Zion, Big Sur, San Bernardino, Cleveland National Forest, I strongly oppose the intent to repeal the Roadless Rule.

The roadless areas of Cleveland National Forest and Inyo National Forest are where I go to get away from roads and buildings. It is my church. I hike, I camp, I climb there, and I want my kids to have this. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens everything those places are. The agency claims in its Rationale for the Proposed Rule that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." That assertion is never reconciled with what the agency's own document also finds. The same document acknowledges that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it notes that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency cannot lean on a forest health rationale while its own findings undercut that rationale. I ask the agency to reconcile these positions squarely, explaining how rescission improves forest health when its document's own data suggests roadless designation does not drive the problem it describes. On recreation, the agency offers this figure in its Economic Benefits from Recreation in Roadless Area Forests section: "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That framing is inadequate. Roads built under a rescinded rule do not disappear after a year. They alter settings permanently. The same section acknowledges that the magnitude of losses is unknown, and it sets that single-year estimate against roadless recreation benefits of upwards of $1.5 billion. I climb and camp in places like the Inyo because the character of the land holds. Once roads go in, that character does not come back. The agency should estimate how cumulative losses to recreation compound over 20 years as roads and settings change, and it should compare that figure honestly against projected timber revenue before finalizing this rule. My kids deserve to know these forests the way I do. This proposed rescission forecloses that without the analysis it requires.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Public lands should be accessible and sustainably maintained for everyone to enjoy, for current and future generations. I am a water resource engineer, and what is proposed here is not a close call: human activities undeniably impact water quality, and we cannot afford to further contaminate such a precious resource. Rescinding the 2001 Roadless Area Conservation Rule for the Trabuco roadless area in Cleveland National Forest, and for the 381 inventoried roadless areas totaling 4,389,760 acres across California, puts that resource directly at risk. Across the Pacific Southwest region alone, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own data shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. From a water resource engineering standpoint, the hydrology here is not ambiguous. Sediment loading of that magnitude, introduced into watersheds that are currently functioning, degrades drinking water quality, increases treatment costs, and creates impairment that is far easier to cause than to reverse. I ask that the agency respond on the record to the question of how it weighs the sediment productivity of new road construction against the drinking water function these watersheds currently provide to the communities they serve. On wildfire, 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 is justified in part on fuels management grounds, yet the agency's own findings indicate that road construction increases ignition risk rather than reducing it. 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 DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission does not hold up on the agency's own numbers. 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." Against that marginal production, the agency's 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 that spans from a loss to a gain. The agency should reconcile the proposal with that analysis and explain how an action whose own accounting cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. That backlog is its own problem. The agency's record states: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." The DEIS indicates that road mileage, deferred maintenance, and management costs are likely to increase under the proposal. Before this rule is finalized, the agency must name the funding source for new road construction and maintenance and state the projected change in that backlog. The Cost Benefit Analysis itself belongs on the docket, not in an agency file folder. The record contains this: "the net present value discounted at 3 percent over 15 years is estimated to be -$92 to $199 million (-$70 to $152 million discounted at 7 percent) and uses maximum potential costs and benefits that do not account for uncertainty." The cost column in that analysis omits road construction estimated at $80,000 to $100,000 per mile, maintenance, and fuel treatment costs that the same document quantifies elsewhere. The upper bound assumes maximum potential harvest the analysis itself calls uncertain. The rule's claim that impacts could exceed $100 million appears with no arithmetic to support it. The agency must place the Cost Benefit Analysis on the docket, restate the net present value with its own quantified road and fuels costs included in the cost column, and show the arithmetic behind that claim. Sustainable management means leaving these areas in a condition that future generations can still use. Rescinding this rule, in the face of the agency's own data on sediment, fire ignition, fiscal shortfalls, and economic uncertainty, moves in the opposite direction.

I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. Since 2001, the Roadless Rule has contributed to America’s greatness in a variety of ways. From supplying over 120 million people with clean water to protecting lands from wildfires as observed and researched by governmental groups and peer-reviewed studies. In addition, these untouched lands provide countless memories for Americans and non-Americans alike. The Roadless Rule has shown to be a tried-and-true legislative action that not only preserves nature but also provide common ground for all people to gather and protect through various efforts for everyone to enjoy. With that said, I strongly oppose the rescission of the Roadless Rule Millions of people who live in the United States rely on public water systems and most of that water comes from forested lands. The Roadless Rule has been a monumental act which provide millions of Americans with daily fresh drinking water while protecting many habitats and allowing for native plants and species to thrive. Finally, the Roadless Rule has consistently shown that this is a great law for America since the water quality tends to be better and higher when protected within the Roadless Rule areas. As recent as 2020 from the Forest Service, they stated that “a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System.” 2 Since this has come from the Forest Service itself, the reasoning to repeal the Roadless Rule per Secretary Brooke Rollins is incorrect. Further, in a 2025 public comment where 4 former Forest Service Chiefs signed off on a letter that stated, “We remain convinced that repealing the 2001 Rule will not be in the long-term interest of the American people, Forest Service employees, and the communities they serve” 3 These former leaders have overseen and managed the National Forests with extensive knowledge and experience. To dismiss their words and still move forward to remove the Roadless Rules means dismissing the evidence, observations, and experience of Mike Dombeck, Dale Bosworth, Tom Tidwell, and Vicik Christiansen; these 4 stewards who oversaw much of America and know its lands better than most. I highly recommend re-reading their letter and reconsider the removal of the Roadless Rule. Lastly, the Roadless Rule has offered countless adventures and trials throughout my life. Living near the Cleveland National Forest has given me the opportunity to appreciate Southern California in many ways. Being in that forest and hiking through the various areas discovering various creeks and seeing what Southern California really looks like with the diverse plants and animals is a stark contrast to being in the city and seeing absolutely little to no diversity or animals. The ability to be at a place where no one is around is a peace that few are able to enjoy and experience. Of course, going through Sequoia National Forest where I would walk amongst giants is a sight to behold. Once you’re off the road and hike a couple kilometers away, you forget that this is also part of California. This Roadless Rule offers a glimpse into the history of each state and what they used to look like before and gives an opportunity for future generations to also appreciate and conserve these lands. I’ve been to several National Forests and I always make it a point to hike on or through areas where vehicles cannot go in order to experience nature in its untouched form. Cleveland, Sequoia, Lolo, Snoqualmie, Gallatain, and Yellowstone are some of the National Forests I have been to and I can honestly say, that’s America in its rawest form and that’s the shock and awe that a documentary can’t do justice when you see the same scenery in-person. Seeing the power of a waterfall on a screen versus hearing and feeling that power in-person is an incomparable feeling one must experience in a lifetime. I hope to still hike these forests where no roads will run through and I urge the agency to: - Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; - Guarantee that no watersheds will be negatively affected by rescission; - Commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Regards, Quang Thai References: 1. Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538 2. Sean P Healey 2020 Environ. Res. Lett. 15 104023 (2020) Long-term forest health implications of roadlessness 3. https://forestpolicypub.com/wp-content/uploads/2025/09/Chiefs-9-15-25-Comments-to-Roadless-NOI.pdf

For nine years, I have taken my son hiking in Cleveland National Forest and Inyo National Forest, observing plants and wildlife, staying fit, and finding relaxation. I want my child, and other children, to have public wilderness available to all, preserved not only for people but for the trees, plants, and animals that live there and far preceded us as species. Trees and plants, after all, allow us air-breathing creatures to live. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens what I value in those forests, and the agency's own document raises questions the notice does not answer. The agency states, in the Rationale for the Proposed Rule, that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." That framing is not reconciled with the document's own findings. The same document cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The agency should reconcile the forest health rationale with those internal findings before finalizing this rule. The agency also estimates, in the section on Economic Benefits from Recreation in Roadless Area Forests, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That figure is set against roadless recreation benefits of upwards of $1.5 billion, and the same section acknowledges that the magnitude of losses is unknown. Roads and changes to recreation settings accumulate and persist; the 1 percent annual cap does not capture that reality. I hike and camp in these forests, and so do my son and other children. The agency should produce a cumulative recreation loss estimate over a longer horizon and compare it with projected timber revenue, rather than relying on a single-year figure that the document itself qualifies as uncertain. Finally, the agency's own data, cited in the section on Implications for Forest Vegetation, Health, and Carbon, show that in the operable areas most likely to be logged, "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest." Old and mature stands together make up the large majority of the timberland the proposed rule would open to harvest. The document does not identify any old-growth-specific protection beyond general land management plan compliance. These are the stands I want my child and other children to still find decades from now. The Forest Service must separately analyze and disclose what safeguards, specific to old-growth, would apply before harvest could proceed in this land base.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The acorn woodpeckers I watch flying between snags in burn scars, the lush forest and stream habitat of Pine Creek, the views near the Pacific Crest Trail from Eagle Peak, one of the closest natural areas to San Diego: these are what the Cleveland National Forest's inventoried roadless areas hold for me, and they are what this rescission puts at risk. I hike the Cleveland and Angeles National Forests for peace and recreation, and I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). California holds 381 inventoried roadless areas totaling 4,389,760 acres. Eagle Peak, at 6,481 acres in the Cleveland National Forest, and Pine Creek, at 503 acres in the same forest, are among them. These are not abstractions. Eagle Peak sits near the Pacific Crest Trail with views that draw people from San Diego. Pine Creek is a place where forest and stream meet in a habitat that is genuinely lush. Opening these places to road construction would change what they are. The agency has not shown why that change is warranted, and the record it produced raises questions it has not answered. The proposal invokes wildfire management as a justification for rescission. The agency's own findings cut against that justification. Its 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 hike burn scar country in the Cleveland. The acorn woodpeckers I watch are part of a fire-adapted landscape. The agency must explain on the record why this proposal departs from its own prior findings on fire occurrence, and it 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 proposal also rests on economic grounds. 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 Cost Benefit Analysis the agency produced 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, with a net present value ranging from -$92 million to +$199 million. The existing road system already carries a $6.9 billion maintenance backlog. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. I want the agency to reconcile the proposal with its own Cost Benefit Analysis, which cannot establish a net benefit, and explain how expanding a road system already burdened by that backlog serves the public interest. The regulatory flexibility analysis that accompanies this proposal certifies no significant impact on small entities. The agency's own record contradicts that conclusion: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The analysis reaches its no-impact conclusion by spreading estimated losses across every small firm in the sector nationally, rather than examining the outfitters and guides actually holding permits in the areas at issue. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, the proposal invites comment on reliance interests. Its own language 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 use of Eagle Peak and Pine Creek, my expectations of finding unroaded habitat in the Cleveland National Forest, the peace and recreation I seek there: these are reliance interests the 2001 rule created. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Sincerely, Morgan Connolly San Diego, CA

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. My name is Darshan Ahluwalia, and I am president of the Warriors of the Santa Anas, a nonprofit organization that maintains trails and works to preserve recreational access in the Cleveland National Forest’s Trabuco Ranger District in Southern California. I spend considerable time in this forest recreating and volunteering, and I want to explain what the Roadless Rule means on the ground in our community. The Trabuco Ranger District contains roughly 50 miles of official Forest Service trails and about 100 miles of forest roads outside San Mateo Canyon Wilderness. It is a large, contiguous backcountry landscape between millions of people in Orange and Riverside counties. Unlike our regional parks, which are largely islands surrounded by development, the Santa Ana Mountains allow people to travel for hours through connected public open space. Inventoried Roadless Areas are a major part of that landscape. In the district, they cover approximately 38,500 acres—about 40 percent of federally owned non-wilderness land. Approximately 37 of our roughly 50 miles of official Forest Service trail pass through these areas, including Holy Jim, West Horsethief, Trabuco Canyon, Los Pinos, San Juan, Viejo Tie and Chiquito. These are not remote places with little public use; they are where our community hikes, bikes, runs, volunteers and explores. The most important value here is not any single trail, but the continuity of the landscape. I have personally completed a 54-mile, one-way ride across the Santa Ana Mountains with roughly 12,500 feet of climbing, and we have proposed an 85-mile Santa Ana Mountains Traverse connecting nearly all of the district’s major Forest Service trails. Experiences like these are possible because the landscape remains large and connected. Additional roads and development could fragment that backcountry character even if individual trails remain open. I recognize the need for the Forest Service to manage wildfire risk and protect communities, but wholesale rescission of the Roadless Rule is not necessary to do that. The existing rule already allows road construction when needed to protect public health and safety from an imminent threat such as fire, and it allows certain timber removal to restore ecosystem conditions and reduce the risk of uncharacteristic wildfire effects. Road construction also involves its own wildfire tradeoffs. A 2026 peer-reviewed Fire Ecology study examining National Forest fires from 1992 through 2024 found ignition density of 7.99 fires per 1,000 hectares within 50 meters of roads, compared with 1.97 in Inventoried Roadless Areas. The largest 2 percent of fires were similar in size regardless of where they started. The study concluded that building roads into roadless areas is likely to produce more ignitions, even while recognizing that roads can provide strategic firefighting access. We have experienced this risk firsthand. The 2024 Airport Fire burned 23,526 acres in and around the Trabuco Ranger District. It was accidentally ignited by heavy equipment being used by an Orange County Public Works crew to place large boulders along Trabuco Creek Road to prevent vehicles, particularly motorcycles, from entering a dry-brush area considered at high fire risk. In other words, the fire was itself started during road-access work intended to reduce fire risk. Two years later, our trail system and recreational infrastructure are still recovering. This does not mean roads have no role in wildfire management. It means that more roads should not automatically be treated as a fire-safety benefit. Management should be strategic and location-specific, while recognizing that increased road access can also increase opportunities for human-caused ignition. The Roadless Rule provides an important national baseline while retaining exceptions for legitimate management needs. In the Santa Ana Mountains, it protects a substantial portion of one of Southern California’s largest connected backcountry landscapes and most of the trails our community uses. I urge USDA not to finalize the proposed rescission and to retain the 2001 Roadless Area Conservation Rule. If additional management flexibility is necessary, it should be addressed through targeted measures rather than eliminating nationwide roadless protections.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I am a resident of San Diego, California and work as a professor in a local community college. I am also the Executive Director of the Friends of Rose Creek, a community group who advocates for and tends Rose Creek. I love to hike in the mountains of San Diego and Los Angeles including the Cleveland National Forest and the Cucamonga Wilderness in the Angeles National Forest. Wildernesses are rare, wild places where one can retreat from civilization and reconnect with the Earth, and find healing, meaning, and significance. Wilderness contributes to the ecologic, economic, and social health and well-being of our citizens. The only way to protect these amazing areas is to not build roads. I recently had the privilege of camping in the Allegheny National Forest. There were thirty year old roads that had been closed off by the Forest Service and that were still visible and my feet could still feel the hard pack. Once a road is built it doesn't go away in a lifetime. Over 80% of wildfires in the west are caused by humans either accidentally or initially. Most wildfires start near roads. If our goal is to reduce wildfires in the backcountry, then we must maintain the Roadless Area Conservation Rule. Wild lands contribute to clean air, protect water sources we depend on, and create spaces for large and critically sensitive species like Big Horn Sheep, Bald Eagles, California Condors, and Mountain Lions to have places to live, hunt, and raise their young without interacting with people. The lack of roads keeps habitats unfragmented and preserves ancient migration routes. Roadless areas in forests shelter more than 220 species that are threatened, endangered or proposed for Endangered Species Act protection. These intact ecosystems not only provide countless benefits to wildlife, but also to humans in shared places to experience the world beyond engines and electronics. The clean air generated by these wild places helps to offset the pollution caused by coal burning energy plants, vehicle emissions, and air polluting manufacturing plants. Clean streams support our fisheries that employ millions of Americans. Wild places help us preserve sacred spaces for indigenous Americans who have lived and prayed on these lands since time immemorial. The first time a young person of the 21st Century experiences a roadless area on a hike, is like transporting a child to the moon. It opens their eyes to a world they never knew existed. We care for these lands today as a down payment on the world we want our children to inherit in 50 or 100 years. Once a road is built, it may still be here 100 years from now and that changes everything for the worse. Respectfully, Karin Zirk 4629 Cass Street #188 San Diego CA 92109 Nature deficit disorder refers to the negative effects experienced by individuals, particularly children, who do not spend enough time outdoors in natural environments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Cleveland National Forest felt like a world away while we were there, even though it is close to where we live. My husband and I camped there early in our relationship. Camping together in a wild space that is not overbuilt helped us lay a solid foundation to our relationship. Trabuco, at 23,341 acres, is beautiful and has wild places with homes close by. Hiking there is meaningful because it is a space of nature in a county that has so much concrete and control. I oppose rescinding the 2001 Roadless Area Conservation Rule and ask the agency to respond to each of the points below. Roads would make the forest crowded with people, and more people would add light and hinder the animals from living their lives. The agency's own fire record reinforces this. "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 not a minor difference. The effects analysis concedes that road access could increase the number and frequency of wildfires, yet the proposal does not translate that concession into projected numbers. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this rule proceeds any further. 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. Trabuco, Ladd at 5,300 acres, and Coldwater at 8,402 acres sit within the Cleveland National Forest, a forest that serves a densely developed region where wild land is already scarce. 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. My husband and I built something real in that forest, and the rule that kept it intact shaped what we expected from it. Under established administrative law, an agency reversing course must identify and weigh the reliance interests its prior policy created. I ask that the agency do exactly that with the comments it receives, including this one. The economic analysis does not hold together. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally rather than assessing the guides and outfitters actually holding permits in the affected areas. It then concedes some firms may lose those receipts. That is not a rigorous assessment. The agency should withdraw the small-business certification and analyze the impact on the entities actually operating in the potentially affected roadless areas, not on a national average that obscures local harm. Finally, the agency has placed its own foreseeable consequences beyond the reach of its own analysis. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." The agency is asking the public to comment on outcomes it has declared out of scope. A forest like the Cleveland, pressed against suburban Orange and San Diego counties, has no room for that kind of deferred accounting. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not handed off to a future proceeding that may offer no equivalent opportunity for public input. I urge the agency to keep the 2001 rule in place and to address each of these points with the specificity they require. Sincerely, Chandra Jenkins Deeks Anaheim, California

I strongly oppose any proposal to fully or partially rescind the Roadless Area Conservation Rule. I have volunteered with the U.S. Forest Service in the Cleveland National Forest (CNF), Trabuco District, since 2010. I also regularly hike and spend time in California’s national forests and other public lands. Through my years of hands-on stewardship, I have picked up trash, removed graffiti, led native plant hikes, and guided meditation-in-nature walks. These experiences have given me a deep appreciation for the ecological value of our public lands—and a firsthand understanding of how much care and protection they require. Roadless areas are among our most valuable remaining intact wildlands. Weakening their protections would put these landscapes at greater risk of habitat fragmentation, invasive species, erosion, and permanent loss of native biodiversity. As a Southern California native, I know how rare and precious intact natural habitats have become. We cannot afford to treat our remaining roadless areas as expendable. Road construction is not simply the addition of a road. It permanently alters the landscape. Roads can fragment habitat, disturb soils, facilitate the spread of non-native plants, increase human access and disturbance, and degrade ecological processes that took generations to develop. Once an intact wildland is fragmented or degraded, restoring its ecological functions can be extraordinarily difficult—and in some cases impossible. Roadless areas also provide essential habitat for native plants, insects, wildlife, and countless other organisms. They protect watersheds and help preserve the ecological connectivity that allows native species and natural processes to persist. These places are also classrooms, refuges, and sources of connection for people. They give children and adults opportunities to experience nature, learn about native ecosystems, and develop a lasting sense of responsibility for our public lands. My years of volunteering in the CNF have made clear to me that protecting these places is not an abstract environmental concern. It is practical stewardship. It means preserving functioning ecosystems rather than attempting to repair them after they have been damaged. The Forest Service should strengthen—not weaken—the protections that keep our remaining roadless areas intact. These lands belong to all of us, and we have a responsibility to pass them on to future generations with their biodiversity, wildlife habitat, clean water, and ecological integrity preserved. I urge the Forest Service to maintain the Roadless Area Conservation Rule and reject any proposal to rescind or weaken its protections. Thank you.

I live in San Diego near the Cleveland National Forest and am just starting to learn the true value of our national forests as uninterrupted habitat for many threatened species. I am doing work to conserve and protect our beautiful plants that are often endemic to just a small area. As a person who appreciates the many values national forests bring to my state, my wellbeing, our wildlife and more, I support Alternative 1: The “No action alternative” because we should keep the Roadless Rule intact. Roadless areas keep our forests healthy. They serve as the ecological backbone of our national forest lands and: - Supply 50% of California’s drinking water - Support Tribal cultural practices - Enhance outdoor recreation including backcountry hiking, backpacking, horseback riding, mountain biking, camping, angling, and hunting - Shelter over 200 imperiled species like the Pacific fisher and Sierra Nevada red fox - Protect the military mission in part by serving as a crucial buffer against urbanization. And, more roads mean more wildfire risk. Most wildfires are caused by humans and most human-caused fires occur near roads. We don’t need more. Please move forward with the No Action Alternative 1: Keep the Roadless Rule intact.