Read the comments.

I spent my career as a forester and ecologist with the USFS, the USFWS and finally with the USDOT/FHWA. I retired 5 years ago with 33 years of federal service. During my career, I conducted field work to determine timber values, suitability of areas for timber harvest and the presence of federally listed plants and animals. I served on teams conducting NEPA analyses for a variety of project types in multiple landscapes. For 18 years, I was a liaison from the USFWS to the NC DOT and consulted on thousands of infrastructure projects for their impacts to streams and wetlands and endangered species. I won awards from both the FWS and the DOT for my work. At the end of my career, I was training State DOTs across the country in the applicability and implementation of the Endangered Species Act and NEPA and working as a subject matter expert to help solve problems with a nexus of transportation and the environment, particularly water resources and rare plants and animals. In my time away from work, I have hiked and enjoyed the National Forests from Washington to North Carolina and most of the nation in between. I have found great value and experience in roadless areas across the country. From the Salmo-Priest area on the Colville NF ——where I conducted my MS research—- to St Peter’s Dome on the Chequamegon NF and finally to my home state of NC and Catfish Lake on the Croatan NF and Harpers Creek on the Pisgah NF, these roadless areas are crucial to clean air, clean water and the survival of multiple species of plants and animals. From migratory birds and forest dwelling bats to endemic plants and salamanders, areas that are not impacted by roads provide habitat not available elsewhere in our national forests. With over 20 years of my career spent in transportation, I can attest to the permanent changes that road corridors, regardless of their classification, bring to the forest. Over decades, road corridors and culverts degrade and deposit sediment to streams and in extreme weather events cause further damage to both streams and the forest. In addition, these corridors provide travel routes for invasive species which can greatly alter habitat for native species. The scale of what roads have already done to the landscape is substantial. An estimated 15 to 20 percent of the contiguous United States is ecologically affected by roads — not just where roads exist, but where the edge effects, runoff patterns, and disturbance cascades from those roads reach (Forman & Alexander 1998). These roadless areas are habitat gems that should never be exploited for the limited resources that they can provide commercially, but instead should be conserved for their tremendous capacity as large habitat patches contributing to biodiversity and conservation of all species, including our own. DO NOT RESCIND THE ROADLESS RULE.

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Five generations of my family have gathered and camped along Sherman Creek, adjacent to the South Huckleberry Roadless Area in Colville National Forest in Washington. We go there to enjoy the beautiful scenery, fish, birdwatch, hike, and watch the creek go by. That place, and others like it where I hike and photograph birds, plants, and other organisms in their natural habitat, represent exactly what the 2001 Roadless Area Conservation Rule was meant to protect. I oppose the proposed rescission of that rule under Docket FS-2025-0001, and I ask the agency to respond in full to the concerns below. The agency justifies rescission in part on permitting and administrative burdens, but its own legal description of the rule undercuts that rationale. The rule, as the proposal acknowledges, "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If exceptions for public health and safety, existing mineral leases, and community wildfire protection are already written into the rule, the agency owes the public a precise accounting of which burdens those exceptions leave unaddressed. I ask the agency to identify those specific remaining burdens and quantify them, with supporting data, before proceeding further. The birds I watch and photograph along the Tam McArthur Rim Trail in the Three Sisters Wilderness and in the South Huckleberry Roadless Area would fare worse under any regime that allows road construction to expand into currently protected habitat. The agency's own analysis does not hide this: the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres. The scale of potential harm to avian communities across that landscape is not speculative; the agency has already documented the mechanism. I want the agency to explain how it squares those documented effects with a decision to rescind the rule. I believe public lands should be managed to ensure the health and function of natural ecosystems, with special care given to protect the biota, hydrology, and soils, and this proposal moves sharply in the opposite direction. The agency must explain how that degradation risk was weighed against the claimed benefits. Finally, the agency's own fire data cuts against the proposal's wildfire rationale. 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. The agency must quantify the expected increase in human-caused ignitions that new road access would produce and weigh that figure honestly against whatever reduction in wildfire hazard it claims to address.

The forest is right across the river from where I live, and that proximity makes this impossible to ignore. I hike and camp by the Pend Oreille lakes with my husband and grandkids, and I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule as it affects the Colville National Forest and all inventoried roadless areas on National Forest System lands. 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." But the agency's own document also finds that the rule did not meaningfully constrain fuel treatments as a share of forested land, and that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. These findings sit alongside the forest health rationale without any reconciliation. I ask the agency to explain, in its response, how that rationale holds when its own findings undercut it so directly. Water is life, and more roads mean more sedimentation and compromised water systems for wildlife and people. The agency claims in the Fire Control section that "With increased road access, initial attack success rates would be expected to increase." But the document shows that less-than-full suppression is used more often in roadless areas, which makes the initial attack comparison unreliable on its face, and the document further acknowledges that most new roads are expected to be temporary timber spurs rather than strategic fire roads. No analysis in the document isolates the effect of roads from suppression strategy. The agency must provide that separation and must estimate how many fire-useful roads are actually expected given real funding constraints. I want my children and grandchildren to have wild places. I want them to experience wildlife. That future depends on the agency taking recreation losses seriously. The document 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." But the same section acknowledges that the magnitude of losses is unknown, and that approximately 52 percent of certain recreation setting classes are more likely to be affected. Roads and changes to recreation settings accumulate and persist over decades. A single-year 1 percent cap cannot capture that reality when set against roadless recreation benefits of upwards of $1.5 billion. The agency should estimate cumulative recreation losses over a meaningful time horizon and compare them honestly with projected timber revenue before any final decision is made.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001. 50 years living in NCDE & Yellowstone Region has given me solace based in truth so cannot tolerate rescission in exchange for marketization of public lands. RR means protections not their removal.RR lands mean connectivity for species survival. Rescission displaces threatened species. ESA listed grizzly bear requires best science. Rescission shuns it and will prove fatal for grizzly populations. Cited lands mirror grizzly DPS compliance. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, specifically inventoried RR areas: Lost Water Canyon (9,251 acres), Custer NF, MTBurnt Mountain (10,698 acres), Custer NF, MT Black Butte (871 acres), Custer NF, MT Red Lodge Creek Hellroaring (17,210 acres), Custer NF, MTOkanogan-Wenatchee NF (1,006,000 acres), Okanogan NF, WAGifford Pinchot National Forest (213,000 acres), Gifford Pinchot National Forest, WAMt. Baker-Snoqualmie NF, WALiberty Bell (108,495 acres), Okanogan NF, WACuster Gallatin NF (848,000 acres), Custer Gallatin NF, MTBob Marshall Wilderness Complex (1,483,000 acres),Bob Marshall Wilderness Complex, MT Paine Gulch (7,875 acres), Lewis & Clark NF, MTMt. High (33,484 acres), Lewis & Clark NF, MTMcgregor - Thompson (27,211 acres), Lolo NF, MTDeep Creek (7,669 acres), Lolo NF, MT Trout Creek (30,851 acres), Kootenai NF, MTCataract (9,442 acres), Lolo NF, MTBlue Slide (17,505 acres), Wenatchee NF, WA Mt. Baker-Snoqualmie NF (415,000 acres), Mt. Baker-Snoqualmie NF, WA , Okanogan NF,Pasayten Rim (17,074 acres), Okanogan NF, WASawtooth (15,693 acres), Lewis & Clark NF, MTwin Sisters (13,051 acres), Colville NF, WA Bridger-Teton National Forest (1,417,000 acres), Bridger-Teton National Forest, WyWest Pioneer (248,631 acres), Beaverhead-Deerlodge NF, MTBear - Marshall - Scapegoat - Swan (344,022 acres), Lewis & Clark NF, MT Bob Marshall-Scapegoat-Swan (334,275 acres), Flathead NF, MT East Pioneer (145,082 acres), Beaverhead-Deerlodge NF, MTWest Big Hole (133,563 acres), Beaverhead-Deerlodge NF, MTMadison (127,859 acres), Gallatin NF, MTSelway-Bitterroot (114,953 acres), Bitterroot NF,MTHoodoo (105,162 acres), Lolo NF, MTAllan Mountain (104,184 acres), Bitterroot NF, MTSnowcrest Mountain (97,649 acres), Beaverhead-Deerlodge NF, MT Freezeout Mountain (97,305 acres), Beaverhead-Deerlodge NF, MT Middle Mtn. / Tobacco Roots (96,487 Beaverhead-Deerlodge NF, MTTuchuck (17,730 acres), Flathead NF, MTThompson Seton (52,235 acres), Flathead NF, MTMt. Henry (13,603 acres), Kootenai NF, MTOlympic National Forest (86,000 acres), Olympic National Forest,WASapphires (66,619 acres), Beaverhead-Deerlodge NF,MTBear Creek (8,123 acres), Beaverhead-Deerlodge NF, MT MTLittle Bighorn (133,949 acres), Bighorn NF, WyoSleeping Child (x1074) (21,433 acres), Bitterroot NF, MT, Bitterroot NF, MTDry Canyon Breaks (4,821 acres), Colville NF, WANorth Absaroka (21,063 acres), Custer NF, MTCrazy Mountain (82,093 acres), Gallatin NF, MTBridger (45,059 acres), Gallatin NF, MTHyalite - Porcupine - Buffalo Horn Wilderness Study Area (143,991 acres), Gallatin NF, MTGallatin Fringe (51,571 acres), Gallatin NF, MT Cabin Creek Wildlife Management Area Ocd (35,048 acres), Gallatin NF, MTWAHellgate Gulch (16,821 acres), Helena NF, MTBig Snowy Mountains Wsa (88,003 acres), Lewis & Clark NF, MTCastle Mountains (29,409 acres), Lewis & Clark NF, MT Crazy Mountains (24,942 acres), Lewis & Clark NF, MT Box Canyon (12,584 acres), Lewis & Clark NF, MT- Big Snowies (9,258 acres), Lewis & Clark NF, MT North Fork Smith (8,444 acres), Lewis & Clark NF, MT Tenderfoot - Deep Creek (85,614 acres), Lewis & Clark NF, MT Eagle Park (5,912 acres), Lewis & Clark NF, MT- Calf Creek (10,108 acres), Lewis & Clark NF, MT- Pilgrim Creek (44,608 acres), Lewis & Clark NF, MT Highwood Baldy (15,305 acres), Lewis & Clark NF, MT Highwoods (24,378 acres), Lewis & Clark NF, MT- TW Mountain (8,388 acres), Lewis & Clark NF, MT Granite Mountain (10,338 acres), Lewis & Clark NF, MT Lewis & Clark NF, MT Middle Fork Judith Wsa (81,131 acres), Lewis & Clark NF, MT Bluff Mountain (38,060 acres), Custer NF, MtLine Creek Plateau (24,825 acres), Custer NF, MT, Custer NF, Mt Shoshone NF, WyoWilderness Study Area (51,961 acres), Targhee NF, Wyo- West Slope Tetons (47,448 acres), Targhee NF, Wy- Silver King (64,289 acres), Beaverhead-Deerlodge NF, Montana, - Selkirks (95,967 acres), Idaho Panhandle NF, Idaho-Grizzly Peak (7,441 acres), Kootenai NF, Montana I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects threatened species and of climate change.I ask that the agency respond to each of them.I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Dan Sullivan Chanhassen, MN

As a scoutmaster, a mom, a nature lover, growing up in the Pacific Northwest has been very special to me and my family. We’ve enjoyed camping and hiking in areas that are special specifically because they are difficult to get to. The protection of the Roadless Rule has afforded us a sense of security that the future generations would be allowed the experience of awe and wonder at the expansive untouched beauty of these areas. Specifically because some of these conservation areas are so remote, we knew that they would stay protected. Without this protection, we all lose! The fact that these areas are undisturbed is what makes them special and irreplaceable. Washington State in particular is negatively impacted by this senseless rollback because it would impact five national forests in Washington state: Olympic National Forest, Mt. Baker-Snoqualmie National Forest, Okanogan-Wenatchee National Forest, Gifford Pinchot National Forest, and Colville National Forest. All of which my family and friends have spent many weeks camping, hiking, fishing, summiting, climbing and in general standing in awe of the powerful healing that being in nature gives to those who spend time there. We need these protections to stand. There is no way to put a value on the benefits that these forests provide. Opening them up to roads, logging and the access to more unnecessary intrusion is unthinkable and careless. Removing these protections is careless, irresponsible and should never be considered. Roadless areas see fewer human-caused wildfires than roaded ones. This doesn't reduce fire risk near communities like mine, it increases it! Please do not allow this change!

I live below one of the access points to the Colville National Forest. In it I have ridden my horse many miles. But in the last ten years the development and popularity of the side by side vehicles has torn up a great deal of land, with signed areas ignored. We should not develop more of the undeveloped national forest.

Please maintain the Roadless Area Conservation to maintain our beautiful National Forests. These are places my family and I visit every year. We love nature, and the quiet beauty of these places. So many beautiful places that need to be protected like these: Mt. Baker-Snoqualmie National Forest, Olympic National Forest, Okanogan-Wenatchee National Forest, and Colville National Forest. Just to name a few in my own state of Washington. I have to imagine this is the same situation around our incredible country. These wild places need to be maintained for our children and grandchildren. Please maintain the Roadless Area Conservation.

I’m writing to support the current 2001 Roadless Area Conservation Rule. I value the existing rule because it places I know and love that provide recreation and solitude. My family values these areas, especially the Profanity Roadless Area in the Colville National Forest. ( I oppose changes that repeal, weaken or rescind the 2001 Roadless Rule. Roadless National Areas are some of the last best places in our country and it is essential that they are protected. Eighty five percent of wildfires start near roads. There are 370,000 miles of roads existing today in our national forests the Forest Service admits it cannot maintain. Building more roads makes no sense!

Subject: Public Comment: Oppose the Rescission of the Roadless Area Conservation Rule (Docket FS-2025-0001) Dear Secretary Rollins and U.S. Forest Service Officials, I am writing as a citizen who lives near the Colville National Forest in Washington State. I'd like to register my opposition to the proposal to weaken the 2001 Roadless Area Conservation Rule. I urge the Forest Service to keep these critical protections intact. The Colville National Forest has over 4,000 miles of existing roads. This extensive road network already provides sufficient motorized access for recreation, resource management, and community needs. The Forest Service maintains a multi-billion dollar backlog in road maintenance. To add more miles of roads to manage is fiscally irresponsible. The roadless areas across the Colville National Forest are irreplaceable. They serve important functions such as, •Providing safe habitat and migration corridors or wildlife. •Maintaining water quality by filtering rainwater and ensuring clean, high-quality drinking water for our communities. Road construction can choke mountain streams with sediment and degrade water systems. •Protecting old growth forests, which provide habitat, quiet spaces to visit, sacred indigenous sites, and are less fire prone. Opening these last wild places to commercial logging, mining, and road-building would elevate human-caused wildfire risks. Data shows that wildfires are significantly more likely to ignite near road corridors. Please preserve the integrity of Washington's public lands. Do not strip protections from the roadless areas that keep the Colville National Forest healthy, wild, and resilient. Sincerely, Heidi Lasher 4402 S Eastern Rd Spokane WA 99223

We favor leaving the existing roadless rule in place. (Alternative 1) We hike, bike and ski in many of these areas on the Colville National Forest and surrounding areas like the Okanogan NF. Some of our favorite places are: Mt Bonaparte (Okanogan NF), Bangs Mountain, Hoodoo, Bald Snow, South Huckleberry, Abercrombie Hooknose, and Profanity peak

Subject: Public Comment: Oppose the Rescission of the Roadless Area Conservation Rule (Docket FS-2025-0001) Dear Secretary Rollins and U.S. Forest Service Officials, I am writing as a local resident living near the Colville National Forest in Washington State to express my strong opposition to the proposal to rescind or weaken the 2001 Roadless Area Conservation Rule. I urge the Forest Service to keep these vital protections completely intact. The Colville National Forest already has over 4,000 miles of existing roads. This extensive road network already provides ample motorized access for recreation, resource management, and community needs. The Forest Service already faces a massive multi-billion dollar backlog in road maintenance; adding more miles of roads to manage is fiscally irresponsible. The inventoried roadless areas across the Colville National Forest are irreplaceable. They serve three critical functions that roads would impact: • Wildlife and Habitat: These unbroken forest tracts are important migration corridors and sanctuaries for wildlife. • Water Quality: Our local roadless watersheds act as natural filtration systems, ensuring clean, high-quality drinking water for our communities. Road construction is known to choke mountain streams with sediment and degrade water systems. • Protection of Old Growth: These protected spaces shelter our remaining old-growth forests. These ancient ecosystems are deeply cherished by locals. • Opening these last wild spaces to commercial logging, mining, and road-building would also fundamentally elevate human-caused wildfire risks, as statistical data shows wildfires are significantly more likely to ignite near road corridors. Please preserve the integrity of northeast Washington's public lands. Do not strip protections from the roadless areas that keep the Colville National Forest healthy, wild, and resilient. Sincerely, Sam Joseph Spokane WA

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Republic, WA where there are several Inventoried Roadless Areas within an hour of my house. These lands are very important to me, as an avid hiker, camper, and angler, I use our public lands on a weekly basis. Specifically, the Bald Snow, Thirteenmile, Cougar, and Clackamas Mountain Roadless Areas are among my favorite places to recreate on the Colville National Forest. I ski, hunt, and hike in these areas regularly, and allowing road construction or commercial logging in these areas would negatively impact the value these wild areas bring to my community. Building roads would increase the fire risk since does are four times more likely to start near a road than in a Roadless forest. Increased threat of fire would negatively impact drinking water, wildlife habitat, and indigenous cultural values and sources of traditional food, fibers, and medicine. For the reasons listed above, rescinding fully or partially the Roadless rule would be a mistake that would not serve the greatest good, nor the future generations we should be stewarding these lands for. 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 What I have seen of fire season, living near a national forest: "I have experienced poor air quality." Clean water is necessary and crucial for all of us, and thanks to protected, undisturbed snowpacks in roadless areas, my community and I can have access to clean water year-round. More roads mean more polluted, unclean water. It does not make sense to build new roads, many of which will not even be accessible to the public and will be used for logging instead of fire protection, when our current roads are lacking in repairs. Instead of inefficient driving on several unkempt roads, existing roads should be improved and made more efficient. I visited South Huckleberry as a kid, and I am still fond of huckleberries. Losing this place to roads and logging means the loss of these unique wild berries and the people and wildlife sustained by them. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about South Huckleberry (10,117 acres), Colville National Forest, Washington. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The agency's own fire data cuts against the proposal I live near a national forest, so fire risk is not abstract to me. The agency's own data points the opposite direction from its 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 itself concedes that road access could increase the number and frequency of wildfires. 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. Issue 2: Its own cost-benefit analysis lists increased fire risk as a cost of this action I live near a national forest, and I am the person the wildfire justification is aimed at. The agency's own accounting undercuts it. Cost Benefit Analysis Table 4 (p. 30), qualitative unquantified costs of the proposal: "Degraded recreation quality; ecological and water impacts; increased ignition risk; agency road maintenance burden." In the benefits column, "reduced wildfire risk" sits among the benefits the agency says it cannot quantify. The rescission is being sold as wildfire protection, and the agency's own accounting books increased ignition risk as a cost while the promised fire benefit is unquantifiable, besides DEIS Table 21's finding of seven and a half times the human-caused ignition density on roaded land. I ask that the agency quantify the net wildfire effect of this action in either direction before relying on wildfire as a justification for it. Issue 3: Wildfire is not the stated legal basis, and the targeted alternative was rejected I live near a national forest, in exactly the kind of place a targeted answer would protect. The agency built that answer and rejected it. The purpose and need is to reduce regulatory burden and return decision-making to local officials. Overlap with the wildland-urban interface as defined by HFRA is 9.8 million acres, 24 percent of the affected area, and the DEIS says the benefits of added fuel-management access "would likely be modest and localized." The agency built and rejected a WUI-targeted alternative that would answer the fire rationale without nationwide rescission. I ask that the agency explain why nationwide rescission was chosen over the WUI-targeted alternative it constructed and rejected. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Ariel Resident of Eastern Washington State

We appreciate that roadless areas are some of the last, best places on our public lands in Washington State that are free from any industrial development. Also, we are learning this means country like the Liberty Bell in Okanogan-Wenatchee National Forest, Abercrombie-Hooknose in Colville National Forest, and the Dark Divide in Gifford Pinchot National Forest are absolutely beautiful places to visit. We (my family and I, four taxpaying and voting adults) have lived on the North Olympic Peninsula for the last 20 years, so appreciate that roadless areas provide the wildland connectivity for wide-ranging wildlife such as lynx, wolverine, black bear and elk. We appreciate that much of the wildlife restoration efforts being made are protected by these areas and all of that depends on habitat free from human development. We know there are already more roads on national forests than can be affordably maintained. Over the years we have watched as the forest service in Montana closed hundreds, then thousands of miles of roads. We understand the Forest Service still has some 380,000 miles of roads with a growing maintenance backlog. Why would you want to allow more road development? We also understand the current roadless rule allows restoration thinning and prescribed burning in the roadless areas, but that it limits commercial timber harvest in steep backcountry terrain. We think there is actually constraint from the topography and economic cost of road development in such rugged areas. We are aware that roads fragment and degrade wildlife habitat, and they dump sediment into fish habitat and spawning beds each year. Those cold, clear rushing streams not only spawn fish, but also provide beautifully clean water for local downstream communities and ranching operations. We understand in Washington State, about 85% of fires are caused by people each year and the roads act as pathways for human fire ignitions, not the regulations or thunderstorms. We think we need our wild country way more than we need new forest roads and the mining of our remaining patches of forest. Please keep our roadless areas that also support Indigenous cultural and subsistence practices and some of the best backcountry recreation available in the state. Our rural economies are supported by the hunting, fishing, paddling, hiking, backpacking, off road riding and bird and botany watchers that abound. Thank you! Mike & Dan Brant and Dan & Lys Burden

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Family outings to the Colville National Forest are how we spend time together, watching wildlife and getting into nature. South Huckleberry, Bangs, Thirteenmile, Cougar Mountain, Bald Snow, and Hoodoo are the kinds of roadless places that make those trips worth taking. I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and to ask the agency to answer the specific questions this record raises. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. The agency proposes to strip the rule protecting all of them. One reason given is wildfire and fuels management, yet 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." That finding does not support rescission; it argues against it. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. Our roads are hardly maintained at all as it is. Adding more roads makes absolutely no sense at all. The agency's record already documents why: "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 projected timber revenue to the Forest Service runs $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The agency cannot establish a net benefit from its own cost-benefit analysis, and the road system it already operates carries a $6.9 billion maintenance backlog against a road budget of roughly $73 million a year. The agency must reconcile the proposal with these numbers and explain how expanding a road network the agency cannot maintain serves the public interest. The agency argues that state-specific approaches can substitute for a national rule, but its own record reflects a different history: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency's own earlier findings acknowledged that local decision-making can incrementally erode nationally significant roadless values. The Ninth Circuit has already reviewed what happens when a national rule is replaced with a state-by-state approach. I ask that the agency explain how this proposal avoids the deficiencies identified in that litigation. The agency also suggests the 2001 rule may have exceeded statutory authority, but a court has already ruled directly on that question. The Tenth Circuit's holding was: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state on the record what legal basis supports a contrary position now. Bear habitat in the Colville National Forest depends on limiting road access. The agency's own record, drawing on the federal grizzly recovery plan, documents that open roads in grizzly habitat increase contact and conflict and can ultimately end in grizzly mortality, with shooting, habituation, and food reward all rising with the use of even secondary unpaved roads. The wildlife my family goes to the Colville to see is directly affected by that finding. The agency must address it directly. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Children should not have to bear the burden of what this will do, to the water, to the wildlife, to the places that remain unroaded. The rule was written after more than 600 public meetings and 1.6 million comments. No comparable process has been held to undo it. The agency should say why that asymmetry is acceptable. Sincerely, Brenda L. Williams Farmington, Wa

SUBMITTED VIA REGULATIONS.GOV Date: Sep 3, 2026 U.S. Department of Agriculture – Forest Service Attn: Public Comments Processing / Proposed Rule Rescission Docket No. FS-2025-0001 (Document: FS-2025-0001-223869) Subject: Formal Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Forest Service Leadership and Rulemaking Committee, I am writing in strong opposition to the U.S. Department of Agriculture and Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule (Docket No. FS-2025-0001). For nearly a quarter-century, the Roadless Rule has provided a balanced, durable framework that safeguards 44.7 million acres of inventoried roadless lands nationwide, including approximately 2 million acres across Washington State. Rescinding this rule to open fragile, backcountry lands to industrial road construction and commercial timber extraction is ecologically harmful, fiscally irresponsible, and fundamentally unnecessary for active forest restoration. I urge the agency to withdraw this proposal and maintain full Roadless Rule protections based on the following substantive grounds: 1. Expanding the Road Network Exacerbates Wildfire Ignition Risks The proposal suggests that road-building is required for wildfire mitigation. However, peer-reviewed fire science and regional data demonstrate that forest roads serve as primary vectors for human-caused wildfire ignitions. In Washington State, approximately 85% of all wildfires are caused by human activity. Expanding road access into remote backcountry dramatically increases ignition vectors in steep, dry, and fire-prone terrain where containment is most difficult. 2. Forest Health and Fuels Reduction Are Already Permitted Under the 2001 Rule The premise that the 2001 Roadless Rule prevents necessary forest health management mischaracterizes existing regulatory flexibilities. The current rule explicitly permits ecological restoration thinning, small-diameter hazardous fuels reduction, and prescribed fire within roadless areas. What the rule restricts is industrial commercial timber harvest and road construction. Hauling heavy commercial timber out of steep, rugged backcountry is constrained by topography and market economics—not forest health regulations. 3. Deepening an Existing $10.8 Billion Road Maintenance Backlog Is Fiscally Irresponsible The Forest Service currently manages an expansive infrastructure network of over 380,000 miles of existing roads, while facing a documented, persistent deferred maintenance backlog exceeding $10.8 billion. The agency receives annual appropriations sufficient to maintain only a small fraction of its existing road inventory. Constructing new roads across steep, erosion-prone terrain will generate long-term liabilities, increase culvert blowouts, accelerate sedimentation into fish-bearing streams, and drain vital resources away from existing road maintenance priorities. 4. Severe Impacts on Habitat Connectivity, Fisheries, and Municipal Headwaters Roadless areas are vital reservoirs of biodiversity and ecological connectivity. In Washington, areas such as the Dark Divide (Gifford Pinchot National Forest), Liberty Bell (Okanogan-Wenatchee National Forest), and Abercrombie-Hooknose (Colville National Forest), along with roadless landscapes across the Cascades, Kettles, Selkirks, Olympics, and Blue Mountains, provide crucial contiguous corridors for wide-ranging species including the Canada lynx and wolverine. Furthermore, these untouched watersheds provide clean, cold, naturally filtered drinking water to downstream municipal communities and protect essential spawning beds for threatened salmon, steelhead, and bull trout from damaging road runoff and sedimentation. 5. Cultural, Subsistence, and Backcountry Economic Values Roadless national forests sustain essential cultural and traditional subsistence practices, while anchoring a vibrant backcountry recreation economy. Hunters, anglers, hikers, and local outfitters depend directly on undisturbed, intact wildlands. Industrial development in these areas degrades the very qualities that draw visitors and sustain rural economies. Conclusion The 2001 Roadless Area Conservation Rule is one of the most successful, widely supported conservation policies in American history. Rescinding it would cause generational ecological degradation while compounding the Forest Service's infrastructure deficit. I respectfully request that the Forest Service cancel this proposed rulemaking and retain the 2001 Roadless Rule in its entirety. Sincerely, M. David Conrad Angler, Outdoorsman, Voter Burien, WA

Roadless areas are some of the last places on public lands free from industrial development. In Washington, that means country like the Dark Divide in the Gifford Pinchot National Forest, Liberty Bell in the Okanogan-Wenatchee National Forest, and Abercrombie-Hooknose in the Colville National Forest. They provide landscape connectivity for wide-ranging species like wolverine and Canada lynx, and clean, cold water for downstream communities. Much of the wildlife we work to protect lives in these areas and depends on habitat free from human development. They also support cultural and subsistence practices and some of the best backcountry recreation in the state. There are already more roads on national forests than can be affordably maintained. The Forest Service manages a 380,000-mile road system with a growing $10.8 billion maintenance backlog that has persisted for decades, and it receives funding to maintain only a fraction of that system. The proposal also misstates what the rule already allows. Restoration thinning and prescribed burning are both permitted in roadless areas. The rule limits commercial timber harvest, but hauling logs out of steep backcountry terrain was never going to pencil out for mills in the first place. The constraint here is economics and topography, not regulation. Roads fragment and degrade wildlife habitat, act as vectors for human fire ignitions, and dump sediment into fish habitat and spawning beds each year. In Washington, about 85% of fires are caused by people each year. We need our wild country more than we need new forest roads.

Growing up in the mountains of the Pacific Northwest, we love to hike, camp, and hunt. Roadless areas are some of the last places on public lands free from industrial development. In Washington, that means country like the Dark Divide in the Gifford Pinchot National Forest, Liberty Bell in the Okanogan-Wenatchee National Forest, and Abercrombie-Hooknose in the Colville National Forest. Growing up in the Pacific northwest, our family loves to hike, camp and hunt. We also visit lands in So. Carolina and GA. We love forested land. Forested land provides for species like wolverine and lynx, and clean, cold water for downstream communities. Much of the wildlife we work to protect lives in these areas and depends on habitat free from human development. They also support cultural and subsistence practices and some of the best backcountry recreation in the state of WA. We want to keep our forests for the animals, for the fish and the cold waters that we love to swim in. Destroying the US FORESTS with clear cuts is wrong, it will enhance the effects of climate change. We must protect our forests............no extra forest roads!

I live in Rochester, WA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, hunting or fishing, camping, wildlife watching, and living in or near a National Forest community. I feed my family from what we harvest in the forest and vehicle travel pushes game away. Sullivan Lake is one place that has shaped my views on this proposal. It is within the Grass Top Inventoried Roadless Area in Colville National Forest. This is my favorite area to hunt and fish. I am concerned about the cost of expanding the National Forest road system. I've seen how the forest service can't keep up with the maintenance they already have. I am concerned about clean water and healthy watersheds. We need to keep the road dust out of our creeks. Roadless areas matter to me for recreation and the experiences they provide. Motor vehicles are tearing up to much land and causing disturbances to animals and people seeking solitude. Before rescinding the national rule, I would like USDA to answer this question: How would USDA account for the long-term cost of maintaining, reconstructing, and eventually decommissioning additional roads? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.