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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fifty years of living near the Eldorado National Forest, and a career spent working for the Forest Service itself, put me in a particular position to say this plainly: rescinding the 2001 Roadless Area Conservation Rule would be a mistake the land cannot recover from. We know what we've got and we love it and will fight tooth and nail to protect it. I have fished creeks on the Eldorado, Tahoe, Stanislaus and Inyo National Forests for trout my whole adult life. I have seen the logging slash left behind after timber operations, clogging streams with debris, slowing their courses, and triggering runoff from denuded slopes. Seldom have logging outfits been required to really clean up the mess they have made, from the quickly cut-in roads to the limbs, stumps and general debris left behind. The agency's own record confirms what I have watched with my own eyes: roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale, and that sedimentation can cause egg and juvenile mortality and reduced suitable habitat for trout. I want the agency to explain, on the record, how it reconciles its own sedimentation data with a proposal that invites exactly that activity into watersheds that are presently functioning. The negative impact to our water supply could be devastating, and the great care the agency has historically taken through its NEPA processes to protect streams, creeks, rivers and lakes is precisely what this rescission would dismantle. The Caples Creek and Silver Fork areas are where I do much of my birding, watching for songbirds, woodpeckers, owls and raptors from spring through summer and into fall. The birds there have water, cover and food because the habitat is intact. The DEIS cites the finding 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. Constructing roads and allowing timber harvests or mining operations would destroy critical habitat, and I and many others would no longer be able to enjoy birding on our National Forests if these protections are removed. The agency must explain what analysis it has conducted of cumulative bird habitat loss across the affected roadless areas in California, which total 4,389,760 acres across 381 inventoried areas, and what mitigation it proposes. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is stated and then left hanging, with no projection applied to the 40.1 million acres of potentially affected environment. I ask that the agency apply that cited fragmentation range to the full affected acreage and publish the result before any final decision. I spent years working in fire support, in contract management of fire and aviation resources during suppression and post-fire rehabilitation, and I have been part of advisory input to fire management on land management decisions during and after fires. I have seen the agency open old jeep trails and abandoned logging roads when fire access required it, using the equipment already available for that purpose. There are so many roads already on the maps that are not maintained, building new ones makes no sense. We do not need new roads. Finally, The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. The agency anticipates the harm and proposes no mitigation for it. It must disclose, species by species, how those likely adverse effects will be avoided or mitigated, and ESA consultation must be completed and published before any final rule is issued. The agency's motto is the greatest good for the greatest number. That means these lands are managed for everyone, including those of us who fish for trout in the Eldorado's creeks, watch woodpeckers along Caples Creek, and photograph the wildness of places that are invaluable precisely because they remain undeveloped. The Caples Creek roadless area, all 17,854 acres of it, and the countless other roadless areas like it, are our heritage. We intend to pass them along intact. Sincerely, Kathryn Griffin Sacramento, California Kathryn Griffin See attached file(s)

Subject: Oppose rescission of the 2001 Roadless Rule – Docket FS-2025-0001 As registered Republicans and 32 year-long residents of rural El Dorado County, my husband and I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. We have spent a great deal of high-quality time hiking, birding, and enjoying wildflowers in the Caples Creek Roadless Area, which is about 2 hours from our home. Visiting there and other Inventoried Roadless Areas in the northern Sierra Nevada has been one of our greatest joys over the years. Our local forest, the Eldorado National Forest, is only about 50 miles east of the state capitol of Sacramento. It’s crisscrossed with old forest roads that are in very poor repair, in many instances degrading to a point where high-clearance 4-wheel drive vehicles are required to navigate these massively eroded former logging roads. The Eldorado National Forest has a huge backlog of these roads needing stabilization and treatment to arrest the head-cutting gullies. The Roadless Rule has been an effective bulwark that has protected high-value backcountry recreation in the Caples Creek Roadless Area from a similar fate. It has protected the wildlife habitat, water quality, and carbon storage in a watershed readily accessible to millions of people living in the Central Valley, the Bay Area, and the Lake Tahoe Basin. If the Roadless Rule is repealed and decisions are made only at the local level, protections will become fragmented and uneven. That weakens the overall conservation framework, without any credible evidence that the national rule itself is what limits our ability to address forest health or wildfire risks. The NOI cites changing conditions, wildfire, insects, disease, and WUI growth. Those realities deserve targeted, site-specific tools. They do not require removing the national safeguards that prevent road building and timber extraction in places where intact landscapes are the very asset we are trying to conserve. Existing authorities already allow necessary exceptions and fuels work with environmental review. Before rescinding the rule, the EIS should rigorously analyze: (1) alternatives that retain the Roadless baseline while enabling time-bounded, decommission-on-completion access for hazard reduction near communities; (2) lifecycle costs and maintenance liabilities of any new roads; (3) impacts to municipal watersheds, fisheries, and backcountry economies; and (4) cumulative effects from increased access on invasive weed spread, already a significant problem on the Eldorado National Forest; and (5) wildlife habitat fragmentation. Finally, a 21-day scoping window is not sufficient for meaningful participation on an action of this magnitude. Please extend the comment period to at least 60–90 days, hold regional public meetings, and ensure the draft EIS includes a robust No Action and Modified Roadless alternative. Thank you for considering these comments. Rosemary Carey and Carl Mesick Eldorado County hikers, boaters, birders, botanists, trout lovers, and nature photographers

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Pyramid (24,347 acres), Eldorado NF, California - West Slope Winds (143,252 acres), Bridger-Teton NF, Wyoming 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 small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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 outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 3: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. 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 4: Road sediment is quantified and then set aside I paddle water that starts in this country, and clean, free-running rivers are the whole reason I go. What roads send into a watershed lands directly on people like me. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. 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, Maggie Phillips California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas I am naming in this comment are real places I care about: Pyramid in the Lake Tahoe Basin Management Unit, Dardanelles, Caples Creek, Tragedy-Elephants Back, Salt Springs, Rubicon, and Raymond Peak in the Eldorado National Forest, Freel in the Lake Tahoe Basin Management Unit, and Mokelumne-Hawkins Peak and Waterhouse B in the Humboldt-Toiyabe National Forest. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The Humboldt-Toiyabe alone holds 354 inventoried roadless areas totaling 3,383,849 acres, scattered across mountain ranges that rise from the Great Basin desert like islands in a sea of sagebrush, each range a sky island carrying its own water, its own ecology, its own wildlife, including Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and mountain goat. Rescinding the 2001 Roadless Area Conservation Rule would put all of this at risk, and the agency's own record does not support that step. The proposal argues that opening roadless areas to road construction will help manage wildfire. The agency's own findings say otherwise. 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." The areas I have named, from the dry Sierra Nevada flanks of the Eldorado to the sky islands of the Humboldt-Toiyabe, already face fire pressure. Adding roads into them to reduce fire risk contradicts the agency's own ignition data, reported in DEIS Table 21, which shows far higher fire density on roaded land than inside roadless areas. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with that data. The economic case is no stronger. The agency's own analysis records that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal production, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $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. That range does not establish a net benefit. The Forest Service 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, and degraded watershed function is a cost the agency's numbers do not adequately capture. The agency must reconcile this proposal with an economic record that cannot demonstrate the action is worth its price. The argument that state-by-state rulemaking can substitute for a national rule has been tried before. The record itself shows that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That state-petition approach was subsequently reviewed by the Ninth Circuit and found wanting, in part because local decision-making can incrementally erode roadless values that are nationally significant. The areas I have named cross administrative boundaries and support connected watersheds. The agency has not explained how this proposal avoids the deficiencies identified the last time it tried to replace national protection with a state-level substitute, and it should do so. Finally, the proposal questions whether the agency had statutory authority to issue the 2001 rule. That question has been litigated. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and held it did not create de facto wilderness. The agency has not explained what legal basis supports a contrary position now. That explanation belongs in this record before any rescission moves forward. Sincerely, Concerned Citizen South Lake Tahoe, CA

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would devastate the public lands near my home, undermine clean water, increase fire risk, negatively impact wildlife habitat, and degrade recreational opportunities that I depend on. I live in Reno, Nevada. At least once a week from late spring through fall I hike on trails that will be impacted on US Forest Service land near my home. Specifically, I hike the trails in the Humboldt-Toiyabe National Forest in the Rose-Evans, Rose-Thomas Meadows, Rose-Whites Canyon, Rose-Galena, and Mt. Rose Roadless Areas. I also hike in the Eldorado National Forest in the Dardanelles and Tragedy – Elephants Back Roadless Areas. I care deeply for these undeveloped lands and cherish my time spent hiking the trails in these pristine areas. I like to hike early in the morning before other people arrive, so it feels like I’m hiking in a wilderness area with no one around. The scenery is spectacular in these areas, and I don’t want to see these areas degraded. Hiking in these areas helps my mental and emotional state, and being outside with no man-made noise, tall trees and plentiful plants and animals helps me appreciate life in our fast-paced world. My hikes have helped me get through difficult times in the last 6 years after the death of several family members. I recreate in Nevada’s roadless areas, and I support maintaining the 2001 Roadless Area Conservation Rule and swift passage of the Roadless Area Conservation Act. Rescinding the Rule would fragment wildlife habitat, increase wildfire risk, and threaten clean water supplies. Instead of dismantling a proven policy, USDA should work with stakeholders to refine and strengthen the Rule to adapt to changing fire regimes and local needs while continuing to conserve backcountry recreation opportunities. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative. Thank you, Nancy Alvarez 573 Echo Ridge Ct Reno, NV 89511

It's essential that we keep the Roadless Rule in place. Roadless areas protect drinking water quality, protect communities and forests from wildfires, and provide precious habitat to animals that have lost too much already. My family hikes in roadless areas in the Eldorado National Forest. This is a tradition I would like my children to be able to continue with their children and down the generations long after I'm gone. The surrounding communities and local wildlife also deserve the safety afforded by the presence of roadless areas. Once these areas are logged or have roads carved into them, they will never be the same. Please protect the Roadless Rule, which protects humans and wildlife alike. Thank you for your consideration.

I firmly believe that Alternative 1 (no rescission of the Roadless Rule) is the best option for the American public as it preserves roadless areas, maintains wildlife habitat, and enhances outdoor recreation. Over the last 15 years I have worked for the Forest Service across 3 national forests as a Hydrologist (I am submitting this comment anonymously for fear of retribution). There are approximately 370,000 miles of roads across the national forest system, the vast majority of which are in a deteriorated condition, and I have observed sediment deposits in streams and wetlands from unmaintained roads. The USDA claims that increased road building is necessary to reduce wildfire activity by allowing for fuel reduction projects. This is a misguided theory, as analysis by the Forest Service itself found that 90% of wildfires start within 0.5 miles of a road, and that only 3% begin within roadless areas. More roads = more cars = more sparks, abandoned campfires, and discarded lit cigarette butts. I was evacuated for 18 days during the 2021 Caldor Fire on the Eldorado National Forest, which was caused from target shooting along a Forest Service road. I worked as a fire fighter, resource advisor, and burned area emergency response Hydrologist. There were roadless areas located within the fire perimeter, but in no way did a lack of roads impact fire fighting abilities as other roads were located nearby. I am an avid outdoor recreationist and spend countless hours hiking, backpacking, mountain biking, and skiing across Forest Service lands, the majority of which occur in roadless areas. Constructing roads in these areas would negatively impact these activities. I hiked the entire Pacific Crest Trail, and there are 63 roadless areas along 288 miles of the PCT in California, Oregon and Washington. Loss of these roadless areas would negatively impact my experience due to noise pollution, dust, and habitat fragmentation. I currently live within the Greater Yellowstone Ecosystem, which generates millions of dollars in visitors coming to the area to view wildlife and fish in blue-ribbon streams, both of which would be negatively impacted by constructing additional roads. The money generated from outdoor recreation far exceeds any potential increase in money that would be generated with logging, the vast majority of which would not go into the local economy. I just spent the last 8 days backpacking in the Crazy Mountains of Montana (north of Livingston, MT), which already has a dense road network. Constructing roads in the roadless areas of this mountain range would have negatively impacted my experience. In summary - there are already an abundance of roads across the national forest system, the vast majority of which are in terrible condition and generating excessive sediment that is negatively impacting water quality, and construction of new roads would lead to increased human-caused wildfires and degradation of outdoor recreational experiences. Please do the responsible thing for the American public and DO NOT repeal the roadless rule.

I strongly oppose the proposed wholesale repeal of the 2001 Roadless Area Conservation Rule (“Roadless Rule”). I am a frequent user of the inventoried roadless areas in California’s Sierra Nevada, in particular those adjacent to and near the Carson Pass Management Area. Those inventoried roadless areas are fragile, high-elevation lands that would face significant risk if roads were allowed to be built there, and the proposed repeal of the Roadless Rule provides no analysis and makes no account for those risks. I regularly hike, backpack, camp, and ski in the inventoried roadless areas adjacent to and near the Carson Pass Management Area. That area is bordered on multiple sides by inventoried roadless areas. These lands are highly sensitive alpine and subalpine ecosystems with thin soils, short growing seasons, wet meadows, and headwater streams and lakes. They recover very slowly from disturbance. Motorized use or road building in those areas will cause irreparable harm. The Roadless Rule is a durable, nationwide backstop. It generally prohibits road development in inventoried roadless areas. Without it, the only remaining barrier would be case-by-case decisions at the forest and project level, where pressure for new motorized access can be intense and where protections can be revised or weakened over time. For areas like those bordering Carson Pass, removing the rule invites new road construction and OHV traffic into places that have been spared from them for 25 years. The Department’s statement that repeal “does not mandate” roads or logging misses the point. The Roadless Rule mandates no roads or logging. If the Department wishes to change that mandate, it should do so in a less-intrusive way, such as by requiring site-specific allowances after adequate environmental review and public input. None of that has happened here. A blanket repeal treats 44 million acres of very different landscapes as interchangeable. It does not meaningfully analyze what would happen in specific sensitive places like the high Sierra. Alpine meadows, riparian corridors, and high-elevation lakes support species that depend on undisturbed habitat, including federally-protected species. Motorized access fragments habitat, compacts soils, damages meadows, degrades water quality through erosion and sedimentation, spreads invasive plants, and brings noise and human disturbance into areas used for breeding and foraging. The agency must analyze those changes under NEPA and the ESA, including consultation where listed species or critical habitat may be affected. Deferring all of that analysis to some future local decision does not satisfy the requirement to evaluate the consequences of the action being taken now. Nor does it satisfy the agency's duty under the Administrative Procedure Act to explain its rejection of the record that supported the Roadless Rule. The Department’s justification that repeal will aid in wildfire management is hollow, especially based on recent research (Graber et al., Fire Ecology 22:8) that more roads increase fire risk, primarily because most wildfires are started by people. The Forest Service reached a similar conclusion in its own 2001 environmental impact statement, which found that building roads into inventoried roadless areas would likely increase human-caused fires because of the increased presence of people. The repeal proposal does not explain why that finding no longer holds. The Carson Pass region is fire-prone, and the 2021 Caldor Fire burned through the Eldorado National Forest and into the Highway 88 corridor near Carson Pass showed how quickly a human-ignited fire can devastate these forests and communities. Opening adjacent roadless areas to new roads and OHV traffic would add ignition sources, including vehicle sparks, equipment, and campfires. The Department's main justification to reduce regulatory burden and return decisions to local officials is also suspect. The Roadless Rule was crafted with extensive public process and meetings. None of that has happened here with the proposed repeal. Six weeks have been provided for public input, compared with the many months of comment offered when the Roadless Rule was adopted. Zero public hearings have been held concerning the repeal. The Department must do better before it can legitimately consider repeal. In conclusion, the Department should withdraw the proposed repeal and retain the Roadless Rule in full. If the Department proceeds with its proposed repeal, it must first conduct genuine area-specific analysis of impacts to species, habitat, water quality, wildfire risk, and recreation, and hold accessible public meetings as it did before when the Roadless Rule was enacted.

Please keep the 2001 Roadless Rule in place. My family backpacks around Shealor Lakes in the Eldorado National Forest, and it has become one of our favorite places anywhere. We slept in a tent under the stars for the first time there, and the trail is where we found a community of people who love the backcountry as much as we do. Development in that basin would erase what makes it so worth the hike. Shealor Lakes looks the way it does because people before us chose to protect it. We inherited that choice, and I want the next generation to inherit it too, with the lakes and granite as wild as we found them. Please leave these protections intact.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Escaping to isolated sections of forest is a major part of my recreation, and it is extremely important and valuable to me. I photograph the natural sites that inspire me: forest-covered hills and mountain peaks that are untouched, places that recall the way the land looked for thousands of years before people altered the large majority of it. The areas I am most concerned about include Sespe-Frazier in Los Padres National Forest, where I carry many fond memories of hiking and backpacking in my twenties and which is wonderful for how accessible it remains from the greater LA area; the rugged landscapes of the San Gabriel Add and Arroyo Seco units in Angeles National Forest, which provide an important escape from the nearby sprawl of LA; Pyramid in Eldorado National Forest, a wonderful place to hike and experience beauty and solitude; and Tioga Lake in Inyo National Forest, a place of immense natural beauty. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and these places represent what remains. We cannot restore a landscape once it is destroyed. So little is left already, and we must save what is left for our children and further descendants. Preserving natural beauty and places of solitude should have a higher priority than wealth extraction. That is the principle I ask this agency to apply in reviewing this proposal. The agency offers wildfire management as part of the justification for rescission, but its own findings contradict that rationale. The 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 places I hike and photograph, these untouched forest-covered hills, carry value precisely because they have remained unroaded. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and to 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 economic rationale fares no better on examination. The agency's own record acknowledges: "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 solitude I seek in places like Sespe-Frazier and the beauty I photograph at Tioga Lake are not abstract values; they represent the kind of recreation that the agency's own cost-benefit analysis recognizes as carrying real economic weight. The same 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 spanning negative $92 million to positive $199 million. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal also argues that state-specific approaches can replace a single national rule, but this ground has been tested before. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." California's 4,389,760 roadless acres, including the watersheds that supply 1,034 municipal water intakes across the Pacific Southwest region, were protected under the national framework precisely because local, incremental decision-making was found to gradually erode nationally significant roadless values. How does this proposal avoid the deficiencies the Ninth Circuit identified the last time the agency substituted a state-by-state approach for the national rule? Finally, the proposal contends that the 2001 rule exceeded statutory authority. But the Tenth Circuit addressed that question directly. The court found the rule 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 plainly on what legal basis it departs from that holding. The places I have described are finite. The Pyramid roadless area covers 24,347 acres. Sespe-Frazier covers 106,910. These numbers do not grow back once a road goes in. I ask the agency to answer each of the questions raised above before proceeding further. Sincerely, Erik Krumrey San Rafael, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I have been hiking and skiing in the pyramid peak area for the last 10 years and value the forests, lakes, and natural beauty it holds. The grays creek area has amazing forests and is a special place to ski. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Pyramid (24,347 acres), Eldorado NF, California - Rose - Gray Creek (366 acres), Humboldt-Toiyabe NF, Nevada 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 small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. 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 outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 3: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. 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 4: Foreseeable plan amendments are placed beyond scope I ride through the interior of these areas, and what future plan changes would open is not an abstraction to me. I raise this because the agency put that future beyond 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 commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. 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, Spencer Eusden Tahoe City, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet is what I go for: the birds singing, water moving, twigs breaking underfoot. I hike and camp to hear those things, and I kayak on lakes because the stillness is grounding in a way that nothing else is. I have paddled Loon Lake in the Rubicon roadless area of Eldorado National Forest, where my fiancee's family has a tradition of going every year, and I was struck by how few other people were on the water. I have backpacked Black Butte in Los Padres National Forest with friends, drawn by its vistas and by the distance it puts between me and human-made noise. Both of those places exist because a rule has protected them. This comment opposes the rescission of that rule. The birds I listen for are not incidental to this argument. The agency's own draft environmental impact statement acknowledges the 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. Rubicon and Black Butte hold what those experiments measured: quiet that sustains abundance. Roads end that. I ask the agency to explain, specifically and on the record, how rescission can be squared with the bird abundance and richness findings its own DEIS cites, and what mitigation, if any, it proposes for the forested roadless habitat those species require. On wildfire, the agency's own text 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 offers wildfire and fuels management as a justification for rescission while its own record reports a human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, figures drawn from DEIS Table 21 covering 2014 through 2024. The DEIS further states that human-caused ignitions increase in abundance with proximity to roads. The agency must quantify the expected increase in human-caused ignitions that new road access would bring and weigh that figure against whatever reduction in wildfire hazard it claims to achieve. The road maintenance numbers make the proposal harder still to defend. The agency carries a backlog measured in billions against an annual road budget of roughly $73 million. It is illogical to push road construction into country that has none when the roads already built cannot be maintained on current funding. I agree with that logic, and I ask the agency to explain why it does not. 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. The drinking water consequences of rescission for California communities are documented in the agency's own analysis and deserve a direct response, not a general assurance. 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 is reached by spreading expenditure losses across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas. The agency should withdraw that certification and assess the impact on the firms that will actually feel it. Finally: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The traditions built around Loon Lake, the trips to Black Butte, the expectation that these areas would remain unroaded because a rule said so, are exactly what an agency changing course is required to identify and weigh. The agency must account for the reliance interests described in the comments it receives, including this one. Sincerely, Maija Wigoda-Mikkila Pacifica, CA

I am writing to urge the U.S. Forest Service to keep the 2001 Roadless Area Conservation Rule in place and reject the proposal to rescind it. My family and I backpack around Shealor Lakes in the Eldorado National Forest. It is where my children slept in a tent under the stars for the first time, swam in cold granite lakes, and learned to carry what they need on their backs and leave no trace. The Roadless Rule protects that area from road building, logging, mining and drilling. Places like it are rare, and they become rarer every time a protection is lifted. I am also a small organic farmer in Santa Clara County, and like every farmer in California, I depend on healthy Sierra Nevada watersheds. Roadless forests protect the headwaters that supply clean water to farms and cities downstream. Roads bring erosion, sediment and more human-caused wildfire starts into these areas. Repealing the rule would put the water and safety of people far beyond the forest boundary at risk. The Roadless Rule was adopted after one of the largest public comment processes in U.S. history, and it has protected these lands for more than two decades without blocking access for hiking, hunting, fishing or camping. Rolling it back would permanently change places that cannot be restored for our children once roads are cut into them. Shealor Lakes was handed down to my generation intact by people who chose to protect it. I am asking you to make the same choice for my children's generation. Please keep the 2001 Roadless Rule in full effect. Sincerely, Rashmi Bachrach San Jose, California

I minored in outdoor recreation in college. Then, worked for 6 years, from 2010-2016, in the outdoor industry for a local southern California company selling retail and wholesale outdoor recreation products like backpacks, boots, tents, and snow shoes. We also rented used gear locally at very low cost so more people could experience the outdoors at any price point. The purpose and mission was to grow an outdoor community that would return again and again to both the great outdoors and our stores for reliable gear and advice. Our stores, and the $1.3 trillion U.S. outdoor recreation industry as a whole, rely on access to public lands and pristine wild spaces. The 2001 Roadless Area Conservation Rule protects roughly 4.0 to 4.4 million acres (about 20% to 21%) of California's national forest lands across Inventoried Roadless Areas (IRAs). The federal proposal to rescind the Roadless Rule impacts pristine and undeveloped forest regions statewide, spanning Northern, Central, and Southern California national forests. Rescinding protections of these public lands like the Roadless Rule will have direct economic impacts on the outdoor recreation industry and recreation community nationwide, everyday Americans making a living and enjoying this great land, our greatest heritage. Some of the impacted National Forests and regions I have directly spent time in will be impacted by rescinding the Roadless Rule: • Southern California: Protects over 1 million acres across the Angeles National Forest, Cleveland National Forest, Los Padres National Forest, and San Bernardino National Forest. I have personally spent countless hours and numerous camping trips in these national forests. I have introduced friends and family to the joys of backpacking, camping, and hiking here. They are absolutely remarkable areas and at risk from fires and encroaching development. • Sierra-Cascades & Central California: Covers high-elevation conifer and old-growth zones in the Eldorado National Forest, Inyo National Forest, Lassen National Forest, Sierra and Sequoia National Forests, Tahoe National Forest, and roughly 200,000 acres around the Lake Tahoe Basin Management Unit. I have camped and backpacker with my family most summers since 2007 in the Inyo National Forest. It is a treasure. This is where I introduced my sister to backpacking and my husband to snow camping in the early spring. All of the small outdoor shops and guiding services along Highway 395 depend on these wild spaces remaining pristine and accessible. I now live in Washington State and absolutely love the mountains and forests here, too. I climb, hike, and mountain bike in them nearly every weekend. The Roadless Rule protects parts of six major national forests across Washington, including the following where I personally spend time enjoying the outdoors on public land: • Mount Baker-Snoqualmie National Forest, • Okanogan-Wenatchee National Forest, • Olympic National Forest, • Giffort Pinchot National Forest. I am an American taxpayer and the Roadless Rule matters to me personally. It also matters to the Outdoor Industry which provides jobs and income to countless people across the country, jobs that will exist even as AI grows and other industries suffer. People need access to America's wild spaces, its undeveloped serenity, and its pristine beauty now more than ever. Once lost, this great heritage of wild public spaces will be gone forever. For biodiversity, for mental and physical health, for decreased fire danger, for present stewardship, and for future generations, please do not rescind the Roadless Rule. It was and remains wildly popular among voters and American citizens. Thank you for your consideration.

Subject: Keep the 2001 Roadless Rule Intact (Docket FS–2025–0001 or RIN 0596-AD66) I am writing to urge you to keep the Roadless Rule in place and oppose the proposed rescission. Instead of an overly broad repeal, the agency should pursue targeted improvements to the Roadless Rule that strengthen wildfire resilience and recreation access, while keeping its strong safeguards in place. I have a great concern based on years of firefighting and prescribed fire use that building new roads or opening old roads will only add to fire problems not curtail them. My background; 34 years as a Forest Service employee (retired Forest Fire Staff, Type 1 Incident Commander, Operations Section Chief and Prescribed Fire Manager) 21 years as a California State Deputy Fire and Rescue Chief. I will use the Eldorado National Forest as an example of fires and road access. There are about 3000 acres of current or disused roads that could be used to access the forest and where the large fires have started. Currently on the Eldorado NF and other Forests where there are no roads-the Roadless Rule areas- are either to steep or rocky, burned over or have nothing of commercial value that would justify the costs of building road. The recent fire history of the Eldorado NF illustrates the proximity of roads and large fires is not an abstract concept. 1959 Ice House Fire 18600 acres burning logging slash off of Granite Springs Road 1959 Javbird Fire 7600 acres burning logging slash off of Ice house Road 1973 Park Fire 900 acres arson fire started on Camp Creek Road 1973 Pillikan Fire 10000 acres (1 firefighter fatality) started on the Mormon Emigrant Trail 1981 Wrights Fire 3600 acres vehicle fire highway 50. 1992 Cleveland Fire 24580 acres (2 airtanker pilots, killed 41 structures burned) Fire started on Ice House Road from driver throwing burning debris from vehicle. 2004 Power Fire 17000 acres Utility workers working on power lines accessed by the road to Salt Springs Reservoir. 2004 Freds Fire 7600 acres Utility workers working on power lines on highway 50. 2014 King Fire 91700 acres (80 structures destroyed 12 civilian injuries) arson started off of King Rd in Pollock Pines. 2021 Caldor Fire 221835 acres (1005 structures destroyed major damage to Sierra at Tahoe Ski area) human caused start off of road near Omo Ranch. A scientific study, published by members of the Wilderness Society in Springer Nature’s Fire Ecology Journal, examined patterns of fire size in a nationwide dataset of U.S. Forest Service regions from 1992 to 2024. The researchers found that the highest wildfire-ignition density among the lands studied was in lands within 164 feet of roads, at just under 8 fires per 2,471 acres, while the second highest wildfire-ignition density was in other national forest lands outside the 164-foot buffer, but not in wilderness or roadless areas, at 3.5 fires per 2,471 acres. Wildfire-ignition density was at its lowest in designated wilderness areas without roads, at 1.75 fires per 2,471 acres. In my years of experience of wildland firefighting roads can be helpful for suppressing fires depending on fire intensity. All of the fires except the Park Fire burned over roads and dozer lines until either a change in fuels, topography and or weather reduced the spread of the fire. Adding more roads in the current roadless areas is an invitation to human carelessness or intent to do damage to our national forests. In California, about 86% of wildfires are human-caused, with ignition risk four times higher near roads. The lands protected by the Roadless Rule were identified for their critical role in safeguarding clean water, providing wildlife habitat, preserving Tribal cultural resources, and offering cherished backcountry experiences. They also sustain thriving recreation economies while supporting community safety through wildfire prevention, firefighting access, and road maintenance. The Forest Service already manages roughly 380,000 miles of roads across the National Forest System, much of which it does not have the resources to maintain. The Forest Service since the 1980’s has reduced the capacity to maintain even the most used roads. More roads will increase forest fragmentation, erosion, invasive species, and wildfire risk. The Roadless Rule strikes the right balance: it allows managers to reduce fuels and protect communities while maintaining a consistent national safeguard against unnecessary new roads. Please reject this broad repeal and preserve the Roadless Rule. Sincerely, Scott Vail 240 Judy Drive Placerville, California 95667 530 748 5438vail.s@sbcglobal.net

I am a resident of South Lake Tahoe, California. I hike year-round in the national forests around the Lake Tahoe Basin, and I regularly camp and hike with my dog on trails and in undeveloped country that stay quiet because they are not laced with new roads. I oppose the proposed rule to rescind the 2001 Roadless Area Conservation Rule by removing and reserving 36 CFR part 294, subpart B. I also oppose the draft EIS preferred alternative that would eliminate national roadless protections on inventoried roadless areas, including those on the Lake Tahoe Basin Management Unit, Tahoe National Forest, Eldorado National Forest, and nearby Humboldt-Toiyabe lands. These are the places that make living here worth it. I use local trails and high country near South Lake Tahoe — including walks along the Upper Truckee and routes into the meadows, ridgelines, and backcountry that sit behind and above town. I take my dog camping and hiking in settings that still feel like forest, not a project area. Roadless protections are a big part of why those trips stay quiet, why streams run clearer, and why I can get off a trailhead and be in intact country within a short drive of home. The 2001 rule does not lock these forests up. It already allows hiking, camping, hunting, fishing, existing road maintenance, Tribal uses, firefighting, and wildfire-resilience work, including thinning and fuels treatments. Hundreds of thousands of acres of California inventoried roadless areas have been treated since 2001. Local examples, including work in the Caples Creek area before the Caldor Fire, show that the current rule can accommodate fuels reduction without opening the last intact forests to a new road network and industrial logging. If the problem is implementation or funding for treatments already allowed, that is not solved by deleting the national standard. What the proposed rescission would change is the default. Decisions would fall to individual forest plans and project-by-project review on more than 44 million acres nationwide, including roughly 4.4 million inventoried roadless acres in California and tens of thousands of acres in the Tahoe and Plumas country. Around Tahoe, that includes inventoried roadless ground on Tahoe National Forest (on the order of 147,000 acres in the original inventory, including Castle Peak and Grouse Lakes) and on the Lake Tahoe Basin Management Unit. New roads and commercial harvest in those areas would bring erosion into headwaters that feed Lake Tahoe, more sediment and noise on trails I use with my dog, and a slow conversion of quiet backcountry into managed access corridors. The draft EIS itself identifies potential water-quality, habitat, and quiet-recreation effects where roadbuilding and timber cutting occur. Those are not abstract impacts here. They are the difference between a Saturday hike and a Saturday next to a new road cut. Local forest planning is important. It is not a substitute for a national sideboard on the last large undeveloped national forest blocks. The Forest Service is already stretched. Shifting every roadless decision to plan revision and project NEPA does not create more capacity for careful public involvement; it creates more pressure to punch roads for access, timber, and “management” in places that have stayed roadless for a reason. I support active fuels work where it is needed, including near communities and in the wildland-urban interface around South Lake Tahoe. I do not support repealing the 2001 rule in its entirety in order to get that work done. The rule already allows it. Please retain the 2001 Roadless Area Conservation Rule, reject the proposed removal of 36 CFR part 294, subpart B, and select the no-action alternative in the final EIS. Thank you for considering my comments. Andrew Scott-Jester South Lake Tahoe, CA

Dear Chief: I am fortunate to live in an area that has easy access to the Lake Tahoe Basin Management Unit and the El Dorado and Humboldt-Toiyabe National Forests, and they are all spectacular places. I want the Department to understand that rescinding this rule forecloses something genuinely public and genuinely irreversible. The Caldor Fire in 2022 required us to evacuate. The Forest Service and CalFire used existing roads to combat the fire. I can see the destruction caused by the Caldor Fire from my home. There is active land management underway in adjacent and nearby areas that were not burned, and has been possible despite the existence of the roadless rule. Rescinding it will not make fire suppression or control any better. Regarding the Dardanelles in the Eldorado National Forest, California: Within Eldorado National Forest, the Dardanelles IRA provides habitat for Sierra Nevada Yellow-legged Frog (Rana sierrae, G2), a species subject to 7.1 - Fire & fire suppression — a threat assessed at not assessed severity affecting not assessed of the population. "We document over a one-quarter decline in bird abundance and almost complete avoidance by some species between noise-on and noise-off periods along the phantom road and no such effects at control sites—suggesting that traffic noise is a major driver of effects of roads on populations of animals. We replicated the sound of a roadway at intervals during the autumn migratory period using a 0.5 km array of speakers within an established stopover site in southern Idaho." — Proceedings of the Royal Society B: Biological Sciences (PMC), 2013 Road networks serve as vectors for the secondary impacts classified under 7.1 - Fire & fire suppression: they open previously inaccessible terrain to resource extraction, facilitate introduction of invasive species, and concentrate human disturbance along corridors through Sierra Nevada Yellow-legged Frog habitat. The roadless areas are critical to the overall heath of our environment. Proper fire and land management is not curtailed by the existence of the roadless rule. With kind regards, CommentID: RLC-20260927-8UUFBC

Please rescind the roadless rule and open our forests to motorized recreation,dispersed camping and forest thinning projects. Many people think our current environment protection laws protect our forests,wildlife and water quality.After 5 decades of hiking,biking,skiing,fishing,dirtbike riding and dispersed camping in Eldorado National Forest I've found that what is not burned is horribly overgrown and could be the next wildfire! I believe the fires and overgrowth have been caused by overly zealous environment protecting non profits and the donating overly emotional public suing the USFS using our innapropriatley written environment protection laws which doesn't allow the USFS to do their job! The Wilderness act doesn't allow for fire protection.Example-The Tamarack Fire which could have been put out with a hand crew burn't 68,637 acres and devastated Alpine counties scenic wonder land and threatened Markleeville Ca. and Topaz Ranch Estates Nv. Endangered Species Act closed Northern Californias forests to logging for 40 years which led to devastating logging based communities,mills closing,a monopoly by Sierra Pacific Industries and an overgrown forest which led to 18 million acres burn't in Northern Ca. between 2015 and 2024! it took biololigists 40 years to figure out the spotted owl was in jeapordy from it's natural enemy the barred owl.By the way thse fires caused home owners insurance and power bills to have huge increases! The Roadless act caused the USFS to close every dirt road and trail that wasn't on their maps. What it did to my family and other forest recreationists and loggers was close our dispersed camp areas,firewood cutting areas,motorized travel and and mechanized thinning! These are but a few examples of the inequity of our laws! If we want a healthy forest we need to modify or lose our environment protection laws.We need to allow the USFS to properly manage our forests.

I urge you not to repeal the 2001 Roadless Rule. Some of my family's most meaningful time outdoors has been spent backpacking around Shealor Lakes in the Eldorado National Forest — country that remains pristine today precisely because the Roadless Rule has kept it safe from logging, mining, drilling, and road construction. It is where we built community, experienced nature, and slept in a tent under the stars for the first time. These lands were preserved and handed down to us by the generations before, and we have an obligation to pass them on intact. Repealing the Roadless Rule would open irreplaceable backcountry to permanent damage for short-term gain. Please keep these protections in place.

I urge you not to repeal the 2001 Roadless Rule. Some of my family's most meaningful time outdoors has been spent backpacking around Shealor Lakes in the Eldorado National Forest — country that remains pristine today precisely because this rule has kept it safe from logging, mining, drilling, and road construction. It is where we built community, experienced nature, and slept in a tent under the stars for the first time. Repeal would also cause concrete harm. Forest roads are a major source of sediment in headwater streams, and roadless areas protect watersheds that supply drinking water to communities across California. And if the goal is better fire management, repeal works against it: most wildfires in California are human-caused, and human ignitions cluster along roads. Building roads into intact backcountry adds ignition sources to terrain that is currently among the least likely to burn. The Forest Service also cannot maintain the road system it already has. Adding more miles to a backlog measured in billions of dollars is not a serviceable plan. These lands were preserved and handed down to us, and we have an obligation to pass them on intact. Please keep the Roadless Rule in place.