Read the comments.

I support Alternative 1: keep the Roadless Rule in place. Some of my favorite trails for hiking and biking sit within the George Washington National Forest. I love having a beautiful, wooded place to connect with nature and get exercise. Please protect these rare and cherished areas.

I strongly support Alternative 1, to maintain and protect the roadless areas! The remote nature of the George Washington National Forest provides critical resources and protection for wildlife, as roads lead to soil disturbance and erosion plus opportunities for invasive species introduction and spread, vehicular collisions causing death/injury to all species from small to large, and noise and other pollution. Please protect roadless areas!

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Green Mountain, the White Mountain, Piscah, George Washington, and Je!erson National Forests (to list a few) are where I go for my spirit to feel wild, for peace of mind. That is the plain reason I oppose this rescission, and I want the agency to read these concerns carefully. Protecting wilderness (as through the Roadless Rule) is a moral imperative. In the words from Edward Abbey's Desert Solitaire, "Wilderness is not a luxury but a necessity of the human spirit, and as vital to our lives as water and good bread. A civilization which destroys what little remains of the wild, the spare, the original, is cutting itself o! from its origins and betraying the principle of civilization itself." I'm deeply concerned for the vistas, mountain creeks, and forests I've lived and loved in my entire life. Elliott Knob, inside the George Washington National Forest in Virginia, is a serene place. Enough accessible roads sit close by, yet it remains far enough into the wilderness to stay wild. That balance is what the 2001 Roadless Area Conservation Rule protects. Virginia holds 64 inventoried roadless areas totaling 393,682 acres. Elliott Knob at 9,380 acres is one of them, alongside Crawford Mountain at 9,892 acres, Saint Marys Addition at 1,454 acres, Adams Peak at 7,135 acres, Rough Mountain Addition at 1,142 acres, and Jerkemtight at 16,687 acres, all in the George Washington. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing a!ected roadless areas. Roads bring sediment. Rescission puts those intakes at greater risk, and I want the agency to say plainly how it intends to protect those drinking water sources if this rule falls. The agency's own record undermines its wildfire rationale for rescission. The 2001 rule states: "Building a road into a forest at high risk from uncharacteristic wildfire e!ects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why this proposal departs from that prior finding 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 a!ected roadless areas. The economics do not hold up either. The agency's own record acknowledges: "the total timber volume a!ected 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." It does not make sense to ignore the billions of dollars inmaintenance backlogs on roads already accessible to the public. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying a $6.9 billion maintenance backlog on a budget of roughly $73 million a year? The agency must reconcile those numbers in this record before proceeding. The agency argues that state-specific approaches can substitute for a national rule. But the agency's own prior record states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide approach.' 70 Fed.Reg. at 25,656." That experiment was tried before and failed judicial review. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state scheme. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. The Weeks Act of 1911, which authorized federal purchase of private land for national forests, was passed because of what happened when New England's mountains were clearcut. I have hiked those forests. I know what is at stake. The agency should leave the 2001 rule in place. Sincerely,

My family lives in Harrisonburg and we care deeply about the George Washington National Forest Area and value the Roadless Rule, which impacts our enjoyment of the national forest as well as the quality of the drinking water we have in our city. I am writing to petition you to keep the Roadless Rule in place. The temperate ecosystem of the national forest is one of interdependence-a variety of plant and animal species can be found among it and each plays a special role in keeping this ecosystem healthy. A healthy ecosystem means clean water and air for us, which we depend on! In our learning about forest ecosystems with our daughters, we have been constantly naming the benefits of trees and forests-how they help keep water supplies clean, provide food sources and shelter for many species, and how trees have a very important role in "eating" carbon dioxide in the photosynthesis process and storing it in the earth rather than allowing it to build up even more in our atmosphere. On Shenandoah Mountain, our roadless areas are home to black bear, rare salamanders, and 250 species of birds, just to name a few. We value these species and think it is a gift to have opportunities to encounter them in their natural habitat. We recognize and name the ways human consumption and greed is increasingly making their habitats smaller and threatening their existence. The roadless rule helps to create areas that are protected habitat. We name the benefit of this to these specific species as well as to us, because we are not disconnected from the wildlife around us. We too depend on our forests for clean water and air and also for the natural beauty and undisturbed recreation they offer. Both of our daughters attend forest school programs, which utilize areas in George Washington National Forest for nature learning and observation. I am concerned about how rescinding the Roadless Rule will impact wildlife and how we can observe it. It is a treasure to have undisturbed natural areas around us and we do not take it for granted. By eliminating the Roadless Rule, there will be too many opportunities to obstruct this fragile and valuable ecosystem on Shenandoah mountain. The water we drink comes from streams in the roadless area; because the ecosystem in these roadless areas is able to better clean the water and the water sources aren't as tainted by pollution, the water does not require a high level of treatment to be safe. This is of economic value to our city and ideal for our health. We'd like to keep it this way. When new roads are introduced, the soil is greatly disturbed and it creates prime opportunity for invasive plants to enter into a pristine area. There is no remedy for this impact and it will harm the ecosystem that is there. In addition to this, I am concerned with how adding roads to these areas will lead to more off-road vehicles using the space and therefore causing more noise, more damage to fragile areas, more erosion, more litter, and less solitude. Because of this, I ask you to please NOT rescind the Roadless Rule. There are plenty of areas in our national forest area where there is already road access. If you must do logging, you can use what is already there. Do not go to our roadless areas and taint what has been preserved-our forests are valuable. We hope these wild places will be wild for generations to come. We strongly implore you to NOT rescind the Roadless Rule.

10/6/2026 Dear Forest Service, Please do not rescind the Roadless Rule. As a lifelong Virginian, I believe roadless areas are essential for our state. They supply fish and wildlife habitat we can secure nowhere else, they are sources of drinking water for nearby communities and millions more downstream, and they are loved places for outdoor recreation. All of these values and resources benefit our quality of life and economy in Virginia. I grew up on a farm in southern Augusta County, in the Shenandoah Valley, and still live in the area. The George Washington National Forest – and roadless areas specifically – is the scenic backdrop to Valley communities and a refuge for locals and visitors alike. Areas like Kelley Mountain on the east side and Elliott Knob, Crawford Mountain, Little River, Oak Knob, Gum Run/Dry River west of the Valley are popular places to get out for a hike or mountain bike ride, run the dog, camp, fish, or just quietly enjoy these beautiful mountain forests. As a fly fisher, I know our Virginia roadless areas have some of the best native brook trout habitat left in the entire Southern Appalachian region. Our communities also benefit from the scenic beauty and outdoor recreation opportunities that roadless areas provide to our area, where drawing visitors for tourism and recreation is critical to the local economy. Beyond the benefits to Virginia, the national Roadless Rule should remain in place. The rule represents a balanced approach to managing our national forests. All Americans benefit from a consistent approach that sets this strong base level of protection for all roadless areas. Fish and wildlife and water resources often move across state lines. I want to have the opportunity – and all Americans deserve the same opportunity – to visit and enjoy roadless areas in other states, across the public National Forest System. The rule is also incredibly popular. I would be hard-pressed to identify any single issue on which 99% of Americans agree, but the public comment numbers shows that 99% of those who have expressed an opinion to the Forest Service agree that the Roadless Rule should stand. This support has not wavered since the agency began developing the rule in the 1990s, in fact, support may have grown. The popularity of the rule belies the agency’s claims that local Forest Service officials should make decisions for roadless areas in their bailiwick, informed by input from stakeholders, communities, and local, state, and tribal governments. Many voices have already spoken up strongly for keeping the nationwide Roadless Rule in place. If the Forest Service actually intends to listen to the public, then it should withdraw this misguided proposal to rescind the Roadless Rule. The Forest Service should retain the Roadless Rule of 2001 in entirety. Thank you for considering my comment. Sincerely, Sarah Francisco Staunton and Lyndhurst, VA

I support Alternative 1: please keep the 2001 Roadless Area Conservation Rule in place. I [ride / hike / hunt / fish] at [place] in the George Washington National Forest, and wild, roadless places like it are why I [live in / visit] the Shenandoah Valley. These areas protect the headwaters that supply our drinking water, including Harrisonburg’s Switzer Reservoir, and they support the outdoor recreation economy our communities rely on. The Forest Service already can’t maintain the roads it has. Please don’t add more. Keep the Roadless Rule intact.

Ten years ago, I moved from an urban area to the Shenandoah Valley after spending years driving out to hikes out here. I wanted to be near untouched areas, clean water, wildlife, and recreation in the George Washington National Forest and to be closer to the roadless areas on Shenandoah Mountain provide. I joined a naturalist group so I could understand the ecology here better and to get trained to take on exciting and impactful volunteer projects to support this beautiful land. There are more fires near areas with roads and conflicts between cars and animals. The GWF has the most and the largest roadless areas. These areas are special and biologically rich and have been successfully protected from logging and development for years. The habitat deserves protection as we encroach more and more in undeveloped lands. Our Valley towns deserve clean water and we are downstream of these roadless areas. Our community members and tourists deserve to have beautiful unique places to explore recreationally. We have something special here to share with others and when they visit, they spend money to support our local economies. Please do not proceed with the rescission of the roadless rule. Once you move forward with it, there’s no going back and too much to lose.

I am writing to voice my strong support for maintaining the 2001 Roadless Area Conservation Rule and to urge the Forest Service to select Alternative 1: No Action. As someone who frequently hikes in the George Washington National Forest, I know firsthand how invaluable these intact, roadless backcountry areas are. The peace, solitude, and rugged natural beauty found along these undisturbed trails cannot be replaced once they are split apart by industrial development. Protecting the roadless areas within the national forests is vital for several reasons: • Preserving Trails: Backcountry hiking trails depend on intact forest ecosystems to maintain their scenic value and prevent severe trail erosion. • Clean Water: These undisturbed tracts safeguard crucial watersheds and supply clean drinking water for millions of communities downstream. • Wildlife Protection: Roadless areas provide a safe, connected habitat for native wildlife away from the disruptions of vehicle traffic. • Wildfire Prevention: Research shows that human-caused wildfires are significantly more likely to start in areas with roads than in intact, roadless forest tracts. • Fiscal Responsibility: Building new roads burdens taxpayers, especially considering the Forest Service's already massive, multi-billion-dollar road maintenance backlog. Please listen to the outdoor recreation community and keep the Roadless Rule fully intact to protect places like the George Washington National Forest for generations to come

I support Alternative 1: keep the Roadless Rule in place. I have lived in the Shenandoah Valley for over twenty years and have spent countless hours fishing for wild brook trout in the mountain streams of George Washington National Forest and mountain biking its many trails. Losing the roadless rules would put much of that in jeopardy. Please leave the roadless rule intact.

To the Forest Service: I am writing to oppose the proposed repeal of the 2001 Roadless Area Conservation Rule and to urge the agency to adopt Alternative 1, which keeps the rule in place. One of the greatest and most valuable resources this country has is its extensive network of public lands. Public lands are owned by all and provide value for all stakeholders. I have grown up largely on the East Coast. One of the first trips I took once I got my drivers license in high school was to drive to George Washington National Forest and fly fish on the Dry River. I didn't know how to fly fish, but I wanted to learn, and this area of public land afforded me that opportunity. I went back multiple times to that same National Forest, always hiking deeper and exploring new sections of river, and since that time I have gone to many more public land areas. The Linville Gorge Wilderness area in North Carolina has afforded me some of the greatest adventures of my life, and I hope one day to bring my children there and to many other public lands. These places exist and have resisted the encroachment of human civilization because politicians in the past have had the courage to protect them. The current proposal seeks to remove protections from roughly 44.7 million acres of national forest land, covering all roadless areas outside Colorado and Idaho. That is a vast share of the last wild backcountry in our public forests, and it belongs to all Americans, not just to those who live near it or profit from it. I understand the stated rationale: that the rule hinders wildfire mitigation and forest health work. But the record does not support it. The rule already contains exceptions that allow the agency to build roads in inventoried roadless areas when needed for firefighting, and it allows certain hazardous fuels work. The Forest Service's own research found that forests with and without roads burned at similar rates since the rule took effect. If this repeal is really about forestry health and management and fire mitigation, then why not state that? Why not propose evidenced based legislation aimed at fire mitigation strategies that are backed by science? I fear that repealing the roadless rule would place these inherently pristine areas of backcountry at an existential level of risk with marginal, if any benefit. Roadless areas are also an economic asset. Hunting, fishing and backcountry recreation support rural businesses, outfitters and guides, and local communities, and they depend on exactly the kind of undeveloped land this rule protects. That value is lost the moment an area is opened to logging and road construction. I learned in elementary school to revere Teddy Roosevelt. Roosevelt had the controversial and courageous idea that the U.S. had a lot of areas worth protecting. And if he didn't protect those areas, then their value and worth would be gone forever. Overwhelmingly public sentiment is in favor of protecting these areas from road building and industrial interests. If the interests of a few wealthy and powerful interest groups outweigh the overwhelming public sentiment that opposes road building, then I would argue that's not very democratic. And the legacy of this administration will be one of ecological pain and destruction that will not be revered by those who come behind us. I urge the Forest Service to select Alternative 1 and keep the 2001 Roadless Rule in place.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Vernal pools hold time still. Kneeling at the edge of one to record frog eggs and salamander larvae, watching the water catch light through an unbroken canopy, I understand exactly what is at stake in this proposal. I am a volunteer wildlife monitor for vernal pools, those ephemeral bodies of water that are home to the eggs and larvae of frogs and salamanders. Several pools I monitor are in the Jefferson National Forest. These pools, and the animals that use them, depend on a healthy forest ecosystem, which means an intact forest. I also use the Jefferson and George Washington National Forest to hike, camp, photograph the natural world, and soak in the wonder of these special places. I go roaming in the forest with my grandchildren and introduce them to what I can only call magical ground. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that the agency take my concerns seriously and answer them in the record. The agency justifies this rescission in part on wildfire and fuels management grounds, but its own prior findings cut directly against that rationale. The rule's 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 vernal pools I monitor in the Jefferson depend on a stable forest structure that repeated ignitions would degrade, and the salamanders and frogs that breed in those pools have no refuge if the surrounding forest burns at uncharacteristic intensity. The agency must explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and it must reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic justification for this rescission is equally difficult to square with the agency's own analysis. The record before the agency states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and the road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. The forests where I monitor pools and hike with my grandchildren generate real, lasting value for people precisely because they remain intact. The agency must explain on the record how an action whose own economic analysis cannot establish a net benefit justifies expanding a road network the agency cannot currently afford to maintain. The agency also argues that state-specific approaches can substitute for the national rule, but this ground has already been tested. The record reflects that the USDA previously "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-by-state approach was challenged and rejected in court. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and must explain how this proposal avoids the deficiencies identified the last time it substituted a patchwork of state rules for uniform national protection. Finally, the agency's suggestion that the 2001 rule exceeded its statutory authority is contradicted by judicial review of precisely that question. The court 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 Tenth Circuit upheld the rule as within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the public a plain statement of the legal basis for any position contrary to that holding before it proceeds further with this rescission. Sincerely, Alison Nichols Roanoke, Virginia

I am opposed to the proposal to rescind the 2001 Roadless Area Conservation Rule. For 25 years it has served well the country's forests, and the rivers and streams that originate and flow through those areas. In the central Shenandoah Valley where I live, we depend on the waters that flow from the George Washington National Forest (GWNF) for our community water supplies as well as to nourish our agricultural production (largest agricultural counties in Virginia). Protecting the forests and watersheds from erosion and sediment runoff that roads create is central to this productive area. The forests and waterways in the area also are central to the variety of outdoor recreational activities that locals and visitors enjoy - hunting, fishing, birdwatching, hiking, and canoeing. Wildlife and fish cannot thrive in habitats cut up by roads that bring in invasive species and contribute to wildfires (more wildfires and invasive species problem areas are adjacent to roads). These outdoors activities also contribute significantly to the local economy. If the forests are further damaged by additional road construction through them, wildlife habitats are threatened, and hunting and fishing are impaired. At this time of limited US Forest Service funding, as evidenced by staffing shortages across the service nationwide, eliminating the Roadless Area Conservation Rule also does not make sense fiscally. Road construction in mountainous areas is expensive and maintenance of those roads also is difficult and expensive. The Forest Service is unable to adequately maintain the roads that currently exist in the national forest system. I read the stated reasons for this proposed change and they include statements that indicate the changes will not substantially impact in a negative way these protected areas and their management will be put under a decentralized system of management plans. However, I take no assurance in those statements, as we have long advocated for the GWNF that borders us to be further protected from road development and commercial timber harvesting - not for the protections to be reduced. We opposed pipelines through the area, knowing how they would cause erosion and clog the rivers and streams with sediment - and adversely affect our water supplies. I love hiking in the GWNF. I love the wildlife and deep forest vegetation. I am opposed to ending the 2001 Roadless Area Conservation Rule - it has proven to be a great success. Why rescind it?

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Waking up to cars covered in ash, wearing N95 masks to school, being told to stay indoors: that is the reality I lived through during California's fire seasons, most of them ignited near a road line. Human-generated fires, from forest roads, shaped those years. That experience is why I cannot support rescinding the 2001 Roadless Area Conservation Rule, and why the agency's stated justifications for doing so upsets me as deeply as it does. The agency frames rescission partly as a wildfire management measure. Its own record says otherwise. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I watched that dynamic play out with my own eyes across Tahoe, Big Sir and Yosemite, California. I ask that the agency explain why the proposal departs from this finding, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I fish rivers in Virginia and the Kenai River of Alaska. After logging and other industrial projects, I have seen a reduction in natural salmon habitats and watched river banks erode away, taking homes with them. That observation tracks what the agency's own documents record. The DEIS notes that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and that warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, in areas that include Essential Fish Habitat and critical habitats managed by NMFS. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, and across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own DEIS states that 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." That number appears in the document and then 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 before any final action is taken. I also ride and camp in the George Washington National Forest. The economic case offered for rescission does not hold up against the agency's own figures. The record states 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." The agency's Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Finally, the agency cites permitting and administrative burden as grounds for rescission. The rule as written already accommodates the situations most often cited. It 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)." The agency has not identified which specific burdens fall outside those existing exceptions. It should do so, in specific and quantified terms, before proceeding further. I often bird watch for pileated woodpeckers and Steller's jays. I fish for trout, bass, salmon and catfish. I ride my bike in the George Washington national forest. This rule is not abstract to me, and the agency's own numbers do not support removing it. Sincerely, Dean Harrisonburg, VA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The George Washington National Forest is where I go to recharge. I hike and camp there, and fall is my favorite season because of the mild temperatures and the colorful leaves. The forest is peaceful because there aren't many roads there. Southern Massanutten, where I live, is part of that beauty. Adding roads would drastically change this environment. I am asking you to keep the Roadless Rule fully intact. I love watching and listening to birds in the forest. Their calls are calming, and research has shown that listening to birds can reduce stress levels, positively impact mood, and improve cognitive function. The agency's own environmental analysis confirms what I experience: 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. I also watch deer in these woods. The DEIS itself cites research finding that roads built for resource extraction may have altered mule deer migration routes and increased their movement speed, with the agency's own analysis identifying disrupted migration and lost unroaded security as the danger. Virginia holds 64 inventoried roadless areas totaling 393,682 acres, including Southern Massanutten, Gum Run, Oak Knob, Dry River, and Skidmore in the George Washington. Every road opened into these areas narrows the habitat birds and deer depend on. I ask the agency to explain, with specificity, how this rescission is compatible with what its own DEIS documents about roads and wildlife. Nothing is more important than clean drinking water. Rescinding the Roadless Rule would negatively impact the safety and availability of drinking water, and that is unacceptable. Across the Southern region, which includes Virginia, 378 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. Opening these roadless areas risks the majority that are still clean. The agency must explain what it intends to do to protect those watersheds if the rule that protects them is gone. If a road went into Southern Massanutten, I would be devastated. It doesn't make sense to create new roads when current roads aren't able to be maintained well. The agency is already carrying a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. The agency's own record states 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." The agency must reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain on the record how an action whose own numbers cannot establish a net benefit justifies expanding a road system already collapsing under its maintenance burden. The proposal also rests on a wildfire justification that the agency's own data contradicts. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from this finding. Finally, the claim that the 2001 rule exceeded statutory authority is contradicted by the courts that reviewed it. The Tenth Circuit held, exercising jurisdiction under 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 within the authority Congress granted under the Organic Act and MUSYA, and found it did not create de facto wilderness. The agency has not explained what legal basis exists for a contrary position, and it should. Public land must be protected from development. The forest is peaceful because there aren't many roads there. Please don't change this. Sincerely, Katie in Massanutten, VA

I support Alternative 1. Please keep the 2001 Roadless Area Conservation Rule in place. I hike and trail run along Reddish knob, Wolf Ridge and many other areas in the George Washington National Forest, and wild, roadless places like it are part of why I love living the Shenandoah Valley. These areas protect the headwaters that supply our drinking water, including Harrisonburg’s Switzer Reservoir, and they support the outdoor recreation economy our communities rely on. We don’t need more destructive access, more roads and less trees. Keep the Roadless Rule intact.

My name is Craig Fergus I am a residence of Front Royal Virginia and I'm writing to oppose the recession to the roadless rule. I often hike in the George Washington National Forest taking advantage of its numerous roadless areas to enjoy deeper areas of nature and can be found in other locations. However my appreciation for the continuation of the roadless rule is based primarily on the ecosystem services provided by these lower impact zones. As a wildlife biologist who has studied the impacts of roads on wildlife species, I believe the extent to which these areas contribute to healthy water quality, limit fragmentation, and in general support functioning ecosystems in a way that areas impacted by roadways cannot is something that should not be thrown away lightly. The most substantive argument I have seen for the change to the rule is one of improved fire control. However the Forest Services own research (Long-term forest health implications of roadlessness, Healey 2020) found that roadless and non-roadless areas had equal likelihood of burning. It also found that roadless areas had significantly lower numbers of invasive species. So if the agency's own data doesn't support the decision, why make the change? So again, 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 The George Washington National Forest offers some respite from the busy and fragmented Eastern United States, and that respite depends on what the Roadless Area Conservation Rule has protected. I oppose rescission of that rule and ask the agency to address the following. Much wildlife, including migrating birds, like warblers and vireos, draw me to these forests, and the agency's own research documents what roads do to them. 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. If the agency proceeds, it should explain what weight it gave these documented effects on bird communities in areas like the George Washington when it concluded that rescission would not cause significant harm. Clean drinking water is imperative. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and the record reflects that more than 7,000 municipal water intakes sit in watersheds fed by roadless areas, with approximately 24 million Americans drinking water that originates there. Fewer than 12 percent of those watersheds have impaired streams today. Opening roadless lands to road construction risks that record. The agency should explain what analysis on water quality it conducted before concluding that ending the roadless rule is in the public interest. On wildfire, the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless justifies rescission partly on fuels and wildfire management grounds. The DEIS reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that "human-caused ignitions increase in abundance with proximity to roads." These figures are not reconciled with the claimed wildfire rationale. 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, and separately explain why the proposal departs from its own prior findings as documented in DEIS Table 21. 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 loss 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 the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. 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. Places to recreate, undisturbed space for wildlife and birds, and clean water sources have been protected party due to this rule. Under the legal standard governing agency reversals, those interests must be identified and weighed, not solicited and then omitted from analysis. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Amy Risko Harrisonburg, VA 22801

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I moved to the Shenandoah Valley 10 years ago after having lived in areas of the world with fewer natural amenities. Depressed areas where outdoors was only a transition between highly-controlled indoors. To escape, you would have to travel hours just to experience a sliver of the peace I find in George Washington National Forest minutes away. When I moved here for work, it was the low cost of living and the "easy" living paired with the access to pristine nature that convinced me to relocate. When I visit others outside of the valley and tell them where I live, they are immediately attracted to the mythos of The Shenandoah Valley. "Oh it must be beautiful down there." And it is. When other job offers come up, I weigh them against the way of life here. The bike trails, the bird watching, the hiking. And as the cost of living rises and more influence from Northern Virginia takes root in the valley, I return to the fundamentals of what makes this area special. The great people and the great outdoors. "Friendly by Nature" is the slogan of my new home of Harrisonburg. I want to protect the nature. Especially in a disconnected world so overrun by data center projects, resources and people vulnerable to exploitation by big corporations, invasive species of plants and bugs, and a crisis of oil consumption. There are so many attacks on conservation from so many directions. At the simplest level, there is a value that these roadless areas add to the life here that might not be captured by pure economics. One of the few of the idealized places left in America, especially on the east coast. The reputation of the Shenandoah Valley recruited me.The peace of the George Washington National Forest has sustained and kept me here. I choose to stay in the Valley. I choose to shop local. I choose to embrace "friendly by nature." I choose the Shenandoah Valley. I will not move for work to a big city because of the connection to pristine nature here and the profound quietness that can be found in the GW forest. I believe the roadless areas should be left alone in favor of logging other areas. I want future generations to experience the magic of these mountains and to call this beautiful mythologized region home. We need retreats from the digital and the depressing. Please consider my plea to not rescind the Roadless Area Conservation Rule. Thank you very much for your time.

I am deeply concerned and dismayed to learn of ANY rescission of the Roadless Rule, and primarily for me in the George Washington National Forest. I live in Harrisonburg and recreate frequently throughout these areas, hiking, biking and fishing. Our roadless areas are natural havens of biodiversity and beauty. As an American citizen, I am proud of our national preservation of wilderness areas on public land. I believe that it is imperative to maintain these wild zones for future generations. NO ROADS !!’

For the last 25 years, the Roadless Rule has been key to protecting nearly 400,000 acres of land and 545 miles of river in my home state of Virginia. These forests and waters are home to hundreds of species that depend on unbroken forest habitat & clean, unpolluted rivers to survive. In addition to animal life, hundreds of thousands of people depend on these roadless areas for clean drinking water, as rivers and streams in Virginia’s roadless feed into reservoirs and aquifers supplying water to cities and rural communities. As a refuge for wildlife, roadless areas are critically important. Whitetail deer and bear are two major inhabitants of the state’s national forests, and require large unbroken tracts of habitat to flourish. These species are an incentive for hunting, wildlife photography, and other types of recreation that attracts people to these areas. Others, such as brook trout - another recreation-linked species - depend on extremely specific water conditions to thrive; road construction and logging runoff would decimate their populations in Virginia’s forests and drive away significant tourist dollars in lost fishing revenue; similarly, lack of roadless area for hunting access will decrease use from hunters and those who depend upon wild game for food. Readily available clean drinking water is critical to every community in the state, and for many places, the clean water flowing from streams saves countless dollars that would otherwise be spent on filtration. It is estimated that Harrisonburg alone saves multiple millions of dollars in filtration costs by virtue of water sources in the George Washington National Forest - costs that would otherwise be passed on to taxpayers to ensure a similar standard of hygiene (Hilt, 2026). Roadless areas, with their lack of pollution and intact vegetative communities - which help to filter rainwater as it flows into streams and aquifers - are hereby a critical contributor to the infrastructure of communities across the state whose access to clean water will be threatened. Should this rule be repealed, over 3 million people who depend on roadless areas in national forests in Virginia will have their access to clean water diminished (Hilt, 2026). Roadless areas are also a massive tourism draw. The George Washington National Forest is scarcely two hours from some 10 million potential visitors; Virginia’s national forests (including the GWNF) see some 3.8 million visitors per year. Of these 3.8 million, 80% are non-local; each of these national forest visits in the state generate around $300 on average for local tourism-related business - $1.4 billion in total per year (Friends of Shenandoah Mountain, n.d). Lack of access to these areas would undoubtedly cause a sharp decrease in tourist and local dollars flowing into the local economy. Perhaps most importantly - and despite protestations to the contrary by USDA officials who are discounting the scientific expertise present in the agency - there is no evidence that fire management is hampered by roadless areas; rather, “fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System” (Healy, 2020, p.1). According to recent research, “fire risks are approximately equal inside and outside of roadless areas. Further, inventory data suggest that roads are key to the spread of invasive plant species, a long-term threat to the function and composition of federal forests,” (Healy, 2020, p. 4). Roadless areas, then, naturally leave forests more resilient to fire and the threat of invasive species. Additionally, the USFS can ill afford to create new roads - most of which will not be open to the public - while it still carries an infrastructure maintenance backlog of over $5 billion for roads and other infrastructure (Blue Ribbon Coalition, 2025; USFS, n.d.). Additionally, logging has historically been a much less efficient use of taxpayer money than leaving roadless lands alone & reaping economic benefits as a windfall of ecological process (see above regarding clean water, recreation, etc.). Timber sales are a net loss to taxpayers, with management for carbon sequestration and ecosystem benefits producing more than twice the value of timber sales (Talberth, 2019).. It is estimated that – while they take up only 1% of the country’s area – roadways affect around 20% of the land in the U.S. due to impacts that stretch beyond their edges (Clevenger & Huijser, 2011; Donaldson & Weber, 2006; Iuell, Bekker, Cuperus, et al., 2003; Wade et al., 2003). I support Alternative 1; keep the Roadless Rule and the tangible benefits it brings to Virginia’s communities. Repealing this rule will not make our local communities safer, more prosperous, or competitive, but it will irrevocably scar landscapes that provide far more tangible benefits than unsustainable logging and the profits it stands to raise for a small few.