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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

Re: Docket FS-2025-0001, RIN 0596-AD66, proposed rescission of the 2001 Roadless Area Conservation Rule I oppose the proposed rescission and urge the Department to select the no-action alternative, keeping the 2001 Roadless Rule in full. The stated rationale is wildfire and active management, but the peer-reviewed evidence points the other way. A 19922024 analysis of all eight contiguous Forest Service regions found 7.99 ignitions per 1,000 hectares within 50 meters of roads, against 1.97 in inventoried roadless areas, and concluded that building roads into roadless areas is likely to produce more fires (Aplet et al. 2026). The existing rule already has exceptions that allow timber projects aimed at reducing wildfire risk, so rescission is not needed to treat fuels where it matters. Rescission would also put water supplies at risk. Roadless areas are the primary protection for more than 100,000 km of streams and rivers, and watersheds they influence supply drinking water to at least 25 million Americans (Olden et al. 2026). Road construction and logging raise sediment loads and treatment costs for downstream communities. The final EIS should address these findings directly and explain how more roads would reduce, not increase, fire starts. I am a lifetime beneficiary of the services derived from US roadless areas. The water supply in my hometown is partly derived from roadless areas in George Washington National Forest. I have hiked the Appalachian Trail through roadless areas in Virginia, North Carolina and New Hampshire. I have benefited from the wildlife habitat services of roadless areas in Colorado, Wyoming, Montana, Alaska, Utah, Oregon, and California, and surely more that I can't even remember. Roadless areas are a uniquely American invention. No other country in the world has had the foresight to protect wildlands such as these for future generations. It is inconceivable to me that we would forgo the benefits of these uniquely productive areas on such flimsy grounds as those proposed. Sincerely, William M. Shobe, Charlottesville, VA 22901 References: Aplet, G.H., Hartger, P., & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22:8. https://doi.org/10.1186/s42408-026-00450-2 Olden, J.D., Postel, S.L., Dombeck, M.P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538

To the United State Forest Service and Department of Agriculture, The proposal to repeal the Roadless Area Conservation Rule is the wrong decision and should not be finalized. The Roadless Rule protects tens of millions of acres of land across the country, and the broad proposal to repeal the rule – and the alternative to heavily modify it – fails to appropriately assess the impacts this would have on countless unique ecosystems. Repealing Roadless Rule protections for a given area must only be done after careful scientific analysis of whether the ecosystem can withstand road building and resource extraction without irreparable damage to human wellbeing or species survival. Each individual Roadless Area must be assessed, which this proposal and accompanying DEIS utterly fails to do. Two adjacent Roadless Areas may have very different characteristics, and a careful analysis of each is necessary to ensure we do not irreversibly damage critical ecosystems, cause rare or endangered species to go extinct, or threaten human wellbeing through actions like contaminating drinking water. In Virginia, some Roadless Areas in the George Washington National Forest are home to endemic salamander species that should clearly be of top concern for maintaining roadless protection. A complete repeal of the Roadless Rule provides no security to ensure critical Roadless Areas remain protected, and instead opens every single area to potentially catastrophic human activity. Other Roadless Areas in Virginia are important for protecting drinking water. Millions of Virginians rely on the James River for drinking water, and the headwaters of the James are protected and kept clean and healthy by Roadless Areas. Many other Roadless Areas across the country have this same benefit. Repealing or heavily modifying the Roadless Rule without examining each Area with critical drinking water protections to ensure they remain protected and do not cause a public health crisis for millions of Americans is unacceptable. Another important reason to keep the Roadless Rule in place is that it provides economic benefit across the country. In the White Mountain National Forest in New Hampshire, tourism for hiking, camping, and similar outdoor activities is one of the main economic forces for many nearby towns, such as Gorham and Conway. Opening these areas to roads, logging, and mining could not only destroy the mountain ecosystems, but the livelihoods of thousands of people and the vitality of the towns themselves. Another economic factor against repealing the Roadless Rule is the huge cost of road building. The US Forest Service already has a massive backlog of projects it does not have the money, nor the manpower, to complete. Opening millions more acres to roadbuilding will make this problem grow exponentially, causing further delays in places already open to roads. Another point is that US taxpayers often do not benefit much from road building and logging in National Forests. The government often builds roads with taxpayer dollars, but the roads are then used by private companies for logging or mining, the profits of which are shipped overseas or into the coffers of already ultra-wealthy corporations and billionaires. Instead, we lose our public forests, harm our air and water, threaten species survival, and receive nothing in return. The Forest Service must pay more attention to how Americans will actually be impacted—not a few huge corporations, wealthy individuals, and foreign buyers, but the average American. An elderly person living on Social Security and Medicare in rural Virginia. My grandmother is such a person, and the evidence shows me the impact on her will be a threat to her drinking water, a loss of scenic beauty and joy from her home, and the potential disappearance of the wildlife she loves so much. She will not receive a single dollar of financial benefit. Nor will she receive any significantly increased protection from wildfire. The Roadless Rule already has exceptions for necessary fire fighting, and building roads and resource extraction into Roadless Areas is very likely to increase fire risk, something the Forest Service does not examine in enough depth before proposing to open over 40 million acres to new road projects. In conclusion, repealing or even heavily modifying the Roadless Rule is a decision with detrimental effects of great but unknown magnitude. More attention must be paid to all of the things I mentioned, at a locally specific level, not a whole National Forest or the level of the whole country. Each Area needs its own assessment before its protections are removed, or we are sure to lose species, destroy vital ecosystems, ruin local economies and towns, and cause illness and death to people. Please reconsider your proposal and keep the critical protections of the Roadless Area Conservation Rule in place. Sincerely, Connor Ransom Bumpass, VA 23024