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RE: Docket Number FS-2025-0001 or RIN 0596-AD66 I am writing to submit my comments regarding rescinding the Roadless Rule, Docket Number FS-2025-0001 or RIN 0596-AD66. I respectfully request that the Roadless Rule remain in full force. I reside adjacent to the Gifford Pinchot National Forest in Klickitat County. As a lifelong resident of the Pacific Northwest, I treasure the natural beauty it offers and hold dear the preservation of areas intended to serve nature solely for itself without the threat of human pressures. As a small forest owner/steward I know how impactful any type of disturbance can be to the ecosystem. We spent five weeks witnessing the destruction of 44 acres of the parcel that borders us on two sides while they installed roads and clear-cut last summer (June 2025). The logging trucks start rolling (four per hour at a minimum) in at 2:30 AM and the feller buncher fires up at the very same time, running for ten to twelve hours- six days a week. A decibel meter registered readings of 95 db. for many hours over the course of the day. It was impossible to sleep and the production of our flock of chickens dropped to less than half for the duration of the logging operations. Those are just two of the impacts, there were many more to ourselves and the surrounding community. Every type of wildlife left for the duration of the logging, and it took until this spring for them to begin to return. Our forests had been planted at the same time, and the trees were more than 75 years old- young in the life of a forest and a lifetime for most humans. Our adjoining parcels contain extensive wetlands, seasonal waterways, and ponds. None of these were protected from the destruction and oversight to ensure that setbacks were observed was non-existent. The impact was and has been intense, causing tremendous flooding where it had not occurred previously. Water and precipitation at our elevation (2000’) is precious and would have stayed higher in the watershed had those trees still been there and the wetlands not been demolished during the logging. We are in our fourth year of drought here in the northwest and every drop feels precious. Our pond is the lowest we’ve ever witnessed in the 10 plus years we’ve owned. I share our experience in the hope that you will closely consider the ALL of the potential impacts of rescinding the Roadless Rule- both short term and long term. Our forests are under tremendous pressure, at a time when we need them more than ever to help offset climate change. Humans have spent the past three centuries creating monocultures, including in our forests. The lack of complex ecosystems has dramatically impacted the health of our forests, and now policy makers, Department of Natural resources, and logging interests are using the perceived threat of forest fires to push a narrative of burning to enhance forest health. Rescinding the roadless rule will have tremendous impacts that will take generations to repair. The Roadless Rule helps preserve: •Clean Water for Communities •Wildlife Habitat and Biodiversity •Outdoor Recreation and Local Economies •Natural Resilience •Threaten Tribal Sovereignty and access to traditional, sacred gathering grounds. Any action taken that will reduce these restrictions puts these pristine areas at risk. Most Sincerely, Jennifer Sharp 12 Pyatt Rd., White Salmon, WA 98672

Dear Secretary Rollins, I grew up on the edge of the El Dorado National Forest; a place that will forever be dear to my heart, though I now live in the also-magical realm of the Gifford Pinchot National Forest. As someone who recreates in these public lands, I am -not- in support of building more roads in them. I have seen the tragedies of additional road-building in these wild areas too often; habitat is fragmented and animals are often killed trying to access breeding grounds, forage, and other essential habitat. Hazardous chemicals and tire dust from vehicles are dispersed into these environments, threatening drinking water and our Western salmon populations. Though some claim that the Roadless Rule has increased the incidence of wildfire, this is untrue, and wildfires are more likely to ignite near roadsides.(1) Please leave the Roadless Rule in place as it is. I absolutely do not support any of the proposed alternatives that would weaken it. Please spend taxpayer money responsibly on conservation endeavours that support these irreplaceable lands instead of paving them over. References: (1)Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026) https://doi.org/10.1186/s42408-026-00450-2 Sincerely, Nicole Johnston Vancouver, WA 98683 nljohnston.ast@gmail.com

I write in strong support of the U.S. Department of Agriculture’s proposed rule to rescind the 2001 Roadless Area Conservation Rule in its entirety. This one-size-fits-all national restriction has constrained local forest managers for 25 years, limiting timely access for active management, hazardous fuels reduction, and wildfire response across more than 44 million acres of National Forest System lands. Rescinding the rule restores decision-making authority to the local level through existing land management planning processes under the National Forest Management Act, without mandating any particular road construction or timber harvest. This change is especially important for communities like those in Skamania County, Washington, which border and depend on the Gifford Pinchot National Forest. The Gifford Pinchot contains substantial inventoried roadless areas (approximately 213,000 acres based on Forest Service inventory data). These lands sit amid a landscape that has faced elevated wildfire risk, including recent high and very high fire danger ratings, fire restrictions, and incidents such as the Backbone, and High Lava fires. Local officials in Skamania County have highlighted the heavy fuel loads on the forest and the need for strategic fuel breaks and treatments to protect communities, infrastructure, and residual old-growth and wildlife habitat from catastrophic fire. The Roadless Rule has restricted road construction and reconstruction needed for efficient access to conduct thinning, prescribed fire, and other fuels treatments in many of these areas. Forest Service data indicate that more than 40 percent of inventoried roadless areas nationwide carry high or very high wildfire hazard potential, yet only about 5 percent have received hazardous fuels reduction treatments since 2014. A significant portion of these lands already lie near existing roads. Removing the national prohibition gives Gifford Pinchot managers the flexibility to evaluate site-specific needs—improving firefighter access, reducing response times, creating defensible space near communities and critical infrastructure, and treating fuels before they accumulate into extreme fire behavior—while still operating under full NEPA review, forest plans, and other environmental laws. For Skamania County residents, the stakes are practical and immediate: safer communities, reduced risk of large, destructive fires that threaten homes, water supplies, recreation, and local economies, and the ability for the Forest Service to manage the land based on current conditions rather than a 25-year-old blanket restriction. Active management is essential to restoring forest health and resilience in the Cascades. I urge the Department to finalize the full rescission of the 2001 Roadless Rule. Returning authority to local national forest managers will better enable the Gifford Pinchot National Forest and similar forests across the West to address wildfire risk, protect neighboring communities such as those in Skamania County, and sustain the multiple uses and values these public lands provide. Thank you for the opportunity to comment and for prioritizing practical, science-informed forest management. Sincerely, Asa Leckie asal00@msn.com

Dear USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule as an Oregon Certified Naturalist, since my retirement in 2012, a birder and teacher of the young people in my family for three generations. I have been volunteering in nature research studies and environmental education, working with State Parks, National Parks Service, Bird Alliance of Oregon and others to understand the forests and the many species there which I have enjoyed all of my life in Oregon and to teach others how to appreciate and protect our unique wild lands which are so important to us. I have shared the wonders of these areas with my own family as well as many other young people, in Outdoor School and other public education programs, adding to their enjoyment of growing up in Oregon and contributing to their understanding of the unique place we live, particularly in the Inventoried Roadless Areas around Mt. Hood in the Mt. Hood National Forest and those in the Gifford Pinchot National Forest. Inventoried Roadless Areas offer tremendous benefits to communities and ecosystems that would be threatened or destroyed by road building. Here are just a couple of examples I have witnessed personally of the benefits of retaining the Roadless Rule. Wildlife habitat: imperiled species like Northern Spotted Owls, Marbled Murrelets, and countless other birds rely on large, intact forests with undammed, unlogged streams and connected landscapes. Salmon, trout, elk, and other species are also threatened when habitat is fragmented. This became very clear to me when I participated with Bird alliance of Oregon in monitoring Marbled Murrelets in 2019, and could see how little nesting habitat is still accessible to them. Drinking water: 60 million Americans rely on national forests for drinking water; intact forests filter water naturally. Many inventoried roadless areas are important parts of watersheds. I was fortunate in 2014 to join a tour group from the City of Portland’s Water Bureau to take a field trip to tour several parts of the Bull Run Water Shed to learn firsthand how this is possible and came to appreciate the role such places play in supplying some of the purest cleanest drinking water in the state. Outdoor Recreation: Roadless areas offer abundant outdoor recreation opportunities such as hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands, and roadless areas contribute millions of dollars to local economies through the recreation industry. My family and friends have spent most of our vacations throughout our lives camping and hiking together in these places in Oregon, across the state. As a volunteer I always meet folks when I am conducting my wildlife surveys, who are happy to share that they love about who are happy to share how much they enjoy their time in these wild places, and how important it is to them. I urge you to keep the Roadless Rule in place as it is. Thank you for your attention to my request. Donna Acord

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

I learned about the recindence of the roadless rule while on a trip to the Dark Divide wilderness in the Gifford Pinchot National Forest of Washington. While there I traveled by foot through old growth forests and witnessed some of the most amazing trees. Some over 700 years old. The United States is a very special country where we have public lands with the most diverse variety of landscapes for the world to see. Logging these old growth forests and destroying these wilderness regions for short term gains will be one of the irresponsible things we can do. Short term gains for few people who have never seen these natural wonders. Please consider the long term gains which always end of being more valuable and not rescind the roadless rule. Tha k you.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Nearly 80 years old and I have never seen a northern spotted owl, a black bear, or an elk. I have not stopped looking. They are out there in the 213,000 roadless acres of the Gifford Pinchot National Forest, 15 miles away. I have lived in the Pacific Northwest all my life. This has been and will always be my home. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that this comment be entered into the record. The elk I have spent years looking for depend on that unroaded country. The agency's own record shows that elk avoid areas near roads and select habitat away from them, and that elk survival rates rose during a road closure and fell again when the gates were removed. Every mile of new road pushed into the Gifford Pinchot is habitat the elk abandon. The same record ties open roads to increased contact, conflict, and mortality risk for bears. I have not yet seen a black bear in that forest. Rescission makes it less likely anyone will. I ask the agency to explain how this outcome is consistent with its own wildlife findings, and to specify what road-avoidance data it weighed before concluding that expanded road access serves the animals living inside these areas. Every summer is now a fire season in the Pacific Northwest. The air becomes dangerous to breathe for both humans and wildlife, and the areas coming under evacuation orders keep coming closer. Additional roads only increase the odds of human-caused fires. The agency's own language confirms exactly this: "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 claims wildfire management as a justification for rescission. That justification and this finding cannot both be true at once. I ask that the agency explain on the record why the proposal departs from its own prior findings on fire occurrence, and that it 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. Roads degrade watersheds. Washington alone holds 1,522 municipal water intakes in watersheds containing affected roadless areas. . The agency does not have the funding to manage the roads it already has. It makes no sense to add roads it cannot maintain. 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." A fraction of a percent of national production does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. I ask that the agency reconcile the proposal with its own economic 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 that it explain how an action whose own cost-benefit analysis cannot establish a net benefit is justified. The rule as it stands already allows the agency to act where it must. It states that 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 shown which specific burdens fall outside those exceptions. I ask that it identify them, quantify them, and show the record behind that accounting. The agency's own DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, part of the 40.1 million acres of potentially affected environment. That fragmentation range is cited and then set aside, never applied to the full scope of what is at stake. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and enter that analysis into the record before any final decision is made. Old growth forests will not grow back in one lifetime. The roads that allowed access to removing them will remain as scars. The Gifford Pinchot held more than 600 public meetings and took 1.6 million comments to build the rule that protects these places. Losing the Gifford Pinchot to logging, mining, additional grazing, and harmful motorized use would be one of the greatest sorrows of my life. The generations to come should not have less to inherit. Sincerely, Kathryn Edgecomb Vancouver, Washington

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Dark Divide felt like nothing else I've seen in the Cascades. I ran a 100 mile race there in September, moving through country where you could go mile after mile without seeing a car or a road. That is what roadless areas make possible, and it is what this rescission would end. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I am an ultra trail runner. The acreage to run without seeing cars or roads in roadless areas is my favorite way to experience the National Forests. The Dark Divide, at 52,483 acres in the Gifford Pinchot National Forest, gave me that. So does Drift Creek, 6,333 acres in the Siuslaw National Forest, which sits surrounded by private clearcut logging and stands as an echo of the majesty of what the Oregon Coast Range temperate forest used to be before extractive colonialism stripped it. Hebo 1a, another 13,930 acres in the Siuslaw, is another small remnant of what remains of that rainforest. These places are also where old growth forest still stands, and old growth is where I go to photograph, where biodiversity is greatest, and where, even as summers grow hotter and drier, the forest still feels cool and damp. What remains of that old growth is rare. Roadless areas help balance the conservation mission of the Forest Service by protecting some of the 4% of remaining old growth in this country. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The agency should say plainly, on the record, what share of remaining old growth in Oregon would be exposed to road construction and timber extraction if those areas lose their protection. The agency's own analysis undermines the wildfire rationale it offers for this rescission. 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." 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. 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 that it explain how the proposal departs from its own prior findings as recorded in DEIS Table 21. Intact forests protect and clean water for communities and wildlife. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. My tax dollars should go toward protecting those ecosystem services, not toward building new roads into country that has none, especially when the agency already carries a $6.9 billion maintenance backlog against a road budget of roughly $73 million a year. The record the agency itself assembled states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile the proposal with its own cost-benefit analysis, which 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 the agency cannot afford to maintain? The rule as written already accommodates the concerns the agency invokes. 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)." I ask that the agency identify specifically which burdens are not already addressed by those existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify each claimed burden with evidence in the record. I commented on this rescission in 2025. By the agency's own count, 99.5% of comments were against it. That the administration proceeds regardless raises a direct question about its obligations under the Administrative Procedure Act and the notice-and-comment process. The agency must address in the record how a response rate of that character is consistent with its duty to consider public input rather than to discard it. Sincerely, Brian Dugovich Corvallis, Oregon

I strongly oppose the changes being made to the roadless rule outlined in the DEIS. Under the guise of improved access wildland fire and fuels management, the proposal suggests opening up some of the 45 million acres to increased road access. Of those acres, in the past 40 years, less than 20% of that land has burned in wildfire and of that 20% that has burned, roughly half burned at the low-severity level that helps to support healthy forest ecology(Aplet et. al 2026). Evidence supports the lowest instances of human-caused wildfire ignitions occur in designated wilderness areas (woo for 1964 Wilderness Act!) followed roadless areas with higher levels of ignitions correlating with increased proximity to roads. Careless cigarette butts, improperly secured tow chains, lazy campfire management, and intentional arson, all occur more easily with easy road access. This season has seen the USWFS and partner agencies (have your guys at Ag been swept up into that yet or are they still keeping you separate from DOI?) stretched thin under one of the worst wildfire seasons on record. As of writing this comment, we're less than 200,000 acres away from breaking our record for the worst. This pulls red carded staff away from other important jobs, demands disaster resources that are needed for national security, and uproots and ends the lives of Americans throughout the country. By protecting the roadless rule (which HAS provisions for roads to be constructed during wildfires for the purposes of containment and access), we'll be protecting our wildland fire infrastructure, the American people, and our forests. Further, I'm alarmed by the phrasing on page 102 of the DEIS indicating that timber harvesting is the primary motivation for the rescission of protections offered these lands by the roadless rule. Current challenges associated with lumber cost and access in America are primarily the result of tariff related policies. The profits brought by the timber industry pale in comparison to the profits brought by tourism and recreation on our roadless lands. In 2024, tourists to roadless areas spent over $8billion on their recreation implements and in gateway communities. As places are parceled off for timber industry, these people will take their money and seek the experience they had elsewhere or not at all. These are evergeen (pardon the pun) sources of revenue. Parents bring their children to the places their parents brought them and a new customer is introduced to the wonder of White Mountain National Forest in New Hampshire. Or Gifford Pinchot National Forest in Washington or any of the dozens of National Forests I've had the delight of calling my favorite places and that I hope to someday show to my children. If left to the timber lobby, once these places are removed from public access, I think it's reasonable to assume that we cannot get them back. And to the Forest Service staff who might read this: thank you for what you do.

I oppose the repeal of the Roadless Area Conservation Rule. I am 67, and most of my life I have appreciated the opportunities to recreate in the backcountry areas of Colorado and Washington. Accessing areas that are only reached on foot or horseback allow you to experience the solitude and beauty of these undisturbed areas. Allowing new resource extraction, infrastructure development, or other activities that will disturb this natural environment will have a negative impact for the general public that want to preserve these areas for enjoyment of recreational opportunities, preservation of wildlife and water resources, and for future generations. Allowing roads and vehicle access closer to pristine alpine areas will degrade the value of the recreational experiences and the preservation of these wild areas. Over the past 20 years living in Washington State, going to the mountains for backcountry hikes, backpacks and climbs, are my primary recreational activity. I spend nearly every weekend in pursuit of exploring these untouched and protected areas. In reviewing the map of current roadless areas in Washington, many of the areas that I visit frequently on trails and to destinations will be either partially, or completely affected by the repeal of the rule. These include areas in the the Okanogan-Wenatchee National Forest; Chelan area, Boiling Lake, Sawtooth area, Eagle, Martin, Cooney, Crater Lakes. Bigelow, Martin, and Switchback Peaks, Libby Creek trail, East Fork Buttermil trail, West Fork Buttermilk trail, Eagle Creek trail, Willliams Creek trail, Heather Maple Pass trail. Tobinson, Golden Horn, Tower, Hardy, Azuirte, Gardner and N Gardner Peaks, Grasshopper Pass, Cutthroat Pass, Snowy Lakes. Long Swamp area: Thirty Mile trailhead, Chewuch trailhead. Pasayten Rim: Copper Glance trailhead, Big Craggy and W Craggy Peaks. Myrtly Lake; Phelps Creek trailhead, Entiat River trailhead. Twin Lakes area: Dirty Face trailhead. nason Ridge area: Rock Mountain, Merritt Lake trail. Alpine Lakes area: Jim Hill Mountain, Lanham Lake trail. Heather Lake area; Skyline Ridge trail, Lake Minotaur trailhead, Heather Lake trailhead. Also trails, mountains and lakes in the Mount Baker-Snoqualmie NF and Gifford Pinchot NF; Glacier Peak area, Boulder River area, Maount Baker area, Horseshoe area.

I'm writing to comment in opposition to the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). I'm based in Juneau, Alaska, and regularly recreate within roadless areas here in the Tongass National Forest. In Alaska,, I most often recreate in the following roadless areas: Taku-Snettisham, Juneau-Skagway Icefield, Juneau Urban, and Douglas Island. Additionally, I have recreated on roadless areas in several states including but not limited to: Allegheny National Forest, PA, Monoghaela National Forest in West Virginia, White Mountian National Forest in New Hampshire, Jefferson National Forest in Virginia, Ocala National Forest in Florida, Chattahooche National Forest in South Carolina, Pisgah National Forest in North Carolina, Olympic National Forst and Gifford Pinchot National Forest in Washington. When recreating, I often seek out roadless areas and feel that protections for these areas are critical to ensuring future generations can enjoy these lands as I have. I believe the rule is well written, and the language allows for a variety of exemptions (timber harvest, wildfire fighting, roadbuilding, resource access, thinning, etc.). Most importantly, local Forest Service officials already have the authority to review and approve these exemptions. Roadless areas provide critical habitat for wildlife and serve as an important natural protection, helping ensure communities across the country have clean drinking water. Here in Alaska, I’m most concerned with the potential impacts that new subsidized road development for the timber industry would have on salmon habitat. Local economic engines have been designed around roadless areas. Just this summer, I paid a rafting company to raft through a roadless area, and a climbing guide to access a local crag via roadless-area trails. Here in Alaska, over 2 million cruise ship passengers will sail through the inside passage, marveling at our intact forest. Repealing the rule could put this billion-dollar industry at risk. The rule was originally designed to save taxpayers' money and allow the USFS to prioritize the maintenance backlog. Rolling back the rule could result in spending US Taxpayer dollars on road subsidies and a return to a time when the US government subsidized the Timber Industry. I find the "Purpose and Need for Action" for FS-2025-0001-223869 frivolous. I'd like to encourage the USDA to move away from a top-down, DC-driven approach. Roadless Rule protections have been in place for more than two decades; they are working, and the rule is serving the American public well. Again, I oppose the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule. I'll continue to raise my voice so my nieces and nephews have the same opportunities I've had to bike, hike, ski, raft in roadless areas. Thanks for your time and consideratio

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I care most about sit in the Pacific Northwest. Mt. Hood National Forest, Gifford Pinchot National Forest, and Salmon-Huckleberry National Forest are where I camp, hike, and photograph land formations, plants, trees, rivers, and lakes. I share those photographs with elders and others who cannot get out there themselves. I also watch birds and animals to see how they live and communicate in the wilderness. Those forests, and the wildlife in them, are what this comment is about. I oppose rescinding the 2001 Roadless Area Conservation Rule. Roads hurt birds. The agency's own record acknowledges this directly. 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. The birds I watch in these forests depend on the quiet that roadless protection provides. Rescission opens the door to road construction in areas where that protection currently holds. I ask the agency to explain on the record why it weighed this documented harm to bird communities as acceptable, and what mitigation it proposes. The agency's own fire data also cuts directly against the rationale offered here. The DEIS reports that 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. I hike and camp in these forests. I have a direct stake in whether they burn. The agency claims road access reduces wildfire hazard, but its own numbers point the other way. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh that increase against any claimed reduction in wildfire hazard, with that analysis made available for public review. The economic certification accompanying this proposal does not hold together. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The underlying flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not an assessment of the affected entities. It is an average that obscures the harm to specific businesses. 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. Finally, the agency's treatment of future plan amendments is not defensible as 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 cannot simultaneously declare a foreseeable consequence out of scope and ask the public to comment on it. That is asking commenters to perform the analysis the agency itself declined to do. The forests I visit in the Pacific Northwest could be directly affected by exactly the plan amendments the agency is refusing to evaluate. I ask that the agency analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this rulemaking action. The proposal also invites comment on reliance interests without ever analyzing them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have organized my recreation, my photography, and my practice of sharing the wilderness with people who cannot reach it around the protection this rule provides. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. I urge the agency to withdraw this proposal. Sincerely, Andree Nyary Portland, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting in the woods with friends, breathing clean air in the campgrounds of Oregon and Washington, watching the recovery continue on the slopes of Mount St. Helens. These are the things I am asking you to protect when I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. Being out in the woods is good for the soul. The beauty of wild places and the animals in them is unmatched. I also spend time in state and national campgrounds in Oregon and Washington for the clean air, the quiet, and the enjoyment of nature away from the noise of city life. It is affordable vacation for many people. I want my children and grandchildren to have wild places with old-growth trees to revere and experience. I do not think they should inherit fewer of these places than I did. The Siuslaw National Forest holds the Oregon coast range, the dunes, fresh water, and salmon. Salmon depend on cold water, and the agency's own record states 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, with the affected area including Essential Fish Habitat and critical habitats managed by NMFS. The Siuslaw's roadless areas amount to 52,000 acres of coast range forest that the agency would open to new road construction. I ask the agency to address what specific protections replace those lost for cold-water fish habitat in the Siuslaw if this rule is rescinded. The Deschutes National Forest is a high desert place of calderas and ancient formations, fantastic and unlike anywhere else. Bend and the surrounding area get their water from this forest, and this should not be threatened. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The Deschutes holds 136,000 acres of inventoried roadless area, and the lower Deschutes holds one of only two national strongholds for federally threatened bull trout. I ask the agency to explain how rescinding federal roadless protections over these watersheds is consistent with its obligations to communities and to listed species whose strongholds sit inside them. The Olympic National Forest is magical. Having no roads through the middle of the peninsula is a true treasure. The 86,000 acres of roadless area there, with their old growth and pure water, must be maintained. The agency argues that new roads serve wildfire management, yet its 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." I ask that the agency reconcile this proposal with that finding and explain what ignition data now overrides it. The agency also argues that opening these areas generates economic benefit. Its own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. The agency already carries a $6.9 billion road maintenance backlog on a road budget of about $73 million a year. No new roads. The Gifford Pinchot National Forest, with Mount St. Helens and its continuing recovery, holds 213,000 acres of roadless area I have visited since childhood. The agency now argues that state-specific management can replace the national rule, yet its own record shows: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit already rejected the last attempt to substitute local approaches for a national rule, finding that piecemeal local decisions can erode nationally significant roadless values. Leave the little remaining old growth alone. Leave the natural water sources alone. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That process failure alone demands a full answer before this rescission moves any further. Sincerely, Kristina Rheaume Portland, Oregon

Subject: Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule – Docket No. FS-2025-0001 To the U.S. Forest Service and the U.S. Department of Agriculture: I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). As a resident of Portland, Oregon and an advocate for our nation’s public lands, roadless areas matter deeply to me. I frequently visit and recreate in Mt. Hood National Forest, Gifford Pinchot National Forest, Mt. St. Helens National Monument, Mark o. Hatfield Wilderness, Suislaw National Forest and other areas throughout the Pacific Northwest. I feel a special kinship with these areas, where I hike, forage (where permitted) and enjoy deep solitude. In fact, I moved to Oregon nearly 25 years ago when meeting friends on a camping trip in the Columbia Gorge. I fell in love on that trip; not with another person, but with the incredible natural beauty of Oregon and Washington. It's literally the reason I moved to Portland. These incredible natural landscapes are worth protecting, for several critical reasons: • Clean Water and Watersheds: Roadless areas safeguard essential headwaters and drinking water sources for downstream communities. This is especially true for the Portland metro area; the Bull Run Watershed supplies drinking water to nearly one million residents. • Wildlife Habitat: Roads fragment ecosystems, disrupting sensitive wildlife corridors. More roads are a threat to preserving or restoring biodiversity and protecting endangered species. • Climate and Resilience: Intact forests act as natural carbon sinks and are more resilient to severe disturbances than fragmented, heavily managed timber lands. Shifting management decisions to local forest plans without a national safeguard risks opening millions of acres of pristine backcountry to industrial/commercial logging and road construction. We have seen what happens when national protections are disregarded; wanton destruction of huge swaths of land with major downstream impacts to fish, wildlife, and even human habitation (when near poorly managed forests). I urge the Forest Service to select Alternative 1 (No Action) and maintain a continuation of full, nationwide protections for all designated inventoried roadless areas. This action would maintain current prohibitions against road construction, road reconstruction, and timber harvesting across roughly 44.7 million acres of inventoried roadless areas on national forest lands. Thank you for the opportunity to comment on this critical rule. Sincerely, Ü. Kleppinger Portland, Oregon, 97211

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Dear U.S. Forest Service Officials, I respectfully urge the Forest Service to retain the 2001 Roadless Rule and reject the proposed rescission. Roadless lands are not idle land. They supply clean water, wildlife habitat, and recreation to communities nationwide, and rescission would do far more harm than good. WHAT IS AT STAKE (Forest Service roadless inventory) - Deschutes NF, central Oregon: about 137,000 acres protecting the headwaters of the Deschutes and Metolius rivers. Oregon's roadless lands protect drinking water for about 800,000 people, including Bend. - Wallowa-Whitman NF, northeast Oregon: about 515,000 acres. Its mountain streams supply Baker City, one of only two Oregon cities whose water is clean enough to go unfiltered. - Gifford Pinchot NF, southwest Washington: about 213,000 acres. Its streams supply drinking water to communities and support threatened Chinook and coho salmon, steelhead, bull trout, and the northern spotted owl. - Superior NF, northeast Minnesota: about 62,000 acres bordering the Boundary Waters, home to moose and threatened Canada lynx. - White Mountain NF, New Hampshire and Maine: about 235,000 acres, including headwaters of the Pemigewasset River, which forms the Merrimack, a drinking water source for Manchester, Nashua, and Massachusetts towns. - Bridger-Teton NF, western Wyoming: about 1.4 million acres at the headwaters of the Snake and Green rivers, feeding the Columbia and Colorado systems, with grizzly bears, wolverines, lynx, and native cutthroat trout. Nationally, roadless watersheds supply drinking water to about 25 million Americans. THE FOREST SERVICE'S OWN SCIENCE The agency's report Forest Roads: A Synthesis of Scientific Information (PNW-GTR-509) found that roads contribute more sediment to streams than any other land management activity, and that most sediment from timber harvest is tied to roads. Forest Service research on Washington's Clearwater River found fine sediment making up 15 to 25 percent of spawning gravels in heavily roaded basins, smothering salmon eggs. That matters: the Columbia Basin once produced 10 to 16 million salmon a year, and logging and road building were among the causes of its decline, alongside dams. The current DEIS itself acknowledges that new roads and logging could bring more human-caused fires, sedimentation, harm to threatened and endangered species, and recreation losses. WILDLIFE Roadless areas cover about 2 percent of U.S. land but support roughly 25 percent of threatened and endangered species. In Idaho, 75 percent of Chinook salmon and steelhead habitat is in roadless areas. The U.S. Fish and Wildlife Service has called roads probably the most imminent threat to grizzly habitat. Roads also fragment migration routes and push elk out of secure cover: in Wyoming, hunters in mostly roadless country harvest about one bull elk per 2.4 square miles, versus one per 25 square miles in heavily developed areas. THE COST OF ROADS The proposed rule anticipates permanent roads could be built across 18.2 million acres now protected. Yet the Forest Service already manages over 370,000 miles of roads with a maintenance backlog the agency puts at about $6.9 billion, and fewer than one in five roads is fully maintained. Neglected roads wash out, plug culverts, and send sediment into streams, and deferred repairs grow costly. Former Chief Mike Dombeck noted that reconstructing five miles of one road cost $1.4 million when $100,000 in earlier upkeep would have preserved it. The DEIS projects just $5 to $11 million a year in new timber revenue and admits this would not cover the cost of building and maintaining new roads. Adding roads the agency cannot maintain shifts the bill to taxpayers and downstream communities. WILDFIRE The rule already allows thinning and road access to reduce fire risk, and areas near roads have recorded nearly four times as many human-caused ignitions as roadless areas. I ask the Forest Service to keep the Roadless Rule in place and pursue any needed changes through targeted reform with full public input. Thank you for considering my comments. Sincerely, Marguerite Nico Allen, Texas

My name is Cheryl Thramer and I live in beautiful. Washington State. I am a cabin owner that leases land in the Gifford Pinchot National Forest right near the Trapper Creek Wilderness area. My grandfather built a cabin on this tract in the 60s. There are cabins that have been in this area since the 20s. This area is full of beautiful old growth trees, pristine waterways, hiking trails, animals, flora and fauna that are treasured in this area. Please do not get rid of the roadless rule. No doubt additional roads in this area will lead to additional logging. The loss of habitat that would bring to this area would be devastating.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Places like Silver Star are one of one. That conviction is why I am filing this comment against the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. The areas I care about, including Silver Star in the Gifford Pinchot National Forest and Larch in the Mt. Hood National Forest, exist as they are because the rule held. I do not want them to become something else. The agency justifies rescission in part on wildfire and fuels management grounds, but its own record does not support that rationale. 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." Silver Star and Larch sit within a region where the value of keeping roads out is not theoretical. The agency has not explained why it is moving toward a policy that contradicts findings it placed in its own environmental review. I ask that the agency explain, in its final decision, why the proposal departs from these prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. Erosion and water quality connect directly to what roadless status protects in places like these. The DEIS acknowledges 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 figure is stated and then the document moves on. No projection of sediment delivery into downstream watersheds follows it. Across the Pacific Northwest region, which includes Oregon where Larch sits, 1,522 municipal water intakes are located in watersheds containing affected roadless areas. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres. What happens to those intakes when sediment loads rise is a question the DEIS raises with its own number and then declines to answer. The agency should quantify projected sediment delivery to the municipal intakes downstream of these areas before any final action is taken. The drinking water issue is larger than the Pacific Northwest. The DEIS itself states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." The document then asserts that existing forest plans address sources of public drinking water, without identifying a single enforceable provision that would replace the protections at 36 CFR 294.12 and 294.13. Asserting that plans are adequate without naming what in those plans performs equivalent work is not analysis. The agency must identify, forest by forest, which specific plan provisions would serve the same function as the sections of the rule it proposes to eliminate. Finally, The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is wide and the low end alone is severe. Yet the document applies this finding to no acreage, makes no projection across the landscape that would actually be affected, and draws no conclusion from it. The 40.1 million acres of potentially affected environment represent a real and bounded area. A finding about fragmentation and biodiversity loss that is cited but never applied to the area under review is not a basis for a decision. The agency should apply the cited fragmentation range to those 40.1 million acres and show what the projected outcome means for species and habitat before it finalizes this proposal. Sincerely, Brian Roy Milwaukie, OR

Agency: FOREST SERVICE (FS) Document Type: Proposed Rule Title: Special Areas: Roadless Area Conservation Document ID: FS-2025-0001-223869 Comment: Subject: Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule – Docket No. FS-2025-0001 To the U.S. Forest Service and the U.S. Department of Agriculture: I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I frequently visit my daughter in Portland and we always schedule a trip either to Mt. Hood National Forest, Gifford Pinchot National Forest, Mt. St. Helens National Monument, Mark o. Hatfield Wilderness, Suislaw National Forest or other areas throughout the Pacific Northwest. I feel a special kinship with these areas, where we hike, forage (where permitted) and enjoy deep solitude. These incredible natural landscapes are worth protecting, for several critical reasons: • Clean Water and Watersheds: Roadless areas safeguard essential headwaters and drinking water sources for downstream communities. This is especially true for the Portland metro area; the Bull Run Watershed supplies drinking water to nearly one million residents. • Wildlife Habitat: Roads fragment ecosystems, disrupting sensitive wildlife corridors. More roads are a threat to preserving or restoring biodiversity and protecting endangered species. • Climate and Resilience: Intact forests act as natural carbon sinks and are more resilient to severe disturbances than fragmented, heavily managed timber lands. Shifting management decisions to local forest plans without a national safeguard risks opening millions of acres of pristine backcountry to industrial/commercial logging and road construction. We have seen what happens when national protections are disregarded; wanton destruction of huge swaths of land with major downstream impacts to fish, wildlife, and even human habitation (when near poorly managed forests). I urge the Forest Service to select Alternative 1 (No Action) and maintain a continuation of full, nationwide protections for all designated inventoried roadless areas. This action would maintain current prohibitions against road construction, road reconstruction, and timber harvesting across roughly 44.7 million acres of inventoried roadless areas on national forest lands. Thank you for the opportunity to comment on this critical ruling. KEEP THESE LANDS, ANIMALS, WATER AND FRESH AIR FOR OUR CHILDREN'S CHILDREN AND THEIR CHILDREN!!! Adele Garger, Thousand Palms CA.

I am writing to express my strong opposition to the proposed rescinding of the Roadless Area Conservation Rule and to urge you to maintain full protections for these essential public lands. The Gifford Pinchot National Forest serves as a vital sanctuary for countless individuals, offering an indispensable space for recreation, retreat, and mental well-being. Allowing road construction and industrial development in these protected areas will directly harm those who rely on these lands for solace. Furthermore, rescinding the Roadless Rule poses a severe threat to the forest's delicate ecosystem by risking critical watersheds, threatening local wildlife habitats, and eroding the region's unique biodiversity. Additionally, altering these protections risks exacerbating the severe wildfires our region is already experiencing and threatens to disrupt or eliminate the Pacific Crest Trail (PCT) experience for thousands of hikers each year. Above all, opening these roadless areas to development violates the sanctity of our shared public lands. Protecting these roadless areas is essential for preserving our environment, safeguarding vital recreational resources, and ensuring they remain intact for future generations. I strongly urge you to uphold the Roadless Rule and keep these public lands fully protected. Thank you for your time and for considering my input on this critical issue.

Re: Docket No. FS-2025-0001, RIN 0596-AD66 — Proposed rescission of the 2001 Roadless Area Conservation Rule My name is Kari Hansen. I live in rural Washington County, Oregon, five miles down a gravel road from the nearest pavement. The woods are not scenery to me. They are where I live. I live in the Tualatin Mountains on the edge of Oregon's Coast Range, so the Siuslaw National Forest is my neighboring national forest. Places like the roadless ridges around Mount Hebo are the kind of country I live beside. The Mt. Hood National Forest's roadless acres matter to me too. And across the river in Washington, the Dark Divide in the Gifford Pinchot National Forest is the largest unprotected roadless area in the Cascades, and it deserves to stay that way. I oppose rescinding the 2001 Roadless Rule. It has protected some of the last large undeveloped forests in this country for 25 years. Once the roads go in, the quiet goes, the clean water goes, and the habitat goes, and none of that comes back. Please keep the 2001 Roadless Rule in place. Kari Hansen North Plains, Oregon