Read the comments.

Dear Secretary Brooke L. Rollins: I am commenting because I care about the roadless areas of this country and I think that they need to be protected. Regarding the Lye Brook Addition 09085 in the Green Mountain and Finger Lakes National Forests, Vermont: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Rescinding the Roadless Rule would open the Lye Brook Addition 09085, Green Mountain and Finger Lakes National Forests to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. If this rule is rescinded I lose a beautiful place to find peace and inspiration in We need to keep the roadless rule because it helps to protect the wild areas of this country for the plants, animals and people. For the reasons set forth in this comment, the proposed rescission should not proceed. With appreciation, CommentID: RLC-20261006-CG5IKT

Dear Secretary: From the vantage of a wildlife observer and native plant advocate who has walked the boundary between roaded and roadless units of the same forest, I can attest that the difference is detectable, and on that basis I oppose the proposed rescission. Quiet, untouched places in nature like the Devil's Den are the sole remaining places humans can go to calm nervous systems undoing the cortisol damage created by man made work environments, affordability stressors and unchecked marketing our current society bestows on its' inhabitants. Paved roads immediately reduce permeable surface area and increase the speed at which water travels, impacting native flora and fauna and access to clean, fresh water. Invest in public railways or public transportation instead. Regarding the Devil's Den 09083 in the Green Mountain and Finger Lakes National Forests, Vermont: Roads, disturbance, and altered ecosystems create invasion pathways that let non-native plants, pathogens, and animals displace native biota. Non-native species concentrate near roads. A 2025 study tracking plant communities at varying distances from roads found non-native species in 94 percent of roadside plots, 27 percent of adjacent plots, and only 15 percent of plots furthest from the road. Roads also altered the underlying soil conditions in ways that favored non-native plants over native species (Clavel et al. 2025). — Clavel et al., 2025 (https://doi.org/10.1111/oik.11075) Rescinding the Roadless Rule would open the Devil's Den 09083, Green Mountain and Finger Lakes National Forests to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” Please see attached issues with invasive species not addressed by the literature of the rule repeal. Rescission of the Roadless Area Conservation Rule is opposed; its retention is respectfully requested. Best, C.N.

Dear Secretary Brooke L. Rollins: In my experience, roadless backcountry is not just scenery — it's functioning habitat, clean water, and quiet. Humanity finds refuge and redemption in wild places. The decision to rescind the roadless rule is one that forever destroys irreplaceable wilderness. Regarding the Devil's Den 09083 in the Green Mountain and Finger Lakes National Forests, Vermont: Forest plan consistency, multiple-use direction, and how proposed management would alter the roadless character of inventoried areas. Roadless areas fill gaps the existing protected-area system does not cover. Adding inventoried roadless areas to the U.S. protected-area system would increase representation of underprotected ecosystem types — including temperate grasslands (+57 percent) and cool temperate forests (+52 percent) — and would reduce the number of species of conservation concern considered "poorly represented" by 38 species. Forest plans alone do not provide the cross-forest consistency this network offers (Talty et al. 2020; Dietz et al. 2021). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288); Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943); UNKNOWN, 2021 (https://doi.org/10.1016/j.gecco.2021.e01943) Rescinding the Roadless Rule would open the Devil's Den 09083, Green Mountain and Finger Lakes National Forests to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Four generations of our family have hiked and fished and explored the wilderness of the Green Mountains of Vermont. Destroying these areas destroys our history, destroys our ability to enjoy these areas forever. These lands belong to all of us. The rule that protects them should stay. Thank you, CommentID: RLC-20261005-VPYTWC

I'm a college student who enjoys visiting national forests, and I support the proposal to establish recreation fee sites in the Green Mountain and Finger Lakes National Forests. Well kept trails, restrooms, and campsites cost money, and it's fair for the people who use these sites to help cover that upkeep, especially since the fees would stay local and go directly toward maintaining and improving the sites. The proposed fees also seem reasonable compared to similar sites nearby. My one request is that the Forest Service keep these places accessible to students and lower-income visitors, for example, by offering free days or discounted passes. With that addition, I think this proposal is a good way to protect these forests for future visitors.

Dear Secretary: My children are going to ask me what I did when this was proposed. I want to be able to honestly answer that we did what we could as a community. Nature is a sacred space for us and spending time in the outdoors is how we reset. We are teaching our kids the importance of protecting all species on this planet - animals and plants. My kids are Girl Scouts and we enjoy camping in areas such as this. Regarding the Woodford 09086 in the Green Mountain and Finger Lakes National Forests, Vermont: Headwater Protection for the West Branch Deerfield River Drainage — This 2,456-acre roadless area encompasses the headwaters of the West Branch Deerfield River and its tributaries, including Yaw Pond Brook and Rake Branch. The unbroken forest canopy over these streams maintains cold water temperatures critical for native fish populations and regulates streamflow during both wet and dry periods. Road construction would remove riparian shade and destabilize slopes, causing sedimentation and warming that would degrade spawning and rearing habitat throughout the entire downstream drainage network. Without road corridors, the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests, maintains the interior forest conditions that support breeding success for 2 Atlantic Flyway neotropical migrants. The roadless condition is not incidental to this breeding community — it is the mechanism that sustains it. Edge-associated nest predators and Brown-headed Cowbirds are excluded by the same unbroken canopy every one of these species requires. The DEIS must analyze the pathway by which road corridors through the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests, introduce Brown-headed Cowbird brood parasitism into interior forest used by 2 Atlantic Flyway breeding songbird species. Cowbird parasitism is a documented cause of reproductive failure in every species in this assemblage. The analysis must address the community-level impact, not individual host species in isolation. "Neotropical migrants are particularly susceptible to brood parasitism by brown-headed cowbirds. Before the 1900's, the cowbird was largely absent from Eastern forests, occurring primarily in the grasslands west of the Mississippi. When grassy areas are interspersed with fragmented forests, cowbirds can be abundant and have dramatic impacts on the breeding success of Forest Interior Dwelling Species (FIDS). Long-distance migrants are more vulnerable to predation and parasitism than resident birds because of their limited breeding season." — Maryland DNR - A Guide to the Conservation of Forest Interior Dwelling Birds in the Chesapeake Bay Critical Area, 2000 Rescission serves the fewest. The Rule serves the most. Keep the Rule. Warmly, Emily Tisdale

Dear Secretary Rollins: I am an ecological landscape designer who spends my time studying and actively creating habitat for threatened and endangered species. We cannot afford to build roads through our protected landscapes. Not only because of the critical habitat that will be lost, but the threat to our water quality, and fire risk that road construction creates. Construction inevitably introduces invasive plant species which displace our native species that our insects and birds rely on. I have not yet had the chance to get to Devils Den, but it is high on my list of places to visit. I want to see it in its pristine state, not a damaged, disturbed version. I am much less likely to visit a protected place that has been cut up with roads. Regarding the Devil's Den 09083 in the Green Mountain and Finger Lakes National Forests, Vermont: Extreme or 71-100% pop. decline severity and not assessed scope characterize the impact of 8.1 - Invasive non-native/alien species/diseases on Northern Myotis (Myotis septentrionalis, G2) in the Devil's Den 09083 Inventoried Roadless Area, Green Mountain and Finger Lakes National Forests — losses that the current Roadless Rule helps constrain. Road construction in Devil's Den 09083 introduces sediment, alters hydrology, and delivers chemical contaminants to adjacent habitats — the direct physical drivers of 8.1 - Invasive non-native/alien species/diseases. The absence of site-specific analysis for Northern Myotis (Myotis septentrionalis) in the Devil's Den 09083 Inventoried Roadless Area, Green Mountain and Finger Lakes National Forests, constitutes a gap in the administrative record that exposes the final decision to legal challenge. The DEIS must evaluate 8.1 - Invasive non-native/alien species/diseases at the documented severity and scope. "In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people." — Conservation Science and Practice (Wiley), 2020 The Assessment Documents Roads as Invasive-Species Vectors Threatening 60 Percent of Listed Plants The USFWS Biological Assessment states at page 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At page 344 it quantifies the stakes: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive or non-native species." The record before the agency confirms the mechanism from the states' own experts: the North Carolina Wildlife Resources Commission (DEIS Vol. III, p. 210) — "IRAs often have less non-native invasive plants due to the lack of roads and other pathways generally associated with their spread and distribution" — and the Nevada Department of Wildlife (p. 187), documenting the loss of "nearly 71% of its core sagebrush habitats, driven in part by invasive annual grasses… Roads are known vectors for these invasives." The DEIS contains no quantified analysis connecting foreseeable new road mileage to invasive-species spread in the very areas whose comparative freedom from invasives its own record documents. I request the FEIS analyze invasive-species introduction risk by alternative, using the vector mechanism and the 60-percent threat figure its own assessment supplies. This land belongs to the public. Don't sign it away. Yours truly, CommentID: RLC-20260909-QLJO29

Dear Secretary: As an outdoor enthusiast who regularly uses areas of national forest that retain their current character specifically because the 2001 Rule prohibits road construction within them, I respectfully submit that the Department's obligation under applicable statutes includes giving full weight to the public interest in those conditions before authorizing their alteration. Regarding the Woodford 09086 in the Green Mountain and Finger Lakes National Forests, Vermont: These public lands belong to the people and it is our job to protect them, including maintaining the federal protection for roadless areas. It's imperative we keep nature wild. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Caliskan, 2013 (https://doi.org/10.1186/1735-2746-10-23) Rescinding the Roadless Rule would open the Woodford 09086, Green Mountain and Finger Lakes National Forests to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Not a fan of this proposal. Pull it. With thanks, Delia O'Donnell

Do NOT repeal the 2001 Roadless Rule. I am a New York resident and National Forest user. I have benefitted from the wild places, notably the Green Mountain and Finger Lakes National Forests in Vermont and the Pisgah and Nantahallah National Forests in Tennessee and North Carolina. These places should be kept wild and should not be opened to further logging and road-building. Wildfires are regenerative, and instead of using them as a scapegoat and an excuse to give away logging rights, they should be managed—which is possible when the Forest Service has its funding restored. This country is great because of its natural spaces, and they should be protected and kept wild at all costs.

To the Roadless Rule Rulemaking Docket: For an outdoor enthusiast, roadless public land is not a luxury — it's the version of public land that delivers what public land is for. Regarding the Woodford 09086 in the Green Mountain and Finger Lakes National Forests, Vermont: Population-level impacts of not assessed severity across not assessed scope are documented for Northern Myotis (Myotis septentrionalis, G2, E) in the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests, driven by 6.1 - Recreational activities. The roadless character of Woodford 09086 currently prevents the infrastructure penetration that initiates 6.1 - Recreational activities. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for Northern Myotis. The agency cannot satisfy its analytical obligations with a national-level discussion of roadless values. The DEIS must address 6.1 - Recreational activities as it affects Northern Myotis (Myotis septentrionalis) specifically within the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests. "Grazing by domestic herbivores is the most widespread land use on the planet, and also a major global change driver in grasslands. We show that aridity partly explains the responses of biodiversity and multifunctionality to long-term livestock grazing. Grazing greatly reduced biodiversity and multifunctionality in steppes with higher aridity, while had no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relative lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity." — Nature Communications, 2023 “The current national forest road system includes 380,000 miles of roads. The agency also has a road reconstruction and maintenance backlog of approximately $8.4 billion, and it receives only about 20 percent of the annual funding needed to maintain its road system up to safety and environmental standards. — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-james-furnish-statement-before-senate-20000726-stelprdb5137345.pdf)” “When the 2001 Rule was issued, the NFS road system was over 386,000 miles long. The FS argued that budget constraints, coupled with the size of the forest road system, prevented the agency from managing the road system to required safety and environmental standards. For example, in issuing the 2001 Rule, the FS indicated that there was an estimated $8.4 billion in deferred maintenance and reconstruction on NFS roads and that, in addition to the 2001 Rule, it sought additional measures to control the transportation share of its budget. — Congressional Research Service, 2020 (https://www.congress.gov/crs_external_products/R/PDF/R46504/R46504.2.pdf)” “Roads cause habitat loss and fragmentation not only through their physical occupation, but also through traffic noise. The results showed that the habitat loss due to noise effect zone is dramatically higher than that due to road land-take only (35% versus 1.04% of the total area). We conclude that, although the roads are breaking apart the patches by land-take, road noise not only dissects habitat patches but takes much larger proportions of or even functionally eliminates entire patches. — Hossein Madadi | Hossein Moradi | Alireza Soffianian | Abdolrassoul Salmanmahiny | Josef Senn | Davide Geneletti, 2017 · Environmental Impact Assessment Review (https://doi.org/10.1016/j.eiar.2017.05.003)” “Construction of roads, utility corridors and other human infrastructure kills any sessile or slow-moving animal and all vegetation in the path of the feature. Roads and other linear infrastructure negatively impact wildlife through increased mortality, decreased habitat amount and quality, changing species movement patterns, and fragmentation of populations into smaller subpopulations, which are more vulnerable to local extinction. — Trombulak, S. C., and C. A. Frissell, 2000 · Conservation Biology (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. — René E. van Dijk, Toine Morel, Karen Zwerver, Paul van Els, Ruud P. B. Foppen, 2025 · Landscape Ecology (https://doi.org/10.1007/s10980-025-02100-5)” Nothing in the proposal persuades me that the Rule has failed to serve the purposes for which it was adopted. Sincerely, Dr. Becky Phillips

Dear Secretary Brooke L. Rollins: In my experience as an outdoor enthusiast who has used national forests in multiple regions over many years, I have come to understand that roadless areas are not the norm but the exception — the product of deliberate regulatory protection — and that the proposed rescission would remove the instrument responsible for maintaining that exception. My time spent in nature not only enriches my life but helps me restore my energy, feeling recharged to continue working as a health care provider contributing to the public health and well being of my community. The Rule has, for nearly twenty-five years, preserved the character of places like the one described here; rescinding it would be an irreversible administrative act with irreversible consequences on the ground. Regarding the Griffith Lake 09084 in the Green Mountain and Finger Lakes National Forests, Vermont: What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Research - Fire Safety” “Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation. The surfaces of unpaved roads can route fine sediments to streams, lakes, and wetlands, increasing the turbidity of the waters, reducing productivity and survival or growth of fishes. Roads have been responsible for the majority of hillslope failures and gully erosion in most steep, forested landscapes. Alteration of hydrodynamics and sediment deposition can result in changes in channels or shorelines many kilometers away, both down- and up-gradient of the road crossing. — Conservation Biology, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” The Department is urged to give full weight to the administrative record compiled over more than two decades before proceeding with any rescission action. Yours truly, Jen Walsh CommentID: RLC-20260823-4QZHY9