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Dear Chief Schultz, My name is Nolan, and I live in Indiana. I may not live near a roadless conservation area, but this issue is still extremely important to me. The rescission of the Roadless Rule is the exact opposite of climate crisis mitigation that the country’s vast forest areas work hard to achieve. I want the Roadless Rule to stay. Keeping our forests roadless will leave forest carbon work undisturbed, which will maintain a source of healing for the climate in its current time of crisis. I have never been to Mogan Ridge or any section of Hoosier National Forest, but I imagine it offers a lot more to discover and more habitats to be amazed at as the woodland areas past my backyard and where I hike through. I would like for my local section of the Hoosier National Forest to stick around for me to explore it someday. One time I walked through a roadless area was when my family and I hiked the Hemlock Cliffs trail in Crawford County, Indiana. We were in awe at the massive cliff rocks that we were able to stand under and the bright green plants. The rescission of the Roadless Rule takes the possibility of hiking the Mogan Ridge Trail, if not the enjoyment of hiking it, away from me. Nobody would want to walk through a state park with a four-lane road through the middle of it. The level of exposure to vehicle emissions would be perilous in a place where that shouldn’t be a problem. Paving roads through Mogan Ridge will drastically increase sediment levels. That excess sediment rushing through road ditches and stream will reduce oxygen for the Pink Mucket species that Mogan Ridge is known for. In other words, the bursts of sediment originating from roads will kill the Pink Mucket species. Regarding the Mogan Ridge in the Hoosier National Forest, Indiana: Interior Forest Conditions for Shade-Intolerant Oak Regeneration — The dry and dry-mesic upland forests of Mogan Ridge contain mature white oak and hickory trees that are essential seed sources for the oak-hickory forest type. These species require specific light and fire regimes that are maintained in roadless areas where natural disturbance patterns persist and where the absence of fragmentation allows seed dispersal and seedling establishment across large, unbroken forest blocks. Road construction introduces edge effects—increased light penetration, invasive species colonization, and altered microclimate—that favor shade-tolerant competitors like American beech and sugar maple, permanently shifting the forest composition away from oak dominance. The DEIS must conduct a site-specific, watershed-level analysis of road construction impacts on aquatic habitat in the Mogan Ridge IRA, Hoosier National Forest, for Pink Mucket (Lampsilis abrupta, Critically Imperiled). A programmatic EIS that treats all roadless areas as interchangeable fails to satisfy NEPA's requirement for analysis proportional to the significance of the resource at risk — and a G1-ranked aquatic species is a significant resource. "Future projections indicate a basinwide maximum 7-day average of daily maximum stream temperature increases of 1.42°C–2.04°C for the midcentury, and 1.84°C–3.24°C by the end of the 21st century. These increases reduce the most thermally suitable habitats for steelhead, coho, Chinook, and bull trout by an average of 27%–36% during the mid-century time period, and 35%–51% by the end-of-century time period." — Journal of Environmental Management / ScienceDirect, 2025 The Department should take seriously how much I, along with millions of Americans treasure protected forest lands. Although hiking is closest to my heart, there are many other important purposes protected areas serve. Rescission is a slap in the face to anyone who has ever spent a single minute in a preserved area such as the Hoosier National Forest. Regards, Nolan CommentID: RLC-20261007-FB7671

I am a retired employee of the USDA conservation service (Soil Conservation Service / Natural Resources Conservation Service), with decades of experience in soil and water conservation. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (docket FS-2025-0001). For a quarter century, this rule has protected approximately 44.7 million acres of National Forest System lands from new road construction and timber harvesting. Rescinding it would not restore local control of healthy forests; it would open landscapes to roadbuilding and logging that have thrived precisely because they were left intact. The wildfire rationale does not hold up: published research (Aplet, Hartger & Dietz, January 2026) found that national-forest wildfires are four times more likely to start near roads. More roads mean more ignitions, not fewer. As an Indiana resident, I note the Hoosier National Forest contains roughly 8,000 acres of inventoried roadless areas (per the Forest Service's own mapping), within a forest that anchors recreation and clean water for south-central Indiana. The Lake Monroe watershed — sole drinking-water source for more than 130,000 residents — depends on intact forest on steep, erosion-prone slopes; it is the cheapest water-treatment infrastructure in the region. Finally, the record shows this is not what the public wants: the 2025 scoping process drew more than 220,000 comment letters representing over 625,000 individuals, with roughly 99% opposed to rescission. Please keep the 2001 Roadless Rule in place.

The Roadless Area Conservation Rule should not be rescinded. I am in strong support of Alternative 1, the No Action alternative, in the Draft Environmental Impact Statement for Roadless Area Conservation. I urge the Forest Service to retain the 2001 Roadless Rule in its entirety and reject any proposals to rescind or weaken these vital protections across our national forests. Inventoried roadless areas provide irreplaceable ecological, economic, and social values that must be preserved for current and future generations. I oppose Alternatives 2 and 3 since they would jeopardize the following benefits to the American public. Vital Habitat for Imperiled Species - The lands in question include diverse forests, wetlands, canyons and other undeveloped lands that are critical to our nation's ecological health. Because they are not fragmented by roads, these Roadless Areas provide habitat for many imperiled species such as California condors, grizzly bears and wolves in the Yellowstone area, native salmon and trout in the Pacific Northwest, migratory songbirds in the Appalachian hardwoods and more. They also sustain wild salmon, especially in Alaska where they are the lifeblood for both the fishing industry and traditional subsistence practices of Indigenous communities.   America’s Drinking Water - The US National Forests are the headwaters of many of our great rivers and one of the largest sources of municipal water supply in the nation, serving over 60 million people in 3,400 communities in 33 states. Because it protects these headwaters, the 2001 Roadless Rule 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. Economic and Recreational Value - Roadless areas offer abundant outdoor recreation opportunities such as hiking, hunting, fishing, and camping in primitive settings. Every year, millions of people visit roadless outdoor areas and directly support a robust outdoor recreation economy. According to maps from Outdoor Alliance’s GIS Lab, roadless areas protect 11,337 climbing routes and boulder problems, more than 1,000 whitewater paddling runs, 43,826 miles of trail, and 20,298 mountain biking trails. Large sections of the Continental Divide, Pacific Crest, and Appalachian National Trails traverse protected roadless areas. Precious Old Growth Forests - Many roadless areas are sanctuaries of the last remaining fragments of old growth forests. While the biggest ones are found in the western US and Alaska, the tiny fragments that remain in our eastern national forests can be as small as a few thousand acres. Many of these areas have remained roadless because they are not suitable to extractive industries, often having steep slopes and poor soil. We must protect the few precious fragments of old growth that we have left. Millions Support the Roadless Rule - The Roadless Rule is a highly popular policy that is often celebrated as one of America’s most successful conservation measures. Prior to its enactment, more than 600 public hearings were held nationwide, and 1.6 million Americans weighed in to call for protection of these forestlands. More recently, more than 45 members of the House and Senate have signed onto legislation that would codify the Roadless Rule so that in the future, it could not be rolled back without an act of Congress. Rollback Paves the Way for Logging - The real reason a rollback of the Roadless Rule is being proposed is to re-open these forests to logging and other industrial development. This proposal follows other administrative actions that have called for a dramatic increase in logging and oil and gas drilling on federal lands. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. Roadbuilding Drains Taxpayers - Even with the Roadless Rule in place, the Forest Service already has a 370,000-mile road system – twice as long as the nation’s highway system – crisscrossing national forests. This forest road infrastructure is already so big that the Forest Service can’t afford to properly maintain it, triggering billions in maintenance backlogs for needed repairs. Taxpayers have subsidized this already unwieldy road network and would be stuck paying for any new roads built in backcountry forest areas following this rollback. For example, the Hoosier National Forest is currently proposing to close a popular road, Tower Ridge Road, that has been open for generations due to lack of maintenance funding. The Forest Service cannot take on additional mileage that would come from removing the Roadless Area Conservation rule. The Roadless Rule protects America’s last remaining wild places, and should be strengthened, not rescinded.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Having lived in places that will be directly affected by rescission of the Roadless Rule, including Washington and North Carolina, and hope to visit more soon, I am filing this comment against Docket FS-2025-0001 because what is at stake is not a policy abstraction. It is land that has stood for thousands of years and should not be carved up by an administration against the wishes of its citizens. Indiana has so few uninterrupted areas of public land that include Mogan Ridge, at 8,435 acres in the Hoosier National Forest, carries an outsized weight. We should be doing everything we can to preserve what already exists, not breaking it up further for industry or potential data centers. The Wolfpen area in Daniel Boone National Forest is Kentucky's entire roadless inventory, all 2,835 acres of it, and it protects headwater streams feeding the Red River, Kentucky's only National Wild and Scenic River. The sandstone overhangs of the Red River Gorge shelter over 5,000 Virginia big-eared bats, roughly 40 percent of the global population of a federally endangered species. Indiana bat, Kentucky arrow darter, blackside dace, and northern long-eared bat also depend on that forest. These are not species that can simply relocate. Rescission does not threaten inconvenience; it threatens extinction, and I want the agency to explain in its final record what specific analysis it performed for each of these listed species before concluding that loss of roadless protections would not accelerate their decline. Washington alone holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Clean water is essential for the everyday health and well-being of Americans, and repealing this rule will contaminate water supplies. The agency knows this. Its own analysis establishes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I ask the agency to explain, in response to this comment, how it squares that finding with a proposal to remove protections from the very unroaded lands whose sediment-free streams supply drinking water to communities across the country. The proposal invokes wildfire management as a rationale, but 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 agency must reconcile this rescission with the ignition data in its own DEIS and explain why a proposal that will increase the roaded footprint of the national forests is an appropriate wildfire response. On the economics, the agency's own record concedes: "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." I ask the agency to reconcile the proposal with its own cost-benefit analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and to explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal argues that state-by-state approaches can replace one national rule, but the agency's own record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit evaluated that precise experiment and found it wanting. The agency should address how this attempt avoids the same deficiencies. Finally, on the question of statutory authority, the record contains this holding from a court that reviewed it: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The lands should be preserved for future generations to maintain environmental stability and the continued existence of species that will otherwise go extinct, not sacrificed for short-term profit. The agency must state plainly and on the record the legal basis for any position contrary to that holding. Sincerely, A concerned citizen

To the Department of Agriculture: I am a lifelong conservationist. A youth spent mostly going to zoos and mourning the loss of habitats around the world led to a career in wildlife conservation where I realized just how much is at stake. That loss across the world has already been here, we've lost more habitats and species than most will ever know. And we cannot risk losing more to deregulation based on unscientific claims that we know will accelerate human-caused environmental damage and negatively impact human health. The already strained federal wildfire workforce, which includes managers and biologists who are not in explicit fire roles, is already limited in their ability to enact proactive wildfire treatments in favor of wholesale wildfire suppression. Over 90% of wildfires occur within 0.5 miles of a road. My friends, colleagues, and neighbors in the community will stand to lose the lands we protect, our homes, our families, and our lives. I do not want to see another obituary of a wildlands firefighter. I do not want to see the death till climb from yet another fire. We will lose our clean water, species that depend on connected habitats, and further exacerbate the spread of invasive species to sites that reflect pre-colonial conditions. This is unacceptable and the roadless rule should remain as it is currently written. Rescinding the Roadless Rule would open the Morgan Ridge, Hoosier National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes this proposed change so harmful. Morgan Ridge's unfragmented interior forest provides critical maternity roost habitat for four federally endangered bat species: the Indiana bat, gray bat, northern long-eared bat, and the proposed endangered tricolored bat. These species require continuous, mature forest canopy to navigate between roosting sites and foraging areas without exposure to predators or weather. Road construction fragments this canopy into isolated patches, severing the movement corridors these bats depend on to access maternity colonies and seasonal hibernacula disruption that is functionally irreversible on the timescale of bat population recovery. Regarding invasive species (which also increase wildfire risk), road construction creates a linear disturbance corridor, including compacted soil, exposed mineral substrate, and altered hydrology, that helps invasive plants colonize rapidly. Non-native species spread from the road into adjacent forest, outcompeting native understory plants including goldenseal and American ginseng. The roads also increase human access to the forest interior, facilitating illegal collection of vulnerable species. Once invasive species establish in the mesic upland and bottomland hardwood forests where goldenseal and ginseng persist, native plant communities are difficult if not nearly impossible to restore. Invasive species will suppress native seed germination and seedling establishment for years or decades. Road building will only increase wildfire risk and bring destruction to crucial ecosystems. Listen to those who've done the research and manage our public lands and do not repeal the roadless rule based on false claims. Do not send my colleagues into deadly fires caused by careless deregulation. Thank you, CommentID: RLC-20261007-412LXA

I would like to express my disagreement and disappointment with the U.S. Forest Service proposed rule to rescind in its entirety the National 2001 Roadless Area Conservation Rule. My family and I are avid nature lovers. We would rather be outside than inside. We prefer to experience the wonders of our nation's outdoors in their natural surroundings. We walk, hike, backpack and camp using Leave No Trace ethics. We admire the changes in nature during the 4 seasons: the new life of Spring, the active growth of Summer, the preparations of Fall, the resting time of Winter. I remember seeing more than 2 dozen varieties of wildflowers blooming during the last week of March on a Spring Break camping trip in Hoosier National Forest, IN. During a Summer backpacking trip in Superior National Forest, MN, I watched the emergence of a dragonfly crawling out from its final stage and making its way to a rock, where it rested and dried itself in the sunshine, gaining strength to fly away. Having grown up in the Chicago Metro area, my first trip to Shawnee National Forest in downstate IL was a wonderful awakening to the fact that Illinois is not made up of just farmland and cities...Downstate IL is Forest! My family has traveled throughout all 50 United States. From White Mountain National Forest, NH, across to Sequoia National Forest, CA, up to Chugach National Forest, AK, over to the Forest Reserves of Hawaii, and many forests in between, our National Forests provide us with un-surpassing beauty, solitude, diversity, and peace. The busy National Parks are crowded with tourists visiting the wonders of our country. Many National Forests border these Parks, providing undisturbed habitat and access to the land. Our children, grandchildren, and future generations deserve the opportunity to seek out the amazing wonders of our unique natural spaces in solitude and peace. My husband and I recently spent time camping and hiking in our nation's first National Forest, Gila NF, NM. The strip mining area outside Silver City, NM, is an ugly example of what happens when the forest and land are destroyed. Opening up NF land to the possibility of new roads being built and private business taking over is not in our nation's best interest. We have an unknown number of species that have not yet been discovered and cataloged. Their survival depends on unique characteristics and habitats found only in the small amount of pristine, untouched, old growth forests we have left. When their habitats are destroyed, species we have never observed will be gone from Earth forever. We can't get them back. Please do not rescind the National 2001 Roadless Area Conservation Rule. Thank you

Dear Secretary Rollins: I am writing as an Indiana resident who strongly opposes repealing the 2001 Roadless Area Conservation Rule FS-2025-0001-223869. Weekly, I spend a great deal of time hiking and visiting parks and natural areas with my family. Through local conservation programs I have learned how delicate our natural areas are. Once disturbed, it takes much more work and finances to repair any damage done. Our national parks service is already back logged with road repairs according to https://www.nps.gov/subjects/infrastructure/maintenance-backlog.htm we have over $35 million in deferred maintenance. I feel adding to this back log is irresponsible and would diminish the quality of our parks and environment. Some of our nation's most treasured habitats are intact and thriving solely because of the roadless rule. Removing this rule would lead to habitat loss for endangered species, overgrowth of invasive species, and a significant increase in the management costs in these areas. These roadless areas include up to 18,000 acers in the Hoosier National Forest, home to 6 endangered species according to https://www.nationalforests.org/forest/hoosier-national-forest/. The loss of these species and the fragmentation of the land would greatly disturb the ecosystem within the Hoosier National Forrest which is responsible for the great air quality and landscape of the area. https://www.edmondok.gov/1234/Trees-Improve-Air-Quality The Roadless Rule does not hinder access to wild natural areas for management. The Roadless Rule helps to protect fragile ecosystems and preservesvaluable public lands for generations to come. Please retain the 2001 Roadless Area Conservation Rule and stop the destruction of public lands. Sincerely, Jacob Ford Clarksville, IN

I strongly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. As a resident of south-central Indiana, there are few pristine natural environments left within easy reach of me, and there few throughout the entire midwest. Mogan Ridge in the Hoosier National Forest is the only inventoried roadless area in the state of Indiana, and rescinding the Roadless Area Conservation Rule will put it at risk.. As an avid hiker, camper, fisherman and amateur photographer, I frequently use National Forests lands both in the midwest and throughout the country, frequently visiting these wild lands in both the eastern and western U.S. I value the roadless areas that are placed at risk by the proposed rescission for quiet, remote and self-reliant recreation. There are thousands of miles of trails inside the affected areas and under rescission these areas could shift toward more developed conditions, which would be a tragic loss of wild lands. As a trout angler, I recognize that many of the waters that I fish in originate in these roadless areas. Roads alter watershed hydrology and stream channels. Sedimentation from harvest, and from roads and their skid trails, can promote excessive substrate movement and negatively impact fish such as trout and salmon which are dependent on cold, clean water. The clean water that flows from the impacted roadless lands are the reason why we still have cold-water fisheries in the U.S. today. In addition, millions of Americans depend on the waters that originate in these roadless areas as the eventual source of their drinking water, and removing protections from these lands puts their water quality at risk. Rescission of the roadless rule will have an economic impact on the many businesses, such as outfitters and guide services, that depend on outdoor recreation such as hunting, fishing, hiking and camping. In many states, the outdoor recreation industry far oustrips extractive industries in impact on the local economy. These areas are the last unroaded parts of the national forests, and the Draft Environmental Impact Statement (DEIS) is explicit about the impact on habitat for birds, fish, and other wildlife. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and in its own words on wide-ranging mammals like the grizzly: they “have suffered habitat loss and the extirpation or fragmentation of their populations.” In the DEIS’s own comparison, the rescission alternative “has the greatest potential for negative effects to scenery.” The stated purpose of the rescission of the Roadless Rule is NOT to promote forest health. The purpose and need is to supposedly reduce regulatory burden on the Forest Service. Every conservation alternative was eliminated for failing that purpose. In its own words, the agency states “This proposed rescission does not mandate timber cutting or road construction.” Nothing about management is promised, only the removal of protections. The last unroaded third of the national forests is at stake with this proposed change. The 2001 rule was written through more than 600 public meetings and more than 1.6 million public comments, yet this proposed rescission has been the subject of no public meetings and a sharply curtailed public comment period. One suspects that the agency understands that this proposed rescission is extremely unpopular and wishes to avoid the negative publicity that such public meetings and comments would generate. Further, this cannot possibly be portrayed as a cost-saving measure for the Forest Service. Road appropriations have fallen from $234 million to $73 million between 2004 and 2024. The DEIS states outright that road mileage, maintenance and management costs are likely to increase. Finally, the rescission of the Roadless Rule will not decrease the number and frequency of wildfires. Human-caused ignitions, the prevalent cause of wildfires in our national forests, occur most frequently around roads, not in roadless areas. In summary, I strongly oppose the proposed rescission of the Roadless Area Conservation Rule. These lands must be protected for the security and enjoyment of future generations.

I strongly oppose the proposal to rescind or partially rescind the Roadless Area Conservation Rule. As a concerned Environmental Scientist from Indiana, roadless areas like the Hoosier National Forest are important to me for preservation of water quality and wildlife habitat. Roadless areas provide clean drinking water for millions of Americans, critical wildlife habitat for threatened species, carbon sequestration, preservation of sacred sites, and recreational opportunities. Roadless areas are also crucial for wildfire prevention, expanding roads into forests would increase wildlife risk. Research has shown that wildfires are four times more likely to start near roads due to human-caused ignitions such as sparks from vehicles or unattended campfires. For the reasons listed above, I strongly oppose the proposal to rescind or partially rescind the Roadless Area Conservation Rule. I support Alternative 1, the No Action alternative.

Subject: Public Comment on Docket FS-2025-0001 – Strong Opposition to Rescinding the 2001 Roadless Rule Dear Forest Service Officials, I am writing as a resident of Ferdinand, Indiana, to express my strong opposition to the proposal to rescind or weaken the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I live near and own a woods near the Hoosier National Forest in southern Indiana. I care deeply about the preservation of our nation's shared natural heritage. The nearly 45 million acres of inventoried roadless areas across the United States belong to all Americans. These public lands serve as critical bulwarks against climate change, acting as massive carbon sinks and protecting the headwaters that provide clean drinking water to millions of people downstream. Opening these pristine, undeveloped lands to industrial logging and road construction will cause irreversible damage to wildlife habitats, increase wildfire vulnerability, and place an unnecessary financial burden on taxpayers to maintain new infrastructure. As a resident and taxpayer, I urge the U.S. Forest Service to uphold its commitment to conservation and sustainable public land management. Please select Alternative 1 (the No Action alternative) in the draft Environmental Impact Statement and keep the 2001 Roadless Rule fully intact. Thank you for your time and consideration of my comments. Sincerely, Rock G. Emmert Ferdinand, IN 47532

I am writing to oppose the recommendation to repeal the 2001 Roadless Area Conservation Rule. I have read Secretary Rollins’ comments about how he and other land managers believe that the rule has hindered efforts to create better access to public lands for the purposes of forest management. I do agree that forest management practices are in need of revision. I also agree that there is great concern for the potential of some of these lands being severely damaged by wildfires. However, I do not believe that the rescission of the roadless rule is the answer nor do I believe that it is the appropriate response. It has been reported that, out of all the significant wildfires in the contiguous United States, only 1% have been associated with roadless areas. A 2017 article published in the Proceedings of the National Academy of Sciences (PNAS) states that “over 84% of the government-recorded wildfires were started by people from 1992 to 2012. Sixty percent of the total land area of the coterminous United States was dominated by human-started wildfires, whereas only 8% of the area was dominated by lightning fires.” Most wildfires are caused as a result of human activity and infrastructure. Human-created causes of wildfires can include, for example: fireworks, escaped camp fires, burning trash, power lines, improperly discarded cigarettes, arson, and sparks from machinery. While it is true that the existence of a road through a public land could aid fire fighters in their efforts to fight a wildfire by enabling them to transport themselves and their equipment more quickly into remote areas, the very existence of such roads would be a double-edged sword for the lands that they would be intended to protect. Roads would allow people greater ease and access to these properties. Even if the use of such new roads were restricted, could we really expect trespassers to abide by other rules (i.e. if someone were to drive onto a forest service road that they are not supposed to be on, how could we trust them to also not light illegal campfires or fireworks, etc.)? Another reason to keep the roadless rule is that some of these roadless areas serve as upstream watersheds for communities that are downstream and outside of these protected zones. For example, the city of Bend, Oregon draws its water from streams that pass through roadless areas in the Deschutes National Forest. The creation of more roads and the act of logging these areas could introduce contamination into drinking water sources. Another issue is monetary. Roads cost money. They cost money to build, and they cost money to maintain. It is reported that the U.S. Forest Service currently has a backlog of several billion dollars for the maintenance of its already existing 380,000 miles of roads. It would make more sense to use funds for roads that have already been built before trying to construct new ones. I would also like to emphasize the importance of preserving these areas for the benefit of all Americans, including future generations who have not even been yet. The United States is a beautiful and ecologically diverse nation. I have personally had the privilege to hike through many national forests, including areas that are part of roadless areas. While I acknowledge that it was a road that enabled me to travel to the trailheads, there are already ample opportunities for recreational activities in these lands that do not require the construction of more roads. I recently returned from a trip out west which included a hike along Tumalo Creek in the Deschutes National Forest in Oregon. Some of that gorgeous forested land is part of a roadless area and is also part of the aforementioned Bend watershed. I have hiked through other roadless areas such as the trail to Tamawanas Falls in the Mount Hood National Forest, on trails in roadless areas near Lake Quinault in Washington state, along the ocean in Oregon Dunes National Recreation Area. These areas are gems of our great country, and they are worth preserving so that future generations of Americans can explore them on foot as well. Having grown up in Indiana, I appreciate that there is even a roadless section in the Hoosier National Forest. My home state was once mostly forest (numbers change depending on the source, but most claim that Indiana was once 70-80% forest even 200 hundred years ago). Today Indiana forests are but a fraction of what they once were. Let us protect and preserve what remains. Now that I live in the concrete jungle of Philadelphia I can appreciate even more greatly the need to protect and preserve natural areas of our country. There are few trees on my city block, and not even a blade of grass. I urge you to protect America’s roadless areas by keeping the roadless rule in place so that we can always have these wonderful lands to enjoy! Respectfully, Taylor Davila

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests closest to me, and every forest in this country, are at stake in this proceeding. I watch for birds, including migrating birds, and other wildlife, and I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). The roadless areas I am most connected to include Perch Lake, Shelp Lake, Shoe Lake Islands, and Wheeler Lake Islands in the Chequamegon-Nicolet National Forest in Wisconsin, as well as Bear Swamp in the Huron-Manistee National Forest in Michigan and Mogan Ridge in the Hoosier National Forest in Indiana. These are places worth protecting without qualification, and the agency has not made a credible case for opening them. The record the agency assembled does not support rescission on economic grounds. The DEIS itself 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." Against that baseline, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. That range cannot establish a net benefit. It also cannot explain how expanding a road system that already carries a $6.9 billion maintenance backlog is fiscally responsible. I ask the agency to reconcile the proposal with these figures in the record and explain how a Cost Benefit Analysis with that spread justifies this action. Bird richness declines with road presence in forested habitat. The DEIS documents this directly, finding that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. I watch for birds, including migrating species, in these forests. The areas I named are among the nearest to me, and Perch Lake alone covers 2,390 acres of the Chequamegon-Nicolet, part of a Wisconsin roadless inventory totaling 68,987 acres across 16 areas. Fragmentation of that habitat does not produce a modest, manageable effect. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and then disappears; no projection across the 40.1 million acres of potentially affected environment follows. I ask the agency to apply that cited range to the full affected acreage and explain what it means for bird populations specifically. The agency documents the relationship between roads and wildlife and then sets the finding aside. "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." No population-level effect on big game is projected anywhere in the document. The agency should project the effects on big game populations and hunter opportunity before finalizing any alternative. Carbon storage is acknowledged and then effectively ignored. "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." The DEIS concludes these lands will continue to sequester and store carbon, but that conclusion does not account for harvest and roading under the action alternatives. The agency must quantify the change in carbon storage and sequestration under each alternative, not assert continuity while proposing development. We do not want roads going through our parks, our forests, our sacred lands. That is a simple and sufficient statement of interest, and it applies to every single forest in this country, not only the ones nearest to me. Wisconsin's roadless watersheds also supply drinking water to communities: across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. Fragmenting these forests and expanding the road network puts both ecological integrity and water supply at risk. The agency has not answered the basic question its own data raises. I ask that it do so. Sincerely, Jen Curley Chicago, IL

As a voting constituent and great appreciator of the amazing public lands we have here in the United States, I'm sending in my strong opposition to rescinding the 2001 Roadless Rule. Conserving and protecting natural spaces without enhancing access to vehicles and people is essential to keeping our natural spaces healthy and beautiful as they are. Road construction and development will destroy the peacefulness for the natural inhabitants as well as those who are able to explore these natural spaces in a respectful manner. The noise, danger to animals, and equipment needed to build and develop in natural spaces is not necessary - are citizens asking for this to be done? This rule has been in place since 2001 and it has effectively protected natural spaces from development. Look at what is happening in Big Bend - this craziness needs to stop. Voters do NOT want our government or greedy developers destroying the natural beauty and spaces that we are fortunate to have preserved and visit. My family lives close to and regularly enjoys hiking in the Hoosier National Forest. I can't imagine what that experience would be like if there were roads and development in the middle of the forests. Please spend the time and energy doing something useful and constructive for the people and natural resources of this country.

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million-acres of National Forest System lands, or about a third of all lands managed by the USDA Forest Service (Forest Service). “Inventoried Roadless Areas” (IRAs) protected by the Roadless Rule represent many of the wildest, healthiest, and most intact landscapes in the United States (https://www.pfpi.net/wp-content/uploads/2026/06/Roadless-Rule-Rescision-Threatens-Preprint-Mildrexler-et-al.-2026.pdf). Over 1.5 million Americans submitted comments in support of the Roadless Rule when it was developed, a record for public participation in federal rulemaking that still holds to this day.In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the White and Green Mountain National Forests, combined. Iconic landscapes protected by the Rule include places like New Hampshire’s Franconia Notch, Mt Moosilauke, Mt Chocorua, and the Presidential Range, as well as Vermont’s White Rocks. The famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Even Indiana benefits from this rule within the Hoosier National Forest - this is a vital area for wildlife and human recreation, a gift that could be lost without the continuation of this rule.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.The work the Roadless Rule is providing implements incredible, irreplaceable protections on an environment that means so much to me & all citizens in the midwest. For a part of the country that used to be completely covered in trees, we must protect the little patches we have left and keep it from being disturbed by human processes.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.I know the environment hasn’t been of the highest priority in Indiana as of late, but it is an integral part of who we are as a state and as a people. I implore you to please change this trend and protect our natural spaces.Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.BriannaIndiana

Hello I have observed first hand the problems that can result when forest management decisions become the rule throughout the vast national forest system. Even age management (clear cutting) way seems to to be the best practice for harvesting a mountainside in a western state, but clear cutting relative small tracts in the Hoosier National Forest created clearings for invasive shrubs and faster growing trees, hindering germination and growth of oak and hickory. The roadless rule was and is a National Forest wide management plan I support whole heartedly. Roads into mature forests is an invitation for trouble to follow. Roads invite off road vehicles which leads to erosion and vegetation damage. It disturbs wildlife during breeding and nesting, and creates more infrastructure that isnt maintained. Allow wise Forest stewards to plan responsibly for sustainable harvests while protecting critical habitat for the insects, birds, and animals that call our national forests home. Larry The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in southwest Ohio and spend time hiking, camping, backpacking, and exploring public lands throughout the Midwest. Places such as Mogan Ridge in the Hoosier National Forest, an 8,435-acre Inventoried Roadless Area, are part of the natural heritage of our region. I believe responsible forest management is important. We need to address wildfire risk, forest health, recreation, timber production, hunting, fishing, and emergency access. But responsible management does not require us to make every acre more accessible, developed, or economically productive. Some places are valuable precisely because they remain undeveloped. Roadless forests provide wildlife habitat, protect watersheds and clean water, preserve biodiversity, and give Americans something increasingly rare: solitude and the opportunity to experience nature without roads, buildings, and infrastructure surrounding us. Once a road fragments an intact forest and changes its character, that decision is difficult—if not impossible—to reverse. A great country should be capable of building for the future while also having the wisdom to preserve places that should never need to be built upon. I want my children and grandchildren to inherit an America with thriving communities and modern infrastructure, but also forests where they can still hear the wind through the trees, encounter wildlife, and experience genuine wilderness. We should not measure progress by how much of our public land we can develop. America does not become greater by developing every place we possibly can. Sometimes greatness is having the wisdom to say: this place is worth keeping. I respectfully ask the Forest Service to retain the 2001 Roadless Area Conservation Rule and maintain a national baseline of protection for these irreplaceable places.

Comment on Proposed Rule: Special Areas; Roadless Area Conservation RIN 0596-AD66 • Docket FS-2025-0001 • 91 FR 53827 (Aug. 20, 2026) I oppose rescinding the 2001 Roadless Area Conservation Rule. I ask USDA to withdraw this proposal, retain 36 CFR part 294, Subpart B (§§ 294.10–294.18), and reject the draft EIS preferred alternative of full national repeal. I am K. Nash Richards, a private citizen in Indiana. I am commenting because inventoried roadless areas are among the last public lands that still function as true wilderness—not a curated park, but unroaded country. Once a road is built, that condition cannot be restored. Indiana’s Hoosier National Forest has only about 8,000 roadless acres. That scarcity is why a national rule matters here as well as in the West. I am also commenting on the nationwide effect: this proposal would lift the national prohibition on new roads and most logging on roughly 45 million acres in 38 states. There are roadless lands I still want to walk myself, and to take my future children into. I have been to Great Smoky Mountains National Park many times, as a child and as an adult. It is gorgeous. It is also a park: roads, overlooks, and a managed visit. I feel the pull of a different kind of country—the unroaded national-forest land this rule still protects. I want my children to see what earlier generations of frontiersmen had to move through to make the country we inherited: forest that had not yet been fitted to a road, not only the version we have already improved for cars. USDA says the 2001 rule blocks wildfire work and that decisions should return to local forest plans. Wildfire risk near communities is a real problem. Full repeal is the wrong tool. The Roadless Rule is not wilderness. It already allows roads and cutting for fire suppression, public safety, and specified fuels treatments. If too little work has been done, the limits are more likely budget, staffing, and a multi-billion-dollar backlog on the existing road system—not the existence of Subpart B. Repeal does not fund crews. It removes the presumption against building permanent roads into land that stayed unroaded after a century of industrial forestry. New roads are also likely to start more fires. People cause most U.S. wildfire ignitions. Studies of national-forest ignitions from 1992–2024 find ignition density lowest in wilderness and inventoried roadless areas, and several times higher near roads. Better access to some fires does not cancel a higher rate of human starts. The highest-value fuels work is at the wildland-urban interface, and along roads the Forest Service already owns. The timber rationale fails a cost test. Most U.S. wood already comes from private land, much of it plantations built to grow fiber. Those lands are closer to mills and cheaper to log. Remaining roadless acres were left unroaded because they were steep, remote, or low-yield. Opening them would require new roads the agency cannot afford to maintain. If the goal is more domestic wood, grow it on working forests and already-roaded suitable timberland—not in the last unroaded public stands. The proposal also underweights harms that are hard to price and impossible to reverse. Roadless headwaters help protect tens of thousands of stream miles and influence drinking water for on the order of 25 million people, many of them far downstream. Roads add sediment and spread invasive plants. These areas hold habitat for game and for rare animals, plants, and fungi that are still poorly inventoried. That is a scientific option value. A later plan revision cannot put it back. Pointing to forest plans is not a substitute. Plans change. A “generally avoid roads” standard is not the same as a national prohibition with listed exceptions. Idaho and Colorado already show that a conservation rule can be tailored without deleting Subpart B. I ask the Department to: Withdraw the proposed rule and keep 36 CFR part 294, Subpart B, including existing fire and safety exceptions. If any change is made, analyze a narrow amendment for fuels work near communities and existing roads—not a national repeal. Put fire funding where homes and infrastructure meet the forest, and report treatments already done in roadless areas under current exceptions. Revise the cost-benefit analysis to include road-maintenance liability, ignition risk, water costs, and the permanent loss of roadless character. Extend the comment period and hold hearings outside Alaska. Thirty days is too short for a nationwide DEIS. Keep the rule. Grow wood where wood is meant to be grown. Treat fuels where people live. Leave the remaining roadless public forest standing so the next generation can still know what wilderness is.

I'm an American that lives near Hoosier national forest. I've lived near national forest all my life and it has been a huge blessing for my family and myself. Having a refuge in nature that has been unmolested and largely unchanged for the last 100 years is important for many people I know. Rescinding this ruling will hurt not only the nature that's being disrupted but Americans of every stripe from those who take time to escape the hustle and bustle of city life to those who depend up forest lands for hunting and fishing to provide for their families. I'm asking you to please consider all of this when making your decisions in the next few weeks.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I grew up in the midwest, paddling the BWCA adjacent to the Superior NF's roadless areas, and hiking the Hoosier National Forest near Morgan Ridge. As an adult, I've hiked countless roadless area including the Three Sisters and other trails in the Deschutes and Willamette NF, I've paddled the Siuslaw Lakes, and photograghed many spectacular "roadless areas." On a recent outing in the Ochoco, I watched dozens of nighthawks catching insects and while gazing at South Sister spied a kestral catching an updraft. Roadless areas belong to all Americans - for the long term. They need to managed to exist for the long term. Changing laws, regulations and designations for a single generation is greedy, short-sighted and unsustainable. We all need wild places - to recreate, re-connect and feel a small part of the entire planet. Research has concluded that wildness and nature are critical to human well-being. Some doctors are already writing prescriptions for "nature." My tax money should be spent in more productive ways. With land management agencies already billions of dollars behind on preventative maintenance, 6.9 mil for USFS on road maintenance alone, there is no need to build more things to maintain. One failed culvert and cause millions of dollars of damage. After seeking and receiving over one and a half million comments to develop the roadless rule, why should this generatation/administration change it? I have two sons who are enthusiasts of wild places. One a photographer, the other a fly fisherman. These roadless areas need to remain roadless so their children, and possibly your own grandchildren, can inherit and experience them. Clean water for over 7,000 cities comes from the watersheds the encompass roadless areas. I have family that lives in Bend and drinks water from the Deschutes watersheds. Bend is a growing city that is surrounding by recreational opportunties and clear flowing streams and rivers. "Muddying the water" is dangerous for the ecosystem, the people and the outdoor recreation economy it supports. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 2: Reliance interests are invited and never assessed I plan trips into these areas year after year, counting on the protection that keeps them what they are. That reliance is exactly what the agency asked commenters to describe. The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Katherine Fuller Newport, Oregon

To the USDA Roadless Rule Rulemaking Team: As someone who uses public land regularly and has a concrete sense of what roadless areas provide, I'd say rescinding this rule would be a durable mistake with limited upside. I have lived adjacent to the Hoosier National Forest for 27 years and have come to appreciate the benefits of its wildness, the diversity of its flora and fauna, and the way it serves as a lung to southern indiana and a respite to those of us who dwell in cities and towns. The Department is respectfully requested to treat that account as what it is — a demonstration of the concrete, non-speculative harm that rescission of the Roadless Area Conservation Rule would produce. Regarding the Mogan Ridge in the Hoosier National Forest, Indiana: 7.1 - Fire & fire suppression drives Moderate or 11-30% pop. decline severity impacts across Restricted (11-30%) scope for Monarch (Danaus plexippus, G4, PT) in the Mogan Ridge IRA, Hoosier National Forest. Road networks serve as vectors for the secondary impacts classified under 7.1 - Fire & fire suppression: they open previously inaccessible terrain to resource extraction, facilitate introduction of invasive species, and concentrate human disturbance along corridors through Monarch habitat. A programmatic analysis is insufficient. The DEIS must evaluate 7.1 - Fire & fire suppression impacts to Monarch (Danaus plexippus, G4) at the scale of the Mogan Ridge Inventoried Roadless Area, Hoosier National Forest, with specificity adequate to inform the decision. "Of the 537 wildlife species of conservation concern in CONUS, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas (IRAs). The median IRA contains suitable habitat for 10 wildlife species of conservation concern, with a maximum of 62 wildlife SCCs. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA CONUS lands. If all IRAs were added to the protected-area system in CONUS, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas." — Global Ecology and Conservation (ScienceDirect), 2021 A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this proposal gives it. With urgency, CommentID: RLC-20260826-0OMYEP