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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas I am naming in this comment are real places I care about: Pyramid in the Lake Tahoe Basin Management Unit, Dardanelles, Caples Creek, Tragedy-Elephants Back, Salt Springs, Rubicon, and Raymond Peak in the Eldorado National Forest, Freel in the Lake Tahoe Basin Management Unit, and Mokelumne-Hawkins Peak and Waterhouse B in the Humboldt-Toiyabe National Forest. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The Humboldt-Toiyabe alone holds 354 inventoried roadless areas totaling 3,383,849 acres, scattered across mountain ranges that rise from the Great Basin desert like islands in a sea of sagebrush, each range a sky island carrying its own water, its own ecology, its own wildlife, including Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and mountain goat. Rescinding the 2001 Roadless Area Conservation Rule would put all of this at risk, and the agency's own record does not support that step. The proposal argues that opening roadless areas to road construction will help manage wildfire. The agency's own findings say otherwise. Its 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 areas I have named, from the dry Sierra Nevada flanks of the Eldorado to the sky islands of the Humboldt-Toiyabe, already face fire pressure. Adding roads into them to reduce fire risk contradicts the agency's own ignition data, reported in DEIS Table 21, which shows far higher fire density on roaded land than inside roadless areas. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with that data. The economic case is no stronger. The agency's own analysis records 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 marginal production, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. The Forest Service road system already carries a $6.9 billion maintenance backlog. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, and degraded watershed function is a cost the agency's numbers do not adequately capture. The agency must reconcile this proposal with an economic record that cannot demonstrate the action is worth its price. The argument that state-by-state rulemaking can substitute for a national rule has been tried before. The record itself shows 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." That state-petition approach was subsequently reviewed by the Ninth Circuit and found wanting, in part because local decision-making can incrementally erode roadless values that are nationally significant. The areas I have named cross administrative boundaries and support connected watersheds. The agency has not explained how this proposal avoids the deficiencies identified the last time it tried to replace national protection with a state-level substitute, and it should do so. Finally, the proposal questions whether the agency had statutory authority to issue the 2001 rule. That question has been litigated. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and held it did not create de facto wilderness. The agency has not explained what legal basis supports a contrary position now. That explanation belongs in this record before any rescission moves forward. Sincerely, Concerned Citizen South Lake Tahoe, CA

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would devastate the public lands near my home, undermine clean water, increase fire risk, negatively impact wildlife habitat, and degrade recreational opportunities that I depend on. I live in Reno, Nevada. At least once a week from late spring through fall I hike on trails that will be impacted on US Forest Service land near my home. Specifically, I hike the trails in the Humboldt-Toiyabe National Forest in the Rose-Evans, Rose-Thomas Meadows, Rose-Whites Canyon, Rose-Galena, and Mt. Rose Roadless Areas. I also hike in the Eldorado National Forest in the Dardanelles and Tragedy – Elephants Back Roadless Areas. I care deeply for these undeveloped lands and cherish my time spent hiking the trails in these pristine areas. I like to hike early in the morning before other people arrive, so it feels like I’m hiking in a wilderness area with no one around. The scenery is spectacular in these areas, and I don’t want to see these areas degraded. Hiking in these areas helps my mental and emotional state, and being outside with no man-made noise, tall trees and plentiful plants and animals helps me appreciate life in our fast-paced world. My hikes have helped me get through difficult times in the last 6 years after the death of several family members. I recreate in Nevada’s roadless areas, and I support maintaining the 2001 Roadless Area Conservation Rule and swift passage of the Roadless Area Conservation Act. Rescinding the Rule would fragment wildlife habitat, increase wildfire risk, and threaten clean water supplies. Instead of dismantling a proven policy, USDA should work with stakeholders to refine and strengthen the Rule to adapt to changing fire regimes and local needs while continuing to conserve backcountry recreation opportunities. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative. Thank you, Nancy Alvarez 573 Echo Ridge Ct Reno, NV 89511

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The alpine lakes and wildlife corridors along Highway 395 are what I keep coming back to. I backpack and hike in roadless areas throughout this corridor, camping in the Saddlebag Lake area, in Virginia Lakes within the Humboldt-Toiyabe National Forest, and in the Twenty Lakes Basin. I photograph what I find there: landscapes, alpine lakes, rivers, wildlife. The areas I visit include the Hoover - Virginia Lks roadless area in the Humboldt-Toiyabe, as well as the Log Cabin Saddlebag, Independence Creek, Rock Creek West, Mono Craters, and Cahuilla Mountain roadless areas in the Inyo and San Bernardino National Forests. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The Humboldt-Toiyabe is the largest national forest in the lower 48, scattered across mountain ranges that rise from the Great Basin like sky islands, each with its own water, its own ecology, its own wildlife. It holds 354 inventoried roadless areas totaling 3,383,849 acres, and verified species there include Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and mountain goat. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The landscapes and wildlife I photograph depend on the ecological integrity that the roadless designation protects. Rescission would put all of that at risk, and the agency's own record does not support the move. The proposal invokes wildfire and fuels management as a rationale, but the agency's own analysis undermines that justification. 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." That is the agency's finding, not mine. The DEIS Table 21 data on fire density reinforces it. I ask that the agency explain why the proposal departs from these findings and reconcile the rescission with the ignition data its own environmental review produced. The economic case for rescission is no stronger. The record itself 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's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. The agency must explain, in direct response to this comment, how expanding a road network with that backlog behind it is justified when the agency's own analysis cannot establish a net benefit. The regulatory flexibility analysis compounds this problem. The agency's record acknowledges it: "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 certification reaches its no-impact conclusion by averaging losses across every small firm in the relevant sector nationally, rather than assessing the guides, outfitters, and tour operators who actually hold permits in the affected areas. Some of those firms may lose those receipts entirely. The certification should be withdrawn and replaced with an analysis centered on the businesses actually operating in these roadless areas. Finally, the proposal itself 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 such an interest. I have structured my backpacking, hiking, and photography around the protections the 2001 rule provides for the areas along Highway 395 where I travel. An agency changing course is required to assess the reliance interests its prior policy created. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before taking any further action on this proposal. Sincerely, James Jenkins Carlsbad, California

The roadless rule protects public land around the country and conserves the unique habitats of the United States. I personally utilize many inventoried roadless areas in various states. They bring immense value to the citizens of this nation whether camping, hiking, hunting, fishing, or just looking at the natural environments around us. From my mule deer hunts in the Humboldt-Toiyabe National Forest to hiking in the Willamette National Forest, I have experienced places that IRAs protect and they keep America beautiful. Keep our roadless areas wild, productive, and accessible. Take the No Action Alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The undeveloped areas of the Humboldt-Toiyabe National Forest are some of the calmest and most peaceful places I have ever visited. Camping in roadless country there is one of the only ways I have to truly escape. Arc Dome is a very special place: it's quiet up there, with no sound except the wind, and an astounding view, and at night I can sit and look at the sky and the moonlit desert and mountains and feel at peace with everything. The Toiyabe Range as a whole is a showcase of the liveliness of a desert ecosystem, where pronghorns and rabbits move through the sagebrush and pinon pines in ways you don't get to see very many places. When I photograph these landscapes, I am looking for places that have been the same for longer than any living person can remember. Those places are becoming fewer and fewer in number as time goes on, and that is exactly why I oppose this rescission. The agency's own record undermines its stated rationale for rolling back protections. The proposal invokes wildfire management as partial justification, yet 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." The Humboldt-Toiyabe is the largest national forest in the lower 48, covering mountain ranges that rise from the Great Basin like sky islands in a sea of sagebrush, each with its own ecology and wildlife. The 354 inventoried roadless areas across this forest total 3,383,849 acres. Introducing roads into that network does not protect it from fire; the agency's own data say the opposite. I ask that the agency explain how this proposal departs from that prior finding and reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case is no stronger. The record reflects 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." Arc Dome alone spans 74,782 acres; the Toiyabe Range covers 99,225 acres. These are not marginal parcels. The agency must reconcile this 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, and 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 argument that state-specific rulemaking can replace a national rule is also a matter of settled record. The agency's own prior proceedings acknowledged 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." That experiment was tried, and the courts rejected it. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain what this proposal does differently to avoid the deficiencies the Ninth Circuit identified the last time the national rule was replaced with a state-by-state approach. On the question of legal authority, a federal appellate court has already answered 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 held that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. I expect the agency to address that holding directly and to state the basis for any contrary legal position. We only get one chance at this. Once these things are damaged, that's it. Nobody gets to see it how God made it, because someone, somewhere, decided His creation wasn't worth preserving, and that it'd be better to log it or pave over it for a few dollars in their pocket. The Humboldt-Toiyabe's roadless ranges, the desert sky above Arc Dome, the pronghorns moving through the Toiyabe sagebrush: these are not recoverable if lost. I urge the agency to withdraw this proposal. Sincerely, Devin Wilson Forest Knolls, CA

Subject: Public Comment on the Proposed Rescission of the 2001 Roadless Area Conservation Rule (RIN0596-AD66) To Whom It May Concern, I am writing to express my strong support for the rescission of the 2001 Roadless Area Conservation Rule, and to specifically advocate that all Inventoried Roadless Areas (IRAs) within the Inyo National Forest and the Humboldt-Toiyabe National Forest be fully excluded from this designation. The current framework relies on a fundamentally misleading premise and creates regulatory confusion by treating multi-use lands across the Sierra Nevada and Great Basin as pseudo-wilderness without proper legislative justification. First, the term "roadless" is factually inaccurate, and there is no better example of this than Coyote Valley / Coyote Flat in the Inyo National Forest. Coyote Valley is widely recognized as one of the most popular and highly utilized Off-Highway Vehicle (OHV) destinations in the entire Eastern Sierra. Despite being home to a robust network of well-established, heavily used 4x4 and OHV routes—including the critical Coyote Valley Road (FS 7S10)—large portions of this area are inappropriately designated as an IRA. Labeling premier motorized recreation hubs and active multi-use corridors across the Inyo and Humboldt-Toiyabe as "roadless" is a direct contradiction in terms and misleads the public about actual infrastructure on the ground. Second, this systemic mislabeling creates severe administrative burdens that unnecessarily restrict public access. By keeping vast tracts of land in the Inyo and Humboldt-Toiyabe forests under the IRA umbrella, the USFS is pressured to manage them with heavy-handed, restrictive policies that closely mimic formal Wilderness Area designations. This severely impacts local land management by complicating routine route maintenance, hindering critical firefighting and emergency vehicle ingress/egress in high-fire-risk regions, and placing undue burdens on historic permitted grazing operations and motorized recreation. If specific tracts of land within these national forests truly warrant the strict protections of a Wilderness Area, they must be proposed through the transparent, legally mandated federal process. The authority to designate permanent Wilderness belongs exclusively to Congress under the Wilderness Act, ensuring local economic input, resource balancing, and democratic accountability. Using administrative rulemaking to lock up active, motorized recreation areas and multi-use lands across the Inyo and Humboldt-Toiyabe under the guise of a "roadless" label is inappropriate, exclusionary, and factually flawed. These areas are not wilderness, and they do not deserve back-door special treatment that strips away multiple-use access. I urge the Department of Agriculture to finalize the rescission of the Roadless Rule and lift these designations across these critical western forests. Sincerely, Randy Short, President, Advocates for Access to Public Lands (AAPL)

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I have been hiking and skiing in the pyramid peak area for the last 10 years and value the forests, lakes, and natural beauty it holds. The grays creek area has amazing forests and is a special place to ski. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Pyramid (24,347 acres), Eldorado NF, California - Rose - Gray Creek (366 acres), Humboldt-Toiyabe NF, Nevada I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. 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. Issue 3: The agency's own fire data cuts against the proposal I hike and camp in this country, and fire shapes every trip I plan. If the agency's own data ties ignitions to road access, I want that weighed honestly. 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. The effects analysis itself concedes that road access could increase the number and frequency of wildfires. 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. Issue 4: Foreseeable plan amendments are placed beyond scope I ride through the interior of these areas, and what future plan changes would open is not an abstraction to me. I raise this because the agency put that future beyond its own 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 is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. 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 for the areas named above. 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, Spencer Eusden Tahoe City, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My father grew up hunting, and I learned to hunt on Molokai, where that skill means feeding your family and protecting natural resources. That foundation shaped how I understand wild land: not as scenery, but as something a community depends on. Camping with family deepened that connection further, giving us something that roads and development cannot restore once it is gone. When I look at the Mokelumne-Spratt roadless area in the Humboldt-Toiyabe National Forest, I see the same logic at work. The Humboldt-Toiyabe holds 354 inventoried roadless areas totaling 3,383,849 acres, each range rising from the Great Basin like a sky island with its own water and its own wildlife. Logging wrecks streams, and it needs to be stopped. That is not a slogan; it is what anyone who has watched a watershed change after road construction understands in their bones. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and 1,034 municipal water intakes across the Pacific Southwest region sit in watersheds containing affected roadless areas. What is proposed here touches all of that. The agency's own findings on fire should stop this proposal before it begins. 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." The rescission is justified in part on wildfire and fuels management grounds, yet the agency's own draft environmental impact statement reports far higher fire density on roaded land than inside the affected roadless areas. I ask that the agency explain, in plain terms and with citation to the record, why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in DEIS Table 21. The economics are just as hard to square. The agency's own record acknowledges 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 those numbers, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The Forest Service already carries a $6.9 billion road maintenance backlog. How does expanding a road system with that kind of deficit, for gains this marginal and this uncertain, constitute sound management? The agency must reconcile those figures before proceeding. The legal history of this rule is not a blank slate. The record reflects 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 agency tried replacing the national rule with a state-by-state framework before, and the Ninth Circuit rejected it, finding that local decision-making can incrementally erode values that are nationally significant. This proposal follows the same path. The agency must address what distinguishes this attempt from the one that failed, and explain on the record how it avoids the deficiencies the Ninth Circuit already identified. On the question of statutory authority, the courts that reviewed the 2001 rule reached a clear conclusion. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and found it did not create de facto wilderness. The current proposal implies a contrary reading of the agency's statutory authority. The agency should state plainly and for the record what legal basis supports a position the Tenth Circuit already rejected. The Humboldt-Toiyabe's sky islands shelter Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and mountain goat. These are not abstract inventory entries. They are what roadless means in practice, and they are what disappears when road networks expand. I oppose this rescission. Caroline Reimal California/Hawaii

My husband grew up in the ruby mountains of northern Nevada. He spent his childhood exploring and camping in the national forests of that area. I myself have camped, climbed and hiked in the ruby mountains and elsewhere in the Humboldt-Toiyabe national forest many times since we got married. A particular favorite was a hike up to an alpine lake in the ruby mountains, not far from spring creek, no. I’ve enjoyed the calm that comes from being in lands untouched by roads and industry. The proposed changes to this rule would make it easier to destroy these pristine areas of Nevada and elsewhere in our beautiful country. I would be devastated if my children did not get to experience northern Nevada the way my husband and I have.

I live in Zephyr Cove, Nevada that sits near the Humboldt-Toiyabe National Forest and the Tahoe National Forest. I spend all summer and fall worried about forest fires. Reno battled four fires in the span of one month, all of which were human caused because the landscape is so vulnerable to fire. That experience, as well as my love for the the mountain bike trails I ride in summer and the backcountry I ski in winter, are why I am filing this comment opposing the rescission of the 2001 Roadless Area Conservation Rule. The removal of the roadless rule would make us more vulnerable to wildfires, not less. The wildfire argument the agency offers for rescission contradicts the agency's own findings. 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." The region where I live and recreate is exactly the kind of landscape this sentence describes, and the fires Reno/Tahoe has seen this year were all human caused, not lightning caused. The agency must explain on the record why this proposal departs from its own prior findings on fire occurrence in roadless areas, and must reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency's own effects analysis makes the same point with numbers: "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." The gap between 22.4 and 3.0 is not a rounding error; it is the central fact the proposal fails to address. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that number honestly against whatever reduction in wildfire hazard it claims to achieve. The economics also do not make sense. Its own analysis concedes 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." Fractions of a percent in national supply are the justification for opening lands that include country where I bike and snowboard. Against that, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a range so wide it cannot establish a net benefit. I ask the agency to reconcile the rescission with those figures and to explain how expanding a road system already carrying a $6.9 billion maintenance backlog is fiscally responsible when its own analysis cannot confirm the action pays. My answer to the maintenance question is a simple one: how will these new roads be maintained when the existing ones are already behind? That is not a rhetorical point; it is a planning question the proposal does not answer. Finally, the administrative-burden rationale for rescission does not hold together when the rule's own text is read carefully. The rule "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. § 294.12(b)(1),(3)." Emergency access, existing mineral leases, community wildfire protection work: the exceptions are already there. The agency should identify on the record which specific administrative burdens are not addressed by those existing exceptions, and it should quantify them. A claim of burden that cannot be itemized is not a basis for rescinding a rule that protects millions of acres and, from where I stand, the forest and the backcountry that define the place I call home.

I oppose rescission of the 2001 Roadless Area Conservation Rule and support the No Action Alternative. As a Nevada hunter and public-land user, I am particularly concerned about the potential effects on the Humboldt-Toiyabe National Forest. Roadless areas provide large, relatively undeveloped habitat blocks that are increasingly important for maintaining habitat connectivity, limiting fragmentation, and supporting wildlife populations across Nevada’s highly arid and fragmented landscape. Road construction is not simply an access decision. Roads can fragment habitat, alter wildlife movement, increase human disturbance, introduce invasive species, accelerate erosion and sediment delivery, and affect watershed and riparian processes. These impacts are particularly important in Nevada, where water availability and riparian habitats are disproportionately important to fish and wildlife. The Forest Service’s own assessment of the Humboldt-Toiyabe identifies riparian and groundwater-dependent ecosystems as important components of fish and wildlife habitat and evaluates water quality, groundwater, channel dynamics, and ecosystem condition as key ecological characteristics. I also question the premise that eliminating roadless protections is necessary to address wildfire risk. The existing rule does not prohibit all vegetation management, prescribed fire, or other appropriate treatments. More importantly, roads themselves can increase the probability of human-caused wildfire ignition and create additional ecological impacts. Scientific research has consistently identified road development as a significant source of habitat fragmentation and ecological disturbance. The Forest Service should use targeted, science-based treatments where wildfire risk or forest health warrants intervention without unnecessarily converting intact roadless landscapes into roaded landscapes. I respectfully request that the Forest Service retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Protecting Nevada’s remaining roadless landscapes is a prudent application of landscape-scale conservation and adaptive forest management.

As a firefighter, sportsman, and public lands owner in Nevada and Michigan, with respect I urge the rejection of this proposed roadless area rule. This rule would harm wildlife habitat and water quality in places my family and I use and care about like the Humboldt-Toiyabe NF, Coronado NF, Kaibab NF, Coconino NF, Inyo NF, Modoc NF, Umatilla NF, Huron-Manistee NF, Ottawa NF and Hiawatha NF and others. It will also likely increase risk of human-caused wildfires, most of which start near roads. This unwise, politically-motivated rule fails the broad public interest for conservation of US forests, watersheds and rural economies. Thank you, Daniel R Patterson, Indian River MI / Boulder City NV

I live in Henderson, Nevada, and I spend a lot of my time hiking and camping across the Humboldt-Toiyabe National Forest and the national forests of southern Utah. I'm writing to oppose rescinding 36 CFR 294 Subpart B, in full or in part. After reading the proposed rule, I don't think the agency's own analysis supports it. 1. Local plans aren't a substitute: The rule leans on land management plans to protect roadless values. But it also confirms that forest supervisors and regional foresters can amend those plans at their discretion, and that later amendments could open up more logging and road building than what was analyzed. Leaving those foreseeable impacts out of scope understates what rescission would actually do. 2. The agency even admits the benefits are small! The rule itself calls the gains "modest and localized." Best-case timber revenue is $5.2–11.4 million a year, and that assumes harvest in every operable area, which the agency says is unlikely. Meanwhile, there's already a $6.9 billion road and bridge maintenance backlog and an estimated $6.1 million a year in lost recreation value. Giving up permanent protection on roughly 45 million acres for a return that small doesn't make sense to me??? 3. The wildfire fix doesn't match the problem: Only 24% of the affected roadless acreage overlaps the wildland-urban interface, yet the proposal removes protection from all of it. The agency also concedes that more access can mean more human-caused fires. If protecting communities is the goal, an alternative focused on the wildland-urban interface would do that. Wholesale rescission goes well beyond it. 4. This affects how I use these lands: The agency acknowledges that rescission trades away "quiet, remote and self-reliant recreation." That's exactly why I go out there! Along with millions of others. The $6.1 million estimate only counts operable areas and misses what intact backcountry means to hikers, campers, and the small towns that depend on us. 5. Water and Wildlife: Roadless areas protect headwaters and habitat for native fish and wildlife. Once roads go in, the sedimentation and fragmentation are essentially permanent. Plan-level protections, on the other hand, can change with the next amendment. 6. WHO ACTUALLY BENEFITS?: This is being sold as fire policy, but the Purpose and Need section cites executive orders on expanding timber production and "unleashing" energy. The Minerals section admits new oil, gas, and coal development in roadless areas is reasonably foreseeable. Then the same section projects no net change in domestic production, and the Energy Effects section says this isn't a significant energy action. Both can't be true. If there's no real energy gain, we're giving up protected land for nothing. If there is, the analysis is wrong. Either way, it looks like a Trojan horse: a regulatory back door for private extractive interests into forests the public has asked, again and again, to keep intact. 7. The People have already spoken! This drew more than 220,000 letters on behalf of over 625,000 people and organizations, all who overwhelmingly opposed. The rule itself notes that most Tribal governments consulted oppose rescission too! The record doesn't support Alternatives 2 or 3. I urge the Forest Service to adopt Alternative 1 and keep the Roadless Rule in place. Logan Brown Henderson, NV

I am a 10 year Oregon resident, formerly a 30 year California resident. Have spent hundreds of days over the years backpacking, day hiking, camping and fishing remote areas, particularly in Humboldt-Toiyabe NF (starting long before those were annexed), Stanislaus, and adjacent NFs. I continue to do so, now including NFs throughout the West. While California has added 10 million people since I started doing this, there remain wonderfully remote areas that can be reached and enjoyed and these areas must be kept remote. I have met over the years with various Forest Supervisors to express concerns and suggest operational changes that I felt would enhance and promote the use of (and thereby, the desire to keep) national forests. The Roadless Rule (as much as I despise what I consider to be tons of OVER-regulation on forest land - don't get me started) is one that I supported in 2001 and continue to think is a very good rule. It is neither necessary nor prudent to rescind this rule at this time. Please recall that the major opponents of the rule to being with were in Idaho, Wyoming and Alaska. These are enormous low-population (low density) states - vastly different from California and Oregon as well. Those states can afford to give up more real estate to roads; the West Coast can not. It would have been smarter in 2001 to have more discretion afforded in those locations. But killing the rule now is dumb. Craft a limited rescission; that would make more sense. And until a better solution is reached, maintain this current rule.

For more than 30 years my family’s vacations have centered on hiking and camping in roadless areas of several National Forests. There is no better way to teach self-reliance to children and grandchildren and inspire reverence for the magnificence of the natural world. The proposed recission claims that roadless protections prevent managers from reducing wildfire risk. This is false. I have extensive familiarity with segments of the Humboldt-Toiyabe National Forest in the Jarbidge and Ruby Mountains areas and segments surrounding Great Basin National Park in Nevada. The 2001 Roadless Rule already allows hazardous fuels treatment in more that 80% of those areas of the Humboldt-Toiyabe. Nationally, about 2 million acres of roadless areas have already been treated. Rescinding the roadless rule is not necessary for this purpose. More fundamentally, roads are fire ignition corridors. They facilitate fires. A 2026 study in Fire Ecology shows the density of fires in National Forests to be four times higher near roads. More than 89% of wildfires nationally are human-caused. The best way to reduce wildfire risk is to keep roads and logging out of national forests. The proposed recission is unnecessary and would almost certainly lead to even more fires. I respectfully request the proposed recission be abandoned.

Dear Brooke L. Rollins, As an outdoor enthusiast who has relied on the protection afforded by the 2001 Rule to access interior national forest in a condition substantially unmodified by motorized infrastructure, I find the Department's proposed rescission inadequately grounded in any countervailing evidence of comparable public benefit. I spend time hiking on these lands, looking at plants, and rock climbing to escape the heat of the city. It is beautiful and full of life, and a precious resource for Americans to get outside in Nevada. I remember hiking and finding clumps of cacti among the older pines and junipers and wondering how long they have existed here. I would hope my children would be able to have these same thoughts and be in awe of these plants. If this rule is rescinded, I will lose valuable untouched wilderness to vehicle disturbance, air pollution, and noise pollution. I go to these areas because they have these rules in place, and I can experience the great outdoors the traditional way - without man’s interference. It will also cut through wilderness areas, cutting them into patches of thinner areas, no good for the wildlife I want to see. Regarding the Potosi Area in the Humboldt-Toiyabe National Forest, Nevada: Conservation status G3 reflects the vulnerability of Eastern Joshua Tree (Yucca jaegeriana) in the Potosi Inventoried Roadless Area, Humboldt-Toiyabe National Forest, where 7.1 - Fire & fire suppression acts at Serious or 31-70% pop. decline severity across Restricted - small scope. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 7.1 - Fire & fire suppression on Eastern Joshua Tree. A programmatic analysis is insufficient. The DEIS must evaluate 7.1 - Fire & fire suppression impacts to Eastern Joshua Tree (Yucca jaegeriana, G3) at the scale of the Potosi Inventoried Roadless Area, Humboldt-Toiyabe National Forest, with specificity adequate to inform the decision. "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 having no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relatively lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity." — Nature Communications, 2023 Regarding wildfires: The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. The Department is urged to give full weight to the administrative record compiled over more than two decades before proceeding with any rescission action. Once the roads are plowed through America’s great wilderness, it cannot be undone. Faithfully, Ali Marie

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting is a generational tradition in my family. Having truly wild areas where we can exercise our right to provide for our family matters deeply to us, and having areas where animals can be unbothered is important for population growth. The Copper Mountains roadless area in Humboldt-Toiyabe National Forest, 31,945 acres of it, has become a significant place to my family. Losing the wildness of that area by allowing roads to be introduced puts it at risk. I oppose the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001, and I ask the agency to respond to the following concerns. The agency's own record states: "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.". It goes directly to what my family depends on in the Copper Mountains and in the other roadless areas of the Humboldt-Toiyabe. No population-level effect on big game is projected anywhere in the rescission document. The agency must project what this proposal does to big game populations and hunter opportunity, and provide that projection in the record before any final decision is made. I have fished Lake Mead for many many years, and I have watched what happens when human activity increases. The shorelines get filthier and illegal roads increase, and that is a National Recreation Area with rangers constantly patrolling. The areas that would lose roadless protection are not patrolled that way. Opening protected areas would lead to increased pollution from vehicle emissions. Across the Intermountain region, which includes Nevada, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The drinking water crisis has been an issue my entire life here in southern Nevada, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The agency must explain what protections replace the rule's watershed safeguards and how sediment loading at those 1,466 intakes is addressed in the record. The proposal claims that state-specific approaches can substitute for a national rule. The record itself states: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That argument has been made before and the courts rejected it. I ask the agency to address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and to explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. The agency also argues the rule imposes permitting and administrative burdens. But the rule's text shows: "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 burden argument requires the agency to identify which specific burdens are not already addressed by these existing exceptions, including those for public health and safety and community wildfire protection, and to quantify those burdens in the record rather than assert them in general terms. On wildfire, the proposal uses fuels management as a justification for rescission. 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." That sentence belongs to the agency, not to opponents of the proposal. The La Madre - Prospect area, 278 acres in the Humboldt-Toiyabe, and Mt. Charleston, where Charleston - Macks Cyn covers 11,378 acres, are forested refuges in the Nevada heat. They are already under pressure from visitation. Adding roads increases ignition risk by the agency's own measure. The agency must explain in the record why it departs from its own prior findings on fire occurrence. It is one thing to open a managed area to the public, but these are wild lands. Without protection, environments suffer from people who are not educated in outdoor recreation. The Currant - Duckwater B and Currant - East Slope areas have been family camping spots for decades, and implementing roads would cause them to lose their wildness. Enjoying nature has been passed through my family for generations. Being able to share these places with my children is important to me, and just like many other traditions, it deserves to be preserved. Sincerely, Alexis Shaul Las Vegas, Nevada

My name is Bridget Tevnan, and I live in Reno, NV. I am commenting on FS-2025-0001, and I oppose the proposal to rescind the Roadless Area Conservation Rule. I hike, backpack, climb, trail run, and botanize in Inventoried Roadless Areas that buttress the Mt Rose Wilderness, throughout the Humboldt-Toiyabe National Forest in Nevada and California, and throughout the Sierra Nevada in California. Furthermore, I worked as an AIM and plant survey technician in central Nevada and a restoration ecologist in the Mojave Desert in southern California. I have observed first-hand how areas with roads are impacted by invasive species; I noticed fewer native plant species, less plant diversity, and increased occurrence of noxious weeds like Russian thistle, tumble mustard, cheat grass. As noted by research from U.S. Forest Service scientist Sean Healey, empirical monitoring data do not support the assumption that roads are required to maintain forest health or mitigate fires, noting instead that roads act as a primary vector for the spread of invasive plant species (Environmental Research Letters, 2020). He goes onto note that “invasive species can inhibit regeneration of native species and affect both economic and ecological services provided by the forest.” Invasive plants tend to be more flammable, leading to higher wildfire risk, and can outcompete native plant species. Furthermore, I am concerned that rescinding the Roadless Area Conservation Rule would negatively impact wildlife and watersheds by fragmenting habit. Many Inventoried Roadless Areas surround designated wilderness, creating buffers of lands with limited human impact and help to insulate wilderness from encroaching development. We are at a critical historical junction where the permanent protection of our remaining Inventoried Roadless Areas is no longer just an environmental preference, but an ecological necessity. Preserving these undeveloped lands is our most effective mechanism for securing ecosystem resilience and protecting biodiversity, mature forests, and ecosystem health. Allowing development or fragmentation in these areas compromises crucial watersheds and wildlife corridors, failing our responsibility to pass down a functional, healthy planet to future generations. Once again, I oppose the proposal to rescind or alter the Roadless Rule; I support Alternative 1, the No Action alternative, and I support the Roadless Area Conservation Act.

As an avid outdoor visitor I have spent countless days recreating in many of the US Forest Service lands impacted by the proposed repeal of the Roadless Rule. I am deeply OPPOSED to any type of repeal of the Rule. I have spent countless days with my family recreating on these lands (camping, hiking, biking and enjoying the natural landscapes) - including the Humboldt-Toiyabe National Forest, the El Dorado National Forest, the Tahoe National Forest (Lake Tahoe Basin Management Unit), the Inyo National Forest, the Dixie National Forest, and many many others. These lands held in trust for the American people are an irreplaceable resource for the voting public of this country and any type of repeal of rules that protect these lands from development or further erosion of the natural state is a disgrace. These lands need to be preserved in the most natural and untouched state possible for the benefit of visitors today and of future generations. It is our duty as citizens of this country to protect the natural resources for our children and grandchildren. OPPOSE the repeal of the Roadless Rule and come out on the right side of history!

My name is Megan Mack. I am submitting this comment on the proposed rule and Draft Environmental Impact Statement regarding the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select Alternative 1 – No Action, retaining the 2001 Roadless Rule in full across all 44.7 million acres of inventoried roadless areas, rather than Alternative 2 or Alternative 3. Why this matters to me personally I spend a significant amount of time recreating in the roadless and backcountry areas of the Humboldt-Toiyabe National Forest near Reno and Lake Tahoe, as well as across the Eastern Sierra in the Inyo National Forest — in particular: Mount Rose Wilderness-adjacent roadless lands (Humboldt-Toiyabe NF) — the backcountry just outside Reno, along the Nevada-California state line above Lake Tahoe. Lake Tahoe Basin roadless areas, including lands adjacent to Desolation and Granite Chief Wilderness — over 100,000 roadless acres within the Tahoe Basin Management Unit alone. Roadless forests around Mono Lake and Mammoth Lakes (Inyo NF) — roughly 32,000 acres safeguarding the watersheds that supply Eastern Sierra communities. Bishop Creek area roadless lands (Inyo NF) — the canyons and high country above Bishop, heavily used for hiking, fishing, and climbing. I have been climbing, hiking, skiing, biking and exploring in these areas with my friends for years. Now I take my daughter. I don't want her and the next generation to miss out on the same beauty and access that I have had. These are not abstract acres to me. They are the intact, unroaded backcountry that makes the country around Reno and the Eastern Sierra worth living near — the source of clean water for downstream communities, functioning habitat for wildlife, and the kind of quiet, undeveloped terrain that is becoming rarer every year across the West. Why Alternative 1 is the right choice 1. The stated rationale for rescission does not hold up. USDA has argued that new roads are needed to reduce wildfire risk. But the agency's own Draft EIS acknowledges that wildfire frequency is significantly lower in roadless areas than in roaded portions of the same forests. Roads bring more human ignition sources — vehicle sparks, campfires, target shooting, arson — and fragment the very landscapes that currently burn less. If wildfire risk reduction is the actual goal, targeted fuels treatments under existing authorities accomplish that without permanently eliminating roadless protections across 44.7 million acres. 2. The economic case is weak. Roadless areas are disproportionately steep, remote, and low-productivity for timber. Independent analyses have found that the cost of building and maintaining new roads into these areas would likely exceed the timber revenue they generate, meaning taxpayers — not industry — would absorb the difference. 3. The environmental review is incomplete. The Draft EIS does not adequately analyze foreseeable impacts to endangered species, cultural and historic properties, or community water supplies that depend on undeveloped watersheds. A rule change of this scale, affecting 44.7 million acres in 37 states, deserves a rigorous and complete analysis before any alternative other than No Action is adopted. 4. The public record already reflects overwhelming opposition. Of the more than 625,000 comments submitted during the 2025 scoping period, the overwhelming majority opposed rescission. Tribal governments consulted on this proposal have also expressed majority opposition, citing impacts to sovereignty, cultural resources, and ancestral homelands. The 2001 Rule itself was the product of the largest public input process in Forest Service history — 600 public hearings and 1.6 million comments. That record should not be discarded through a truncated rulemaking process. 5. Alternative 1 already contains reasonable flexibility. The existing rule is not absolute — it already allows exceptions for public health and safety emergencies, valid existing rights, and active mineral leases. This is a workable balance that does not require wholesale rescission to address legitimate site-specific needs. My request Please select Alternative 1 – No Action and retain the 2001 Roadless Area Conservation Rule without modification. The roadless areas of the Humboldt-Toiyabe and Inyo National Forests, and the 44.7 million acres they represent nationwide, are irreplaceable. Once roads are built and logging occurs, these areas cannot be restored to their current undeveloped condition. Thank you for considering my comment. Megan Mack