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I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. The Roadless Rule has protected almost 45 million acres of our old growth forests and unfragmented national forest land that sustains all lives. My husband and I reside in Michigan and have spent most of our lives in the great outdoors. It is extremely important to our well being. We have back packed, hiked, paddled and biked across this amazing country of ours. In Michigan alone we love being in Huron-Manistee National Forest, Hiawatha and the Ottawa National Forests, we have been on sections of the 44k miles of back country trails across the Pacific Crest Trail, Appalachian Trail and the Continental Divide trails- all of which would be affected if roads were allowed into these areas. These lands provide clean drinking water, critical wildlife habitat, and irreplaceable backcountry recreation access for millions of Americans. I’m extremely concerned about what we could be left with if this is rescinded. I have trouble understanding the logic as it is 90% supported across all parties, for the logging and commercial businesses it has been show that it isn’t even economically feasible to log these areas. My top reasons revolve around the following; WILDFIRE RISK: More roads could mean more human-caused wildfires. Ignitions are 7x higher on other National Forest lands than in roadless areas. The Roadless Rule allows for active fire management and fuel reduction. WILDLIFE HARM: Wildlife and habitat could suffer. Full rescission could adversely affect 327 protected species and 71 critical habitats. Here in Michigan alone - our Great Lakes would be affected. Salmon, trout, bass would be at risk. Our majestic white tailed deer, pheasants, grouse, all our wildlife would be at risk. WATER: Clean drinking water is at stake. About 24 million people use water originating in affected roadless areas. Again, these forests filter water before it gets to our Great Lakes which are critical to our state in a multitude of ways. The Great Lakes represent 20% of the world’s fresh surface water!!!! We can NOT risk this! COST: We can't afford more roads. The Forest Service already has a $6.9 billion road and bridge maintenance backlog. If these incredible forests that we hold dear were opened to intensive commercial harvesting here in Michigan and across the country, future generations, my nieces and nephews, many other’s children would miss out on all the benefits they provide, and the outdoor traditions they support. This plan puts at risk an essential part of our heritage, my upbringing and identity -- as Michiganders and all Americans! Please Do Not rescind the 2001 Roadless Area Conservation Rule.

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. The Roadless Rule has protected almost 45 million acres of our old growth forests and unfragmented national forest land that sustains all lives. My wife and I reside in Michigan and have spent most of our lives in the great outdoors. It is extremely important to our well being. We have back packed, hiked, paddled and biked across this amazing country of ours. In Michigan alone we love being in Huron-Manistee National Forest, Hiawatha and the Ottawa National Forests, we have been on sections of the 44k miles of back country trails across the Pacific Crest Trail, Appalachian Trail and the Continental Divide trails- all of which would be affected if roads were allowed into these areas. These lands provide clean drinking water, critical wildlife habitat, and irreplaceable backcountry recreation access for millions of Americans. I’m extremely concerned about what we could be left with if this is rescinded. I have trouble understanding the logic as it is 90% supported across all parties, for the logging and commercial businesses it has been show that it isn’t even economically feasible to log these areas. My top reasons revolve around the following; WILDFIRE RISK: More roads could mean more human-caused wildfires. Ignitions are 7x higher on other National Forest lands than in roadless areas. The Roadless Rule allows for active fire management and fuel reduction. WILDLIFE HARM: Wildlife and habitat could suffer. Full rescission could adversely affect 327 protected species and 71 critical habitats. Here in Michigan alone - our Great Lakes would be affected. Salmon, trout, bass would be at risk. Our majestic white tailed deer, pheasants, grouse, all our wildlife would be at risk. WATER: Clean drinking water is at stake. About 24 million people use water originating in affected roadless areas. Again, these forests filter water before it gets to our Great Lakes which are critical to our state in a multitude of ways. The Great Lakes represent 20% of the world’s fresh surface water!!!! We can NOT risk this! COST: We can't afford more roads. The Forest Service already has a $6.9 billion road and bridge maintenance backlog. If these incredible forests that we hold dear were opened to intensive commercial harvesting here in Michigan and across the country, future generations, my nieces and nephews, many other’s children would miss out on all the benefits they provide, and the outdoor traditions they support. This plan puts at risk an essential part of our heritage, my upbringing and identity -- as Michiganders and all Americans! Please Do Not rescind the 2001 Roadless Area Conservation Rule.

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Bridget Corwin, and I am an avid hiker based in the beautiful state of Michigan. Although our state has fewer Roadless Areas than many others out West, the ones we do have are extremely special and beloved by local and visiting hikers, anglers, hunters, and campers. I have spent time in the roadless areas of the Hiawatha and Huron-Manistee National Forests, and they are truly incredible places that I believe would be negatively impacted by rescinding this Rule. For example, Bear Swamp in Huron-Manistee National Forest contains the headwaters of Muckwa Creek and Black Creek, which feed into the Big Sable River system—a network that supports cold-water fish populations dependent on stable water temperatures and unobstructed migration corridors. The swamp's vegetation and hydrological function moderate water temperature and maintain baseflow during dry periods- conditions that are critical for fish spawning and survival. Road construction in headwater areas directly threatens this temperature regulation function and creates barriers to fish movement, degrading aquatic habitat throughout the downstream network. Additionally, if roads were built and logging was allowed in this area, sediment from bare slopes and road surfaces would wash into the creeks, smothering the gravel and organic spawning substrate that cold-water fish require for reproduction. Although I understand concerns that the Roadless Rule in its current form may hinder wildfire mitigation efforts, studies have shown that timber harvesting often leads to homogenous forested areas that will then burn at a more uniform, sustained high intensity (https://www.fs.usda.gov/treesearch/pubs/34437). Instead of more roads and logging, I believe we need better planning around the wildland–urban interface and more regular and controlled prescribed burns. It is critical that we allow federal lands like these to stay undeveloped not only to preserve the unique and wonderful plants and animals that live there, but also to protect the activities and places that are special to us as humans both today and for future generations. For this reason, I oppose the proposal to rescind or alter the Roadless Rule and support the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Quiet, peace, nature, and water: those are the things I go to the woods and lakes for, and the 2001 Roadless Area Conservation Rule has protected the places where I find them. I oppose its rescission. I paddle Lake Michigan and Lake Superior. I hike and camp near lakes in Northern Wisconsin and have traveled to Shawnee National Forest in Illinois. The roadless areas I care about most directly, including Bear Swamp in the Huron-Manistee National Forest in Michigan, the island and lake units of the Chequamegon-Nicolet National Forest in Wisconsin, and the Burke Branch, Ripple Hollow, Burden Falls, Bay Creek, Eagle Creek, and Clear Springs areas in the Shawnee, are public land. They are for the public to enjoy, not for logging or mining. That is not a slogan; it is the conclusion I have reached after traveling to these places repeatedly over the years. The agency justifies rescission in part on wildfire and fuels management grounds, but its own record directly contradicts that argument. The agency's prior findings state: "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 does not describe a fringe position; it is the agency's own language, drawn from its own environmental review. Bear Swamp sits within Michigan's 16,124 acres of inventoried roadless land, and the Eastern region, which includes Michigan, contains watersheds holding 286 municipal water intakes inside the affected areas. Opening those landscapes to road construction would increase ignition risk precisely where the agency's own data says roaded land burns harder. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's own record 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." Against that marginal gain, the agency's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service, set against recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a span so wide it cannot establish a benefit. The Forest Service already carries a $6.9 billion road maintenance backlog. I ask that the agency reconcile the proposal with those numbers and explain how it justifies expanding a road system that the agency cannot currently maintain, when its own analysis cannot confirm a net gain. The permitting burden rationale fares no better under scrutiny. The rule as written already provided that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The exceptions for public health, safety, existing mineral leases, and community wildfire protection are already in the rule. The agency has not identified, with specificity, which burdens those provisions fail to address. I ask that the agency name the particular burdens the existing exceptions do not resolve, and quantify them on the record. Finally, the regulatory flexibility analysis certifies no significant impact on small entities, but the record itself names outfitters, guides, and tour operators as affected, and books a minimum recreation benefit loss of $6.1 million a year. The certification is reached by spreading expenditure losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in these specific roadless areas. The Thornapple and Le Roy Creek areas in the Chequamegon-Nicolet, along with the Shawnee units I named above, all support recreational use that feeds exactly those small businesses. A certification built on a national average rather than on the affected permit holders is not an analysis; it is an assumption. The agency must withdraw that certification and assess the impact on the businesses actually operating in these areas. These places belong to the public. Rescission serves none of the purposes the agency claims for it, and the agency's own record says so. I urge that the 2001 Roadless Area Conservation Rule be retained without modification. Sincerely, Katrina Burmeister Sleepy Hollow IL

To: The US Forest Service, pertaining to rescinding the 2001 Roadless Area Conservation Rule protecting 45 millions acres of National Forest, particularly, the 16,000 acres in Michigan. Please. I am asking that you use Option 1, No Action. I want all of the states in the United States of America to have the ability and opportunity to visit and value these spaces. I want and need the state’s roadless forests to stay as is. These particular area are incredibly unique. NEVER to be the same, once ruined. This Rule is one of the only kinds of Protection that we have like this at the Federal level that prevents this Fragmentation. Our third generation farm is not far from the at-risk 3915 acres in Huron-Manistee National Forest, one of the pieces of Land in danger of possibly being developed. Our 56 year old Organization, Michigan Trail Riders Association (MTRA),rides through this forest on our 4 annual Epic Rides from Lake Huron to Lake Michigan. Just short of 250 miles on Horseback, over the span of 12 days. I, and my daughters, have been riding this for 33 years. Federally endangered species like the gray wolf, cougars, (the DNR won’t admit to them in Northern Michigan, but I personally have seen 2 of them and their long 6 foot tails, in my lifetime, here). The Endangered Northern Long-eared bat and wild Lady-Slippers Orchids are found in these Roadless Heaven’s. The Michigan Timbermen’s Association is still struggling to find market’s for the wood that is currently available since the 100 year Ice Storm hit our area, and all the downed trees, in March 2025. Homeowners are GIVING away downed trees and wood for Free. So it is not like you have to promote Logging. And most forest fires are apt to start on woods with roads criss crossing them. Thank you. My family has been here since 1907.

The lakes and forests I am describing here, Bear Swamp in Michigan's Huron-Manistee National Forest and the roadless areas of Wisconsin's Chequamegon-Nicolet, including Wheeler Lake Islands, Shoe Lake Islands, Shelp Lake, Perch Lake, and Foursection, are places I care about, and I am filing this comment because their protection depends on the 2001 Roadless Area Conservation Rule remaining in place. I oppose its rescission.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The loudness of the current world is nearly unavoidable. Places like Bear Swamp in the Huron-Manistee National Forest in Michigan give me solitude and peace that I can only thank God for. I go to those places to photograph landscapes and wildlife, and I go to show others what is there, the way I one day want to show my kids, so they can protect and grow what remains. Rescinding the 2001 Roadless Area Conservation Rule would put that directly at risk, and I am filing this comment to oppose Docket FS-2025-0001. Michigan holds 6 inventoried roadless areas totaling 16,124 acres. Bear Swamp, at 3,915 acres, is among them. These are not abstract acres. They are places I visit to photograph wildlife, bears included, and to find the kind of quiet that has become genuinely rare. The agency's own record notes that increased contact and conflict from open roads in bear habitat can end in bear mortality, and that shooting, habituation and food reward all increase with the use of even secondary unpaved roads. Opening roadless areas to new road construction does not leave wildlife where it is. I ask that the agency explain, with specificity, how it intends to protect bear populations in areas like Bear Swamp if the national rule is removed and local decisions are made without a binding floor. The proposal argues that state-by-state approaches can replace a single national rule. The agency's own record shows it has been down that path. The record 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 approach was challenged and found wanting in federal court. I ask that the agency address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and 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 proposal also argues the 2001 rule exceeded the agency's statutory authority. A federal appellate court reviewed that exact question and held otherwise. The record states: 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 ask that the agency explain on the record the legal basis for any position contrary to that holding. Across the Eastern region, which includes Michigan, 286 municipal water intakes sit in watersheds containing affected roadless areas. Clean resources matter to me. The agency should account for downstream water quality effects on those intakes if the rule is removed, and it should explain what specific protections would remain for those watersheds. On the economic analysis: The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading losses across every small firm in the sector nationally, not the firms actually permitted in the affected areas. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, The 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. I think public land needs to be managed for the good of all, for clean resources, for mental stability, to show our children the world that once was, and to avoid destroying any more of what once was. I have planned around the assumption that Bear Swamp and places like it would remain protected. That is exactly the kind of reliance interest the agency invited and then declined to assess. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Bryce Voss Elgin, Illinois

The true value of our natural resources in the United States of America cannot be fully understood and appreciated unless one has experienced these personally. Land, clean air, healthy trees, adequate and clean water, and wildlife that survive and thrive in our national forests deserve to be protected. Over past decades I have hiked in, boated in, skied, and camped in a number of our spectacular national forests: the Olympic National Forest, Mount Baker Snoqualmie NF, Okanagon-Wenatchee NF, the Cherokee NF in my native state, the Deschutes NF, the Finger Lakes NF, the Gifford Pinchot NF, the Huron-Manistee NF, the Idaho Panhandle NF, the Malheur NF, Mount Hood NF, the Pisgah NF, the Santa Fe NF, the Tongass NF, the Tonto NF, the Umatilla NF, the Umpqua NF, the Wallowa-Whitman NF, and the Willamette NF. In 2001 when the Roadless Rule was enacted, it allowed the NFS get somewhat caught up on maintenance of the 44.7 million acres of Inventoried Roadless Areas (IRAs). The 9.3 million acres of IRAs in the Tongass National Forest have also been better protected than prior to the RR. The claims being made in the Proposed Rule do not « hold water. » It was local control (one of the purported justifications for rescinding the 2001 RR) that led to enormous harm in the Wolverine Fire of 2015 in Washington state. Local pressure by regional fire departments persuaded the Director of the Firefighting Operations, a staffer brought up from the Tonto NF, ordered a CPL (Community Protection Line) that ended up a 50-mile long, 300-foot wide CPL and cut 40% of the critical habitat for the endangered Northern Spotted Owl. Over 930 log trucks hauled out logs, with one tree being so large that it was the only tree on one of the trucks. In my view, it was criminal to do that much damage. The scientist on the Oka-Wen NF tried to persuade the fire director that the fire was not heading in the direction of the CPL cuts. « Managers continued logging even after weather conditions turned rainy and cool, and objections were raised by their own staff, who saw no emergency, internal records and emails to The Seattle Times by US Forest Service showed. The fire never came anywhere near. » (Lawsuit over firelines to curb forest firefighting tactics, August 22, 2016) Another purported reason given for the Proposed RR Rescission is to reduce wildfire. This is not logical or rational. By allowing access to more roads in the roadless areas, there would be a greatly increased likelihood of experiencing human and vehicle-related forest fires. Strong scientific studies support this and argue strongly against opening up our roadless areas to more traffic for logging or other forest treatments. In fact, fires are four times more likely to occur near roads than in roadless (DEIS, p. 87) Good water quality is also more available in IRAs because of limited disturbance. « Retaining the RR ‘provides the greatest protection of water quality’ for municipal water supplies. » (DEIS, p. 122) For these reasons, and in the hope that science and good evidence about the superb values of Roadless Areas in our USFS will prevail, I strongly oppose the Proposed Rescission of the 2001 Roadless Rule. I would appreciate your serious consideration of my comments. Another

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The tranquility and peace of the Huron-Manistee National Forest would be absolutely destroyed by trucks, roads, tree clearing and other obstructions, and the water, air and soil pollution that follows is irreversible in many situations. My family has been hiking, camping and paddling there for years, and we look forward to sharing it with our children as they grow. Up near Marquette we ride and immerse ourselves in nature, and we know what logging roads and mineral extraction do to a place: they destroy it for residents, for tourism, for the ecosystem around it. I oppose this rescission and I want the agency to answer the questions below in the record it compiles. The wildfire rationale the agency offers for rescission is contradicted by 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 proposal nevertheless justifies rescission partly on wildfire and fuels management grounds. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency argues that the 2001 rule exceeded its statutory authority. That argument has been litigated. A federal appellate court ruled: "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. The agency must explain, on the record, the basis for any contrary position, and it must address that holding directly rather than simply reasserting the ultra vires theory as settled. The rule itself already contains exceptions for the activities the agency says it cannot pursue under the rule. The agency's own analysis confirms: "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 proposal justifies rescission on permitting and administrative burden grounds, but it never identifies which specific burdens are not already addressed by those exceptions, including those covering existing mineral leases and community wildfire protection. The agency should quantify those burdens in the record and identify, permit by permit if necessary, what it cannot do today that rescission would allow. Finally, the small-business certification the agency filed does not hold up. 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 places I am talking about, the Huron-Manistee and the forests near Marquette, support exactly these kinds of small operators: guides, outfitters, the tourism economy that depends on land that has not been roaded and cleared. Spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than looking at the operators actually holding permits in the affected areas, does not satisfy the intent of the regulatory flexibility requirements. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas. This land matters to my family and to the communities around it. The agency has not answered the questions its own record raises. I ask that it do so. Sincerely, Alex Hageman Oxford, MI

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

Dear Chief Tom Schultz, As a freshwater ecologist, I understand the importance of intact and undisturbed ecosystems. Rescinding the 25-year-old Roadless Rule would put those untouched forests in jeopardy and would be a true loss for the American people. Pre-European settlement, Michigan was once home to 10.7 million acres of wetlands. Since 1978, that number has dropped to 6.47 million acres. Bear Swamp in the Huron-Manistee National Forest is an intact wetland protected by the Roadless Rule. Bear Swamp is home to federally protected species such as the Eastern Massasauga rattlesnake and Blanding's Turtle. Additionally, Bear Swamp is home to the Brook Trout, a species I studied in college and is an indicator of high water quality. “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” If this rule is rescinded, we lose the pristine headwaters of Muckwa and Black Creek that feed into the larger Big Sable River system. These waters protect important and imperiled cold-water species such as the brook trout. Building roads leads to disconnects in rivers that make fish migration difficult and alters the temperatures of those rivers. Additionally, roads are huge sediment polluters, especially when crossing critical stream/ river habitat. Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan: Communities downstream of the Bear Swamp IRA, Huron-Manistee National Forest, receive clean water because this watershed has no roads. Municipal water supplies, agricultural irrigation, and recreational fisheries all depend on the sediment-free, thermally stable flows that the roadless condition delivers. Road construction transfers the cost of degraded water quality to every downstream user. The Bear Swamp IRA, Huron-Manistee National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently. The DEIS must evaluate the cumulative effects of road construction in the Bear Swamp IRA, Huron-Manistee National Forest, on downstream water users, including changes to turbidity, temperature, and flow regime. The analysis must include the cost of increased water treatment required by downstream municipalities and the economic impact on downstream fisheries and recreation. "Riparian shade restoration (2000s climate) could decrease mean August stream temperatures by 0.62°C across the study network. Removing the current riparian shade resulted in a nearly 50% loss of habitat meeting the numeric temperature water quality criteria (12°C 7DADM) for char spawning and rearing, while restoring vegetation only increased the proportion of fish habitat meeting the criteria by ~10%. The linear relationship established in our models between reach shade and stream temperature indicates an increase of ~40% reach shade should cool a stream reach by ~1°C." — Restoration Ecology (PMC/Wiley), 2022 The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. I'd rather see the Department focused on strengthening forest protections, not rolling them back. This proposal moves in the wrong direction. Sincerely,

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 oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Stephen Hoekwater and I live in Caledonia, Michigan. Public lands matter very much to me and I care deeply about the health of our lands and waters. I enjoy hiking, fishing, backpacking, and hunting and have done so in our National lands in Michigan and all throughout our county. Removing this beneficial regulation will harm our public lands. I have strong concerns that the current administration is moving ahead with energy and resource removal without consideration of the health of the land itself. For instance, if the 2001 Roadless Area Conservation Rule were removed, timber harvesting would cause devastation to mature Forests that are a treasure we must protect. Those in leadership positions are not proving they are looking at the larger picture or the needs of future generations, but instead are seeking instant gains regardless of the harm it will cause. Areas I have particular concern for are those parts of National Forests in Michigan: Hiawatha National Forest, Huron-Manistee National Forest, and Ottawa National Forest. I urge you members of the U.S. Congress to oppose the proposal to rescind or alter the Roadless Rule,” and support “Alternative 1, the No Action alternative. Thank You, Stephen Hoekwater

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I fish, camp, and hike in the mountains of Colorado. Rivers, lakes, trails, the views, the quiet solitude, and wildlife like elk, bighorn sheep, and mountain goats are what I go there for. Logging and road construction in those areas would destroy it. I want my kids to be able to enjoy these areas intact and protected , and the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule does the opposite. The agency's own record is the most damaging witness against this proposal. The agency's prior analysis found that "a human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands," and that "building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. The agency must explain the basis for departing from its own findings on fire occurrence, and reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale is no stronger. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that baseline, the agency's own cost-benefit analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service against recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. The agency must explain how an action whose own analysis cannot establish a net benefit justifies expanding a road network already carrying a $6.9 billion maintenance backlog. The agency also argues that state-by-state rulemaking can replace a national rule. The record shows the agency once "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 reviewed by the courts, and the Ninth Circuit found it wanting. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies identified when the national rule was last dismantled piece by piece. On authority: a court has already reviewed whether the 2001 rule exceeded statutory power. 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 agency should address that holding, explain how it squares any contrary position with the Tenth Circuit's conclusion that the rule fell within authority granted under the Organic Act and MUSYA, and did not create de facto wilderness. The areas at stake to me are not abstractions. Mt. Evans Adjacent Area in the Arapaho-Roosevelt National Forest defines Denver's skyline and the character of the land surrounding it. Indian Peaks Adjacent Area, also in the Arapaho-Roosevelt, looks straight out of a painting, especially at sunset. Green Mountain in the Pike-San Isabel National Forest deserves a visit before anyone considers letting it be logged. The agency's own record confirms that elk avoid roaded areas and that their survival rates rose during a road closure and fell when the gates came back off. It also confirms that bird richness declines with road presence, and that road noise cut bird abundance by over a quarter in a roadless area, with 31 percent of species avoiding the noise entirely. The elk, bighorn sheep, mountain goats, and birds I look for in these places depend on keeping roads out. Bear Swamp in the Huron-Manistee National Forest in Michigan is a wetland, and protecting it is critical. So many wetlands have been lost to development already. The Allegheny Front in the Allegheny National Forest in Pennsylvania is a place for hiking and camping, remarkable in the fall, and that experience would be ruined by logging. The agency built Alternative 3 specifically because commenters asked for protections for big game habitat, fisheries, and wildlife connectivity, then chose the alternative that protects none of it. The agency should explain that choice. The Forest Service held more than 600 public meetings and received 1.6 million comments before writing the 2001 rule. It has held none to undo it. My kids should not inherit fewer of these places than I did. Sincerely, [Your Name] [Your City, State]

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Bear Swamp in the Huron-Manistee National Forest is 3,915 acres of Michigan roadless land I want to see protected. Michigan holds 6 inventoried roadless areas totaling 16,124 acres. What happens to those acres under this proposal is what I am addressing here. The agency's stated rationale for rescission includes wildfire and fuels management, but its own record undercuts that argument directly. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency now proposes to open roadless areas including Bear Swamp to road construction on fire-safety grounds, it needs to explain why it is departing from that finding and how the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside the affected roadless areas, supports rather than defeats the proposal. The economic case for rescission is no stronger. The agency's own record 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." Set against that, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. That range does not establish a net benefit. The agency should explain on the record how an action whose own analysis cannot demonstrate a net positive outcome justifies expanding a road system already carrying a $6.9 billion maintenance backlog, and what that means for the 286 municipal water intakes in the Eastern region that sit in watersheds containing affected roadless areas, including those in Michigan. The proposal argues that state-by-state approaches can replace a national rule, but the agency's own prior rulemaking record expressed dissatisfaction with a one-size-fits-all nationwide approach when it previously replaced the 2001 rule. That replacement was challenged in court and the Ninth Circuit identified specific deficiencies in that state-petition approach, including that local decision-making can incrementally erode nationally significant roadless values. The agency has not explained how this proposal avoids those same deficiencies. That question requires a direct answer, particularly for a state like Michigan where the total roadless inventory is small and any incremental loss is disproportionate. On the question of statutory authority, the agency cannot treat the matter as unsettled without confronting what courts have already decided. The Tenth Circuit, in reversing a district court injunction against the 2001 rule, 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 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and found that it did not create de facto wilderness. The agency owes the public a clear explanation of the legal basis for any contrary position and how it weighs that appellate holding in its current analysis. Bear Swamp is a small piece of ground. Taken together, Michigan's roadless acres are modest by any national measure. What the agency is proposing is permanent, and the record it has assembled does not support the action. I ask that all four of these points receive a substantive response before any final decision is made. Sincerely, CS Manistee, MI

Dear Secretary and Chief: Climate-concerned citizen, late-night reader of EPA reports — I want the record to show a vote against rescinding one of the rare federal protections that's working. I have always enjoyed exploring the many miracles of nature this Earth has to offer. Being outdoors in a natural, roadless environment has many benefits for humanity, from physical to mental health. They are also great places to learn and find meaningful connections. What I've described took a long time to exist. It won't take long to destroy. The rule is what slows that down. I have countless lovely memories of traveling to national parks. I want to protect these spaces now so that many generations to come can experience the same joy that I have. Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan: Huron-Manistee National Forest's Bear Swamp IRA contains 5.0% coverage (~197 acres) of Great Lakes Northern Pine-Oak Forest (Laurentian-Acadian Northern Pine-(Oak) Forest) (GNR), which NatureServe independently identifies as habitat for Indiana Myotis (Myotis sodalis, G2). The species is separately documented present in the area. Road construction degrades this ecosystem and the imperiled species that depends on it. "Wetland species diversity is negatively correlated with paved-road density up to 2 km from wetlands. The effects of roads on wetland diversity take about 3-4 decades to be fully realized. Of 43 species of woodland breeding birds, 26 species (60%) showed reduced densities near highways, and traffic noise explained the most variation in bird density in relation to roads." — Transportation Research Board and National Research Council, 2005 The ecological association between Indiana Myotis (Myotis sodalis) and Great Lakes Northern Pine-Oak Forest (Laurentian-Acadian Northern Pine-(Oak) Forest) means road construction in Bear Swamp operates through a specific degradation pathway: roads alter the physical structure and ecological processes of the ecosystem, which in turn eliminates or degrades the habitat conditions the species requires. The 5.0% coverage (~197 acres) represents the spatial extent of this vulnerability. The rescission of the Roadless Rule will negatively impact the health of the planet by fracturing ecosystems, destroying wildlife habitats and potentially putting crucial species at risk of endangerment/extinction, and disrupt sacred and cultural sites. It would also negatively impact humanity by unnecessarily using up more of our already limited natural resources and spending unnecessary money on maintenance of the roads, etc. These lands deserve better than this. Thank you for your time and consideration. With hope, Sadie Schrodeder CommentID: RLC-20260902-V4TNM3

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: the Hiawatha National Forest, home to the Fibre (7,431 acres) and Delirium (188 acres) Roadless Areas; the Ottawa National Forest, including Norwich Plains and Trap Hills, totaling about 4,600 acres; and the Huron-Manistee National Forest, home to Bear Swamp (3,915 acres). These are Michigan's last large roadless forests. The Roadless Rule keeps these lands free of new road construction and large-scale logging. That is exactly what makes them valuable for mountain biking, hiking, backcountry skiing, snowshoeing, hunting, and paddling today. Rescinding the rule would allow new roads and increased logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently I love to walk in the forests. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States. Sincerely, Alison Stankrauff 120 Seward Apartment 408 Detroit, Michigan 48202

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: the Hiawatha National Forest, home to the Fibre (7,431 acres) and Delirium (188 acres) Roadless Areas; the Ottawa National Forest, including Norwich Plains and Trap Hills, totaling about 4,600 acres; and the Huron-Manistee National Forest, home to Bear Swamp (3,915 acres). These are Michigan's last large roadless forests. The Roadless Rule keeps these lands free of new road construction and large-scale logging. That is exactly what makes them valuable for mountain biking, hiking, backcountry skiing, snowshoeing, hunting, and paddling today. Rescinding the rule would allow new roads and increased logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently offer. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States. Sincerely, Andrew Heer, Highland MI

I am writing to oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Rule (Docket FS-2025-0001, RIN 0596-AD66). Michigan's national forests contain roughly 16,000 acres of Inventoried Roadless Areas across three forests: the Hiawatha National Forest, home to the Fibre (7,431 acres) and Delirium (188 acres) Roadless Areas; the Ottawa National Forest, including Norwich Plains and Trap Hills, totaling about 4,600 acres; and the Huron-Manistee National Forest, home to Bear Swamp (3,915 acres). These are Michigan's last large roadless forests. The Roadless Rule keeps these lands free of new road construction and large-scale logging. That is exactly what makes them valuable for mountain biking, hiking, backcountry skiing, snowshoeing, hunting, and paddling today. Rescinding the rule would allow new roads and increased logging in these areas, fragmenting habitat and changing the primitive backcountry character these forests currently offer. I ask the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule in place for Michigan's Hiawatha, Ottawa, and Huron-Manistee National Forests, along with the rest of the National Forests across the United States. Sincerely, Mark Johnson Wyoming, MI 49519