Read the comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking and hiking through places like Pyramid in the Lake Tahoe Basin and the Paiute roadless area in Inyo National Forest to commune with nature, watch birds, and observe wildlife, I have come to understand what these landscapes hold. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own analysis does not support the step it is proposing to take. I am an avid backpacker and day hiker who lives in Northern California. I have travelled all over the United States to hike and backpack. The impact of roads and off road vehicles on wildlife, the land and the experience being in the “wilderness” is obvious and depressing. Bird watching is not incidental to why I go into roadless areas. It is a central reason. The agency's own record, drawing on research the DEIS cites, documents that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. California already holds 381 inventoried roadless areas totaling 4,389,760 acres, and the birds I go to find depend on the quiet and the unbroken canopy those areas provide. Opening that landscape to road-building does not simply alter the scenery. It restructures the acoustic and ecological conditions that determine whether those species stay or go. I ask the agency to explain, with specificity, how the benefits it claims from rescission can be weighed against documented declines in bird abundance and species presence that its own cited science predicts. The wildfire rationale the agency offers for this rescission conflicts directly with what its own record says. 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." The DEIS further reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency must explain why its proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions from new road access weighed against any claimed reduction in wildfire hazard. The regulatory flexibility certification also cannot stand as written. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading expenditure loss across every small firm in the sector nationally rather than examining the guides and outfitters holding permits in the specific affected areas. The agency concedes some firms may lose those receipts. It should withdraw the certification and assess impact on the small entities actually operating in and permitted for the potentially affected roadless areas. The Chugach National Forest in Alaska is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta within it hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration, including western sandpiper in the millions. Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape at a scale that exists nowhere else in the national forest system. The 2001 rule is the structural protection that has kept those conditions intact. A state-petition process substituted for a national rule creates no guarantee that protection continues, and the agency's own record does not model what happens to that ecosystem if the rule falls. 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. My years of hiking, birding, and backpacking in California's roadless areas, and my expectation that federal policy would continue to protect them, are exactly the kind of reliance interests the agency invited and then declined to assess. The agency must identify and weigh those interests as part of this proceeding, including what this comment represents. Sincerely, Kristen Sorensen Petaluma, CA

I am writing to support Alternative 1: The “No Action” alternative because I believe we should keep the Roadless Rule intact. I live in Sunnyvale, California and frequently enjoy hiking and backpacking in roadless areas. One of my favorite destinations is the Inyo National Forest, and the thought of roads being built for any reason is appalling. Not only would they despoil the natural beauty, their construction would involve vegetation removal which could lead to the loss of native plants and allow for the colonization of invasive plant species with greatly increased ignition risk of forest fires. I am not alone in enjoying such places. Roadless areas support outdoor recreation and tourism for all, which contribute billions to the economy. Please move forward with the No Action Alternative 1, and keep the Roadless Rule intact.

I strongly oppose any efforts to rescind or weaken the 2001 Roadless Area Conservation Rule. As a backpacker, trail runner, hiker, and mountain athlete who values public lands and relies on inventoried roadless areas near Tahoe National Forest, Inyo National Forest, Yosemite National Park, Kings Canyon, Sequoia, etc., protecting these landscapes is vital. These places hold a special place in my heart as well as many other US citizen's hearts. Access to untouched public lands is crucial to the wellbeing of the US as a whole. It is so vital to be able to teach ourselves and future generations about these lands and the wildlife, agriculture, and culture they hold. Key reasons to maintain protections include: • Safeguarding critical municipal watersheds and clean drinking water. • Providing essential, unfragmented wildlife and plant habitats. • Acting as natural fire buffers and supporting local recreation economies. I urge the U.S. Forest Service to maintain full, permanent protections for all currently designated inventoried roadless areas. Sincerely, Oli Pakes Oakland, California

I am writing to oppose the rescission of the Roadless Rule. As a resident of the beautiful Eastern Sierra, I fear how the loss of the roadless rule could disrupt our unique landscapes, increase risk of wildfire (yes, wildfires are more likely to start near roads), and enable extractive industries in a region that has already been harmed by needless and irresponsible extraction of resources. We must keep the Roadless Rule to protect the more than 300,000 acres of roadless areas in the Inyo NF and the more than 3.9 million acres across California.

Dear Secretary and Chief: The experience of moving through national forest that the 2001 Rule has maintained in its current condition has shown me, as an outdoor enthusiast, that the Rule's value is not merely symbolic — it is operational, categorical, and responsible for the specific landscape I access — and the Department should not rescind it without a demonstrably superior means of achieving the same protection. Areas like Benton Range, CA allow me to disconnect from the hustle and bustle of daily life, and to reconnect with nature and what matters - a clean environment that has biodiversity and provides an opportunity for all life to thrive. When an individual has to put effort into getting into the forest, they are rewarded far more - knowing that they had to plan and prepare to be one with the ecosystem. More roaded forest does NOT help our environment, nor do they help the human spirit. We are meant to put effort into adventures in order to be rewarded. Regarding the Benton Range in the Inyo National Forest, California: “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205) The 8.9-mile corridor between Benton Range and Glass Mountain sustains gene flow for 27 species, including Greater Sage-Grouse (G3), Owens Pupfish (G1), Pinyon Jay (G3). Road construction in either IRA severs this exchange, isolating populations that depend on movement between areas for genetic diversity and recolonization after local disturbance.” These lands have been protected for good reasons. The Department should let them stay that way. With appreciation, Rachel Grace CommentID: RLC-20261007-5ED64G

Keep the Roadless Rule and protect our great country and natural resources. No one wants this. Americans care about their land and their freedom. I regularly travel to the Easter Sierra and want to see it protected and not destroyed. Statewide, the Roadless Rule protects more than 3.9 million acres of California's National Forests. The Inyo National Forest has more than 300,000 acres of Inventoried Roadless Areas protected by the Roadless Rule, including the following: Coyote Flat (~36,000 acres). This area is perhaps best known as a premier high-altitude overlanding and off-highway vehicle (OHV) destination, still accessible as such under the Roadless Rule. How could this be? The Roadless Rule didn’t close roads or mandate the future closure of roads in roadless areas. In other words, roadless areas have roads. The Roadless Rule only prevents more from being built. This area is also rich in Tribal cultural resources, is home to the endangered Sierra Nevada Bighorn Sheep, and is a haven for countless other forms of recreation. Mono Lake & Mammoth Lakes Roadless Forests (~32,000 acres). Irreplaceable watersheds that support local communities and recreation economies, while protecting the scenic integrity of the Eastern Sierra. White Mountains Roadless Areas (~82,000 acres). Home to the world's oldest living organisms on the planet: the Ancient Bristlecone Pines, critical desert bighorn sheep habitat, and landscapes held sacred by Indigenous communities. Glass Mountains Roadless Areas (~63,000 acres). Migration corridors for mule deer, habitat for sage-grouse, and popular backcountry hunting and camping destinations. Owens Peak & South Sierra Roadless Areas (~48,000 acres). Critical wildlife linkages cherished by climbers, hikers, and backcountry explorers. Wilderness Adjacent Roadless Areas (~41,000 acres). Pristine backcountry near Yosemite National Park offers world-class hiking, climbing, and fishing. Thank you, Sara Dinges

10/6/2026 I’m writing to express my opposition to the USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). Removing this protective conservation rule will open sensitive land to extractive industries that will destroy wildlife habitat. Sensitive ecosystems will be lost and, at best, negatively impacted. Allowing the logging and mining industries increase the destructive clear cutting of diverse forest and replacing it with farmed monoculture of fast growing single species of tree. Recent reporting by the press that lumber industries have been spraying glyphosate on the land in preparation of replanting that mono crop is now a great concern to me, because we do not know the long term impact that has on our environment and health. This practice has an almost certain chance of continuing onto these protected lands and if it does, will threaten the watershed supply for millions of people across the country. Allowing roads to be cut into currently protected land increases the incidence of man made wildfires, litter, stress and disruptions and conflict with wildlife and migratory habits and habitat. Current national parks and recreational trails can arguably be a testament to this fact. We have to spend millions on wildlife corridors, and other extreme conservation measures to mitigate the impacts from human activity. It always starts with a single road. Some places on this planet just need to be left alone and kept wild for wildlife to move freely — humans can observe from afar, or on foot at one’s own risk. As a young child I grew up camping and fishing, learning to love and appreciate nature. Then life as an adult has me working and in survival mode until fifty years later I realize I need and want that activity back in my life. I recently started hiking and camping again, and this last month, at the age of 61, I went on my first backpacking trip in 45 years. Not since high school have I explored the wild, vast wilderness, miles and miles from the noisy roads and compacted campgrounds. It was glorious, quiet, and so beautiful. This trip covered the eastern Sierra, Inyo National Forest, John Muir wilderness that have some of the most pristine views and water quality. Please keep this and all the places protected under the Roadless Rule this way, do not rescind the Roadless Rule. The intent on the Department’s action says it will return decision making management to the individual national level and provide flexibility for management to plan and implement decisions, but I see the deregulation as weakening the conservation of land and what keeps America’s wilderness unique and beautiful. I worry that rescinding the Roadless Rule opens the opportunity for commercial companies to divide and apply greater pressure or influence over localized and decentralized national Forest management. We can manage national forests and provide flexibility based on that forest’ need. It’s a matter of implementing the interest of conservation for the land and not extraction of the land. It is , in my opinion, disingenuous to say the Department hasn’t been able to make planning decisions because of the Roadless Rule of 2001 since the primary purpose of cutting new roads through the forest is for private industry to have access to cut it down. Another problem of rescinding the Roadless Rule and allowing development of new roads is that will add to the backlog of roadway and infrastructure maintenance and management that already exist and is compounded by this current administration’s funding cuts to the Department. In summary, here are the reasons I am against rescinding the Rule It is bad for wildlife and habitats Increases the backlog of maintenance Potential threat of having a monoculture and glyphosate contamination on land and in water. Potential for mining waste contamination. Respectfully, Doris Bergman

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Roadless Rule has protected millions of acres of backcountry that I depend on. I live near Sequoia National Forest and have backpacked and hiked extensively in Inyo National Forest as well as national forests in Washington, Oregon, Montana, Wyoming, and New Mexico. What draws me to these places is old growth forest and relatively untouched ecosystems. I do not enjoy hiking or camping in clear-cut forests or in areas easily accessible to motorized vehicles, and the Roadless Rule is precisely what keeps those areas from becoming the latter. The agency's own record undermines its wildfire rationale for this rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency is offering wildfire management as a justification for opening roadless areas, it must explain how that argument survives its own findings. I ask that the agency explain why this proposal departs from those prior findings 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 economic case for rescission is similarly thin. 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 that backdrop, the Forest Service is already $6.9 billion behind on maintaining the roads it has, operating on a road budget of roughly $73 million a year. It seems like a great waste of taxpayer money to build new roads into country that has none. I am strongly opposed to my taxes being used to build roads that have no benefit to anyone but timber companies. 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. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying that maintenance backlog? The agency must answer that question with specificity before this rule moves forward. The regulatory flexibility analysis contains a related problem. 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 projected losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should 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 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 one such interest. I have organized my recreational life around public lands protected by the Roadless Rule, choosing where to hike and backpack based on the understanding that those places would not be opened to roads and extractive industry. An agency that invites statements of reliance and then accounts for none of them in its analysis has not discharged its obligations when changing course. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. I am extremely disappointed that despite broad public support for keeping the Roadless Rule, the USDA has continued efforts to repeal it. This is clearly not what the American people want or feel is in their best interest. The agency should explain on the record why it is placing the preferences of extractive industries above those of the public it is charged with serving. Sincerely, Jessica Henning Visalia, CA

I grew up with access to nature, Point Reyes National Seashore was in my backyard and Tahoe National Forest and Inyo National Forest only a few hours away. Backpacking, hiking, and camping in these public lands grew my admiration for the outdoors. Once you fall in love with nature, it is difficult to not be inspired to protect it. This brought me to career in environmental conservation and education, creating outdoor recreation opportunities for youth and young adults. The peace and quiet you experience while walking through the forest, moss coating the trees and fog rolling through a valley. The ridge lines you work hard to hike to and crest, with an expansive view of forest and ocean on the opposing side. These views and landscapes are at risk with the recision of the Roadless Rule. In 2018, while walking through the streets of San Francisco, a soft ash fell from the sky like snow. Fires converged to cause a darkening of the sky and air quality to plummet. Only a few years later I would awake to a dark red sky, thinking it was the middle of the night, until peering at my clock to see 8:30am lit up on the screen. The robin’s egg morning sky was gone, replaced by the dark swell of blackened clouds, like those circling Mount Doom in Mordor. Air quality was so severe that people were encouraged to stay indoors periodically throughout the summer. However, as a frontline worker working on defensible space to protect homes from fires and maintaining local, state and national parks –that wasn’t an option. My crew and I worked outside throughout these periods of poor air quality, because the nature of our work didn’t allow for indoor alternatives. Fire season has extended later into the year and made me fearful to continue to live in California, so I moved. The intensity and consistency of these fires is exacerbated by human error, such as electric companies neglecting their poles in rural areas. Research shows that wildfire ignition is lowest in designated wilderness areas, including National Forests, away from roads, because the leading cause of fires is human ignition/error (Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026)). Beyond fire safety, there is a magic to the wilderness and public lands that are for the people of this country. These are our backyards, our natural spaces that help people fall in love with nature and recognize the importance of protecting it. Beyond the importance of access, these lands are a refugee for wildlife and maintain clean drinking water for over 124 million people across multiple states in cities and towns alike; that statistic is over 15 years old, so with taking into account population growth, that number has surely increased (DellaSala, D. A. (2011). Roadless areas and clean water. Journal of Soil and Water Conservation, 66(3), 78A–79A). I hope that the representatives that we elected, who stand by the people and wild-lands of this country will stand up for the Roadless Rule and the protection of our forests.

I live in Mono County, CA which has many roadless areas protected under the Roadless Conservation Rule of 2001. These lands are managed by the Inyo National Forest. These places are important to me because they are outside of designated wilderness where I can ride a mountain bike or engage in activities not allowed in Wilderness, but also do not have roads and generally have less people than more traveled areas of public lands. These roadless areas also serve as buffers for wildlife and habitat connectivity to congressionally protected areas. I want to see these places managed by the USFS to ensure there is limited development from things like logging and mining. I also believe these places are better prepared to be resilient to wildfire and can be properly managed without the construction of roads. Data show the vast majority of forest fires in California are started by human activities, most often from vehicles and road access. Expanding roads into currently undeveloped areas increases ignition sources and reduces the effectiveness of wildfire prevention and response strategies. These areas also provide drinking water to our local communities and offer a quality of life I have enjoyed for over 14 years as a resident and home owner. Please leave the RACR intact!

I favor reduced government regulations with regard to businesses, but I am strongly opposed to this proposal to rescind the 2001 Roadless Rule. I am a resident of Sacramento California, where I retired 5 years ago to enjoy the outdoors including national forest lands. Those National Forest lands are especially important to me because we can take our dog with us when hiking or camping. That's not allowed in the vast majority of National or State Parks. I chose to live near the Sierra Nevada and multiple national forests from El Dorado National Forest in the south through Tahoe NF to Plumas NF north of Lake Tahoe. But I am within fairly easy driving distance of Inyo NF to the southeast, and Klamath, Shasta Trinity and Six Rivers NF's in the northern part of the state. In the former 3 NF's I see this rescission fragmenting beautiful forest lands that will devalue the forests for biking, fishing, hiking and hunting alike. At the same time easier access for people from an expanded road system (not necessarily loggers and others) will increase the likelihood of increased fire danger. But in the latter four forests the even higher percentage of areas being proposed to allow new roads goes beyond devaluing the forest and approaches fragmenting them into a small number of microforests that destroy the existing wilderness. This does not seem well thought out and has no new budget for supporting an even larger road system (neither construction or maintenance). It is also likely to shift current control from a single government unit to conflicting state and local jurisdictions. Therefore, I am strongly opposed to the proposal to rescind the 2001 Roadless Rule.

To the Forest Service: I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to urge the agency to retain it. I am a hiker and a parent, and I value our national forests because they are some of the last refuges of truly wild nature in this country, places that remain relatively unmolested by human impacts and that still have room for biodiversity to persist on its own terms. My first backpacking trip was as a child in the Inyo National Forest, and walking into country where the roads ended gave me one of my first true feelings of patriotism. I realize that this land is my county and it needs to be protected by its citizens. At its core, our country is the land. Preserving some of it without roads is an act of respect for the country and for the living things that make it what it is. I want my children to grow up in a country where areas of nature can remain untouched by the impacts of roads, and to have the chance to feel what I felt out there. I fear that roads built into these areas will open the way to logging and further tarnish the few pristine places we have left, and that my children will inherit a landscape with nothing like them to experience. I want to explain why I value land that has not been touched by roads. A road changes a place permanently. It brings fragmentation, erosion, sediment in streams, invasive species, and noise, and it makes the surrounding land easier to log, mine, and develop. Once a road is built, the pristine character of that land is gone. Few places in this country are still large enough and quiet enough to support wildlife that needs space, clean headwaters, and solitude. Roadless areas are among the last of them. These lands are also valuable because of what they provide without any management or expense. They filter and store water that downstream communities drink. They give wildlife room to move and breed, and they give people a chance to hike, hunt, and fish in country that is still wild. Every road the agency builds is one it must maintain, and the Forest Service already carries a road maintenance backlog it cannot fund. Opening roughly 44 million acres to new road construction would add to that burden and trade a lasting public benefit for short-term gain. I understand the Department's concern about wildfire and forest health. But the 2001 rule already allows exceptions for fuel reduction and other necessary management, so it does not stop the agency from doing that work. A rule of this magnitude, one that has protected about 59 million acres for 25 years, deserves more than a 30-day comment period and a limited public process. The original rule drew 1.6 million comments and 600 public meetings over 18 months. I urge the Forest Service to withdraw this proposal and keep the Roadless Rule in place. If the agency proceeds, I ask that it extend the comment period, hold public meetings across the affected regions, and fully analyze the effects on water, biodiversity, and the long-term costs to taxpayers. Thank you for considering my comment. Benjamin Resident of Virginia

To the Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). I haven been an avid hike for almost 20 years, hiking several times a week (or more). This includes national parks and national forests including the following: • Angeles National Forest • Arapaho National Forest • Carson National Forest • Cleveland National Forest • Inyo National Forest • Lassen National Forest • Pike National Forest • Rio Grande National Forest • Roosevelt National Forest • Routt National Forest • San Bernardino National Forest • White River National Forest Hiking is important to both my physical and mental health and has played an important role in my volunteer work to help veterans reintegrate following their service and find community. Taking them on hikes has been a powerful way to bolster their health and wellness. The 2001 Rule protects roughly 58.5 million acres of inventoried roadless areas by generally prohibiting road construction, road reconstruction, and timber harvesting, with limited exceptions. Rescinding it removes that protection nationwide. The notice states that the rescission does not itself mandate timber cutting or road building. But it removes the rule that currently prevents them, and the agency should be candid that this makes road construction and logging in these areas possible where they are now generally prohibited. For hikers, the value of these areas is that they are undeveloped. A trail through a roadless area offers quiet, solitude, and a sense of remoteness that cannot be rebuilt once a road is cut through. Opening the door to new roads and logging puts those experiences at risk, and the loss would be permanent in a way that is very hard to undo. The Department's stated reasons for the proposal are to reduce regulatory burden and to return decisions to local Forest Service officials. I ask the agency to address the following in the final rule and EIS: How will recreation be weighed? If decisions move to the local level, what required standard will ensure that the value of undeveloped backcountry for hiking and other dispersed recreation is considered, rather than left to discretion project by project? What is the burden being relieved? Please identify the specific, documented costs of the 2001 Rule, and show that they outweigh the benefits of keeping a consistent nationwide protection. Why rescind rather than amend? If there are specific problems with the rule, why does the Department propose eliminating it entirely instead of a narrower fix? How will the public be involved? Under the proposal, how would hikers and other recreation users learn of and comment on future decisions affecting individual roadless areas? I also ask that the Department give the public adequate time to review a proposal of this size. The rescission was issued alongside a draft environmental impact statement and a cost-benefit analysis, with an original 30-day comment period. I urge the Department to withdraw the proposed rescission and keep the 2001 Roadless Area Conservation Rule in place. Sincerely, Laura W. Fort Collins, CO

Docket ID: FS-2025-0001 Agency: U.S. Forest Service, USDA Subject: Strong Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule Dear Agriculture Secretary Brooke Rollings and Chief of the Forest Service, I am writing to express my unequivocal opposition to the U.S. Forest Service’s proposal to fully rescind the 2001 Roadless Area Conservation Rule. As an active recreationist who relies on the pristine wildlands of California's Sierra Nevada, I strongly urge the agency to maintain existing protections for our remaining Inventoried Roadless Areas (IRAs). The Draft Environmental Impact Statement (DEIS) fails to consider the permanent ecological and economic harm that lifting these protections will bring to the vital gateway landscapes surrounding Yosemite National Park, the Tuolumne River watershed, and the Eastern Sierra. I oppose the rule's repeal for the following substantive reasons: * Threats to the Yosemite and Tuolumne Wilderness Boundaries: The 2001 Roadless Rule protects critical, intact wild tracts on the western slope of the central Sierra, directly adjacent to Yosemite National Park within the Stanislaus and Sierra National Forests. This includes fragile forest buffers framing the Tioga Pass corridor and the high-elevation headwaters of the Tuolumne River watershed. Allowing commercial road construction up to the park boundaries fragments critical ecological buffer zones and risks severe soil erosion and stream sedimentation, threatening downstream municipal water supplies and world-class white-water and backcountry recreation. * Impact on Ansel Adams Wilderness Buffers: The IRAs adjacent to the Ansel Adams Wilderness provide a critical protective shield for one of the most heavily used alpine wilderness areas in the United States. Stripping roadless protections from these bordering lands will allow industrial infrastructure, commercial logging roads, and motorized traffic to encroach directly onto wilderness boundaries, destroying the solitude, dark night skies, and pristine wilderness character that draw millions of visitors to the region annually. * Degrading the Eastern Sierra and Mono Lake Basin: In the Inyo National Forest, roadless areas safeguard the fragile, high-desert sagebrush and alpine transition zones of the Mono Lake basin. These intact landscapes are vital for the regional recreation-based economy, supporting hiking, climbing, fishing, and pack-scouting. Opening these terrains to industrial use will fundamentally disrupt critical wildlife migration corridors for iconic species like the bi-state sage-grouse and Sierra Nevada bighorn sheep. * Flawed Wildfire Justifications: The Forest Service claims that rescinding the rule is necessary for wildfire mitigation, yet the agency's own data contradicts this. Over twenty years of data proves that roadless areas can be—and are—actively treated for fuels reduction using smarter, lower-impact methods. Furthermore, the DEIS acknowledges that building new roads introduces more human traffic and vehicle-related exhaust heat, which exponentially increases the risk of human-caused wildfire ignitions in the severe weather-driven terrain of the Sierra. * Fiscal Irresponsibility: The Forest Service currently faces an unsustainable multibillion-dollar deferred road maintenance backlog. Proposing to build and manage new roads in the rugged terrain of the Sierra Nevada while failing to maintain existing infrastructure is fiscally irresponsible and takes vital funding away from actual local forest restoration efforts. The 2001 Roadless Rule provides a balanced framework that allows for Tribal use, public safety, and wildfire management while protecting our last wild spaces. Do not strip protections from the wild forests that define California's natural heritage. I urge the USDA to withdraw this proposal and maintain the 2001 Roadless Rule in its entirety. Sincerely, Rosa Ramirez Crowley Lake, CA 93546 Rrosarosa819@Gmail.com

I am in favor of keeping the roadless law, I am a fellow ranger from the 80’s and now I see way too much destruction in the Inyo National forest, Thank you!

I am writing to strongly oppose the repeal of the 2001 Roadless Area Conservation Rule. For years I have camped and hiked in the Inyo National Forest, and some of my most best memories were made in its undeveloped backcountry. These places feel as wild and quiet as they do because they have been spared from road building and industrial development. Once a road is cut into a roadless area, that solitude can't be restored. The Roadless Rule protects more than scenery. It safeguards the watersheds that supply drinking water to communities across eastern California, preserves wildlife habitat, and reduces the wildfire risk and costly maintenance burden that come with expanding road networks on public land. Repealing it would trade lasting public benefits for short-term gains, and it would undercut the experiences that draw visitors and support Eastern Sierra towns like Bishop. I urge you to keep the Roadless Rule in place so that future generations can experience the Inyo as I have.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The East and West Fork of the San Gabriel Rivers are not wilderness by any formal designation, but they hold landlocked coastal steelhead, and they are close enough to Los Angeles that people who love them share the water with people who abuse it. I have watched gold miners dig out whole sides of the stream, sending sediment downriver and destroying the natural habitat those fish depend on. I have seen illegal camping all up and down the river creating public health hazards with elevated E. coli. Rescinding the 2001 Roadless Area Conservation Rule for the Angeles National Forest will not reduce that pressure. It will increase it, and it will do so while the agency's own science documents exactly what new roads cost a river. The agency's document states: "The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and 'can contribute up to 90 percent of the sediment generated by timber sale activity.'" That number appears in the record and then vanishes. No projection follows it. Removing riparian vegetation raises stream temperatures beyond what suits cold-water species, and warmer temperatures reduce egg survival, rearing densities and growth of coho salmon. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS. If the agency knows roads and their facilities can produce up to 90 percent of the sediment from a timber sale, it must quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. I am asking for that calculation. The drinking water question is not abstract. The agency's own record states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Water is limited already. Clean drinking water is more limited still. Many of these watersheds feed into aquifers and aqueducts that sustain cities and communities, and the current impairment rate is low precisely because the roadless rule has been holding. The DEIS asserts that forest plans address municipal water sources without identifying a single enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds, and that it do so specifically, not by category. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. A federal appellate court reviewed that question directly and held otherwise: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. I ask that the agency explain the basis for any position contrary to that holding, and that it address that court's reasoning directly. On the economics, the proposal rests in part on timber and energy arguments. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." With a $73 million annual road budget and a $6.9 billion maintenance backlog already in place, spending more to open country that has no roads is a poor decision that goes against any serious principle of avoiding government waste. I also value the Inyo National Forest for its remoteness and high altitude, qualities that exist because development has not reached them. The agency must reconcile this proposal with its own Cost Benefit Analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog serves the public interest. I oppose rescission of the 2001 Roadless Area Conservation Rule. The agency has quantified the harm and declined to follow it to its conclusions. That is not a reasoned decision. The record requires answers, and the public deserves them. Sincerely, Dorothy Dai Los Angeles, CA

I oppose the repeal of the Roadless Area Conservation Rule. I have spent extensive time recreating in our public lands, including in National Forest Roadless Areas. Some of the roadless areas most important to me are the San Joaquin IRA in Inyo NF and the Eagle IRA in Mt Hood NF. The American public supports wilderness areas and we will not believe the claims about needing to repeal the rule for better fire management. 90% of fires are started within 1/2 mile of a road, and analysis has found that Roadless Areas have not burned at significantly higher rates or severity than forest lands with roads (and in the most recent decade, they actually burned less). We already have 370,000 miles of forest roads with a multi-billion dollar maintenance backlog - let's not create more.

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 Escaping to isolated sections of forest is a major part of my recreation, and it is extremely important and valuable to me. I photograph the natural sites that inspire me: forest-covered hills and mountain peaks that are untouched, places that recall the way the land looked for thousands of years before people altered the large majority of it. The areas I am most concerned about include Sespe-Frazier in Los Padres National Forest, where I carry many fond memories of hiking and backpacking in my twenties and which is wonderful for how accessible it remains from the greater LA area; the rugged landscapes of the San Gabriel Add and Arroyo Seco units in Angeles National Forest, which provide an important escape from the nearby sprawl of LA; Pyramid in Eldorado National Forest, a wonderful place to hike and experience beauty and solitude; and Tioga Lake in Inyo National Forest, a place of immense natural beauty. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and these places represent what remains. We cannot restore a landscape once it is destroyed. So little is left already, and we must save what is left for our children and further descendants. Preserving natural beauty and places of solitude should have a higher priority than wealth extraction. That is the principle I ask this agency to apply in reviewing this proposal. The agency offers wildfire management as part of the justification for rescission, but its own findings contradict that rationale. 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 places I hike and photograph, these untouched forest-covered hills, carry value precisely because they have remained unroaded. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and to 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 rationale fares no better on examination. The agency's own record acknowledges: "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 solitude I seek in places like Sespe-Frazier and the beauty I photograph at Tioga Lake are not abstract values; they represent the kind of recreation that the agency's own cost-benefit analysis recognizes as carrying real economic weight. The same 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 and a net present value spanning negative $92 million to positive $199 million. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal also argues that state-specific approaches can replace a single national rule, but this ground has been tested before. 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." California's 4,389,760 roadless acres, including the watersheds that supply 1,034 municipal water intakes across the Pacific Southwest region, were protected under the national framework precisely because local, incremental decision-making was found to gradually erode nationally significant roadless values. How does this proposal avoid the deficiencies the Ninth Circuit identified the last time the agency substituted a state-by-state approach for the national rule? Finally, the proposal contends that the 2001 rule exceeded statutory authority. But the Tenth Circuit addressed that question directly. The court found the rule 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 state plainly on what legal basis it departs from that holding. The places I have described are finite. The Pyramid roadless area covers 24,347 acres. Sespe-Frazier covers 106,910. These numbers do not grow back once a road goes in. I ask the agency to answer each of the questions raised above before proceeding further. Sincerely, Erik Krumrey San Rafael, CA