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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

Dear U.S. Forest Service Officials, I am writing to express my firm opposition to the U.S. Department of Agriculture’s proposal to rescind the 2001 Roadless Area Conservation Rule. As an avid hiker and backpacker who frequently travels through California’s public lands, I urge the agency to protect our backcountry heritage and select the No Action Alternative. My recreation footprint is anchored in several of California's most critical public land units: the San Bernardino, Cleveland, Angeles, and Inyo National Forests. From the high-altitude alpine terrain and pristine lakes of the Eastern Sierra in the Inyo to the rugged, steep backcountry slopes of the Angeles, San Bernardino, and Cleveland forests in Southern California, these intact spaces provide unmatched opportunities for primitive recreation, solitude, and self-reliance. Allowing road construction and expanded logging in these specific Inventoried Roadless Areas (IRAs) will cause immediate, irreversible harm to these environments: 1. Destruction of Primitive Recreation Vibe and Solitude: Backpackers visit areas like the Inyo National Forest specifically to experience unfragmented landscapes and true escape from urban noise. Introducing heavy industrial machinery, logging traffic, and new road corridors directly into these viewsheds ruins the quiet recreation values that define the backcountry experience. 2. Severe Risks to Critical Watersheds: The roadless areas within the San Bernardino, Angeles, and Cleveland National Forests encompass vital, sensitive headwaters that protect municipal drinking water supplies for millions of Southern Californians. Constructing roads on these highly erosive slopes causes severe sedimentation and slope failures, degrading water quality at the source and threatening the fragile riparian systems hikers depend on for trailside water. 3. Exacerbating Human-Caused Wildfire Risks: Southern California forests are already on the front lines of climate and wildfire stress. Data clearly demonstrates that wildfires are significantly more likely to ignite near roads due to increased human access. Bringing new roads into the remaining roadless pockets of the Angeles and San Bernardino forests introduces unnecessary ignition risks into pristine fuel beds. 4. Worsening a Strained Maintenance Backlog: The Forest Service is already struggling to manage a massive deferred maintenance backlog on its existing sprawling road system. Diverting limited agency funding and personnel to cut new roads or clear timber in the rugged backcountry of the Inyo or Cleveland National Forests will inevitably strip vital resources away from maintaining high-use recreational trails, trailheads, and visitor safety facilities. The existing 2001 Roadless Rule provides flexible, balanced management while successfully shielding 4 million acres of California’s wildest forests from fragmented degradation for a quarter of a century. Please abandon this rescission proposal and maintain the 2001 Roadless Rule exactly as written. Sincerely, Terrence Bobryk-Ozaki Running Springs,CA 92382

As a person who appreciates the many values national forests bring to my state, my wellbeing, our wildlife and more, I support Alternative 1: The “No action alternative” because we should keep the Roadless Rule intact. Roadless areas keep our forests healthy. They serve as the ecological backbone of our national forest lands and: - Supply 50% of California’s drinking water - Support Tribal cultural practices - Enhance outdoor recreation including backcountry hiking, backpacking, horseback riding, mountain biking, camping, angling, and hunting - Shelter over 200 imperiled species like the Pacific fisher and Sierra Nevada red fox - Protect the military mission in part by serving as a crucial buffer against urbanization. And, more roads mean more wildfire risk. Most wildfires are caused by humans and most human-caused fires occur near roads. We don’t need more. On a personal note, I’ve lived in the Sacramento area for over 4 years now and been exposed to an incredible wealth of natural forestry in various areas. I recently returned from a trip along the eastern Sierras that included many forests and other lush natural scenery such as Inyo National Forest and Yosemite National Park. I was in utter awe at what the Earth is capable of, and felt very privileged to venture to these places and take in their beauty. Natural wonders such as these and the countless others across the state are an integral part to the culture of California. I’m honored to call California my home now, and the rescinding of the Roadless Rule would be devastating to a place I now consider familiar and incredible. Beyond just me, the health, cultural, and environmental impacts of this rescinding would hurt all Californians and Americans in ways described above. It would be shameful if our legislative institutions lost sight of what contributes to America being a marvel of natural scenery, especially for something as short-sighted as developments for gain or profit. The Earth is our home, the only home we’ve ever known and it has provided us with the wonder of life. We owe it to the Earth, as we owe everything to the Earth, and the beauty of Earth should absolutely be preserved. Please move forward with the No Action Alternative 1: Keep the Roadless Rule intact. Sincerely, Zane Warden Sacramento, CA 95818

Re: Rescission of th e Roadless Area Conservation Rule, Docket FS-2025-0001 The Inyo National Forest and John Muir Wilderness are where I hike, camp, and photograph: trees, flowers, wildlife, and the birds I go looking for, hawks and Clark's nutcrackers and whatever indigenous species the country offers. Roadless areas are my most treasured places. The proposal to rescind the 2001 Roadless Area Conservation Rule would put those places at risk, and the agency's own record supplies the reasons to reject it. I go into roadless areas in part because the birds are there. The DEIS the agency placed before itself cites findings 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. Hawks, nutcrackers, the full range of species indigenous to the places I walk, depend on the quiet interior that the current rule protects. The agency should explain, drawing on those cited findings, how opening these areas to roads and the disturbance roads bring is consistent with its own documented understanding of what roads do to the birds that live there. The wildfire rationale offered for rescission cannot stand against the agency's own data. 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 agency is proposing to expand the road system into areas where, by its own accounting, fire ignition risk would rise dramatically. The agency must reconcile this proposal with that finding and 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 is equally hollow. 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, the agency's 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 -$92 million to +$199 million. The road system the agency would expand already carries a $6.9 billion maintenance backlog. The agency cannot establish a net benefit by its own numbers, and it owes a clear explanation of how an action that fails its own economic test, while worsening a maintenance crisis already measured in billions, serves the public interest. The procedural history of this rule also deserves a direct answer. The record quotes the USDA's own stated dissatisfaction and its rejection of the rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. The agency tried replacing the national rule with state-by-state plans before. The Ninth Circuit found that approach wanting. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and it should explain specifically how this proposal avoids repeating the deficiencies the court identified in that earlier attempt. Finally, the statutory authority argument the proposal advances has already been tested. A federal appeals court considered whether the 2001 rule exceeded what Congress authorized and 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 Tenth Circuit concluded that the rule fell within the authority Congress provided under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. If the agency now holds a contrary position, it must state the legal basis for that position with specificity, distinguishing the reasoning that court applied. I oppose rescission of the 2001 Roadless Area Conservation Rule. The places I photograph and the birds I seek there depend on protections the agency's own record shows are justified. The agency should preserve the rule. Sincerely, Maureen Grabowski Oakland, CA 94602

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing both sides of the Sierra taught me this lesson: the most degraded places are around roads. I fished the up the South Fork Kern River. But cattle grazing and off-road vehicle activity ruined it. I sought more remote. What I found was more roads means greater abuse, more trash, and more environmental degradation. I have hiked and camped from the Appalachian Mountains to Hawaii, from our nation's southern border to its northern one with Canada to enjoy creation's magnificence, to witness nature's unfolding, for the open space free from congestion, noise, and pollution of human built environments. It sustains me, elevates me, rendering strength and hope for the world. In the Sequoia National Forest the inventoried roadless areas I care about include Woolstaff, Channell, Greenhorn Creek, Mill Creek, Woodpecker, South Sierra, Scodies, and Domelands. On the Inyo National Forest, I name Black Canyon, Coyote Southeast, Soldier Canyon, and Coyote North. Another road into any of them means more traffic, more noise, more dust, more trash, less intact habitat, less wildlife, and greater wildfire risk. I am a passionate wildflower lover and a devoted watcher of birds in their home environments. I have grave concerns for their continued existence, and am witnessing a diminution of species. The agency's own record speaks directly to what roads do to bird communities: the DEIS cites findings that bird richness declines around roads in forested habitat, and that road-noise in a roadless area cut bird abundance over 25%, with 31% of species avoiding noise entirely. The agency must explain specific mitigations it proposes for bird communities in the named roadless areas of the Sequoia and Inyo National Forests, and how such mitigations conforms with its own cited research. The wildfire argument for rescission collapses against the agency's own data. Wildfires are a constant presence in my life. Three fires occurred near my home, this year. I have seen the aftermath, and have great respect for the responders. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency must explain why the proposal departs from its own findings on fire occurrence, and reconcile the rescission with its own ignition data. The economic case for rescission is hollow. The Forest Service record concedes that "the total timber volume affected by this rule is less than 0.5 percent of total US production, and the total oil and gas production from all NF lands is about 0.4 percent of the current national production." The FS cannot adequately maintain its current road inventory. Opening roadless areas to new construction exacerbates that terrible situation, especially given the funding shortfalls happening right now. I find it counterintuitive in the extreme. The agency must reconcile the proposal with its own cost-benefit analysis and explain how an action that cannot establish a clear net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The agency argues that state-specific approaches can replace a national rule. That approach was rejected by the courts. The agency should explain how this proposal avoids the same fate. It should also address the Tenth Circuit's holding that reversed a permanent injunction against the 2001 rule, finding: "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's claim that the 2001 rule exceeded its statutory authority must be squared with that holding, and the basis for any contrary position stated plainly. From 31.5 years as an employee of a large municipal drinking water utility, I learned firsthand the necessity of protecting watersheds from degradation, whether from mining, logging, road construction, invasive species, or off-road vehicle recreation. Threatening watersheds is counter to the Preamble to the Constitution of the United States; "...promote the general welfare, and secure the blessings of liberty to ourselves and our POSTERITY." The proposed rescission undercuts these constitutionally mandated purposes. The agency must address this conflict directly. We must protect all remaining intact habitat, thwart its fragmentation, fend off activities that would degrade its integrity, and leave for our progeny the gloriously alive and rich biological legacy earth provides us. This is why I oppose rescission of the 2001 Roadless Area Conservation Rule. Sincerely, David R McMullen 217 Terrace Dr Big Pine, CA 93513

See attached file(s) To: U.S. Forest Service Re: Public Comment on Special Areas; Roadless Area Conservation (Docket No. FS-2025-0001) I am writing to express my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. As an avid outdoor recreationist, I urge the U.S. Forest Service to maintain these critical protections for our nation's remaining wild places, which are irreplaceable hubs for outdoor recreation and essential wildlife habitat. On a personal level, undeveloped public lands are central to my life. I spend much of my free time hiking, backpacking, fishing, and backcountry skiing. While I travel across America seeking out the solitude and adventure that only intact wilderness areas can provide, my deepest connection is to the Eastern Sierra and the Inyo National Forest. In fact, my wife and I chose to get married on Inyo National Forest land. The fondest memories I share with my wife, my family, and my friends have been forged in the backcountry. Repealing the Roadless Rule would jeopardize the very values that make these lands so meaningful to my family and millions of other Americans: •Preserving Recreation and Solitude: Substantive backcountry recreation relies on vast, quiet landscapes. Introducing roads, logging, and industrial development into inventoried roadless areas would permanently destroy the backcountry skiing zones, pristine fishing streams, and quiet trails that drive the outdoor recreation economy and provide vital spaces for human renewal. •Protecting Crucial Wildlife Habitat: Roadless areas act as biological strongholds. They provide critical migration corridors and undisturbed habitat for fish and wildlife. Constructing roads fragments these ecosystems, degrades water quality for fisheries, and intensifies pressure on vulnerable species. Inventoried roadless areas represent a well-balanced, time-tested policy that protects our natural heritage while allowing for traditional backcountry access. Protecting these lands ensures that future generations can experience the same unbroken landscapes and wild adventures that have shaped my life. Thank you for considering my comments. I strongly urge the Forest Service to withdraw this proposal and keep the 2001 Roadless Rule fully intact. Sincerely, Ryan Long Oceanside, CA 92058