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I am attaching my comments and those of two local high school students who attend Craig County High School. The comments were addressed to Beth Christensen District Ranger, George Washington Jefferson National Forest, Eastern Divide District. I was told to submit the comments to the Forest Service through this website/

I have had the privilege of living very near to several IRA's in the last 6 years. I fundamentally oppose the recission of the roadless rule, and I believe it is not based in logic, science, or the law. The roadless rule should not be repealed and should remain as it has been. I went to college in Southwest Virginia and spent as many weekends as I could hiking, camping, and stargazing at Brush Mountain IRA and Brush Mountain East IRA in the Jefferson National Forest. During deer hunting season I volunteered with the Virginia Department of Wildlife Resources to test deer harvested for chronic wasting disease. A few Saturdays during the season we tested deer from various parking lots throughout Montgomery county. Many of those hunters hunted in the National Forest, and many on Brush Mountain. Kids harvested their first does in this IRA and families bonded hiking to tree stands in the Forest they had been hunting for decades. Brush Mountain and Brush Mountain East is a sacred place to everyone who has spent any time in Craig, Roanoke, and Montgomery county. Whether just passing through on a hike, spending four years of weekends there while in college nearby, or living there for generations, the IRA designation of Brush Mountain protects it as a sacred place. In 2021 I had the opportunity to camp host at a camground at the base of Mount Timpanogos. Growing up in the dense green forests of Appalachia, the wide-open Utah landscape kept me in awe every day. I spent every spare moment exploring the area, spending extra time hiking in the Unita IRAs and Wasatch-Cache Utah IRA. I spent a lot of time off-roading in rock crawlers, hauling my camper around to dispersed camp sites, and mountain biking all over Utah, but the time I spent hiking in the IRA is by far the most memorable. The Forest Service is already incapable of maintaining the roads that it has already built. Opening up acreage to build more roads when the ones that exist are not well maintained is illogical. As a lover of motorized recreation, never once have I thought, I wish there were more roads in the national forest. As a hiker and lover of intact wilderness for their ecological and environmental benefits, I am grateful every day for IRAs and the value they provide to big and small game species, the ecosystem overall, and for the peace and tranquility they offer to everyone who visits. The science shows that intact wilderness, like IRAs, are better for the ecosystem, for more productive environmental services, like water filtration and carbon sequestration, and in more cases than not, more resistant to fire when properly managed under the already existing rules and regulations under the roadless rule. It goes against all valid science to say that repealing the roadless rule will have any scientific, environmental, or ecological benefit. Finally, but maybe most importantly, the proposed recission of the roadless rule is illegal. The draft EIS is deficient in every way, arbitrary and capricious, and lacks any valid alternatives analysis. I am finishing my final semester of law school and have spent the last two years reading nearly every past and present NEPA, NFMA, and APA case. I have been a part of a team that has filed two lawsuits to stop the USFS from continuing on with two logging projects in the White Mountain National Forest. In my time working on these suits I have read some well-done Environmental Assessments and Environmental Impact Statements. I know what a well-done, comprehensive, and legally sound NEPA process looks like, and this roadless rule recission process is the furthest thing from well-done, comprehensive, or legally sound.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Vernal pools hold time still. Kneeling at the edge of one to record frog eggs and salamander larvae, watching the water catch light through an unbroken canopy, I understand exactly what is at stake in this proposal. I am a volunteer wildlife monitor for vernal pools, those ephemeral bodies of water that are home to the eggs and larvae of frogs and salamanders. Several pools I monitor are in the Jefferson National Forest. These pools, and the animals that use them, depend on a healthy forest ecosystem, which means an intact forest. I also use the Jefferson and George Washington National Forest to hike, camp, photograph the natural world, and soak in the wonder of these special places. I go roaming in the forest with my grandchildren and introduce them to what I can only call magical ground. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that the agency take my concerns seriously and answer them in the record. The agency justifies this rescission in part on wildfire and fuels management grounds, but its own prior findings cut directly against that rationale. The rule's 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 vernal pools I monitor in the Jefferson depend on a stable forest structure that repeated ignitions would degrade, and the salamanders and frogs that breed in those pools have no refuge if the surrounding forest burns at uncharacteristic intensity. The agency must explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and it must reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic justification for this rescission is equally difficult to square with the agency's own analysis. The record before the agency states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." 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 -$92 million to +$199 million, and the road system the agency proposes to expand already carries a $6.9 billion maintenance backlog. The forests where I monitor pools and hike with my grandchildren generate real, lasting value for people precisely because they remain intact. The agency must explain on the record how an action whose own economic analysis cannot establish a net benefit justifies expanding a road network the agency cannot currently afford to maintain. The agency also argues that state-specific approaches can substitute for the national rule, but this ground has already been tested. The record reflects that the USDA previously "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That state-by-state approach was challenged and rejected in court. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and must explain how this proposal avoids the deficiencies identified the last time it substituted a patchwork of state rules for uniform national protection. Finally, the agency's suggestion that the 2001 rule exceeded its statutory authority is contradicted by judicial review of precisely that question. The court 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 upheld the rule as within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the public a plain statement of the legal basis for any position contrary to that holding before it proceeds further with this rescission. Sincerely, Alison Nichols Roanoke, Virginia

I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I write as a citizen, landowner, outdoor enthusiast, and wildlife specialist. I have spent a career advocating for wildlife conservation and have continued my advocacy into my retirement. I retired adjacent to the Washington Jefferson National Forest because I love the concept of our national forests as mixed use resources shared by all. We are neighbors with a campground that specializes in mountain bike races and that helps maintain trails in the forest, a recording studio that draws clients to the serenity of the forest to develop and express art, several air B&Bs that derive income from their proximity to the forest, a number of country markets that benefit from tourism driven by the campgrounds and lakes in the forest, in short a thriving local economy driven by the forest as it is. Further, roads in the US Forest system comprise eight times more miles than the entire US highway system. It is hard to believe that additional roads in the forest system are necessary, and opening up our forests for further extractive industries risks local economies. Finally, the roadless rule has preserved contiguous habitat for untold native wildlife species, particularly for rare, threatened, and endangered plants and animals. In my region alone, there are 14 threatened and endangered species of plants and animals, and even more when state listed species are accounted for. Opening these precious habitats to roadbuilding and logging destroys the integrity of the forest, which is something we can never get back. A few unfortunately familiar phrases come to mind: Extinction is forever, and from the national musical icon Joni Mitchell, "Don't it always seem to go that you don't know what you've got till it's gone? They paved paradise, put up a parking lot." Please leave paradise alone.

I support Alternative 1: Keep the Roadless Rule fully intact. I am an avid hiker, camper, and mountain biker in the George Washington and Jefferson National Forest in Virginia and West Virginia. This National Forest, my home National Forest, is part of the 45 million acres that will lose protections if the Roadless Rule is rescinded as described in Alternatives 2 and 3 of the Draft Environmental Impact Statement (DEIS). I seek out public lands like Pisgah National Forest as a destination for the solitude and high quality recreational opportunities. As an Environmental Scientist, I understand the urgent need to protect water resources like headwater streams, watersheds, and ecologically sensitive areas. These areas must remain protected and roadless to protect species like the Eastern Hellbender. We owe it to future generations to keep the Roadless Rule fully intact. For the reasons outlined above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the DEIS risks irreversible damage to water resources and ecologically sensitive areas that provide habitat for at-risk species like the Eastern Hellbender. We owe it to future generations to keep the Roadless Rule fully intact. I support Alternative 1 to Keep the Roadless Rule unchanged.

My name is Kerry O'Connor and I oppose the proposal to fully and partially rescind the Roadless Area Conservation Rule. I was born and raised and currently live in Virginia. The George Washington and Jefferson National Forest have been in my life since I was a kid. I have also benefited from traveling this great country for four years, visiting national parks and national forests. I've seen first hand and participated in the economic benefits of recreation and tourism near roadless areas. Rescinding the roadless rule will harm local jobs and economies - tourism brings in more money to these communities than timber. And our families have lifetimes of memories based in these lands. I am also concerned about the longer term cascading and devastating impacts to the environment and to human health. Roadless areas rich in biodiversity help recharge water. The City of Harrisonburg - where I went to college - gets its water from a reservoir recharged by the headwaters in a roadless area. Approximately 2 million people in Virginia get drinking water from the flow from roadless areas. More roads for timber harvesting increases soil erosion and compaction, which leads to an increasing negative feedback loop in which water quality is reduced due to sediment run-off, future seedling growth is reduced due to compaction, and the amount of rainfall that held on the land to recharge rather than run-off is reduced without a health stand of trees and vegetation. Virginia has experienced a serious drought this year. We cannot afford to play fast and loose with our natural water cycle. Allowing new roads in these areas does not make budgetary sense. It degrades community economies. The Forest Service does not currently have the budget to maintain existing road infrastructure. And the impact of these roads hurts downstream communities - possibly for generation. The roadless rule is good policy that helps maintain these forest for many generations into the future. We must keep this rule in place.

I'm writing to comment in opposition to the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). I'm based in Juneau, Alaska, and regularly recreate within roadless areas here in the Tongass National Forest. In Alaska,, I most often recreate in the following roadless areas: Taku-Snettisham, Juneau-Skagway Icefield, Juneau Urban, and Douglas Island. Additionally, I have recreated on roadless areas in several states including but not limited to: Allegheny National Forest, PA, Monoghaela National Forest in West Virginia, White Mountian National Forest in New Hampshire, Jefferson National Forest in Virginia, Ocala National Forest in Florida, Chattahooche National Forest in South Carolina, Pisgah National Forest in North Carolina, Olympic National Forst and Gifford Pinchot National Forest in Washington. When recreating, I often seek out roadless areas and feel that protections for these areas are critical to ensuring future generations can enjoy these lands as I have. I believe the rule is well written, and the language allows for a variety of exemptions (timber harvest, wildfire fighting, roadbuilding, resource access, thinning, etc.). Most importantly, local Forest Service officials already have the authority to review and approve these exemptions. Roadless areas provide critical habitat for wildlife and serve as an important natural protection, helping ensure communities across the country have clean drinking water. Here in Alaska, I’m most concerned with the potential impacts that new subsidized road development for the timber industry would have on salmon habitat. Local economic engines have been designed around roadless areas. Just this summer, I paid a rafting company to raft through a roadless area, and a climbing guide to access a local crag via roadless-area trails. Here in Alaska, over 2 million cruise ship passengers will sail through the inside passage, marveling at our intact forest. Repealing the rule could put this billion-dollar industry at risk. The rule was originally designed to save taxpayers' money and allow the USFS to prioritize the maintenance backlog. Rolling back the rule could result in spending US Taxpayer dollars on road subsidies and a return to a time when the US government subsidized the Timber Industry. I find the "Purpose and Need for Action" for FS-2025-0001-223869 frivolous. I'd like to encourage the USDA to move away from a top-down, DC-driven approach. Roadless Rule protections have been in place for more than two decades; they are working, and the rule is serving the American public well. Again, I oppose the USDA's proposal to rescind the 2001 Roadless Area Conservation Rule. I'll continue to raise my voice so my nieces and nephews have the same opportunities I've had to bike, hike, ski, raft in roadless areas. Thanks for your time and consideratio

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. We live within walking distance to the George Washington and Jefferson National Forest and have thoroughly enjoyed the wildlife and fresh air it has to offer. Our family takes walks though the luscious trees without worry of traffic imposing our path and fresh air. I believe rescinding the roadless area conservation rule will negatively impact our quality of wildlife, water, walking paths, and sounds of nature that we experience every time we step into the forest. Please take a moment and consider the impact rescinding could have on our wildlife and conservation of the protected nature resource that we have. Thank you

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Camping and hiking in the Jefferson National Forest has been part of much of my life. I go there for recreation and for my health- health of body and mind. I ride my bike and hike around Pandapas Pond in the Brush Mountain area, and I hike on the AT. These and other roadless areas offer a place to I can feel peaceful in a hectic world. This peace and this land I will do my part to protect. As the US government, you need to do your part. The agency frames this rescission partly around wildfire and fuels management, but its own record cuts the other way. I have long worried that more access roads could lead to more human-caused wildfires, fires we do not have the resources to fight. The agency's own language confirms that worry: "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 has concluded that rescission is nonetheless justified on wildfire grounds, I ask that it explain, plainly and on the record, why this proposal departs from those prior findings, and that it reconcile the rescission with the ignition data its own draft environmental impact statement reports. That data sharpens the concern. The DEIS itself states: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The gap between those two numbers, 22.4 against 3.0, is not a minor variance. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh that increase honestly against whatever claimed reduction in wildfire hazard it is relying on, rather than treating the two as if they point in the same direction. Clean water depends on the same land. More roads open the door to timber sales and other resource extraction, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The watersheds that feed the Jefferson, and the communities downstream that rely on them, are not abstractions. Trees filter water and reduce runoff. When road-building disturbs those watersheds, the cost falls on real people, not on the corporations that benefit from access. The agency should tell the public how it weighs those costs. The regulatory flexibility analysis does not do that work. The proposal certifies no significant impact on small entities while the agency's own record states: "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." Spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas, does not constitute an assessment. The agency must withdraw that certification and analyze the impact on the businesses actually operating where the rule would take effect. Finally, the agency invited this comment. Its own notice 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 have organized my recreation, my health, and my sense of what public land is for around the protections the 2001 rule provides. That is a reliance interest. The agency is obligated, under the legal standards that govern rule changes, to identify and weigh the interests described in the comments it receives, including this one. I ask that it do so. Please put the health, safety, and wellbeing of American citizens before profits and corporate interests. Please put Americans first. Sincerely, Marissa Phillips Roanoke, Virginia

Hello, I'm very strongly opposed to the repeal of the roadless rule because it will allow an easy pathway for extractive industry to permanently degrade the wilderness characteristic of our beautiful public lands. There's nothing I look forward to in this life more than getting far removed from the confines of civilization and completely separating myself from the artificial, human-constructed world. I'm not a spiritual person, but these places feel sacred to me, and the addition of human infrastructure to these wiped and untarnished places is an affront to the sanctity of these wild places. I'd happily pay significantly more for my goods and services and contribute more to taxes if it meant we could reserve more totally wild, untarnished land. I've spent many weekends and vacations exploring wilderness areas local to me and afar, including the Dolly Sods wilderness, Roaring Plains Wilderness, Monongahela National Forest, George Washington and Jefferson National Forest, the Great Dismal Swamp, and many other places both local and far away that are worth more than money to me. Hiking trails are are as much development as is appropriate for these places. It was extremely disheartening to witness the clear-cutting of forest off of Squirrel Gap Road near Wardensville West Virginia, that I can't help but respect was facilitated by the road that runs through the area. I can't help but lose hope for the future every time we move toward the removal of these wild places for some quick flash-in-the-pan monetary benefit. I'm an east-coaster from Maryland that spends a lot of time daydreaming of my trips out to the great, untamed American west, and I would very passionately support efforts to maintain minimally impacted wildlands with intact old growth forest and minerals beneath unspoiled ground. I will campaign vigorously against any politicians in my jurisdiction that is in favor of the repeal of the roadless rule. I will contribute financially to the campaigns of politicians that oppose this rule, no matter what party they come from. This is my single issue of concern.

I am writing express my support for the Roadless Rule and urge the U.S. Forest Service not to repeal it. The Forest Service is responsible for managing our nation's forests to sustain their health, ecological diversity, and productivity, which includes the protection of old-growth and mature forests. Special places near my home in North Carolina, like the Jefferson National Forest, should be protected fortheir ecological value for birds, their extensive carbon stores, and their subsistence, heritage, and recreational value for current and future generations. Having visited areas of the Jefferson National Forest, I recall firsthand the natural beauty, including unique wildlife sightings that future generations might never experience if this crucial habitat is lost. Roadless areas represent some of the most intact public lands and wildlife habitats left in the country, home to more than 77 bird species of conservation concern and other potential sensitive species. These lands contribute to local and rural economies through recreation, birdwatching, hunting, and fishing, while also ensuring that downstream communities have safe drinking water. Ecological forest management to mitigate fire risk, ensure community safety, and improve habitat is important. The Forest Service should focus on how roadless areas are managed and maintained to improve habitats and reduce fire risk, rather than narrowly focusing on road-building and large-scale timber harvests in remote and ecologically sensitive areas. This development would only seem to profit private interests rather than the American public at large. The intact forests of the National Forest System are essential for healthy wildlife populations, and these public lands are part of what makes our country great. The Forest Service should not repeal the long-standing protections for forests in the Roadless Rule.

Roadless Rule Public Comment BCHVH The Back Country Horsemen of the Virginia Highlands are opposed to rescinding the Roadless Rule and are in agreement of Alternative #1. The Back Country Horsemen of the Virginia Highlands is a chapter of the Back Country Horsemen of America, a volunteer organization maintaining trails on America’s public lands. We contribute over 1000 volunteer hours a year maintaining the trails in the Mount Rogers National Recreation Area, a part of the George Washington and Jefferson National Forest in southwest Virginia. The Back Country Horsemen represent the historical tradition of pack and saddle stock use on public land. Protection of roadless areas is fundamental to preserving this heritage for the future. The back country, trails, and the outdoor experience are very important to us as horseback riders and stewards of the land and we believe these lands should be protected from additional road construction and the subsequent extraction industries that will have a profound impact on these forests. Unlike the West’s vast landscapes, the forests of the East are much smaller and scattered about and roadless areas insure that these places remain available for quiet back country recreation and solitude. Many roadless areas contain the headwaters of streams and rivers that provide clean water for fish, wildlife, communities, and downstream users and provide intact habitat that wildlife needs to survive and thrive. Roads fragment wildlife habitat. They alter drainage patterns, increase disturbance and can open the door to further development. They require construction, maintenance and eventually taxpayer dollars to keep them open. The USFS current road maintenance backlog on its 380,000 miles of existing roads is in excess of 10 billion dollars. Does it make sense to build more roads? We feel strongly that it is important to preserve these roadless areas for future generations so our children and grand children can enjoy and experience the same opportunities and landscapes that we value today. Roadless areas are among the last places in the country where people can experience undeveloped landscapes and a sense of solitude, once they disappear, they are lost. Protect the Roadless Rule. Protect the backcountry. Protect the trails and landscapes that make our mission possible.

I am writing in opposition to rescinding the Roadless Rule and agree with Alternative #1 to take no action. I am a horseback rider, hiker and a trail volunteer in the Mount Rogers National Recreation Area, a part of the George Washington and Jefferson National Forest and being able to escape to the forest is very important to me. Roadless Areas ensure that, especially on the east coast, where vast landscapes are nonexistent, back country lands are reserved for the enjoyment of future generations as well as populations of the present. In addition to recreation, roadless areas protect water quality downstream and provide wildlife habitat. Roads fragment wildlife habitat. They alter drainage patterns, increase disturbance and can open the door to further development. They require construction, maintenance and eventually taxpayer dollars to keep them open. The USFS current road maintenance backlog on its 380,000 miles of existing roads is in excess of 10 billion dollars. Does it make sense to build more roads? Roadless areas are among the last places in the country where people can experience undeveloped landscapes and a sense of solitude, once they disappear, they are lost. I feel strongly that it is important to preserve these roadless areas for future generations so our children and grand children can enjoy and experience the same opportunities and landscapes that we value today.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The diversity of plants and wildlife in the Jefferson National Forest is astounding. The sounds of nature, without all the human activity, are a gift I hope my children and grandchildren will be able to cherish forever. That hope is precisely why I oppose the rescission of the 2001 Roadless Area Conservation Rule, and why I expect the agency to answer the specific concerns below on its record. Public land should be managed with gratitude and reverence for the forests that sustain us. That means listening and observing before acting, then developing plans for producing and harvesting food, medicine and timber that do not trade lasting ecosystem health for the demands of rampant consumption. The agency's own data on fire risk alone should give this proposal pause. 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." I ask that the agency explain why this proposal departs from that finding, 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. We must protect our rivers and streams. There is nothing more foolish than contaminating the life-sustaining waters of our forested lands. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I want my tax money to support and protect the natural ecosystem of which we are a part, not degrade it. That extends to the fiscal question as well. The record shows: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain 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. We can do better than the constant extraction and exploitation, and small businesses operating in these forests deserve an honest accounting of what rescission will cost them. The regulatory flexibility analysis reaches its no-impact conclusion by spreading costs across every small firm in the sector nationally rather than examining the outfitters, guides and tour operators who actually hold permits in the affected areas. 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 agency should withdraw that certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. We are speaking for those who do not yet have a voice, for my children, for theirs unborn. Let there be wild places for them to experience. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting these last unroaded lands. It has held none to undo it. 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. This comment is precisely such an interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. This forest is our home. We do not see it merely as a store of resources to manage. We seek to integrate with the forest, to learn from it how to live more in balance with the natural world and how to thrive together, as one composite-organism. I urge the agency to withdraw this proposal. Sincerely, Andrew Fry Montgomery County, VA

I live close to Washington and Jefferson National forest and my family visits often. Losing part of our spectacular wild areas would be a tragedy.

I oppose rescinding the Roadless Rule. Existing roadless areas provide multiple benefits to the public, including fire safety, environmental and economic benefits. Cutting roads into roadless areas will not decrease wildfires. A recent study found that 80 percent of human-caused fires happen within a half mile of a road. Roadless areas thus reduce fire risk rather than increasing it. Roadless areas protect water quality. Logging roads, open stream fords and denuded forests all increase soil erosion and stream sedimentation. Forestry best management practices call for stabilization for old logging roads and stream crossings or “putting them to sleep.” Let them sleep. Roadless areas are often adjacent to designated wilderness areas. They provide a buffer zone between the wilderness and human development. They also provide a travel corridor for wildlife between pockets of forest habitat. Roadless areas benefit the economy. Less than 5 percent of the U.S. is roadless or wilderness. Meanwhile, the recreation economy — which often relies on roadless areas and public lands — represents a whopping $1.3 trillion in economic output, almost 2.4 percent of the entire U.S. GDP. And hunting generates $33.5 billion in wages and income, with a total economic output of over $107 billion. That is greater than the GDP of 121 countries. The market for wood pulp has crashed. Timber owners have a poor market for pulp wood produced during thinning cuts. Paper companies are selling off timber land. There is no need for opening additional acreage to logging. The U S Forest Service should invest in research and development of new markets for pulp wood, not new roads. The U.S. Forest Service has 371,000 miles of roads already — roughly eight times more than the entire U.S. interstate highway system. And the maintenance backlog for these forest roads is $6.1 billion. I am a trail volunteer in George Washington Jefferson National Forest. I travel the existing forest roads to access trails in need of maintenance. Limited forest service staff cannot keep up the roads they have. Rescinding the Roadless Rule can only hurt backcountry recreation and the environment with limited economic benefit to the few logging companies geared toward cutting old growth forests. It does not serve the interests of the American people.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The quiet I go looking for in Jefferson National Forest, in the Sawtooth Mountains in Idaho, and in national forests and BLM land across Arizona, Utah, Washington, and Oregon is already hard to find. It is harder every decade. I have hiked and camped in these places since childhood, going there for quiet, to escape light pollution, and to see and hear the wildlife. I have sat by a river in the Sawtooth Mountains and watched a bald eagle sweep out of the sky and take a fish from the water. That is not a small thing. Rescinding the Roadless Area Conservation Rule puts that kind of experience, and the places that make it possible, at permanent risk. Brush Mountain in Jefferson National Forest is supposed to be protected from the ills that have already devastated much of Appalachia: mountaintop removal, deforestation, displacement of wildlife, contamination of the water table. It is supposed to be a place for nature to recover and thrive. Angeles National Forest is not only essential for wildlife like the mountain lion that need uninterrupted space to roam and hunt, but for the residents of the Los Angeles metropolitan area who need relief from constant noise, light, and traffic. A road into either place means more noise, more pollution, a total corruption of the environment for people, animals, plants, and water. The agency owes the public a direct explanation of how opening these 6,002 and 7,245 acres, respectively, to road-building serves a purpose commensurate with what would be destroyed. The agency's own record addresses bird abundance in roadless areas, and the findings are unambiguous. The DEIS cites the 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. The bald eagles, the countless other birds I go to these places to find: the science on what roads do to them is already in the record. The agency must explain why it is proceeding anyway. The wildfire justification offered for this rescission is contradicted by the agency's own findings. 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." I lived through multiple fire seasons in California. I saw Angeles National Forest burn. I was affected by smoke and road closures, and was evacuated from work sites because of forest fires. Friends lost access to their homes. The agency must reconcile this proposal with the ignition data in its own DEIS, which shows far higher fire density on roaded land. As a taxpayer, I object to what this proposal represents financially. The road maintenance backlog already stands at $6.9 billion. The agency's own economic 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 ranging from -$92 million to +$199 million. The record also 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." The agency must explain how a cost-benefit analysis that cannot establish a net benefit justifies expanding a road system already in this condition. Drinking water is already a serious problem across this country, from Flint, Michigan to Appalachia. With 24 million Americans' drinking water coming from roadless areas, and with the agency's own analysis showing that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, the risk to those watersheds is not speculative. Across the Southwestern region alone, 739 municipal water intakes sit in watersheds containing affected roadless areas. The agency should state plainly what its plan is to protect those intakes. The forests themselves are the resource. A home for plants and wildlife, and a place for humans to rest and recharge. Not something to extract for commodities. We have so few of these spaces left. The Native Americans believe we must consider the impact our decisions will have on the next seven generations, and this rescission would rob future Americans of places that are, as the agency's own record implies, invaluable and irreplaceable. I urge the agency to withdraw this proposal. Sincerely, Rose Shawhan Blacksburg, VA

I strongly support the roadless area rule. I have been recreating in the GW/Jefferson National Forest in Virginia my entire life. I currently live in the Shenandoah Valley and frequent the trails on Shenandoah Mountain which includes the largest roadless area east of the Mississippi! I LOVE Shenandoah Mountain - it is one of the major attractions for outdoor recreation enthusiasts in this area. The trails are unmatched for hiking and biking, and the Roadless Rule is a big part of what has kept the area pristine for the last few decades. My 2 boys grew up wandering around the ridges and creeks of the GW, and I hope the Roadless Rule is sustained so that their children can enjoy the same wild and beautiful spots. Further, I love the idea of the Shenandoah Mountain National Scenic Area and my hope is that it will be enacted soon.

My family paddles the New, Little, and James Rivers, watches birds and butterflies along the banks, photographs the water and the light, and goes out under open sky to watch meteor showers and the full moon rise over unpaved country. The Jefferson National Forest feeds the New River Valley of Southwest Virginia, and the clean, uncontaminated water that flows from it is not an abstraction to us. We have taken our children, now grown, from Buffalo Mountain to Raptor Ridge to see views of our area that show the world as it might have been before us. What I am opposing is the Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule, which would strip national-level protections from inventoried roadless areas across National Forest System lands and hand those decisions back down to individual forests with no baseline guarantee against road construction or timber harvest. The agency's own document states, at the Scope of the Analysis section, that "An irreversible or irretrievable commitment of resources will not be made by the rulemaking because none of the rulemaking alternatives propose specific actions." That claim cannot stand next to what the same document discloses in its biodiversity, vegetation, and roads chapters: that the proposed rescission is likely to adversely affect 327 ESA-listed species and 71 critical habitats, and that permanent road construction and old-growth removal are reasonably foreseeable consequences. Two statements in the same document cannot describe the same set of probable outcomes and one of them call those outcomes non-irreversible. The agency must revise the Scope of the Analysis section to honestly account for the irreversible and irretrievable commitments its own effects analysis predicts, and must explain, specifically and plainly, how those two positions coexist. On the timber side, the document discloses at Implications for Forest Vegetation, Health, and Carbon that in the operable areas most likely to be logged under the proposed action, "approximately 11-16 percent is old-growth forest, 54-63 percent is mature forest, and 26-31 percent is young forest." Old and mature stands together make up the overwhelming majority of the timberland this rescission would open. The draft EIS identifies no old-growth-specific safeguards beyond general land management plan compliance, which varies by forest and provides no uniform floor of protection. I photograph birds, the sky, and the water, and I know that the habitats holding those things together are disproportionately concentrated in exactly this kind of mature, unroaded forest. The agency must separately analyze what protections would apply specifically to old-growth stands before any harvest could proceed in this largely mature and old-growth land base. The agency's stated rationale also needs to be reconciled with its own findings. At Rationale for the Proposed Rule, the document asserts that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Yet elsewhere the same document cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The forest health rationale for rescission rests on a claim the agency's own evidence undercuts. The agency must reconcile these findings before using forest health as justification. Clean water is essential to all of us, and the water of the Jefferson National Forest serves the New River Valley. Roads bring sedimentation; sedimentation degrades the rivers I paddle and the water my community drinks. My tax money should preserve these places, not pave them over for the benefit of those who, as I see it, have never spent time in the quiet beauty of undeveloped land. Responsible stewardship, as Teddy Roosevelt envisioned it, means protecting these places with pride. The reckless cost of this rescission is not only financial. It is permanent.

To the USDA and Forest Service, I am writing as a concerned citizen, a resident of a community east and downstream of the Washington & Jefferson National Forest, a former resident of Mount Hood National Forest, and as a parent who loves hiking, camping, and creating memories in the wild areas of National Forests across the U.S. with my children. I urge you to maintain the Roadless Rule. Rescinding it is not only environmentally damaging but also fiscally irresponsible. My opposition is rooted in personal experience with the devastating economic and human costs of road-facilitated disasters, infrastructure neglect, and the loss of the wild spaces that define our quality of life. 1. The Economic Impact of Human-Caused Fires I have personally witnessed the scars of human-caused wildfires in National Forests. In 2015, I drove through Yellowstone and saw the lingering damage from the 1988 North Fork Fire that started near a road inside the adjacent Targhee National Forest and destroyed over 400,000 acres. Even 25 years later, the area was a monoculture of lodgepole pines rather than a resilient ecosystem. The logger that started the fire by tossing a lit cigarette, only had access because logging roads allowed him into vulnerable, drought-stricken stands. Without those roads, that ignition would have been impossible. Roads invite human presence into deep wilderness, exponentially increasing ignition risk. The problem is only getting worse, and the economic toll is staggering: - The 2020 Creek Fire (Sequoia NF, CA): Sparked by an overheating vehicle catalytic converter on a roadside, this fire burned 380,000 acres and cost $193 million to suppress, destroying 63 homes. - The 2026 Oregon Wildfire Season: Record-breaking suppression costs reached an all-time high of $1.4 billion statewide. Localized blazes near Mount Hood, such as the 94,000-acre Grasshopper Fire, destroyed 8 homes and 25 minor structures, heavily disrupting the regional recreation economy. 2. Personal Impact on Mount Hood Communities I owned a cabin on Mount Hood and personally felt the fear communities experience when forest fires threaten their homes. I saw our local businesses suffer as tourists stayed away. But it’s not just fires that drive tourists away; it’s also the polluted rivers caused by road runoff and the fragmented, clear-cut landscapes that replace our wild forests. These factors directly harm the recreational tourism that drives the local economy and supports rural livelihoods. The Mount Hood NF and the broader Columbia River Gorge region alone normally generates $500–$600 million annually. 3. Water Security and Fiscal Responsibility I have seen rivers that once ran clear turn brown from road runoff. Failed roads & poor drainage are leading sources of sediment and pollution in National Forest waterways. This sedimentation chokes fish spawning beds, threatens food security for communities relying on fish, and destroys the recreational fishing tourism that drives local economies. Furthermore, roadless areas protect 354 municipal watersheds across the US, supplying drinking water to millions and saving communities millions in filtration costs. The community where I lived in the Mount Hood National Forest relies on a community well for drinking water. Rescinding the rule weakens these protections, directly threatening the quality and affordability of my water. As a resident downstream of the Washington & Jefferson National Forest, I also understand how vital intact forest landscapes are for maintaining water quality & flood control for downstream communities. 4. The Forest Service Road Maintenance Backlog There is already an estimated $19.3 billion backlog for the existing 220,000+ National Forest roads. The Forest Service is chronically underfunded & forced to prioritize fire suppression over infrastructure maintenance. Maintaining existing roads costs approximately $3.8 billion annually. I believe it is fiscally irresponsible to build new roads when existing ones are deteriorating. These crumbling roads pose safety risks to my family and the public. In my Mount Hood community, the fire department is all-volunteer. I watched our community burn & saw volunteer firefighters work 24-hour shifts to protect our homes. Poorly maintained roads impede emergency access & increase erosion, complicating recovery efforts. In conclusion, I do not believe more roads should be built when the existing system is failing. I want to ensure my children inherit a legacy of clean water & wild, unfragmented forests, not a multi-billion dollar maintenance backlog. The Roadless Rule is the only thing standing between our children & a future where “wild” is just a memory. Please do not rescind the Roadless Rule.