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I am writing to object to the repeal of the roadless rule. My first season of trail work was on a crew assigned to the Klamath National Forest. No complex tools. Not even wheel barrows. Despite the grueling work schedule, it was one of the most indescribably beautiful seasons I've ever experienced. I have since worked at multiple national parks, another forest, and a monument, but I don't expect I will ever again feel the peace I felt in the Klamath. I've been evacuated due to uncontained forest fires, multiple times. I've seen projects I spent hours on ruined. Fires are more likely to start near roads. We wouldn't even park our trucks on leaves or pine needles during fire season. Accessibility is better achieved by prioritizing projects building ADA compliant trails, offering all terrain wheelchairs. Hell, prioritize trail maintenance period. No one is using a trail they can't find because of years worth of blow downs and overgrown brush. Americans overwhelmingly support protecting public lands. Whether for hiking, camping, fishing, hunting, public lands are what make America great.

Public Comment on Proposed Rule: Special Areas; Roadless Area Conservation RIN 0596-AD66 | Federal Register Vol. 91, No. 160 | Submitted October 6, 2026 Submitted by: David J. Vance, P.G. (Georgia), Atlanta, Georgia To whom it may concern: I submit this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule and request that USDA withdraw this proposed rule in its entirety. In 2003, I served as a Forest Geologist on the Klamath National Forest in northern California. We were actively decommissioning roads and redesigning drainage structures to reduce sediment delivery to salmonid-bearing streams — driven by science and Endangered Species Act obligations. Roads, particularly poorly maintained ones, are primary vectors of aquatic habitat degradation and not mention wildfire risk. The proposed rescission moves the agency in precisely the wrong direction. My full comment with citations is attached as a PDF. My key points are below: 1. The USFS road maintenance system is in a documented fiscal crisis. The agency receives less than 20% of the annual funding needed to maintain existing roads and carries a $6.9 billion deferred road maintenance backlog. Road appropriations fell from $234M (2004) to $73M (2024). Adding new road miles under these conditions deepens an unfunded public liability. (Source: USFS CBA, August 2026) 2. Road density is a well-established driver of salmonid habitat degradation. The government's own NMFS Biological Assessment identifies sediment loading and road density as primary stressor pathways for 27 ESA-listed salmonid ESUs/DPSs in the action area, including Chinook, coho, steelhead, green sturgeon, eulachon, and Southern Resident killer whale. Rescission is structurally at odds with ESA Section 7 recovery obligations. (Source: USFS Draft BA for NMFS Species, August 2026) 3. The 2001 Roadless Rule already provides the flexibility USDA claims is needed. It includes explicit exceptions for public safety, mineral rights, road realignment, ecological restoration, and wildfire hazard reduction. Land management plans independently restrict road construction on 54.5% and timber harvest on 66.5% of potentially affected IRA acreage. The claimed flexibility gap is overstated. (Source: 36 CFR 294.12-294.13; USFS NMFS BA) A 16% workforce reduction — approximately 6,000 employees lost in 2025 — means the Forest Service lacks the scientific and engineering staff to responsibly evaluate and monitor new road construction in hydrologically sensitive IRA terrain. Expanding development authority without oversight capacity is not responsible management. (Source: Center for Western Priorities, 2026) 4. The economic case for rescission is weak. Timber revenue from IRAs is estimated at just $9.9-$22M/year, while recreation visitor spending in those same areas is estimated at $886M/year, with total consumer surplus exceeding $1.9 billion. The agency's own CBA acknowledges long-term recreation losses under rescission are likely. (Source: USFS Economic Analysis, August 2026) 5. The litigation standstill cycle — in which NEPA-complete, ESA-consulted fuel treatment decisions are enjoined for years while untreated stands accumulate fire load and eventually burn in stand-replacing crown fires — is a structural flaw in ESA Section 7 Biological Opinion requirements. BiOps are not currently required to formally quantify no-action fire risk to listed species. A Comparative Ecological Risk Analysis (CERA) requirement, implementable through rulemaking under 50 C.F.R. Part 402, would close this gap. (Source: 16 U.S.C. § 6516; 50 C.F.R. Part 402) 6. S.1462, the Fix Our Forests Act, addresses judicial review and programmatic ESA consultation and should be enacted. Its Fireshed Registry (Sec. 103) provides the quantitative fire risk data infrastructure CERA requires. S.140, the Wildfire Prevention Act, imposes mandatory treatment volume targets without litigation or ESA reform and would worsen the standstill cycle as a standalone measure. The correct sequence is enactment of S.1462 plus the CERA rulemaking first, then enactment of the S.140 objective accountability second. 7. The correct policy response is for the Secretary of Agriculture to request increased funding for the Forest Service, not deregulation that generates new infrastructure liabilities without new funding resources or new qualified staff. The Secretary and Congress should fully fund road maintenance and where necessary decommissioning, restore scientific and engineering staffing, enact S.1462, and mutually engage the resource agencies (NMFS and USFWS) to implement CERA — and the Secretary should direct USDA to withdraw this proposed rule. I urge USDA to withdraw this proposed rule and pursue the policy changes listed in my comment letter and summarized above. My full comment with citations is provided in the attached PDF document. Sincerely, David J. Vance, PG

Hello, I am submitting public comment in disapproval of the U.S. Department of Agriculture’s (USDA) proposal to rescind the 2001 Roadless Area Conservation Rule. Public opinion from Pew research polling indicates over 70% of US voters oppose repealing the roadless rule. This rule was passed in broad support in 2001 and has not been contentious piece of regulation. The roadless rule provides imminence environmental protections that do not just serve recreationists who hunt and hike into these areas but preserves the environmental resources that then stem out beyond roadless areas. They protect sources of clean water, habitat for animals and forests. Some of these areas are small but impactful like the Dark Divide of Gifford Pinchot National Forest in Washington whose watersheds support salmon runs that help bolster the broader Columbia River watershed salmon runs and has some of the healthier forests in the region. Other roadless areas such as the Tongass in Alaska are large and keep a healthy and large forest that acts as a large carbon sink to buffer the increasingly challenging climate conditions. While the environmental protections are of the top priority for me, the economics of rescinding the roadless rule does not make much sense either. The National Forest Service does not have the budget to properly maintain the forest roads and trails that exist already. This is large reason why the roadless rule was enacted to begin with as many of the roads were too burdensome to maintain. It does not make sense to rescind the rules when there is not sufficient governmental support to build and maintain roads. Logging and mining operations were also already long on the decline prior to the roadless rule’s enactment. Industry towns that prosper today do so for having built a healthy tourism and recreational industry and diversified their economy with other businesses while still operating scaled back and more sustainable logging operations. The protected watersheds that bolster salmon runs along the west coast can only be damaged by the rescinding the roadless rule which again notes another negative economical impact. In the Klamath watershed, after years of debate, we as a community in Oregon and California, determined the impact of dams along the Klamath River cost us more benefits than we received from the energy of the hydroelectric dams. The dams were recently removed, and the speed of the fish restoration has been nothing less than historic. To then begin degrading this watershed by building new roads and logging mountainsides all actions that lead to significant erosion and sediment loading of the creeks and rivers would be a tragedy to the recent work and progress within the Klamath National Forest that has been hailed as a huge victory. I implore the USDA to drop the proposal to rescind the 2001 roadless rule. The proposal will have many negative impacts to both the environment and the economy at large. The few economic benefits of increased logging will only benefit a few of the most wealthy and not the communities at whole. Sincerely, Harrison Holzgang Concerned Citizen and Industrial Environmental Manager

As a PCT'19 alumni and wildands advocate, I oppose the repeal of the Roadless Area Conservation Rule. There are 63 roadless areas along 288 miles of the PCT in California, Oregon and Washington. These miles represent roughly 11% of the trail. Roadless areas provide clean drinking water to 60 million Americans. This also provides connected wildlife corridors and undisturbed natural connected ecosytems. These undeveloped lands are critical to our nation’s ecological health.  These areas store 20% of all carbon in U.S. national forests. Roadless areas offer abundant outdoor recreation opportunities such as hiking hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. The outdoor recreation economy generates $730 billion annually, far more than timber sales. Roadless areas are crucial habitat for 1,600+ threatened species. We already have 370,000 miles of forest roads with a multi-billion dollar maintenance backlog. Studies show wildfire ignitions are 4x more likely near roads than in roadless areas Please keep these roadless areas roadless! Deep Creek IRA—San Bernardino National Forest: On the north slope of the San Bernardino Mountains about 60 miles east of Los Angeles. Starting at 6,200 feet above sea level, the stream through the IRA drops about 3,000 ft through dramatic canyons in its 22-mile course before flowing into the East Fork of the Mojave River. It includes deep pools and hot springs and is a popular spot for day hikers. South Sierra IRA—Inyo National Forest: On the PCT and near the South Fork of the Kern River. San Joaquin IRA—Inyo National Forest: Red’s Meadow is a beloved respite along the PCT and a starting point for horse packers at the Agnew Meadows Pack Station. Dardanelles IRA—Lake Tahoe Basin Management Unit: Nearly the entire PCT from Carson Pass to Echo Summit is in this roadless area. Granite Chief IRA—Lake Tahoe Basin Management Unit: Heading north from Barker Pass, the PCT, and the contiguous Tahoe Rim Trail climb to dramatic ridgelines, yielding dreamlike views of Lake Tahoe amidst red fir and hemlock forests. Further north, the trail enters Granite Chief Wilderness and intersects the Western States Trail. Areas between Granite Chief Wilderness and Donner Pass are within this IRA, jeopardizing views enjoyed by thru-hikers, day hikers, and even skiers who use Olympic Valley, Lake Tahoe’s largest ski park. Mount Eddy IRA—Shasta-Trinity National Forest: Just across the valley from Mount Shasta, Mount Eddy is the tallest peak along the Trinity Divide, and the tallest peak in CA west of I-5. This subrange of the Klamath Mountains features a unique landscape of towering granite spires, lush evergreen forests, and alpine lakes deep in glacier-carved cirques. The area is under the jurisdiction of the U.S. Forest Service and was established as a Research Natural Area (RNA) to study its ecological significance, serving as the headwaters for the North Fork Sacramento River. Grider IRA—Klamath National Forest: This is a popular area for campers and day hikers along the creek, which feeds the Klamath River. Severely burned in the 2014 Happy Camp Complex, the regrowing brush gives way to large stands of surviving trees, and the sound of rushing water is a constant along the trail. The area has already been the subject of a legal fight over logging. Norse Peak IRA—Okanogan-Wenatchee National Forest: Next to Mount Ranier National Park, Sheep Lake is a picturesque alpine lake and a welcome destination for families for swimming, backpacking and camping. The hike to the lake is a gentle, 1.8-mile climb past summer wildflowers and red huckleberry plants in the fall, with great views of the Rainier fork of the American River, Mount Rainier, and Naches Peak. Liberty Bell IRA—Okanogan-Wenatchee National Forest: Some 30 miles of the PCT from Rainy Pass to Harts Pass, including the popular day hike to Cutthroat Pass, are within this large IRA. Situated in the heart of the North Cascades, this area is home to the mighty Methow River, many alpine passes, and some of the highest elevation stretches of the PCT in Washington.

I strongly oppose rescinding the 2001 Roadless Area Conservation Ruel. As a resident of a remote community surrounded by National Forest System lands, including Shasta-Trinity National Forest, Six Rivers National Forest, and Klamath National Forest, I am deeply concerned about the severe, localized impacts such a sweeping policy change would bring to my local economy and our natural heritage. I urge the USDA and the Forest Service to maintain the 2001 Roadless Rule protections based on the following three points of impact: 1) The Severe Economic Impact on Ecotourism: My rural community depends directly on a thriving outdoor recreation and ecotourism economy. Visitors travel here precisely because these roadless areas offer pristine, unfragmented natural landscapes for hiking, wildlife viewing, and backcountry recreation. Stripping these protections to allow industrial timber harvesting and road building will permanently degrade the visual and environmental integrity of these lands, directly harming local small businesses, guiding services, hospitality, and our municipal tax base. 2) Irreversible Habitat and Wildlife Fragmentation: The preservation of intact, roadless ecosystems is vital for local wildlife conservation. Constructing new roads and introducing commercial logging operations will fragment critical migration corridors, further disrupt fragile habitats, and degrade water quality in local watersheds. Once these pristine areas are developed, the ecological damage to biodiversity cannot simply be reversed. 3) Aggravated Wildfire Risks Near Infrastructure: While the administration cites wildfire defense as a rationale for local thinning, peer-reviewed data consistently shows that roads frequently serve as a primary vector for human-caused wildfire ignitions. Introducing miles of new road infrastructure deeper into our national forests increases, rather than decreases, the long-term wildfire threat to nearby wildland-urban interface (WUI) communities like mine. National forests should be managed to protect local community stability, biological diversity, and sustainable outdoor recreation. Rescinding the 2001 rule contradicts these values and directly threatens my community's livelihood. Please withdraw this proposed rescission and uphold national roadless area protections. Thank you for considering my comments.

I am writing to urge you to not revoke protections for roadless areas. As a Californian who has had the privilege of experiencing the wonder of forests in Northern and Southern California, such as the Klamath National Forest, Los Padres National Forest, and the San Gabriel Mountains, I believe that keeping these places roadless will continue to shape the quality of life in our state. Roadless areas are some of the last places where old-growth trees still stand and where wildlife is able to live as it has for thousands of years, with its habitat intact. Once a road is built, that continuity is broken and cannot be restored. These places are irreplaceable. California's wilderness is what makes living here feel rich. Hiking through forests, breathing fresh air, and knowing that wild places still exist is inspiring and healthy. With so little undeveloped land left, protecting the health of what remains of our forests, its watersheds, and its wildlife is worth far more than destroying it. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in San Jose, California. Public lands matter to me because they allow spaces that people, me included can connect to nature. In these public lands you can see what is left of these ecosystems in action and get a better understanding of how the world around us is supposed to work. Some areas near me that will be affected are the Klamath National Forest, the Siskiyou National Forest, the Six Rivers National Forest and the El Dorado National Forest. These areas hold headwaters for major rivers that sustain wildlife, snowpact and maintain scarce wildlife habitat for threatened and endangered species. I enjoy hiking in these areas as well. In these areas, there are 21,808 miles of trails inside the affected areas, including 1,127 miles of national scenic and historic trails, and most of those miles are non-motorized. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation, and that under rescission the settings could shift toward more developed conditions. You do not have to camp inside a roadless area to be affected: the water in your drainage starts up there, and the wildlife you hope to see moves through (DEIS recreation analysis). As I am also a fisherman, an unfragmented forest or any endangered habitat for that matter is really important for rivers and their water quality. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and its own words on wide-ranging mammals like the grizzly: they “have suffered habitat loss and the extirpation or fragmentation of their populations.” (DEIS wildlife analysis; Haddad et al. 2015). Another thing is that I want the forests managed responsibly, only around 6% of the untouched old growth forest remains in the US. The purpose and need is to reduce regulatory burden and return decisionmaking to local officials, not forest health and not fire. Every conservation alternative was eliminated for failing that purpose: more acreage “would not be responsive to the deregulatory executive orders,” and one option was cut partly because analysing roadless values is “an administrative and legal burden for the agency.” The agency even monetized what roadlessness itself is worth to people who never visit: $5.3 to $11.5 million a year forgone, landing in the same range as the timber gain, which is why its own accounting cannot clear zero. And in its own words, “This proposed rescission does not mandate timber cutting or road construction”: nothing about management is promised, only the removal of the protection (DEIS purpose and need; alternatives analysis). Roads also cause fires. The agency’s own new analysis, 2014 to 2024: human-caused ignitions run 22.4 per million acres per year on roaded national forest land, against 3.0 inside the affected roadless areas. Seven and a half times. Its own conclusion: “human caused ignitions increase in abundance with proximity to roads,” and its effects analysis concedes road access could increase the number and frequency of wildfires (DEIS Table 21). Roads are also more expensive to maintain than we can afford, as this is taxpayer money. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase (DEIS economics and infrastructure analysis; USDA Cost Benefit Analysis, p. 29). Sediment and vegitation removal near or within proximity of these headwaters due to these roads in these areas harm threatened fish populations by killing eggs and raising water temperatures. The DEIS: sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale (DEIS; USFWS 2024; Patric 1976; Swift 1988). The DEIS: removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS (DEIS; Carter 2005). For the reasons stated above and many more, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would cause irreversible harm and permanently negatively effect all peoples in the US.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My daughter is only 3 years old. I am writing this comment because I want her to inherit these mountains, these rivers, and this country intact, and because the agency proposing to rescind the 2001 Roadless Area Conservation Rule has not held a single public meeting to justify doing so, after the Forest Service held more than 600 public meetings and received 1.6 million comments to write it. I live in Siskiyou County. I live here because I can drive literal minutes to recreate in beautiful wilderness zones that surround my home. The West Girard roadless area in the Shasta-Trinity National Forest covers 37,516 acres, and I have hiked the PCT through that country many times. The Siskiyou roadless area in the Klamath National Forest covers 54,039 acres of mountains and forests that host a vast amount of wildlife. That area may be underrepresented in human population, but it is an important source of life nonetheless. The Castle Crags B area matters both for its geology and wildlife and for its Native American ties. This is not abstract public land to me. This is, as I can only say it, truly my backyard. The wildfire rationale offered to justify this rescission is flatly contradicted by the agency's own findings. The Forest Service'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 agency must explain why its current proposal departs from that finding, and must reconcile the rescission with the ignition data in its own draft environmental impact statement at DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I photograph the plants, animals, and geology of this home zone because I love the richness and diversity here. Roads are not a neutral tool in that landscape. On water: my house gets its water from a well, and I also swim and paddle in the rivers and lakes of this region. It is all interconnected. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The agency's own analysis establishes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. What the proposal does not explain is how adding roads into currently unroaded watersheds that are feeding wells, rivers, and intakes serving this region serves any legitimate public interest. I ask the agency to answer that question directly in the final record. The permitting burden rationale is undercut by the rule itself. The existing rule states it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency must identify which specific burdens are not already addressed by those exceptions, including those for community wildfire protection and existing mineral leases, and must quantify those burdens with specificity rather than assertion. In an administration that claims to care about waste and fraud, the small-business certification accompanying this proposal cannot stand without scrutiny. 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 reached its no-impact conclusion by averaging losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency should withdraw that certification and assess the impact on the firms actually operating here. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is exactly the kind of reliance interest the agency invited. I chose to live in Siskiyou County, to raise my daughter here, and to build my life around access to this country as it is. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it acts. Sincerely, Nicole Dove Mount Shasta, California

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The redwoods brought me here. Any old growth forest is something I would call sacred. I feel human there, and that feeling is the reason I am filing this comment opposing the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres, among them Boundary Peak in the Inyo National Forest, the Rincon area in the Sequoia National Forest, the Siskiyou area in the Klamath National Forest, and Orleans Mountain in the Klamath National Forest, along with many others across the state. These are the places I go to remember that we are just humans. I am asking the agency to keep the national rule that protects them. The agency has pursued this exact path before. The record shows that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That rejection led to state-by-state rulemaking, and the Ninth Circuit struck it down. The agency's own prior record acknowledged that local decision-making can incrementally reduce nationally significant roadless values. The forests I care about in California, including the Sespe-Frazier area in the Los Padres National Forest and the Kings River area in the Sierra National Forest, would be governed by whatever replacement approach this proposal produces. I ask that the agency explain, in this proceeding, how the current proposal avoids every deficiency the Ninth Circuit identified when the agency last tried to substitute state-by-state approaches for the national rule. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The courts reviewed that question 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 found the 2001 rule was within the authority Congress granted and did not create de facto wilderness. The Paiute, Carson-Iceberg, Coyote Southeast, Glass Mountain, Fox Mountain, and Sawmill-Badlands roadless areas are real places, held by a real rule, upheld by a real court. The agency must state on the record what legal basis it has for a contrary position, and explain why this action survives the statutory authority analysis the Tenth Circuit already completed. The economic analysis accompanying this proposal cannot be squared with its own findings. 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. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. People who make their living guiding others into these forests, and communities whose water supply depends on intact roadless watersheds, are not statistical abstractions spread across a national average. The agency must withdraw the small-business certification and conduct a genuine assessment of the outfitters, guides, and operators actually permitted to work in the specific roadless areas this proposal would open to new road construction. Finally, the agency opened a door it has not looked through. 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 such a reliance interest. I go to old growth forests because the Roadless Rule has kept them that way. The rule is the basis for expecting they will remain intact. An agency that changes course must account for what people and communities have built around its prior commitments. The agency must identify and weigh the reliance interests that commenters describe, including this one, before it proceeds any further. Sincerely, Zoe Pakledinaz An American citizen who I hope you remember

I am a voter in Anderson, California. I frequently hike, camp, picnic and recreate in the Shasta-Trinity National Forest, the Lassen National Forest, the Six Rivers National Forest, and the Klamath National Forest. I raised my children in these forests, and now as young adults they also frequently recreate there. I am writing to express my strong opposition to the proposal to rescind the nation's landmark roadless rule. This action would open nearly 45 million acres of pristine national forests to road construction, logging, and other development. The consequences of this decision would be far-reaching and devastating for our environment, wildlife, and communities. * Biodiversity: The roadless rule has been instrumental in preserving biodiversity and habitat. These untouched forests provide critical habitat for over 500 imperiled species. * Water Quality: The roadless rule protects millions of acres that serve as the headwaters for major rivers that supply drinking water to more than 60 million people across 33 states. By allowing road construction, we risk introducing significant water pollution to these vital water sources. * Fire Protection: Contrary to the administration's claims, rescinding the roadless rule would actually increase wildfire risk. Scientific studies have shown that wildfires are four times more likely in areas with roads compared to roadless forest tracts. This fact directly contradicts the justification being used to push this harmful proposal forward. My Northern California home area is acutely aware of fire danger: we've lived through massive, devastating wildfires the last several years. Any action that increases fire danger is a direct attack on citizens' lives and property. Top findings from the fire study cited below (Aplet, Hartger, & Dietz): 1. From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1,000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1,000 ha). 2. The highest wildfire-ignition density was in lands within 50 meters of roads (7.99 fires/1,000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1,000 ha). 3. The results show that ignition density is much higher near roads than away from them. Across the National Forest System and in every region examined, the density of wildfire ignitions within 50 meters of a road is higher than in wilderness, Inventoried Roadless Areas, or other national forest lands, often by quite a bit. I implore you to stand against the rescission of the roadless rule. Protect our national forests, endangered species, clean water, and the interests of the millions of Americans who benefit from these pristine wilderness areas. The legacy of our public lands and the health of our environment depend on your action to preserve the roadless rule. Sources/references: U.S. Fish and Wildlife Service, “USFWS Threatened & Endangered Species Active Critical Habitat Report,” Environmental Conservation Online System (ECOS), updated August 7, 2025, accessed April 29, 2026, https://ecos.fws.gov/ecp/report/ table/critical-habitat.html. NOAA Fisheries, “National ESA Critical Habitat Mapper,” updated February 18, 2025, accessed December 8, 2025, https://www.fisheries.noaa.gov/resource/map/national-esa-critical-habitat-mapper U.S. Forest Service, “Water Facts,” https://www.fs.usda.gov/managing-land/national-forestsgrasslands/water-facts. Southern Environmental Law Center, “For Virginians, Roadless Areas Mean Clean Drinking Water,” December 18, 2025, https://www.selc.org/news/for-virginians-roadless-areas-mean-clean-drinking-water; Friends of Shenandoah Mountain, “Water Quality,” accessed March 31, 2026, https://www.friendsofshenandoahmountain.org/water-quality.html U.S. Department of Agriculture Forest Service, “Summary of Public Water Systems and Populations Receiving Surface Drinking Water Supply From National Forest System Land,” GTR WO-100 (September 2022), https://www.fs.usda.gov/ research/publications/gtr/gtr_wo100/GTR-WO-100-Sup1.pdf 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). https://doi.org/10.1186/s42408-026-00450-2

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. My name is Brendan, I am a Certified Public Accountant based in San Francisco, and I have spent a meaningful part of my time outdoors in the national forests this rule protects, including Sequoia National Forest and Klamath National Forest. I genuinely love the American freedom and accessibility provided by the forests. The general public use within the parks is appreciated and well used. Formation of these protected jurisdictions was an important ideal for generations of presidents and visionaries, and is the essence of just and equitable American freedom for everyone. These are not places I know secondhand. I have hiked and camped in areas that would be opened to road construction and logging if this rule is removed, and I have seen the value of keeping them undeveloped, both for the people who use them and for the water and wildlife that depend on them.

I am writing to oppose the proposed partial or full rescinding of the Roadless Area Conservation Rule. As an avid hiker, backpacker, and hunter, in California the existence and sustainability of wild places and the wildlife which rely on these habitats is of paramount importance to me and to many of my fellow citizens. It is clear from reading Alternative 2 and 3 and associated DEIS that these approaches would create negative and irreparable harm to many public land areas throughout the country. Thus, I am strongly urging the agency to go with Alternative 1 — no action, and decline to rescind any portion of the existing Roadless Area Conservation Rule. In particular, living in California I spend time in the Snow Mountain area within Mendocino National Forest, which has 14,457 acres of inventoried roadless area. The region supports habitat for multiple important species, including blacktail deer which I have the privilege of hunting in California. Blacktail deer in California have seen precipitous population declines over the past several decades and this area is an important habitat for them to thrive. Established scientific literature shares a consensus that parceling and developing habitat — through building roads and opening areas for development — puts undue pressure on species such as Blacktail and Tule elk and can lead to their overall decline. The DEIS indicates this is a likely adverse effect of the proposed rules. I have also spent time in Siskiyou area which contains 54,039 inventoried roadless acres within Klamath National forest. In this area there are incredible old growth forests which are an important home for the Northern Spotted Owl and other species. These species depend on undeveloped habitat of old growth forests and the DEIS indicates the proposed rule would adversely affect these species and habitats. Under the proposed rule, I would like to understand how the agency can ensure these populations and habitats are not degraded and will be prevented from suffering irreparable harm by development and road building in these areas? In addition to the impacts on important habitats and species, the expansion of road development into currently inventoried roadless areas fails to make economic sense for agencies like the National Forest Service which already have stretched budgets, scarce resources, and maintenance backlogs. The proposed rule change would result in the American public giving up critical recreation, wildlife, and habitat and having to pay for the inconvenience of doing so. Can the agency explain how it could possibly expect to safely and appropriately maintain additional road and access infrastructure when many of the agencies responsible for these areas similar areas have large maintenance backlogs and thus are not able to maintain the existing infrastructure? Finally, I would like to point to the overwhelming, broad public support for the Roadless Area Conservation Rule upon its adoption, when 95% of submitted comments were in favor of these protections as well as during last fall’s comment period when the Notice of Intent for this rule was proposed. During that comment period, over 600,000 comments overwhelmingly (99%) supported preservation of the Roadless Area Conservation Rule and thus opposed the proposed Alternative 2 and 3. For all of these reasons, I oppose the rescinding of the Roadless Area Conservation Rule and strongly urge the agency to listen to the American public in taking No Action to change the rule.

I am writing to express my strong opposition to any proposal to rescind, weaken, or grant state-level exemptions from the 2001 Roadless Area Conservation Rule (Roadless Rule) for National Forest System lands in California, with specific concern for the Inventoried Roadless Areas (IRAs) within the Klamath National Forest. The Klamath National Forest contains over 300,000 acres of Inventoried Roadless Areas that safeguard irreplaceable biological diversity, cold-water fisheries, and steep headwater slopes. Rescinding roadless protections in this specific region would exacerbate wildfire risks, compromise salmon recovery, and create severe financial and environmental liabilities for the U.S. Forest Service. I urge the Forest Service to maintain full 2001 Roadless Rule protections. Rescinding the Roadless Rule in California, and specifically within the Klamath National Forest, would sacrifice vital clean water supplies, jeopardize sensitive fish populations, and increase human-caused wildfire risk on steep, fragile landscapes. I respectfully request that the Forest Service reject any effort to rollback or carve out exemptions from the 2001 Roadless Area Conservation Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I appreciate all wildlife in these Roadless Areas. Many species of wildlife need pristine areas such as these to thrive. I hike, backpack, camp and trail run in Wilderness and Roadless Areas, mostly on the Klamath and Rogue River National Forests. These unspoiled areas are important to me. National Forests are required to be managed for multiple use. This does not mean that every acre must be roaded and logged. The best use for our remaining Roadless Areas is to remain roadless. There are abut 300.000 miles of roads in the Forest Service system. The roads on the Klamath National Forest are in terrible shape, and I suspect this is true nationally. There are more roads than the agency can maintain, and there are more roads than are necessary for administration and public use. It makes no sense to add yet more roads to a broken system. Roadless areas are necessary to maintain clean water for municipal water supplies and for the survival of the fish and wildlife that depend on them. Roads, mining and logging are pollution sources. We don't need additional sources of pollution. I am a retired wildland firefighter. In my experience, Roadless Areas are not a significant impediment to fire suppression. Roadless areas tend to be healthier and more fire resistant. They provide an opportunity to let wildland fire play its natural role in forested ecosystems. Most fires start along roads. Roadless Areas tend to be in high elevation areas, which means that they are cooler, wetter, and fires that do start there tend to be near the tops of the mountains and so are less destructive; most roadless areas on the Klamath National Forest have burned several times over the past 50 years and so are no longer burdened with unnatural fuel loads. I commented on this subject last year and never got a response. It seems that, as with many other similarly destructive projects, the agency is just going through the motions and is not seriously considering public opinion. I have been to many roadless areas, and I value both the ones I am familiar with and the ones I have never visited. To me, more roads would be a symbol of the agency's managerial, ecological, political and moral bankruptcy. There is a reason that roadless areas are roadless. They are not economically valuable for commodity production. They are not needed for motorized recreation. They have been analyzed several times over the past 50 years or so and there was never any need to road them. Nothing has changed. Leave them alone. The Pacific Crest Trail passes through the Grider roadless area, which is quite wild and scenic. The Tom Martin roadless area is near the historic Lake Mountain Lookout, which I have been to many times. I have backpacked in and around the Boulder Roadless Area. Roads in this general area have had to be abandoned because of the instability of the terrain. The Shackleford Roadless Area is adjacent to the Marble Mountains Wilderness, which I have visited many times. The Mt. Eddy roadless area is adjacent to the Pacific Crest Trail and is a very popular area for hiking and backpacking. The McDonald Peak Roadless Area is adjacent to the Pacific Crest Trail and is a very popular area for hiking, trail running and backpacking. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Grider (10,647 acres), Klamath NF, California - Tom Martin (9,031 acres), Klamath NF, California - Boulder (435 acres), Klamath NF, California - Shackleford (1,679 acres), Klamath NF, California - Mt. Eddy (7,232 acres), Shasta-Trinity NF, California Mcdonald Peak (9,431 acres), Rogue River NF, Oregon Chips Creek (42,029 acres), Plumas and Lassen National Forests, California I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Jeffrey Stone Yreka, CA