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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas around Mt. Rose have been part of my life for 35 years. I have hiked with others and camped in or near Rose - Galena, Rose - Whites Canyon, Rose - Summit, and the Mt. Rose roadless area in the Lake Tahoe Basin Management Unit. I have paddled Lake Tahoe, a world-renowned treasure, and I have been privileged to spot the quite unique band-tailed pigeon in these mountains, along with grouse and other upland species. These places, the Galena drainage, White's Creek drainage, and the Mt. Rose summit country, make northwest Nevada unique. They draw millions of outdoor lovers now, an economic force that was a trickle when I moved here and is a major driver today. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. We have already seen wildfire in the Toiyabe up close, human caused as the population grows. The agency's own data on fire should stop this proposal The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal offers wildfire management as a justification for rescission, while the agency's own draft environmental impact statement records the opposite. The Humboldt-Toiyabe is the largest national forest in the lower 48, scattered across mountain ranges rising from the Great Basin desert, each roadless range a sky island with its own ecology, its own water, its own wildlife. Roads into that terrain, according to the agency's own finding, multiply the chance of ignition. I ask the agency to explain why the proposal departs from its own prior findings on fire occurrence and to reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land than inside these roadless areas. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. A federal appellate court already answered that question. Exercising its jurisdiction, the Tenth Circuit stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the rule was within the authority Congress granted and did not create de facto wilderness. The agency has not explained what has changed in the law since that ruling. I ask the agency to address the Tenth Circuit's holding and explain the legal basis for any contrary position it now takes. The rule already permits what the agency says it cannot do. The agency's own description 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 proposal cites permitting and administrative burden as reasons to rescind the rule entirely, but the rule as written already carves out exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific burdens fall outside those exceptions. Nevada holds 316 inventoried roadless areas totaling 3,186,206 acres, and the Humboldt-Toiyabe alone holds 354 inventoried roadless areas totaling 3,383,849 acres. Across the Intermountain region, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. Runoff into the Truckee from logging in the basin would be a disaster, and clean water from these drainages is not a burden, it is the point. The agency must identify, with specificity and on the record, which burdens are not already addressed by the rule's existing exceptions. Finally, the agency certified no significant impact on small entities while its own Cost Benefit Analysis records lost recreation benefit at a minimum of $6.1 million a year and its own DEIS names outfitters, guides, and tour operators as affected parties. . That is not a regulatory flexibility analysis; it is an averaging exercise designed to obscure the real harm. Much of the U.S. is still scarred by logging for the benefit of a few, while the many who depend on intact forests for their livelihoods and their lives are left with the damage. The agency should withdraw the certification and assess the actual impact on the small businesses operating within the potentially affected roadless areas. Sincerely, Susan Juetten Carson City, Nevada

My name is Brooke Clayton. I live is Stateline, Nevada and frequent many national forests in the area including the Humboldt-Toiyabe, Lake Tahoe Basin Management Unit, El Dorado, and Tahoe National Forest. I am writing this to urge protection for the 2001 Roadless Area Conservation Rule to protect our public lands. Rescinding the protections under this rule will threaten forests and natural places that provide innumerable benefits to human’s physical and mental health- let alone all the wildlife and ecosystems that depend on these wild lands. Public lands make America special. They drive a thriving recreation economy. They are a representation of our country’s commitment to wellbeing over profits. Undeveloped forests requester carbon, protect watersheds, and remind us of a world where nature and people thrive together. The arguments laid out in the proposition to rescind this rule are flawed. They are largely made by those with interests in the logging industry who would profit from less protection. Wildfire control is managed well with the current protections, in fact, section 294.13 already permits tree thinning and emergency fire access. I personally know many people who have worked on wildland fire crews and still oppose the proposed changes. They are able to perform their jobs well under the current protections and also love to see intact forests, recognizing the way they also contribute to healthy ecosystems. Please choose the “no action alternative” and vote to keep the 2001 Roadless Rule fully intact.

I am writing to oppose changes to the Roadless Rule. While I travel around the country to many National Forests, the roadless areas I visit most are in the Lake Tahoe Basin Management Unit. These roadless areas are the Pyramid, Dardanelles, and Freel Roadless Areas. I live and work on National Forest lands as a concessionaire. My business caters to non-motorized recreation as 300 people a day hike in to enjoy my business during the summer. I grew up here in the Lake Tahoe Basin. Public land and the peace and quiet of non-motorized recreation is very important to me. IF the Roadless Rule is rescinded, I will not only loose my customers, but in order to enjoy outdoor recreation without motors I would have to travel to a state or national park, and that is not feasible for me. I am very concerned about increases in wildfire risk. Facts show that most wildfires are human caused and most occur near roads. If this rule is rescinded, not only the national forest will burn but also the surrounding communities. Water quality and thus fisheries will also suffer as these are heavily influenced by erosion and siltation of streams, caused by off road vehicles. Quiet undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting and fishing. This is sustainable, whereas the extraction of timber and mining is not sustainable, and will give short term profits to a few people rather than serve the public forever. Again, I oppose changes to the Roadless Rule. Thank you, Eric Hildinger

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas I am naming in this comment are real places I care about: Pyramid in the Lake Tahoe Basin Management Unit, Dardanelles, Caples Creek, Tragedy-Elephants Back, Salt Springs, Rubicon, and Raymond Peak in the Eldorado National Forest, Freel in the Lake Tahoe Basin Management Unit, and Mokelumne-Hawkins Peak and Waterhouse B in the Humboldt-Toiyabe National Forest. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The Humboldt-Toiyabe alone holds 354 inventoried roadless areas totaling 3,383,849 acres, scattered across mountain ranges that rise from the Great Basin desert like islands in a sea of sagebrush, each range a sky island carrying its own water, its own ecology, its own wildlife, including Lahontan cutthroat trout, greater sage-grouse, pygmy rabbit, and mountain goat. Rescinding the 2001 Roadless Area Conservation Rule would put all of this at risk, and the agency's own record does not support that step. The proposal argues that opening roadless areas to road construction will help manage wildfire. The agency's own findings say otherwise. Its 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 areas I have named, from the dry Sierra Nevada flanks of the Eldorado to the sky islands of the Humboldt-Toiyabe, already face fire pressure. Adding roads into them to reduce fire risk contradicts the agency's own ignition data, reported in DEIS Table 21, which shows far higher fire density on roaded land than inside roadless areas. I ask that the agency explain why this proposal departs from those prior findings and reconcile the rescission with that data. The economic case is no stronger. The agency's own analysis records that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal production, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. The Forest Service road system already carries a $6.9 billion maintenance backlog. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas, and degraded watershed function is a cost the agency's numbers do not adequately capture. The agency must reconcile this proposal with an economic record that cannot demonstrate the action is worth its price. The argument that state-by-state rulemaking can substitute for a national rule has been tried before. The record itself 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 state-petition approach was subsequently reviewed by the Ninth Circuit and found wanting, in part because local decision-making can incrementally erode roadless values that are nationally significant. The areas I have named cross administrative boundaries and support connected watersheds. The agency has not explained how this proposal avoids the deficiencies identified the last time it tried to replace national protection with a state-level substitute, and it should do so. Finally, the proposal questions whether the agency had statutory authority to issue the 2001 rule. That question has been litigated. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the 2001 rule within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and held it did not create de facto wilderness. The agency has not explained what legal basis supports a contrary position now. That explanation belongs in this record before any rescission moves forward. Sincerely, Concerned Citizen South Lake Tahoe, CA

I oppose fully or partially rescinding the present Roadless Area Conservation Rule at this time. I am a retired scientist living walking distance from Lake Tahoe, an Outstanding National Resource Water (ONR), and adjacent to one of its tributaries. My homesite is in a Wilderness Urban Interface (WUI) area where wildfire is a major and now growing catastrophic risk. In recent times (the last twenty years) we have experienced two catastrophic human caused forest fires in the Lake Tahoe Basin Management Unit, each destroying hundreds of residences. My primary concern with full or partial rescission of the Roadless Rule at this time is that various potential enormous damaging effects, particularly from ongoing climate change and increased human usage, have not yet been assessed and quantified to adequate confidence levels. Three types of such possible negative effects are increased wildfire damage, recreation degradation, and water quality loss. Wildfires historically occur much more frequently near roads, and hence would likely increase with Roadless Rule rescission, if local areas were to allow such roads. With climate changes, such as increasing temperatures and higher wind speeds, the range and damage level of severe wildfires has increased dramatically and will likely continue to do so. Communities far from the source of such wildfires will be in range. And there will likely be more such communities due to the national housing shortage. Allowing commercial and recreational vehicle usage in formerly roadless areas, in conjunction with climate change, will inevitably produce ever-increasing wildfire damage, including property losses and fatalities and ecological carbon sequestration losses. More knowledge is needed to define the increased extents and costs of wildfire damage that would result and that is acceptable to the public before rescinding any part of the Roadless Rules. Recreation by people not in vehicles and in search of a natural undisturbed environment in former roadless areas will be degraded by full or partial rescission of the Roadless Rule. Degradations will include introducing on-trail or road vehicle danger, wide-spread vehicle and human noise, loss of access to undisturbed natural habitat, and general new increased roadless area damage and detritus from new commercial and recreational usages. Roadless areas are a national historical irreplaceable recreational treasure of the people. I believe the benefits cited for rescinding the Roadless Rules are not worth enormously degrading their recreational values to the public. Water quality loss is likely due to new difficult to regulate incursions of people and machinery near many formerly isolated sources of potable water. Introducing traffic will cause sediment, dust, and other pollutants toe enter the water supply. Increased wildfire damage to the soil, forests, and meadows due to the higher frequency more more severe wildfires that result from climate change will also degrade the indigenous potable water. In conclusion I hope that the Roadless Rule will not be fully or partially rescinded at this time due to the as yet unquantified potential damage levels to WUI residents lives and property, to loss of recreational value, to loss of water quality, and to the general reduction in sustainability of a healthy environment that would result.

Subject: Public Comment Supporting Rescission of the 2001 Roadless Rule – Docket FS-2025-0001 Dear USDA Forest Service Planning Team, I am writing to strongly support the proposed action to RESCIND the 2001 Roadless Area Conservation Rule. As a resident of El Dorado County living within the Tahoe Basin, I see firsthand the critical need for active, flexible forest management to protect our communities from catastrophic wildfire. It seemed like just yesterday we were fundraising for victims.of the Caldor fire, and even more recently the Hawk Fire. The 2001 blanket national rule creates unnecessary administrative burdens and restrictions that hinder timely fuel-reduction treatments. In the Sierra Nevada, our forests face severe health challenges from overgrowth, drought, and beetle infestations. Local foresters need maximum flexibility—including temporary or permanent road access where appropriate—to effectively thin hazardous fuels and create defensible space near the Wildland-Urban Interface (WUI). Furthermore, the Lake Tahoe Basin is already subject to robust, multi-layered environmental oversight through the Tahoe Regional Planning Agency (TRPA) and the Lake Tahoe Basin Management Unit. We do not need a restrictive national rule to protect our landscape; we need to empower our local forest professionals to make science-based, site-specific decisions that balance ecological health with public safety. Please finalize the proposed rescission and return decision-making authority to the local forest level. Sincerely, Angela Dugan South Lake Tahoe, El Dorado County

I urge you to keep the Roadless Rule in place exactly as it is, and to select Alternative 1, No Action. Like millions of Americans who have spoken out since 2001, I value our public lands and waters, including the 44.7 million acres of undeveloped national forest this rule protects. I am not writing in the abstract. I live in Alpine Meadows, at Lake Tahoe, and I use these forests year-round: backpacking multi-day Sierra routes, running ultra-distance trail events, and backcountry skiing and snowboarding through the winter. My eight-year-old daughter has backpacked with me in Desolation Wilderness, Yosemite, and the eastern Sierra out of Mammoth Lakes. More than 80,000 acres in the Tahoe National Forest and Lake Tahoe Basin Management Unit are inventoried roadless areas, close to a quarter of Forest Service land in the Basin. The Roadless Rule safeguards clean drinking water for millions of Americans. In the Sierra that means the headwaters of the Truckee, San Joaquin, Kings, and Owens rivers, and it means fine sediment control in the Lake Tahoe Basin, where two decades and hundreds of millions of dollars in public investment have gone toward restoring lake clarity. Roads are a principal source of the sediment that investment is fighting. Building more of them in the same watershed works against the public's own money. It provides habitat for threatened and sensitive species, including the Sierra Nevada red fox near Luther Pass, and it sustains old-growth and mature forests that function as carbon sinks. Just as importantly, it keeps these areas connected. The roadless lands between designated wilderness and park units are what allow wide-ranging species to move across the landscape instead of being stranded in islands of protection. It also protects access to climbing, fishing, hiking, backcountry skiing, mountain biking, and paddling, across more than 25,000 miles of trails. The communities around me run on that access. Truckee, Tahoe, Mammoth Lakes, and Bishop have recreation economies, not timber economies. The stated reason for rescission is wildfire risk, and the evidence points the other way. Ignitions are several times denser near roads than in roadless areas, and the Forest Service attributes nine in ten wildfires to human causes. Set against a projected $4.6 to $10.6 million a year in additional timber revenue nationwide, this is not a serious trade. Please keep the Roadless Rule intact and follow Alternative 1, No Action. Thank you, Theresa Smith Olympic Valley, CA

Comments of Grace Anderson, resident of the forests in the Lake Tahoe Basin Management Unit (LTBMU) 1. Withdraw the proposal to rescind the long-effective and widely supported rule that protects select roadless areas of the forested lands owned by the US federal government. 2. Retain the 2001 Roadless Rule in its current form. 3. If a formal petition is received by a specific forest, examine the merits of reducing or increasing the present degree of protection afforded to the geography identified. Address all wildlife and habitat impacts and conduct a respectable, detailed fiscal analysis of any proposed change to protections. 4. Reduce the current level of protection only on a case-by-case basis, NOT through a generic, sweeper recession of a rule that covers all forests. 5. Acknowledge the known effects that road-building has on increase of human-caused fire ignitions and immense resources the USFS has to expend fighting wild land fires and then pursuing restoration of burned lands. 6. Acknowledge the impossibility the constrained USFS staff resources will face in managing incursion of new roads. 7. Address and mitigate the habitat fragmentation that building of new roads will inevitably cause. Under no condition pursue this categorical, nationwide recision. I oppose changes to the 2001 Rule and urge no changes be made at this time. I oppose this recision. Please extend the comment period to allow much greater use of public hearings in each individual forest unit. Thank You Grace Anderson

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 am a resident of the Lake Tahoe Basin. Roadless areas encompass close to a quarter (41,000 acres) of Forest Service-Lake Tahoe Basin Management Unit lands and, to the north, 6% (46,000 acres) of Tahoe National Forest Lands. I am very concerned that rescinding the Roadless Rule will invariably greatly impact the character of our local area. In the Tahoe region, the Roadless Rule protects lands holding well-known landmarks and areas, including Castle Peak, Granite Chief, forests that skirt Desolation Wilderness, and portions of the Tahoe Rim Trail. These lands also encompass Freel Peak, the tallest peak in the Tahoe area, as well as swaths of Tahoe’s west and east shore. I live near the National Forest and enjoy recreation away from roads. Fire danger is the greatest within 1/2 mile of roads and our greatest local danger is fire. More development in the Tahoe Basin area in these remote areas is inclined to increase fire danger, and greatly decrease the wilderness experience. I want to leave the beauty of untouched wilderness areas for future generations. Please do not rescind the Roadless Rule.

I emphatically oppose the attempt to rescind the 2001 Roadless Rule for wilderness areas. I write on behalf of the over 4 million acres of Roadless Rule wilderness protected areas in California. Specifically, I oppose the rescission of the Roadless Rule in two areas: (1) the Ventana Wilderness and Los Padres National Forest in Monterey County, California, and (2) the Inventoried Roadless Areas surrounding and buffering the Desolation Wilderness in the Sierra Nevada Mountains in California. First, the Ventana Wilderness and the Los Padres National Forest should remain Roadless Areas. These areas of wilderness contain the headwaters of Santa Lucia Creek and the Carmel River. These watershed areas provide critical habitat to endangered and threatened species, as well as providing local water supplies for human use. In addition, peer-reviewed studies have shown that fire ignitions increase four-fold near roads transitting forested areas, versus ignitions in those wilderness areas which are not crisscrossed by roads. The Roadless Rule should be preserved to ensure that the Ventana Wilderness and the Los Padres National Forest's irreplaceable watershed resources are not damaged, endangered and threatened species' habitat is protected, and wildfire ignition risk is mitigated. The second set of Roadless Rule areas that are particularly important to me are the Roadless Areas that abut the Desolation Wilderness in the El Dorado National Forest and the Lake Tahoe Basin Management Unit of the U.S.D.A. as follows: the Pyramid Inventoried Roadless Area, the Upper Truckee/ Dardanelles Inventoried Roadless Area, and the Caples Creek Inventoried Roadless Area. The Desolation Wilderness and its surrounding Inventoried Roadless Areas represent an exquisite national treasure. I live in the Lake Tahoe Basin and I hike the Desolation Wilderness and its surrounding Roadless Areas. These three Inventoried Roadless Areas protect pristine alpine streams, lakes, and old growth forests. They preserve contiguous high elevation, back country ecosystems in non-motorized terrain. Watersheds in the Desolation Wilderness and its surrounding Inventoried Roadless Areas drain directly into Lake Tahoe, whose water clarity is world-famous. But Lake Tahoe's water clarity is under threat from the soil erosion, watershed damage, and other ecological insults that would result from the insertion of roads into the Inventoried Roadless Areas surrounding the Desolation Wilderness in the El Dorado National Forest, and within the Lake Tahoe Basin Management Unit. I entreat you not to rescind the 2001 Roadless Rule! Instead, maintain the Roadless Rule in effect to protect our irreplaceable wilderness heritage for generations to come. In addition, to more permanently protect our precious national wilderness, I strongly urge the United States legislature to codify the 2001 Roadless Rule into law, by passing the Roadless Area Conservation Act of 2025 (H.R. 3930). I want my children and my children's children to experience what John Muir meant when he wrote of the trackless wilderness: "The mountains are calling and I must go".

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to fully or partially rescind the Roadless Area Conservation Rule. This action would devastate our public lands, waste taxpayer resources, and undermine the clean water, wildlife habitat, and recreation opportunities that millions of Americans depend on. I urge the agency to take Alternative 1, the No Action alternative and retain full Roadless Rule protections. I live in Belmont, California and spend time hiking and camping in nearby Roadless Areas like the Freel IRA in the Lake Tahoe Basin Management Unit, and the Bear Canyon IRA in the Los Padres National Forest. This year, I had the privilege of hiking through 231 miles of Roadless Areas while “thru-hiking” the Pacific Crest National Scenic Trail (PCT). I have fond memories of many of these Roadless Areas, and met many other American thru-hikers, locals, and international tourists out enjoying them with me. On the ridgelines north of Rainy Pass in Washington’s Okanogan-Wenatchee National Forest, I was blown away by views of the rugged North Cascade mountains. Above the Rosary Lakes in Oregon’s Deschutes National Forest, I enjoyed a beautiful sunset. In the meadows north of Carson Pass in the Lake Tahoe Basin Management Unit, I saw some of the most incredible wildflower displays I have ever seen. And on a sunny Saturday in Southern California’s San Bernardino National Forest, I shared the trail with many local families out swimming and fishing in Deep Creek. Under the agency’s proposed Alternative 2, all of these areas would lose protections. By opening Roadless Areas up to commercial development, we would fundamentally degrade their wild character, threaten water quality and wildlife, and diminish the recreational experience for locals and tourists alike. I hear the argument that roads allow access to help fight fires, but an ounce of prevention is worth a pound of cure, and I am concerned that removing Roadless Rule protections would increase fire risk in our nation’s backcountry forests. In the DEIS, the agency admits that “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” But recent research from The Wilderness Society shows that from 1992 to 2024, wildfires were four times as likely to start in areas with roads as in roadless forest tracts. A 2007 study from the Pacific Biodiversity Institute showed that more than 90 percent of wildfires occurred within half a mile of a road. These studies are attached. If a fire starts of natural causes in a remote, roadless forest far from civilization, that is a natural ecological process, not a problem that needs to be fought. It is well-known that excessive fire suppression leads to more severe fires in the long-run. What we must limit is the number of human-caused fires in our national forests, and building more roads and human infrastructure will only increase that risk. While on the PCT, I met many hikers from other countries. One thing they often said was that their countries don’t have wild land like we have in America. Our beautiful and wild public lands, including these Roadless Areas, are a key part of our shared national heritage. They make America great, and they are one of the reasons that I feel most grateful to live here. I look forward to revisiting the areas that I previously listed, to exploring Roadless Areas across many other states, and to sharing them with future generations of kids and grandkids. I only hope that the administration will allow that to happen. For these reasons, I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative. Thank you

I minored in outdoor recreation in college. Then, worked for 6 years, from 2010-2016, in the outdoor industry for a local southern California company selling retail and wholesale outdoor recreation products like backpacks, boots, tents, and snow shoes. We also rented used gear locally at very low cost so more people could experience the outdoors at any price point. The purpose and mission was to grow an outdoor community that would return again and again to both the great outdoors and our stores for reliable gear and advice. Our stores, and the $1.3 trillion U.S. outdoor recreation industry as a whole, rely on access to public lands and pristine wild spaces. The 2001 Roadless Area Conservation Rule protects roughly 4.0 to 4.4 million acres (about 20% to 21%) of California's national forest lands across Inventoried Roadless Areas (IRAs). The federal proposal to rescind the Roadless Rule impacts pristine and undeveloped forest regions statewide, spanning Northern, Central, and Southern California national forests. Rescinding protections of these public lands like the Roadless Rule will have direct economic impacts on the outdoor recreation industry and recreation community nationwide, everyday Americans making a living and enjoying this great land, our greatest heritage. Some of the impacted National Forests and regions I have directly spent time in will be impacted by rescinding the Roadless Rule: • Southern California: Protects over 1 million acres across the Angeles National Forest, Cleveland National Forest, Los Padres National Forest, and San Bernardino National Forest. I have personally spent countless hours and numerous camping trips in these national forests. I have introduced friends and family to the joys of backpacking, camping, and hiking here. They are absolutely remarkable areas and at risk from fires and encroaching development. • Sierra-Cascades & Central California: Covers high-elevation conifer and old-growth zones in the Eldorado National Forest, Inyo National Forest, Lassen National Forest, Sierra and Sequoia National Forests, Tahoe National Forest, and roughly 200,000 acres around the Lake Tahoe Basin Management Unit. I have camped and backpacker with my family most summers since 2007 in the Inyo National Forest. It is a treasure. This is where I introduced my sister to backpacking and my husband to snow camping in the early spring. All of the small outdoor shops and guiding services along Highway 395 depend on these wild spaces remaining pristine and accessible. I now live in Washington State and absolutely love the mountains and forests here, too. I climb, hike, and mountain bike in them nearly every weekend. The Roadless Rule protects parts of six major national forests across Washington, including the following where I personally spend time enjoying the outdoors on public land: • Mount Baker-Snoqualmie National Forest, • Okanogan-Wenatchee National Forest, • Olympic National Forest, • Giffort Pinchot National Forest. I am an American taxpayer and the Roadless Rule matters to me personally. It also matters to the Outdoor Industry which provides jobs and income to countless people across the country, jobs that will exist even as AI grows and other industries suffer. People need access to America's wild spaces, its undeveloped serenity, and its pristine beauty now more than ever. Once lost, this great heritage of wild public spaces will be gone forever. For biodiversity, for mental and physical health, for decreased fire danger, for present stewardship, and for future generations, please do not rescind the Roadless Rule. It was and remains wildly popular among voters and American citizens. Thank you for your consideration.

I am a resident of South Lake Tahoe, California. I hike year-round in the national forests around the Lake Tahoe Basin, and I regularly camp and hike with my dog on trails and in undeveloped country that stay quiet because they are not laced with new roads. I oppose the proposed rule to rescind the 2001 Roadless Area Conservation Rule by removing and reserving 36 CFR part 294, subpart B. I also oppose the draft EIS preferred alternative that would eliminate national roadless protections on inventoried roadless areas, including those on the Lake Tahoe Basin Management Unit, Tahoe National Forest, Eldorado National Forest, and nearby Humboldt-Toiyabe lands. These are the places that make living here worth it. I use local trails and high country near South Lake Tahoe — including walks along the Upper Truckee and routes into the meadows, ridgelines, and backcountry that sit behind and above town. I take my dog camping and hiking in settings that still feel like forest, not a project area. Roadless protections are a big part of why those trips stay quiet, why streams run clearer, and why I can get off a trailhead and be in intact country within a short drive of home. The 2001 rule does not lock these forests up. It already allows hiking, camping, hunting, fishing, existing road maintenance, Tribal uses, firefighting, and wildfire-resilience work, including thinning and fuels treatments. Hundreds of thousands of acres of California inventoried roadless areas have been treated since 2001. Local examples, including work in the Caples Creek area before the Caldor Fire, show that the current rule can accommodate fuels reduction without opening the last intact forests to a new road network and industrial logging. If the problem is implementation or funding for treatments already allowed, that is not solved by deleting the national standard. What the proposed rescission would change is the default. Decisions would fall to individual forest plans and project-by-project review on more than 44 million acres nationwide, including roughly 4.4 million inventoried roadless acres in California and tens of thousands of acres in the Tahoe and Plumas country. Around Tahoe, that includes inventoried roadless ground on Tahoe National Forest (on the order of 147,000 acres in the original inventory, including Castle Peak and Grouse Lakes) and on the Lake Tahoe Basin Management Unit. New roads and commercial harvest in those areas would bring erosion into headwaters that feed Lake Tahoe, more sediment and noise on trails I use with my dog, and a slow conversion of quiet backcountry into managed access corridors. The draft EIS itself identifies potential water-quality, habitat, and quiet-recreation effects where roadbuilding and timber cutting occur. Those are not abstract impacts here. They are the difference between a Saturday hike and a Saturday next to a new road cut. Local forest planning is important. It is not a substitute for a national sideboard on the last large undeveloped national forest blocks. The Forest Service is already stretched. Shifting every roadless decision to plan revision and project NEPA does not create more capacity for careful public involvement; it creates more pressure to punch roads for access, timber, and “management” in places that have stayed roadless for a reason. I support active fuels work where it is needed, including near communities and in the wildland-urban interface around South Lake Tahoe. I do not support repealing the 2001 rule in its entirety in order to get that work done. The rule already allows it. Please retain the 2001 Roadless Area Conservation Rule, reject the proposed removal of 36 CFR part 294, subpart B, and select the no-action alternative in the final EIS. Thank you for considering my comments. Andrew Scott-Jester South Lake Tahoe, CA

Dear Chief: I am fortunate to live in an area that has easy access to the Lake Tahoe Basin Management Unit and the El Dorado and Humboldt-Toiyabe National Forests, and they are all spectacular places. I want the Department to understand that rescinding this rule forecloses something genuinely public and genuinely irreversible. The Caldor Fire in 2022 required us to evacuate. The Forest Service and CalFire used existing roads to combat the fire. I can see the destruction caused by the Caldor Fire from my home. There is active land management underway in adjacent and nearby areas that were not burned, and has been possible despite the existence of the roadless rule. Rescinding it will not make fire suppression or control any better. Regarding the Dardanelles in the Eldorado National Forest, California: Within Eldorado National Forest, the Dardanelles IRA provides habitat for Sierra Nevada Yellow-legged Frog (Rana sierrae, G2), a species subject to 7.1 - Fire & fire suppression — a threat assessed at not assessed severity affecting not assessed of the population. "We document over a one-quarter decline in bird abundance and almost complete avoidance by some species between noise-on and noise-off periods along the phantom road and no such effects at control sites—suggesting that traffic noise is a major driver of effects of roads on populations of animals. We replicated the sound of a roadway at intervals during the autumn migratory period using a 0.5 km array of speakers within an established stopover site in southern Idaho." — Proceedings of the Royal Society B: Biological Sciences (PMC), 2013 Road networks serve as vectors for the secondary impacts classified under 7.1 - Fire & fire suppression: they open previously inaccessible terrain to resource extraction, facilitate introduction of invasive species, and concentrate human disturbance along corridors through Sierra Nevada Yellow-legged Frog habitat. The roadless areas are critical to the overall heath of our environment. Proper fire and land management is not curtailed by the existence of the roadless rule. With kind regards, CommentID: RLC-20260927-8UUFBC

We are writing as concessionaires—our family has had a concession on U.S. Forest Service lands since 1917. As 2nd, 3rd and 4th generations, we grew up spending summers on USFS land and winters adjacent to the National Forest in the Lake Tahoe Basin. Our concession is directly adjacent to a roadless area, and depends in part on its status for our success. We have hiked, backpacked, skied, biked, hunted, observed wildlife, and driven throughout national forests across the country. As lifelong USFS concessionaires, property owners, business owners, and public-land users, we urge you to select Alternative 1—no change to the Roadless Rule. Inventoried roadless areas provide essential wildlife habitat, protect watersheds, preserve plant and animal communities, and maintain connectivity between ecosystems. We have spent many hours in roadless areas of the Lake Tahoe Basin Management Unit forests and have personally observed their importance. In the Tahoe Basin, the Pyramid and Freel Peak Roadless Areas provide habitat and travel corridors for wildlife moving into and out of the basin. They also drain directly into Lake Tahoe, an irreplaceable national resource. Constructing roads and authorizing associated development would fragment habitat and cause lasting damage to wildlife, plants, soils, and water quality. The Draft Environmental Impact Statement identifies habitat for more than 300 threatened, endangered, and proposed species, as well as 79 U.S. Fish and Wildlife Service and 19 National Marine Fisheries Service critical habitats. However, it does not adequately connect those baseline figures to the likely impacts of increased road construction, timber harvest, habitat fragmentation, and sedimentation under Alternatives 2 and 3. Research has documented measurable habitat degradation extending up to five kilometers from roads, including cumulative effects on isolation and population viability. The DEIS should address this research and provide species-specific or habitat-guild-level analysis before any change is finalized. Such analysis is required under Robertson v. Methow Valley Citizens Council, Neighbors of Cuddy Mountain v. U.S. Forest Service, and the Administrative Procedure Act, 5 U.S.C. § 706(2)(A). The claim that rescinding the Roadless Rule is necessary for wildfire or fuels management is also unsupported. The current rule already allows fuels management in certain circumstances, including projects intended to reduce fuel loads in the wildland-urban interface and improve habitat for threatened, endangered, or sensitive species. Such work has already occurred in roadless areas in the Tahoe Basin directly adjacent to our concession. Forest Service research has also found that roadless areas have historically received a larger proportion of fuels-management projects than other National Forest System lands. We have firsthand experience that reinforces the danger of expanding road access. We have witnessed both the 2007 Angora Fire and the 2021 Caldor Fire, and have personally extinguished multiple human-caused fires started on or near roads in our vicinity. Major California fires, including the 2025 Gifford, 2021 Caldor, and 2018 Carr fires, crossed roads and bulldozed fire lines multiple times. The DEIS itself states that wildfire ignition density is lower in designated wilderness and potentially affected roadless areas than on other National Forest System lands, while acknowledging that increased road access could increase the number and frequency of human-caused ignitions. The agency should cite the source for its ignition-density comparison and reconcile this evidence with any argument that additional roads would reduce wildfire risk. The Forest Service cannot adequately maintain the roads it already owns. The Economic Analysis reports a $6.9 billion deferred-maintenance backlog for roads and bridges in 2024. Other comments in the administrative record cite billions more in road-maintenance needs and indicate that the Forest Service receives less than 20 percent of the funding required to maintain its existing road network. Nevertheless, the DEIS and cost-benefit analysis do not quantify the construction and lifecycle maintenance costs of new roads or explain how those costs would increase the existing backlog. The Final EIS should provide that analysis. Expanding roads into roadless areas threatens wildlife, watersheds, public safety, and the long-term financial sustainability of the National Forest System. It could also directly affect our home, livelihood, business, and recreational opportunities if increased access leads to wildfire or environmental degradation. Please select Alternative 1 and retain the existing Roadless Rule. Thank you for considering our comments.

Sirs: I urge you not to rescind the Roadless Rule. The proposed recision would make advisory, rather than binding, the current national Forest Service baseline requirements. I have a recreation residence in the Lake Tahoe Basin Management Unit and have participated in Forest Service rule-making processes. I believe I speak from some experience. Recission of this rule would force understaffed local rangers to manually evaluate and close thousands of trails, a task that will overwhelm the agency and lead to severe environmental degradation, wildlife disruption, and user conflicts between motorized vehicles and traditional hikers or mountain bikers. Introducing commercial timber harvesting into these area will bring additional costs for road and bridge construction, fire management, law enforcement, and timber sale planning and administration, at a time when Forest Service budgets have been drastically reduced. Recission of the Roadless Rule will lead to increasing costs for the Forest Service, when no provision is made for funding them. Additionally, as the proposed recision of the rule aims to increase logging, such an increase would come at the expense of recreation, tourism and quiet enjoyment. It will also increase wildfire risk by intruding roads deeper into forest lands. Please do not rescind the Roadless Rule.

I am a retired National Forest Wildlife Biologist who worked on three National Forest across the country (Cleveland NF, Lake Tahoe Basin Management Unit, and Shawnee NF). I served in the USFS for approximately 33 years. I received many awards in all three locations for high quality fish and wildlife management and both short and long term planning for 4 Forest Plans for those NF’s. As part of my job, I spent many hours in roadless/wilderness areas in those NF’s. I also worked on a number of wildfire crews working in a number of roadless areas on other NF’s throughout the West. In all those jobs/experiences I observed some of the most unique and diverse landscapes and habitats for fish and wildlife because they were minimally disturbed by roads and road related activities. I strongly disagree that these areas needed to be roaded in the future for management actions. Based upon my observations and experiences needed forest and fish/wildlife work in these areas can be done without roads. I am opposed to elimination of the roadless area rule of 2001. Thank you for allowing me to comment. Steve Widowski, Vienna, IL

As an avid outdoor visitor I have spent countless days recreating in many of the US Forest Service lands impacted by the proposed repeal of the Roadless Rule. I am deeply OPPOSED to any type of repeal of the Rule. I have spent countless days with my family recreating on these lands (camping, hiking, biking and enjoying the natural landscapes) - including the Humboldt-Toiyabe National Forest, the El Dorado National Forest, the Tahoe National Forest (Lake Tahoe Basin Management Unit), the Inyo National Forest, the Dixie National Forest, and many many others. These lands held in trust for the American people are an irreplaceable resource for the voting public of this country and any type of repeal of rules that protect these lands from development or further erosion of the natural state is a disgrace. These lands need to be preserved in the most natural and untouched state possible for the benefit of visitors today and of future generations. It is our duty as citizens of this country to protect the natural resources for our children and grandchildren. OPPOSE the repeal of the Roadless Rule and come out on the right side of history!

I’m deeply disturbed by your plans to remove protection from Forest Service roadless areas. These are places where we can enjoy fishing, hiking, and the natural quiet of the forest. They should remain as they are. The roadless areas in the Eldorado National Forest and the Lake Tahoe Basin Management Unit are particularly valuable. I hike and camp there regularly and work as a volunteer with the Desolation Wilderness Volunteers. Roadbuilding in the lands surrounding Desolation will reduce the area that can be enjoyed for its scenic values and natural quiet. It would also degrade the wilderness experience as noise from vehicles, logging, and roadbuilding encroaches in the wilderness. The Desolation and Mokelumne wildernesses are very heavily used. The most popular trails there are at their carrying capacity and cannot take any more use. Nearby wildlands help relieve pressure on these areas. Although not designated wilderness, the Meiss Country and other roadless areas south of Lake Tahoe are places where people can enjoy fishing and hiking and get away from engines and roads. These areas should remain roadless. Further west is the Caples Creek roadless area. This area has excellent fishing and, with its lower elevation, is a good place for early-season camping and hiking. This area also shows how roadless areas can contribute to fire protection. The southeast flank of the 2021 Caldor fire—started in a roaded area—was held back in the Caples Creek area. Here, fuel reduction projects done a few years earlier without any roadbuilding protected this area along with Kirkwood and lands along State Route 88. The roadless rule protects lands for all of us. I urge you to adopt Alternative 1—the “No action alternative” and keep the Roadless Rule intact. Sincerely, Adrian Griffin