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Dear Tom Schultz, I am writing to oppose the recisision of the 2001 Roadless Rule. Years ago I worked in Lassen National Forest, and I saw first hand the impact that roads (many of the "temporary") had on the Forest. I am from New Hampshire and while our forests are quite different, the climate is changing. Droughts are becoming longer and more frequent. The compounding environmental damage from roads and the extractive logging they facilitate will bring us similar problems. My memories of my time in Lassen include the fine dust on the Forest Service roads (reading more about the issue, I now realize that many of them may be considered "temporary" and were never counted in any inventory of roads) and the constant fire danger. The Forestwide bans on chainsaws (for fear of fire danger) or target shooting (sparks) were implemented earlier than normal that year. I live in Europe at the moment. Living away from home has given me a new perspective on what makes the USA special. Being able to enjoy large areas without roads is a very rare thing. Personally I lose the joy of hiking in my home state with my kid, showing them the the wonders of the forest, undisturbed by roads. Keep the forest whole.

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

"I am writing as a public lands user to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Roadless Rule). As a community member, I am concerned about the claim that the proposed rescission emphasizes greater local decision-making authority in forest planning processes. The Roadless Rule was established in part due to the failure of local forest planning processes to maintain ecological, cultural, and public values of roadless areas to an adequate level across the National Forest System. Political partisanship and corruption is being factored into the current push to dismantle this rule, which is not reflective of the opinions of the people they represent. The Roadless rule is supported by the VAST majority of voters across the political spectrum— 76% according to recent Pew polling. Returning these decisions to wholly local planning processes should not be treated as a substitute for consistent nationwide protection measures. Once nationwide protections are removed, individual decisions may fail to account for the cumulative loss and fragmentation of roadless landscapes across the National Forest System. As a community member, I am concerned about the claim that removing the Roadless Rule is necessary to reduce wildfire risk. 96.2% of fires start within 800 meters of a road (Pacific Biodiversity Institute). It is clear that more roads mean more fires. As a sister in-law of a CA firefighter. We’ve seen and have intimate knowledge of wildfires. They will tell you that the majority of fires are due to human activities. Roads invite more people and vehicles deeper into the woods. Those roads that are built “in case of wildfires” are also pushing potential fires deeper into the landscape. Wildfire risk reduction should not be used as a blanket justification for expanding roads and resource extraction into millions of acres of roadless wildlands. Effective fire management should prioritize strategic, science-based, site-specific treatments where they meaningfully protect communities and firefighters, rather than broadly removing protections from remote landscapes. I am particularly concerned about climate resilience. The claim that putting these forests under local control would have little adverse impact on land managers' ability to protect undeveloped wildlands puts these values at risk. I have an intimate knowledge of the Lassen National Forest: Mill Creek Inventoried Roadless Area roadless area(s). I am particularly concerned about Climate resilience affects all of us. It affects all animals and plants, and that affects you. The Roadless Rule keeps old growth forests intact, protects multitudes of species and biodiversity, protects the air and drinking water, increases wildfire resilience, protects from land erosion, and is critical infrastructure as the effects of climate change intensify and create unstable and unpredictable changes to our everyday lives. All of these changes affect you, your loved ones, and all future generations of your family. This area - Supports large old growth forest, California spotted owl and other old growth dependent species. - Supports one of the few wild runs of threatened spring chinook salmon and winter steelhead flowing into the Central Valley. - Homeland of the Yahi Indians and the story of Ishi. - Important migration corridor for the Tehama black tailed deer herd - The Mill Creek Inventoried Roadless Area is recommended for wilderness protection by the USFS. - The USFS recommended wilderness protection for the Mill Creek Inventoried Roadless Area and National Wild and Scenic River protection for Mill Creek. Not only is the change proposed to the Roadless Rule terrible on it’s face for animals, the environment, and the people these biomes support in different ways (often unnoticed but absolutely crucial to our health), it’s also a cynical bid to disregard the will of the vast majority of The People in order to make a few people richer. It steals an asset that is explicitly under the stewardship of the People of the United States. Our tax dollars are what supports these areas. We do not consent to this change. And the corrupt few who are in power and pushing for this rule are not doing their job of representing the will of The People. Keep the roadless rule by choosing the no action alternative."

Hello, I am a citizen deeply concerned about the proposed docket to rescind the U.S. Forest Service. I am also concerned that the Draft Environmental Impact Statement is inadequate and is missing some of the crucial impacts this rule change will have on the nation’s forests. I live in Sacramento, and am lucky to be a short drive to many incredible National Forests. One of my favorites is El Dorado National Forest, specifically Bassi Falls (near Union Valley Reservoir) and the surrounding area. The hiking areas into the Pyramid Roadless Area are so important to me and my family, and where we find an opportunity to be surrounded by nature without vehicles in sight. Allowing roads in this area would negatively impact the recreation, habitat, and wildlife that make the area so special, and the Draft Environmental Impact Statement is missing additional analysis on these impacts. My family owns a cabin bordering Lassen National Forest, and the area’s beautiful forest and river shaped my life and career. Allowing new roads to be built in some of the forest’s roadless areas would increase the risk of fires and vandalism in an already at-risk forest, putting the forest and bordering properties at risk. Allowing road-building will not reduce fire damage; research such as Aplet et al. 2026 demonstrates that devastating fires are often started near roads. I am also concerned that the Forest Service will be unable to maintain newly constructed roads. The Forest Service already operates many miles of roads that they are unable to maintain, and are difficult to traverse in most vehicles. If the Forest Service wants to focus on roads, they should improve existing roads instead of allowing construction of new roads that will eventually become difficult to utilize. The DEIS states that the Roadless Rule has prevented officials from managing vegetation in certain areas, adding to negative forest health impacts. Can the EIS please provide specific examples of this? The Forest Service already seems understaffed and unable to conduct vegetation management in high-priority areas with roads, so I fail to see how rescinding the roadless rule will help with their already overwhelming workload. Lastly, the public engagement for this proposal was disappointing. There were no public meetings or opportunities to learn from Forest Service officials, which I would have gladly participated in. When reading the DEIS, it appears that Native American tribes were also not adequately consulted in this process, which is unacceptable and must be remedied for the final Environmental Impact Statement.

Hello, I am a citizen deeply concerned about the proposed docket to rescind the U.S. Forest Service. I am also concerned that the Draft Environmental Impact Statement is inadequate and is missing some of the crucial impacts this rule change will have on the nation’s forests. I live in Sacramento, and am lucky to be a short drive to many incredible National Forests. One of my favorites is El Dorado National Forest, specifically Bassi Falls (near Union Valley Reservoir) and the surrounding area. The hiking areas into the Pyramid Roadless Area are so important to me and my family, and where we find an opportunity to be surrounded by nature without vehicles in sight. Allowing roads in this area would negatively impact the recreation, habitat, and wildlife that make the area so special, and the Draft Environmental Impact Statement is missing additional analysis on these impacts. My family owns a cabin bordering Lassen National Forest, and the area’s beautiful forest and river shaped my life and career. Allowing new roads to be built in some of the forest’s roadless areas would increase the risk of fires and vandalism in an already at-risk forest, putting the forest and bordering properties at risk. Allowing road-building will not reduce fire damage; research such as Aplet et al. 2026 demonstrates that devastating fires are often started near roads. I am also concerned that the Forest Service will be unable to maintain newly constructed roads. The Forest Service already operates many miles of roads that they are unable to maintain, and are difficult to traverse in most vehicles. If the Forest Service wants to focus on roads, they should improve existing roads instead of allowing construction of new roads that will eventually become difficult to utilize. The DEIS states that the Roadless Rule has prevented officials from managing vegetation in certain areas, adding to negative forest health impacts. Can the EIS please provide specific examples of this? The Forest Service already seems understaffed and unable to conduct vegetation management in high-priority areas with roads, so I fail to see how rescinding the roadless rule will help with their already overwhelming workload. Lastly, the public engagement for this proposal was disappointing. There were no public meetings or opportunities to learn from Forest Service officials, which I would have gladly participated in. When reading the DEIS, it appears that Native American tribes were also not adequately consulted in this process, which is unacceptable and must be remedied for the final Environmental Impact Statement. I urge the Forest Service to change course and accept Alternative 1.

Please Preserve the Roadless Rule — Docket FS-2025-0001 Dear U.S. Forest Service, I strongly oppose rescinding the 2001 Roadless Area Conservation Rule. Retain these protections and reject the proposal to remove them. I have lived in the Bend, Oregon, area since the early 1980s. Before that, I spent many summers in Lassen National Forest in Northern California, where I still spend time today. These forests have been part of my life for decades. Access to wild places on foot is one of the reasons we choose to live here. Quiet, solitude, and the opportunity to experience an undeveloped forest are valuable in their own right. Building roads into these places would diminish the very qualities we treasure. Over the years, I have witnessed and experienced wildfires. Many of the fires that have affected the places I know have been human-caused. I oppose expanding road access into remote forests and creating more opportunities for human-caused fires. Our forests and nearby communities already face enough risk. Our national forests also attract visitors and support local businesses in the Bend area. Protecting their natural beauty and opportunities for recreation helps preserve our community’s quality of life and economic future. I want future generations to inherit forests with their wild character intact. Once these places are altered by roads and development, the consequences can last for generations. Do not rescind the Roadless Rule. Preserve the existing protections. Thank you for considering my comment.

I'm writing to oppose rescinding the Roadless Rule, either in whole or in part. The proposed rule would remove the Roadless Rule’s protections against destructive commercial logging and road building from nearly 45 million acres of forests on public lands that belong to all Americans. Alternative 3 does not offer a meaningful alternative to a full rescission, as it would remove roadless designations from more than 30 million acres of forest. Rescinding the 2001 Roadless Rule would irreparably harm our nation’s most important resources, which your agency under the current administration has started to disrespect and attempt to sell off, privatize, and ruthlessly extract from, all of which are egregious departures from the Forest Service's original intent when the agency was established. Roadless areas experience some of the lowest rates of fire ignition across the national forest system. While many of the USDA’s statements regarding the rule’s rescission have asserted a need to cut roads into these intact forests to prevent wildfires, the latest scientific information effectively dispels that myth. The DEIS itself belies those assertions, finding that fire ignitions are four times more common near roads than in roadless areas; it states that “ignition density is approximately four times greater on other NFS lands compared to potentially affected IRAs and wilderness.” More roads will only heighten wildfire risk. And fuel treatments and forest health initiatives are already taking place across roadless areas. The forests protected by the Roadless Rule play a vital role in sustaining wildlife, providing habitat for 57% of vulnerable terrestrial wildlife. Intact mature and old-growth forests, many of which are protected by roadless areas, serve as essential refuges for wildlife facing mounting pressures from climate change, wildfire, and human development. It is our responsibility to safeguard these species and the forests they call home. Additionally, forests protected by the Roadless Rule provide habitat for many endangered species, protect and promote biodiversity, and provide the conditions many wildlife species need to survive. The biological assessments accompanying the proposed rule identify 327 threatened and endangered species and 71 critical habitats as being likely to be adversely affected by rescinding the Roadless Rule. This is unacceptable. The Roadless Rule protects over 80,000 miles of streams and rivers. Building roads through these currently protected forests would cause diversions of rainwater's natural path across the landscape, cause sediment buildup in streams and rivers, and increase the possibility of landslides and other stability issues caused by runoff. Pollution from road traffic and toxic byproducts accumulate on the road’s surface, further degrading the water quality entering rivers and streams and directly threatening sensitive aquatic life, including native fish species. Additionally, our Roadless forests protect the headwaters of many rivers and streams. At least 25 million Americans rely directly on roadless area-influenced watersheds for their drinking water. Commercial logging, which is a major motivation for rule rescission, directly degrades water quality by increasing sedimentation, turbidity, and nutrient runoff, effectively driving up water treatment costs for millions of customers in downstream municipalities. The only option is to take the No Action alternative and keep the Roadless Rule intact. Further, the outdoor recreation economy brings in more money than commercial logging. One report estimated that the Roadless Area Conservation Rule brings $24 billion dollars of benefits each year across habitat, scenic, and recreation values. Hunting, fishing, and wildlife-watching alone contribute nearly $400 billion to the U.S. economy, while the broader outdoor recreation economy generates over $1.3 trillion annually. A potential 5-10% increase in Forest Service timber production from IRA logging would yield just $5.2-11.4 million of revenue to the federal government. This potential logging revenue would not add to the economic value of these forests. Rather, it would degrade the scenic beauty and other environmental values that drive our recreation economy. I live near many protected roadless areas, including the Shasta-Trinity National Forest, the Lassen NF, and the Klamath mountains. Rescinding the Roadless Rule would negatively impact my love and enjoyment of these lands. I stand for the protection of our roadless areas and the beauty of the American landscape. I oppose rescinding the Roadless Rule and urge the Forest Service to take the No Action alternative.

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I live near Los Padres National Forest and oftentimes recreate in the National forests of the Sierra Nevadas (such as Inyo National Forest, and Lassen National Forest). These roadless forests are some of the last places where we can still find and experience true wilderness. They are oftentimes critically important to ensuring the local communities surrounding them are supported through tourism. The Roadless Rule is immensely important for ensuring the biodiversity, water protection, and health of this beautiful state are protected. The rule also already allows important wildfire resilience work to be conducted and opening up these areas to roads and other disturbances would increase their fire risk due to human activities such as vehicle sparks, cigarettes, and arson. Removing the national protections would open these last intact forests to new roads and industrial logging at a time when agency capacity for careful planning and public engagement is already stretched to the limits. Removing the rule would also damage the intrinsic value wilderness provides to humanity. Please keep the Roadless Rule in place.

Rescinding these protections would be the single greatest setback in conservation efforts history, and would directly negatively affect the place that I work (Lassen National Forest). Please do not get rid of these protections.

I am commenting from a position as a lifelong user of our public lands. I grew up in Inyo County and the Eastern Sierra was my backyard. I backpacked, fished, hunted throughout the Sierra and Inyo/White mountains. I also worked for the Inyo NF first on a YACC crew, later a trail crew and also as a seasonal firefighter, so I feel have a lot invested in this issue. I have experienced access shrink on the Inyo NF and local BLM areas probably about 50 percent. Areas designated "wilderness areas" that have two track roads with ruts up to your knees, posted now as wilderness with no access (Inyo Mt Wilderness) and many other closed roads with no real input from local users. I've experienced the same thing on other forests where I also recreated and worked (Lassen NF, where I worked on a road crew) Plumas NF, and Shasta/Trinity NF while living in Lassen County. Over the years (decades actually) I've experienced our access to public lands through two track, minor roads, fire access and otherwise roads not considered maintained two lane roads. These roads have impacted land management and fire access which have created an extreme fire danger is many areas where the fire danger and intensity have resulted in millions of acres of severe loss of resources. Many of the fires have burned so hot that the soils have been virtually destroyed through sterilization and creating a water repellent surface. I have personally seen extensive erosion from these conditions and the lands will take decades if not centuries to recover. Let's move on to access. There are many folks who aren't able to walk in to sites that have existing roads that are closed due to administrative access restrictions with no real explanation as to the reason other than it's being studied or because the district ranger "said so". The citizens who actually own these lands are being shut out of them by kowtowing to special interest groups and the "sue and settle" process they use to force their will on everyone. This process impacts those people who are the least able to access these lands by means other than walking. The government strives to conform to ADA requirements but tends to shut out folks with mobility issues other than highly developed and very crowded areas. These roadless areas also impact those who have grazing, mining and logging leases which make it much more difficult to manage and rehabilitate the lands they have as a lease agreement. It seems that the heavy handed government land managers in many places (not all) are using roadless areas as a tool to erase years and decades of lands which are stated to be "multiple use" public lands. We need to have reasonable oversight and re-open these lands which have been "studied" for 3 to four DECADES! It is high time to open these lands again for public use and start managing these public properties. Locking up land and leaving it alone which increases fuel loads, lose access to prevent of fight fire, arrest erosion, and allow grazing lease holders to improve water catchment, fencing and range (feed) management. Thank you for considering my points towards re-opening restricted "roadless" areas, many which have existing roads but were redefined during the Clinton Administration to make it easier to close access to previously open areas. Randal Stevenson

I am a member of the public who has spent over a year volunteering on public lands and who has hiked thousands of backcountry miles, including the entire Pacific Crest Trail and Colorado Trail. I have deep experience specifically in Alaska, the Okanogan-Wenatchee National Forest and Lassen National Forest. I oppose the recission of Roadless Rule protections for several reasons. First and foremost, the country already has more forest roads than we can afford to maintain. As of 2023 - prior to recent Forest Service budget and staffing cuts - there was a backlog of $8.6 billion in deferred maintenance. I've hiked and attempted to drive on many miles of existing "road" that no longer accessible except to brave drivers with rugged vehicles, saws, and winches. Allowing more roads would only exacerbate this issue. Second, there is sufficient existing road coverage. Excluding Alaska, only about 25% of the acreage in the National Forests of the continental US is currently roadless; there is not a great enough economic need to erode that percentage further. (Alaska should perhaps be a special case, since it is around 2/3 roadless and since its tribal corporations have more land management rights.) Third, the Roadless Rule has already withstood many legal battles and proven its public support through over a million positive public comments when it was first created. Fourth, changes to these rules on federal land - owned by ALL members of the public - would have disproportionate impact on different communities. Eastern states would see little impact, but resource extraction industries in certain western states would accrue huge benefit. Fifth, this change would cost taxpayers money in a time when the federal government is already wildly overspending. Since natural resource sales from these lands are highly subsidized, more sales would mean more subsidies paid by federal taxpayers. It is hard for me to understand why anyone except timber harvesters, miners, and their friends would want this!

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.

Agency: U.S. Forest Service 
Docket: Proposed Revision/Rescission of the 2001 Roadless Rule To Whom It May Concern: My name is Dede Smullen, Co-Founder, Owner, and Board Chair of Earth Foundries, and a current Board Member, former Board Chair, former CEO, and former President of the Santa Clara County FireSafe Council. My work focuses on forest health, biomass utilization, wildfire resilience, and community wildfire risk reduction. I support revising the Roadless Rule to provide the U.S. Forest Service with greater flexibility to construct, maintain, and improve roads where necessary for wildfire mitigation, forest restoration, hazardous fuel reduction, and emergency response. Roads are a management tool and are often essential for the responsible stewardship of our public lands. This issue is personal to me. I have been directly impacted by both the Dixie Fire and the Park Fire in the Lassen National Forest region. These fires demonstrated the consequences of fuel accumulation and the challenges of managing large forest landscapes where access for restoration, fuel reduction, and suppression activities can be limited. Through my work with Earth Foundries, I have seen firsthand how inadequate access can increase the cost and complexity of forest restoration projects. Roads are often necessary to conduct mechanical thinning, remove hazardous fuels, and transport excess woody biomass to productive uses. Without access, many restoration projects become economically infeasible, leaving dangerous fuel loads on the landscape and reducing opportunities to utilize material generated through restoration efforts. Likewise, through years of leadership with the Santa Clara County FireSafe Council, I have seen the value of strategic access for fuel breaks, vegetation management, prescribed fire, and emergency response. Effective wildfire resilience depends on giving land managers the practical tools needed to reduce risk before catastrophic fires occur. I am concerned that the discussion surrounding the Roadless Rule increasingly emphasizes recreation and recreational access while overlooking the urgent need for active forest management. Recreation is an important use of our National Forests, but healthy forests, protected watersheds, resilient wildlife habitat, and safe communities must remain the highest priorities. I encourage the Forest Service to adopt a balanced approach that allows roads when they are necessary to improve forest health, reduce wildfire risk, support restoration activities, and protect communities and natural resources. Project-specific environmental review and modern best management practices can address resource concerns more effectively than blanket restrictions on access. Our public lands should be managed for long-term ecological resilience, not maintained under policies that can limit the ability to address conditions that contribute to catastrophic wildfire. Thoughtfully planned roads can help ensure that forest managers have the access necessary to restore and steward these landscapes for future generations. Thank you for considering my comments. Sincerely, Dede Smullen 
Co-Founder, Owner & Board Chair, Earth Foundries 
Current Board Member, Former Board Chair, Former CEO & Former President 
Santa Clara County FireSafe Council

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing this comment to oppose the rescindment of the 2001 Roadless Rule. The regional, state, and national parks of California are some of my favorite spots to visit and immerse myself in nature. Some of my fondest memories are of hiking the various trails, seeing the different ecosystems and wildlife that call these places their homes, and taking pictures of the scenery. Those experiences depend on the protections the 2001 Roadless Area Conservation Rule provides, and I oppose rescinding it. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The trails and wildlife I have sought out across this state and hope to visit in the future, such as Lassen National Forest and Sequoia National Forest, exist in large part because road construction has been kept out of these landscapes. The agency's own record makes clear that opening them is not a neutral act: "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 nonetheless justifies rescission partly on wildfire and fuels management grounds. I ask that the agency explain why the proposal departs from its own prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic rationale for rescission is just as difficult to follow. The agency's record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those marginal gains, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service while booking recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. That range cannot establish a net benefit, and the road system this rescission would expand already carries a $6.9 billion maintenance backlog, not to mention the great financial, cultural, recreational, and wildlife loss that this would cause. The agency must reconcile the proposal with those figures before proceeding. The regulatory flexibility analysis fails by the same measure. 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, meaning the downstream consequences for small businesses tied to clean water and recreation are not confined to timber counties. The agency reached its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. That methodology should not survive scrutiny. The agency must withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. Finally, the agency has structured public comment in a way that contradicts its own scoping decision. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). Asking the public to comment on scenarios the agency has simultaneously declared out of scope transfers the analytical burden to commenters rather than the agency. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred. To conclude, I oppose rescinding the 2001 Roadless Rule and ask the agency to take the actions noted above.

I am writing regarding the proposed recission to the 2001 Roadless Area Conservation Rule (docket number FS-2025-0001). The existing 2001 Roadless Area Conservation Rule, as it stands, is consistent with a conservative philosophy toward the National Forests and associated lands, and the stated rationale does not provide sufficient evidence for rescinding the Rule. First, the existing Rule already provides for recreation. I write as an individual who has traveled twice this year to remote areas for recreational purposes including hiking and dark-sky star gazing. Most recently, I returned only this week from Lassen Volcanic National Park and Lassen National Forest. My travels to these areas, and those of thousands of others like me, support local economies through lodging, food purchases, and various other expenses. The intent to travel to these remote areas is specifically to enjoy undeveloped areas, not to sit in traffic jams. Further, roads have a documented effect in fragmenting forests, and they provide a ready means for invasive insects or other species to travel easily. The proposed rationale provides no evidence that an increased number of roads would reduce insect or disease outbreaks. More broadly, fragmented forests are more susceptible to disruption as there is increased mortality for a variety of animals and generally altering the very ecosystems that the Forest Service is charged with maintaining. In short, the 2001 Roadless Area Conservation Rule is serving its intended purpose and recission of it would not be in the public interest.

Dear Special Areas: Roadless Area Conservation, Dear As a former U.S. Forest Service Hydrologic Technician across 5 National Forests in Washington, Oregon, Idaho, South Dakota, and California, I've experience the the wonder that lies in the depths of our public lands beyond the end of a road more than many of my fellow citizens. I've walked up on wolf pups in Washington, had a 200lb mountain walk up on me in Oregon, greeted a mother black bear and two cubs on a field survey, sprung bull moose while collecting water quality samples, night snorkeled a restored floodplain to find bull trout, and more. I completed my graduate research on hydrologic impacts of forest management on Lassen National Forest (Hydrologic Impacts of Forest Thinning: A Plot Scale Analysis, Serpa 2020, University of Nevada Reno). I'm an avid outdoor enthusiast, adventuring by foot, by bike, by packraft, and by rope, who takes every opportunity to share my love for our public lands with my two children who are 1 and 5 years old, especially in the Prescott, Kaibab, and Coconino National Forests near our home in Prescott Valley AZ. I have an intimate knowledge and connection to what lies beyond the end of the roads in our nation's Roadless Areas. In response to the U.S. Department of Agriculture's announcement that it is proposing a complete rollback of the 2001 Roadless Rule, I ask you to resist making this change. This is a move that, if finalized, would be the largest loss of protections for rivers on federal lands in U.S. history. Since 2001, the Roadless Rule has protected millions of acres of national forest lands that form the headwaters of some of the nation's most critical drinking water sources. Roadless areas safeguard more than 80,000 miles of rivers and streams, protecting fish and wildlife habitat and helping ensure clean drinking water for more than 25 million Americans, including residents of Denver, Atlanta, and Bozeman. This repeal threatens a conservation legacy that benefits all Americans. I urge you to conserve our nation's roadless forests and keep the Roadless Area Conservation Rule in place. I urge you on behalf of me, but more over on behalf of my 1 and 5 year old daughters, so that they may have the opportunity to experience what lies beyond the “end of the road” throughout their lives, and their children's lives. Even if they choose not to go and see these places, they will be among the millions of Americans who rely on the water and other and environmental services these Roadless Areas provide. Please DO NOT rescind the Roadless Area Conservation Rule. We all need these places to remain protected, so take action on my behalf, and on behalf of my daughters to uphold their protection. Please reconsider this action, and keep the Roadless Rule as it is: a significant protection for rivers, clean water, and wildlife across the country. Sincerely, Benjamin Serpa 7658 N Winding Trl Prescott Valley, AZ 86315 bserpa213@gmail.com Sincerely, Benjamin Serpa

As a former U.S. Forest Service Hydrologic Technician across 5 National Forests in Washington, Oregon, Idaho, South Dakota, and California, I’ve experience the the wonder that lies in the depths of our public lands beyond the end of a road more than many of my fellow citizens. I’ve walked up on wolf pups in Washington, had a 200lb mountain walk up on me in Oregon, greeted a mother black bear and two cubs on a field survey, sprung bull moose while collecting water quality samples, night snorkeled a restored floodplain to find bull trout, and more. I completed my graduate research on hydrologic impacts of forest management on Lassen National Forest (Hydrologic Impacts of Forest Thinning: A Plot Scale Analysis, Serpa 2020, University of Nevada Reno). I’m an avid outdoor enthusiast, adventuring by foot, by bike, by packraft, and by rope, who takes every opportunity to share my love for our public lands with my two children who are 1 and 5 years old, especially in the Prescott, Kaibab, and Coconino National Forests near our home in Prescott Valley AZ. I have an intimate knowledge and connection to what lies beyond the end of the roads in our nation’s Roadless Areas. I firmly oppose the repeal of the U.S. Forest Service’s Roadless Area Conservation Rule. The Roadless Rule is critical to the wellbeing of local communities across the country and protects thousands of miles of popular trails and beloved recreation spaces—repealing it would open millions of acres of conserved forests to development resulting in irreversible damage not only to our forests, rivers and wildlife but also to the American people and future generations who rely upon them. Further, there are significant fire risks from building roads into roadless forests. Between 80-85% of wildfires are started by people because of improperly discarded cigarettes, sparks from equipment and vehicles, unattended campfires, fireworks and arson. Research continues to prove that fires are far more likely to start alongside roads than in roadless areas. Leading wildfire scientists agree that repealing the Roadless Rule could unintentionally lead to an increase in fire ignitions. This repeal threatens a conservation legacy that benefits all Americans. I urge you to conserve our nation’s roadless forests and keep the Roadless Area Conservation Rule in place. I urge you on behalf of me, but more over on behalf of my 1 and 5 year old daughters, so that they may have the opportunity to experience what lies beyond the “end of the road” throughout their lives, and their children’s lives. Even if they choose not to go and see these places, they will be among the millions of Americans who rely on the water and other and environmental services these Roadless Areas provide. Please DO NOT rescind the Roadless Area Conservation Rule. We all need these places to remain protected, so take action on my behalf, and on behalf of my daughters to uphold their protection. Thank you for taking action on my belay as a valued citizen, voter, and public land shareholder.

I oppose rescission of the 2001 Roadless Rule – Docket FS-2025-0001 The Roadless Rule is one of America’s most important conservation wins. Having hiked and backpacked in some of the West's still wild areas (Tahoe National Forest, the PCT and Lassen National Forest) I have seen first-hand Nature undisturbed. Only the sound of my footsteps, birds, rushing water and wind have kept me company. It is an amazing feeling that I wish all people had a chance to experience, to help others understand the importance of leaving a part of our natural world alone. Plenty of land is open to logging, mining and motorized vehicles. Let us keep some of our unique wild lands untouched so that life, other than humans, can thrive as best they can in a heating world. The Roadless Rule has been an effective, durable baseline that protects water quality, wildlife habitat, carbon storage, and high-value backcountry recreation across tens of millions of acres. If the Roadless Rule is repealed and decisions are made only at the local level, protections will become fragmented and uneven. That weakens the overall conservation framework, without any credible evidence that the national rule itself is what limits our ability to address forest health or wildfire risks.

To the USDA Roadless Rule Rulemaking Team: For a scientist, the words 'best available science' in a federal document are a commitment. This proposal doesn't honor that commitment. I am an environmental biologist who has studied conservation science. The plan to remove the roadless rule has the potential to cause irreversible harm to our ecosystems. The fallacy that removing the roadless rule will decrease fires is not supported by any science. Removing the roadless rule will likely cause massive increases in fires, all while impacting our local water quality and habitat for protected wildlife. Roadless areas are not administrative abstractions; they are the places this comment has described, and the Rule is the legal instrument that keeps them whole. Regarding the Mill Creek in the Lassen National Forest, California: Within Lassen National Forest, the Mill Creek IRA provides habitat for California Spotted Owl (Strix occidentalis occidentalis, T2), a species subject to 7.1 - Fire & fire suppression — a threat assessed at Serious - moderate severity affecting Pervasive - large of the population. Road construction in Mill Creek introduces sediment, alters hydrology, and delivers chemical contaminants to adjacent habitats — the direct physical drivers of 7.1 - Fire & fire suppression. The DEIS must provide site-specific analysis of 7.1 - Fire & fire suppression impacts to California Spotted Owl (Strix occidentalis occidentalis) in the Mill Creek IRA — not a programmatic discussion of roadless areas generally but a particularized assessment of this species in this place. "Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. Effect distances were positively associated with traffic intensity in various ecological species groups." — Landscape Ecology (Springer Nature), 2025 The 2001 Roadless Area Conservation Rule represents a valid exercise of the Department's rulemaking authority and should not be undone. With concern, CommentID: RLC-20260901-XNUDYP