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I am a lifelong California resident who grew up in the Los Padres National Forest. America’s national forests and untouched wilderness are some of our most precious resources. We need to preserve our wilderness—not because they need to be mined or logged or drilled but because they sustain the ecosystems, clean air, and clean water needed to continue living on this planet. We have already suffered devastating impacts to our climate and natural resources, including clean water, that threaten human lives on a broad scale. Increasing frequency and scope of wildfires is one example of looming danger to more and more communities every year. It is a misconception that the Roadless Rule increases wildfire risk. From the Sierra Club website: “New research from The Wilderness Society (now in peer review) shows that from 1992-2024, wildfires were four times more likely to start in roaded areas than in roadless forest tracts” and “another study by the Pacific Biodiversity Institute showed that over 90% of wildfires started within half a mile of a road.” I nearly lost my parents to the Thomas Fire in 2017 and have known people who lost their homes or suffered lasting health effects from the increasingly catastrophic wildfires in California. Reduce wildfire risk. Preserve our wilderness. Do not repeal the Roadless Rule.

I strongly support keeping the Roadless Rule in place, including protections for roadless areas in the Los Padres National Forest. I grew up spending a lot of time outdoors, and those experiences shaped my deep appreciation for wild places. The forests, mountains, and open spaces I was fortunate enough to experience helped teach me to love and respect the natural world. I want future generations to have that same opportunity. Protecting roadless areas is about more than preserving beautiful landscapes. It is about maintaining safe, undisturbed spaces where wildlife can thrive, supporting biodiversity, protecting intact ecosystems, and allowing wild places to remain wild. Once these places are fragmented or developed, we cannot simply recreate what was lost. The Los Padres National Forest is a special part of our natural heritage, and its remaining roadless areas deserve to be protected. I urge decision-makers to keep the Roadless Rule and preserve these wild spaces for wildlife, for future generations, and for everyone who finds meaning and connection in the outdoors.

I strongly support keeping the Roadless Rule in place, including protections for roadless areas in the Los Padres National Forest. I grew up spending a lot of time outdoors, and those experiences shaped my deep appreciation for wild places. The forests, mountains, and open spaces I was fortunate enough to experience helped teach me to love and respect the natural world. I want future generations to have that same opportunity. Protecting roadless areas is about more than preserving beautiful landscapes. It is about maintaining safe, undisturbed spaces where wildlife can thrive, supporting biodiversity, protecting intact ecosystems, and allowing wild places to remain wild. Once these places are fragmented or developed, we cannot simply recreate what was lost. The Los Padres National Forest is a special part of our natural heritage, and its remaining roadless areas deserve to be protected. I urge decision-makers to keep the Roadless Rule and preserve these wild spaces for wildlife, for future generations, and for everyone who finds meaning and connection in the outdoors.

I support keeping the Roadless Rule and continuing to protect the remaining roadless areas within the Los Padres National Forest. I was fortunate to grow up spending a great deal of time outdoors, and those experiences gave me a lasting appreciation for wild places and the importance of protecting them. Being able to experience nature in its more untouched form shaped how I see and value the natural world, and I believe we have a responsibility to preserve those opportunities for future generations. Roadless areas provide essential habitat where wildlife can thrive with less disturbance, while also helping protect biodiversity and intact ecosystems. These wild spaces have value simply because they exist as they are — places where nature can continue to function without being altered or fragmented. The Los Padres National Forest is an important part of California's natural landscape, and its roadless areas deserve continued protection. I urge decision-makers to maintain the Roadless Rule and ensure the

I am writing to strongly urge the United States Forest Service (USFS) to preserve the Roadless Rule in its full capacity. The science is clear, roads are one of the biggest threats to healthy ecosystems across our federal lands. We know that roads create erosion, roads deposit sediment into watersheds, roads inhibit animal migration. It also is known that the vast majority of human caused wildfires are caused on or along roads! While the USFS is currently arguing that we need roads to mitigate wildfire risk, we need to acknowledge the serious threat that building more roads creates for the very issue it aims to address. Simply put, roads are the source of many wildfires. I fell in love with the natural environment and studying environmental sciences in wild and roadless places within the Los Padres National Forest in Coastal California. I took that love of nature and dedicated my professional career to it. Now, with a degree in Environmental Science and a career in Natural Resources Management, I look at the USFS attempted rescission of the Roadless Rule as one of the worst decisions this agency has attempted to make in recent history. It is painfully obvious that the intent of rescinding the Roadless Rule is not truly to mitigate wildfire risk. Rather, the public can safely assume that rescinding this rule is a sorry attempt at opening federal lands for increased natural resource extraction. I hope USFS decision makers understand the permanent detriment that rescinding the Roadless Rule will have on our federal lands. Wild places will never be wild again. People will never be able to enjoy these serene landscapes again in the same capacity. Ecosystems will forever be impacted. And worst of all, the door will be opened for private resource extraction in some of the most ecologically valuable places in America. Once that door is open, it will never be closed. I strongly urge the USFS to preserve the Roadless Rule and fulfill its responsibility to properly manage the public lands of America.

October 5, 2026 Secretary Rollins, I am in firm opposition of the proposed repeal of the U.S. Forest Service’s Roadless Area Conservation Rule. My name is Molly Troup and I have my master’s degree in environmental science and management. Since obtaining my degree, I have dedicated my career to protecting the public resources that the Roadless Rule currently helps to protect including creeks, rivers, and wildlife. Road building and logging will have detrimental effects on important resources, particularly water resources through soil erosion, runoff, and stream sedimentation (DEIS pg 111, 117, 118). Building roads in wilderness areas will negatively impact biodiversity and degrade critical habitats and has the potential to increase the introduction and spread of non-native species (DEIS pg 151, 160). Additionally, I am a trail runner, hiker, and backpacker and an avid user of our incredible local wilderness area, the Los Padres National Forest. I spend time in the Los Padres National Forest every week. In addition to my local roadless areas, I deeply value other ones as well. My family and I, including my three year old son, actively seek out these areas to explore and recreate in for or vacations. I deeply value these vast areas, as do so many others. This is clearly supported by the outdoor recreational economic activity. Recreation and tourism contribute billions of dollars to the economy (DEIS pg 212), which is much more than the millions that logging is projected to produce (DEIS pg 220). There are many more reasons that this repeal does not make sense, including facts that forest fires are most often caused by humans, creating more roads will simply increase the number of fires. Additionally, the Forest Service is unable to maintain the number of roads that they currently have in their inventory, new ones should not be added. This repeal threatens a legacy that benefits all Americans. I urge, particularly for current and future generations to conserve our nation’s roadless forests and keep the Roadless Area Conservation Rule in place. Sincerely, Molly Troup

My name is Christina and I live in Santa Barbara, CA with my 9 year old son. I'm raising him as a single mom. We treasure our time together hiking and running together in the Los Padres National Forest. We both are imploring you to KEEP the Roadless Rule! The Roadless Rule has protected over 58 million acres of wild forests nationwide for more than 20 years, including nearly 9 million acres in California. These protections keep streams clean, safeguard wildlife habitat, and preserve access to unspoiled landscapes for hiking, fishing, and connection with nature. Studies have shown that more roads near wilderness areas increase the number of wildfires. Please do NOT let it be rescinded! When I was growing up there was never a "wildfire season" and now the threat of wildfires are a definite concern. Some of the largest wildfires have happened in Santa Barbara County and one where I have vivid memories is of the Zaca Fire in 2007. It "burned for four months in the backcountry, scorched many of the 240,000 acres within its final perimeter for the first time in recorded history, and cost $120 million to contain." "(source: https://sbfiresafecouncil.org/fire-history-of-santa-barbara-county/) The air quality was so bad and I remember it being so hot and not being able to open windows with no a/c with the loud of whirr of helicopters and planes pretty much non-stop trying to contain it. Then in 2009 the Jesusita Fire, and in 2017 the Thomas Fire where I ended up voluntarily evacuating because my son was still so little and I didn't want him breathing in all the bad air. We were actually wearing N95 masks INSIDE my workplace at the University of California, Santa Barbara at the time because the air quality was so bad! Studies have shown that there are an increase in the start of these wildfires where there are roads. We have the Roadless Rule in place for a reason, let's not do anything do make the current global climate worse off than we are already. I want outdoor spaces I can show and share with my son, for him to have the love for nature and appreciation for spaces that I do. Spaces where he can go to clear his head and get away from the busyness of life. We all deserve to have spaces like that. Let's keep the Roadless Rule in place please, let's preserve and protect our natural resources. Thank you for reading and listening.

I am writing to support the 2001 Roadless Area Conservation Rule. I grew up in a small town nestled in the Los Padres National Forest, surrounded by nature and beautiful wilderness that would later become Antimony and Sespe Roadless areas. As an adult I have been an avid hiker, including significant portions of the Pacific Crest Trail in addition to my home mountains. It is important to preserve these wilderness areas for the good of all American people. Wildfire is always a concern in our dry part of California, but logging of trees that provide shade and wildlife habitats does not reduce fire risk. Brush clearance and closing of the National Forest during wind events has successfully prevented fires in our area. Increased roads and logging of trees that would take decades or a century to grow back would be just as catastrophic as wildfire. We need our old growth trees to preserve wildlife habitats, watershed and recreation which supports our local economy. Please protect our roadless public land and resources for future generations. Thank you.

he Road Rule should remain in place. Removing the protection will be a detriment to our forests, wildlife, waterways and commerce. Studies have shown that wildfires start near roads. Careless people throwing stuff out the windows and such. Black Butte roadless area in Los Padres National Forest is the kind of place the 2001 Roadless Area Conservation Rule was written to protect, and I am filing this comment to oppose its rescission under Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres. Black Butte, at 5,116 acres, is one of them. The rule has stood for more than two decades as the legal foundation protecting that landscape from road construction and the cascade of consequences roads bring. Rescinding it without a credible substitute is a detriment to our environment. It is not necessary for any additional roads to be built. They also require additional maintenance. The forests should remain pristine. The agency advances wildfire management as a justification for rescission, but its own prior findings directly undermine that argument. The agency already found: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. Noting that a human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially roadless lands." That finding did not vanish because the agency changed administrations. The agency’s current reliance on wildfire management therefore appears inconsistent with its earlier recognition that increased road access can itself heighten the risk of human-caused wildfire. Why is agency departing from its own prior findings on fire occurrence and fuel treatment in roadless areas? Why would you want to rescind in spite of the ignition data its own draft environmental impact statement contains? Doesn't make sense. Seems the only reason these protections are being rescinded so they can be extorted and logged and mined. Once a road is in place easier access to destroy. Extending roads will mean more car traffic and cars killing animals, struck while crossing the road. Rescinding the rule would put wildlife at risk. Timber and mining make the land unstable so remaining trees could have ill effects and definitely the soil erosion would present a problem. The quality of our air and water would also be effected by building roads in the currently protected forest. We also have an environmental industry that this would adversely effect.The protection of those watersheds has supported not only ecological integrity but also the outfitters, guides, and recreation businesses that depend on intact, unroaded landscapes. 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. That certification is reached by spreading estimated losses across every small firm in the sector nationally rather than examining the businesses that actually hold permits in the areas at risk. The agency concedes that some firms may lose those receipts entirely. A certification that reduces the effects on individual small entities to a national average does not fulfill the purpose of a regulatory flexibility analysis. The agency should withdraw the certification and instead evaluate specific impacts on small entities operating within the roadless area that would be affected.

I oppose rescinding the 2001 Roadless Rule and ask the USDA to keep these protections in place. Through my work with the Greenfield and Salinas Community Science Workshops, I help connect children and families in Monterey County with science and the outdoors. Places like Arroyo Seco and the Los Padres National Forest are important to this work. They give young people opportunities to explore, ask questions, and learn about the natural world firsthand. For the communities we serve, protecting these places means protecting opportunities for children and families to experience them. It also means caring for the water, wildlife, and landscapes that are part of our home. I am particularly concerned about preserving the headwaters of Santa Lucia Creek near Arroyo Seco. Keeping roadless protections in place will help safeguard this area while efforts toward permanent wilderness protection continue. Please retain the Roadless Rule. Our children deserve the opportunity to know and enjoy these places, and we have a responsibility to care for them. José S. Sánchez

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Sespe Wilderness in the Los Padres National Forest is where I go to find untouched nature. The quiet there is real. I hike and camp in those public lands because I can still see rabbit, coyotes, deer, foxes, and birds moving through country that roads have not yet broken apart. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule. The agency's own record undermines the wildfire rationale offered for 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." If opening roadless areas to new construction increases ignition risk by that magnitude, the agency must explain why it is advancing a proposal that its own findings predict will make fire more likely, and it must reconcile that explanation with the ignition data in DEIS Table 21, which the record shows reports far higher fire density on roaded land than inside the affected roadless areas. The deer I see in the Los Padres matter to this analysis. The DEIS cites research finding that roads built for oil extraction may have altered mule deer migration routes and increased their movement speed. The agency's own record also credits the rule's protections with contributing to the recovery of deer populations in Alaska by preserving old-growth winter shelter. Rescinding the rule would expose deer in forests like the Los Padres to exactly the disrupted migration and lost unroaded security that the agency's own citations document. I ask that the agency explain what specific habitat and wildlife findings support departing from that record where deer are concerned. Birds are the other reason I go out there. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The Los Padres holds birds I can currently find in places that roads have not reached. What assurance does the agency offer that rescinding this rule will not produce the abundance and richness losses its own cited research predicts? The economics do not support rescission either. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified when the agency's own numbers cannot establish a net benefit. The legal footing for rescission is no stronger. The proposal argues that state-by-state approaches can replace a national rule, but the agency's own record states: "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." The Ninth Circuit already reviewed a state-by-state replacement and found it wanting. The agency must address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values and explain how this proposal avoids those same deficiencies. On authority, the proposal argues the 2001 rule exceeded what Congress permitted. The Tenth Circuit held otherwise, and its own words are clear: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address that court's holding that the 2001 rule fell within authority granted under the Organic Act and MUSYA and did not create de facto wilderness, and state plainly what legal basis supports a contrary position now. The Los Padres is peaceful because it is intact. I want it to stay that way. The agency has not answered its own record, and it should. The Roadless Rule should not be rescinded. Sincerely, Mitchell Johnson Ojai, California

The Honorable Brooke Rollins Secretary, U.S. Department of Agriculture 1400 Independence Avenue SW Washington, DC 20250 Dear Secretary Rollins, I am writing to urge you to select the No Action Alternative and keep the national Roadless Rule fully intact. The rule protects some of the last unfragmented backcountry in our national forests, and repealing it would put more than 40 million acres at risk of new road construction and industrial development. I live in Ojai, California, at the edge of the Los Padres National Forest. For over a decade I have hiked the Nordhoff Inventoried Roadless Area, which rises just above my home. I have watched it through drought, fire, and recovery, and it remains one of the quiet, wild places that make this community what it is. My family and I also hike and camp in the Sespe-Frazier Inventoried Roadless Area, where my kids have learned what it means to spend time in country that is still wild. Places like these cannot be replaced once roads cut through them. Across the Los Padres, more than 600,000 acres of roadless land are at stake. These lands matter for several reasons. Wildlife and biodiversity - Roadless forests give mountain lions, black bears, California condors, and many other species the large, connected habitat they need. Roads fragment that habitat, and they put the native plant communities these animals depend on at risk too. Clean drinking water - Roadless areas protect headwaters and watersheds that supply drinking water to communities downstream. More roads mean more erosion and sedimentation, and poorer water quality. Wildfire - I speak about this issue from experience. I worked as a seasonal wildland firefighter for eight years across the Mountain West with the U.S. Forest Service, Bureau of Land Management, and Joshua Tree National Park and I know how fires start and spread. You argue that repealing the Roadless Rule would improve fire management, but research shows that wildfires are more likely to start near roads, because roads bring people and ignition sources deeper into the forest. The rule already allows many forest management and fire mitigation activities. In my experience, what makes communities safer is investing in defensible space, home hardening, and prescribed fire near communities, not building new roads into remote backcountry. The Roadless Rule has protected our national forests for more than two decades with broad public support. Please keep it in place, choose the No Action Alternative, and protect America's remaining intact forests for the next generation. Thank you for your consideration.

Hello, While the benefits I feel are personal as I enjoy being able to visit and hike through California's natural forests and landmarks, I am also opposed to the rescinding of the Roadless Rules/Roadless Areas Conservation for the additional following reasons: While Roadless Areas only comprise 20% of California’s national forests, their benefits are varied and vast, including: Roadless Areas protect drinking water supplies and water sources for agriculture. Roadless areas supply 50% of California’s drinking water. Roadless Areas act as fire buffers for communities and land managers since roadless areas experience far fewer human-caused fire starts than do areas with roads Roadless Areas support the military in many areas of California by helping to maintain large, undeveloped areas of land to conduct training and operations and/or serve as a crucial buffer against urbanization and other forms of outside influences that inhibit capacity for training and testing activities. Contrary to assertions by the USDA, the 2001 Roadless Rule does not do any of the following: The Roadless Rule does not impede national forest planning at the local level. Rather, the Roadless Rule is one of many overarching rules that guide local national forest staff. The Roadless Rule does not harm local economies. In fact, the Roadless Rule keeps drinking water clean for rural and urban communities alike here in California, thereby helping decrease cost on water. Water for agriculture and domestic use and public land related visitation and tourism benefit rural communities thanks in part to the lands covered by the Roadless Rule. The Roadless Rule does not impede fire suppression. To the contrary, the Forest Service is allowed to use all tools available for firefighting in roadless areas, including bulldozers and aircraft. Fire suppression of active wildfires in roadless areas in California’s national forests is not uncommon. The Roadless Rule does not impede fire risk reduction. Actually, California national forests such as the Los Padres National Forest and Tahoe National Forest conduct fuel management projects in roadless areas while adhering to the Roadless Rule. Existing roads on the boundaries of roadless areas provide adequate access for fire risk reduction. The current proposal would allow new road construction and the logging of our largest trees in roadless areas, despite the increased fire risk and the fact that the U.S. Forest Service cannot currently afford to maintain its existing 47,000 miles of roads in California.

I have hiked most of the Pacific Crest Trail (PCT) which passes through 63 Inventoried Roadless Areas (IRAs) along 288 of its 2653 miles. I write to strongly oppose the proposal to eliminate protections in these and other IRAs around the nation. The administration falsely claims that road building in IRAs will help to prevent wildfires. In reality, and as numerous studies have shown, the presence of roads greatly increases the chances of ignition from passing vehicles, carelessness, or deliberate arson. Consider the Angeles National Forest that has seen one human-caused fire after another. Now almost no large trees are left. The 2009 Station Fire that burned 160,000 acres was started by an arsonist who used Highway 2 to gain access to the forest near mileage marker 29. The huge network of USDA Forest Service roads that penetrate our national forests have likewise been the source of countless ignitions. Indeed the past century of Forest Service mismanagement has had a devastating effect on these lands, mismanagement that is closely connected with roads. Secretary of Agriculture Brooke Rollins is not going to get away with her lies about real sources of most wildfire. And the mismanagement does not end with fires. Forest Service roads are poorly maintained, eroding the landscape and posing hazards to people that use them. The Forest Service is in no position to expand its road network further; instead it must remove roads and restore our lands. Such a positive activity would protect and enhance trails such as the PCT. Since the Forest Service has almost entirely given up maintaining trails, this work is largely conducted by dedicated volunteers. Removing protections for IRAs such as the extensive ones found in the Klamath Mountains or Los Padres National Forest would be a slap in the face to the volunteers like me who have worked to cover for the failings of the Forest Service. How dare the administration consider doing this! Of course we know the reason for this proposal: It is all about serving Mammon, about "getting the cut out" and "getting the oil out." In reality outdoor recreation is a true and enduring source of economic activity -- one that does not devastate the land. The outdoor recreation economy generates $730 billion annually, far more than timber sales. IRAs store 20% of all carbon in U.S. national forests. And IRAs are crucial habitat for 1,600+ threatened species. The greed and dishonesty of the administration will be its undoing.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The California Condors soaring over the Los Padres National Forest, the mountain lions, badgers, kangaroo rats, and arroyo toads I have spent years observing in roadless areas throughout that forest, and the raw wild places I seek out on foot, by bike, and with a camera to capture canyons, watersheds, meadows and mountains unmarked by roads, are all directly threatened by the proposal to rescind the 2001 Roadless Area Conservation Rule. I am filing this comment in opposition to Docket FS-2025-0001. The White Ledge Roadless Area, all 18,632 acres of it, is the closest roadless area to where I live and have grown up. It is a place I have admired from afar for my whole lifetime and, more recently, explored on foot and by bike on trails including Cold Springs and Boulder Canyon. Much of what characterizes White Ledge is the lack of roads, and the agency's own record speaks directly to what roads would bring. The agency has stated: "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 White Ledge watershed and its habitat would face exactly this elevated ignition risk the moment road construction begins. The proposal justifies rescission in part on wildfire and fuels management grounds, yet it departs from its own prior findings. I ask that the agency explain, in plain terms responsive to the record, why the rescission contradicts its own ignition data, including the fire density comparisons reported in DEIS Table 21, which show far higher fire density on roaded land than inside affected roadless areas. The Sespe-Frazier Roadless Area covers 106,910 acres, acts as a critical buffer zone to the Sespe Wilderness and condor sanctuary, and supports recreation and tourism throughout my neck of the woods. California condors have little margin for error, and neither does this landscape. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. Roads degrade water quality; I have said that plainly with respect to White Ledge and the principle holds no less for Sespe-Frazier. The agency should be required to explain on the record how water quality across those 1,034 intake watersheds is protected under this proposal. The economic justification for this rescission is not sustained by the agency's own numbers. The record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million per year against recreation losses of at least $6.1 million per year, with a net present value ranging from -$92 million to +$199 million. That range cannot establish a net benefit. The agency must reconcile this proposal with a road system already carrying a $6.9 billion maintenance backlog and explain how adding roads to places like the trails I ride, including Oceanview, Franklin, Romero, Gridley, Middle Sespe and others throughout the Los Padres, is fiscally responsible when the numbers in its own analysis do not close. On the question of replacing a national rule with state-by-state approaches, the agency's own record states: "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." The Ninth Circuit has already examined that logic and found it wanting the last time the agency pursued this path. The agency must address, specifically and on the record, how this proposal avoids the deficiencies the Ninth Circuit identified in the prior state-by-state attempt, and how local decision-making will not incrementally reduce nationally significant roadless values in ways that cannot be undone. Finally, the rescission is framed in part as a response to administrative and permitting burdens, yet the rule as written already provides that 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)." Before eliminating protections that give places like White Ledge and Sespe-Frazier their character, the agency must identify with specificity which burdens are not already handled by these existing exceptions, and quantify them. Sincerely, Ben Van Der Kar Carpinteria, CA

See attached file(s) Dear Acting Director White: The undersigned organizations working throughout California's central coast region, including communities surrounding Los Padres National Forest, submit these comments in opposition of rescission of the 2001 Roadless Area Conservation Rule (“Rule”). We urge USDA to select Alternative 1, No Action, and retain its protections. Rescission would expose roadless lands to additional road construction and industrial development, increasing wildfire risk and threatening the clean water, wildlife habitat, cultural resources, and outdoor experiences these landscapes sustain. The Draft Environmental Impact Statement (DEIS) acknowledges many of these impacts.

I live in Colorado and recreating in the Western United States is the great joy of my life. Running, climbing and fishing are the most meaningful experiences for me and seeing the areas that would be impacted by the proposed change is nothing short of devastating. I would very much encourage those proposing the change to listen to the voices of those who enjoy this land and live in the United States because of our amazing access. We need to preserve the land that makes this country special, not listen to the greedy extractive demands of those who have hardly stepped foot on the places they will destroy. Places impacted by this change that I frequently use would include Bears Ears, Grand Staircase Escalante, Los Padres National Forest, Sierra National Forest, Cuyamaca Mountains, the La Sals, and many other places over the years.

Re: Special Areas; Roadless Area Conservation - proposed rescission, 91 FR 53827 (Aug. 20, 2026) | RIN 0596-AD66 | Docket FS-2025-0001 I oppose rescinding the 2001 Roadless Rule and ask that the Department withdraw the proposed rule, or at minimum adopt an alternative that retains the national baseline and requires site-specific NEPA before any road construction or commercial harvest in inventoried roadless areas. I am a U.S. military veteran and an America the Beautiful Military Lifetime Pass holder. I live in San Francisco, and these areas are where I actually spend my time - the San Gorgonio Wilderness (San Bernardino NF), the Cucamonga Wilderness and the San Gabriel high country around Mount Baldy (Angeles NF), the Mount Pinos country in Los Padres NF, and the eastern Sierra out of Mammoth. The reason those places are still quiet is the 2001 rule. I also drive SR-38 to the Vivian Creek trailhead, which has washed out repeatedly since the 2020 El Dorado Fire - a reminder of what these steep headwater drainages do after fire, and why road density and ground disturbance in them matter. Four specific comments: 1. The stated problem does not require this remedy. USDA keeps the Idaho (subpart C) and Colorado (subpart D) roadless rules and notes that any state, tribe, or entity may petition under 5 U.S.C. 553(e) for tailored management. If place-based roadless rules are workable - and USDA is retaining two - then "one-size-fits-all" is not a justification for repealing the baseline everywhere else. The Department already has the mechanism it says it needs. 2. "Returning decisions to land management plans" is a plan of absence. The notice states the rule "does not require or compel the amendment or revision of any land management plan." For forests whose plans do not independently prohibit road construction and harvest in roadless areas, rescission leaves a gap with no protection until a plan is revised - years, for many units. The final EIS should state, acre by acre, how much of the 58.5 million acres retains equivalent protection on day one and how much does not. The notice asserts effects are "bounded by existing land management plan direction" without demonstrating what that direction is. 3. The economics are close to a wash; the losses are not. USDA's own figures: timber-industry gain of $4.6-10.6M/yr, recreation loss estimated at $6.1M/yr - against a $6.9 billion deferred-maintenance backlog on the existing forest road network. Building new roads you cannot afford to maintain, for revenue the same order as the recreation value displaced, is not a net-benefit case. The road-maintenance liability of new permanent roads is missing from the analysis. 4. Wildfire. The notice concedes greater access "can increase human-caused ignition potential." If road construction is justified as fire-risk treatment, the EIS should quantify treatment acreage actually achievable within operability and budget over ten years, and compare it against the acres each new road puts at higher ignition risk. The 9.8 million WUI acres overlapping roadless areas deserve a spatially explicit alternative, not blanket repeal. Alternative I support: No Action, or a targeted-WUI-treatment alternative permitting fuels reduction and temporary access within a defined distance of at-risk communities while retaining the prohibition on new permanent roads and commercial harvest in the interior of inventoried roadless areas. As a veteran, I value these lands for the quiet, self-reliant recreation they provide, and I ask the Department to keep the protection that makes them what they are. Please withdraw the proposed rule. Brian Mauck - San Francisco, CA

I live minutes away from the Los Padres National Forest in California. This is why the Roadless Rule Still Matters: The Los Padres National Forest is one of California’s greatest treasures — a wild landscape of chaparral, pine forests, meadows, and rivers. It provides clean drinking water, habitat for endangered species like the California condor, and an escape into nature for millions of people each year. But today, it faces a serious threat: the rollback of the Roadless Area Conservation Rule, which safeguards 58 million acres of national forest lands across the country. If protections are stripped away, more than 600,000 acres of wilderness-eligible lands in Los Padres could be opened to road construction and industrial logging [1]. These are some of the most ecologically intact areas in Southern California, and losing them would irreversibly fragment habitats, degrade watersheds, and diminish the forest’s wild character. One of the most biodiverse of these landscapes, the Sespe-Frazier roadless area, is home to the endangered California steelhead trout [6]. Altogether, Los Padres shelters 23 threatened and endangered animals, plus iconic species like mountain lions, bears, and the California condor, along with 3 federally listed plants and 74 rare or sensitive plants [7]. This biodiversity makes the forest irreplaceable. Supporters of eliminating the Roadless Rule argue that it would reduce wildfire risks. But research shows that roads actually increase the likelihood of fire by clustering human-caused ignitions [2][3]. Between 2013 and 2023, nearly 88% of wildfires nationwide were caused by people, most of them accidental [3]. Building more roads will not make us safer — it will make fire risk worse. Logging too is no silver bullet; salvage logging can leave behind fuels and younger forests that burn more intensely [5]. Beyond fire, development pressures are mounting near Santa Barbara, Ventura, and San Luis Obispo. Grading for housing and roads threatens watersheds, while habitat fragmentation severs wildlife corridors critical for species like mountain lions and bears [4]. Recently, more than 90 environmental, tribal, and community groups called on the Forest Service to rethink a plan to log and clear nearly 91,000 acres of Los Padres. They propose a 'Community Alternative' that scales back the plan by 83%, protects sensitive ecosystems, and focuses vegetation treatments where they actually reduce fire risk near communities [8]. This is a clear example of how local expertise and ecological science can guide smarter, safer management of our forests. Los Padres is more than just open space — it is a living system that sustains clean water, biodiversity, and California’s cultural and natural heritage. Weakening protections would be a short-sighted mistake with lasting consequences. Instead, we must strengthen conservation, focus development in safer places, and embrace fire prevention rooted in science rather than politics. If we value clean water, biodiversity, and the chance to experience unbroken wilderness where condors soar, steelhead trout run, and mountain lions and bears still roam free, we must act now to keep Los Padres wild. Sources [1] San Luis Obispo Tribune. 'Protections at Risk for 600,000 Acres of Los Padres National Forest.' https://www.sanluisobispo.com/news/local/environment/article309740815.html [2] Narayanaraj, Ganapathy, et al. 'Influences of forest roads on the spatial patterns of human- and lightning-caused wildfire ignitions.' Applied Geography, 2012. https://www.researchgate.net/publication/256972109_Influences_of_forest_roads_on_the_spatial_patterns_of_human-_and_lightning-caused_wildfire_ignitions [3] Edgeley, Catrin M., et al. 'Preventing Human-Caused Wildfire Ignitions on Public Lands: A Review of Best Practices.' Forest Science, 2025. https://www.researchgate.net/publication/392102962_Preventing_Human-Caused_Wildfire_Ignitions_on_Public_Lands_A_Review_of_Best_Practices [4] California Board of Forestry and Fire Protection. Chapter 0340 – Fire Protection Policies, 2003. https://bof.fire.ca.gov/media/9116/8-6-chapter_0340_fireprotectionpolicies-ada.pdf [5] Wibbenmeyer, Matthew, and David N. Wear. 'Will Increased Timber Harvesting on Federal Lands Reduce Growing Wildfire Hazards?' Resources for the Future, 2025. https://www.rff.org/publications/reports/will-increased-timber-harvesting-on-federal-lands-reduce-growing-wildfire-hazards/ [6] U.S. Forest Service. Sespe Wild and Scenic River. https://rivers.gov/river/sespe [7] U.S. Forest Service. About Los Padres National Forest. https://www.fs.usda.gov/r05/lospadres/about-area [8] Los Padres ForestWatch. 'Groups Sound Alarm on Controversial Logging and Clearing Plan.' June 2025. https://forestwatch.org/news/groups-sound-alarm-on-controversial-logging-clearing-plan/ Sincerely,

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Ben Van Der Kar, I live in Carpinteria, CA and work as an avocado grower. I hold a Volunteer Service Agreement with the Ojai Ranger District of the Los Padres National Forest as an official volunteer of the district, helping provide reports on the condition of trails, campsites and forest service roads and also helping to lead volunteer trail maintenance events. Through my passion for the well-being of our shared public lands, I also play a lead role in several local volunteer trail organizations including the Ojai Get it Done Crew, Los Padres Forest Association, Montecito Trails Foundation, and SAGE Trail Alliance. Additionally, I am part of the ambassador team of stewards for Bikepacking Roots, a national non-profit committed to bikepacking access, education, and route stewardship. In my area, the Roadless Rule provides valuable protections that help preserve the rural, undisturbed nature of the landscape while also helping protect water quality, habitat, and unique recreational opportunities that can only be found in roadless areas. Wildfire mitigation and risk reduction is another huge benefit offered by areas protected by the roadless rule, as countless studies have demonstrated that the presence of roads inherently increases wildfire risk. Moreover, there is a growing understanding of the cognitive benefits that come from being able to recreate in areas free from roads and development and yet sadly, such places are increasingly limited and thus, increasingly important to preserve. From my backyard, I look up at several Roadless Areas, namely the White Ledge and Sespe-Frazier RA's of the Los Padres National Forest. These are special areas whose character is greatly defined by the absence of roads and infrastructure. They are home to important plant and animal species, they offer incredibly unique recreation opportunities, they safeguard habitat, clean air and water, and they serve as critical buffer zones for some of our local wilderness areas such as the Sespe Wilderness and the Dick Smith. I have observed the Forest Service have an increasingly difficult time in maintaining the current network of roads and trails and I'm not in favor of any additional roads being created when there is such a backlog of maintenance resulting in unsafe conditions for hikers, bikers, hunters and all who recreate in roadless areas. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. On behalf of my local trails community and the constituents of Bikepacking Roots, Los Padres Forest Association, Montecito Trails Foundation and SAGE Trail Alliance, I adamantly oppose the proposal to rescind or alter the Roadless Rule," and support "Alternative 1, the No Action alternative." Thank you for your consideration of this very important matter. Signed, Ben Van Der Kar Tuesday, October 6th - 2026