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Dear USFS: I have lived in Pendleton, Oregon for 21 years. During that time I have come to see the ecological damage caused by road development in the forest. Around 2001 or 2002 I volunteered with members of the Blue Mountain Mountain Chapter of Trout Unlimited to work with the Malheur National Forest to CLOSE roads in the national forest south of John Day. The roads were deemed unnecessary and potential pollutant sources. Fact: road development exposes soil to erosion that pollutes the nearby streams. Roads fragment the forest, relocate and kill wildlife, are sources of industrial noise pollution, and are a primary source for wildfire ignition by making access to the forest easier for motor vehicles. Fact: Humans cause 84% of wildfires. In 2001 the USFS’s own findings was that roads increase human-caused fire. Moreover, the proposed rule change admits that increased public road access could raise the number and frequency of wildfires. Fact: Vehicle tires contain 6PPD, a chemical added to minimize material breakdown. 6PPD reacts with ambient atmospheric ozone to form 6PPD-quinone. As tire particles scuff off due to normal road abrasion, roads become a primary source of environmental 6PPD-quinone. Roads, particularly those near streams, culverts and bridges serve as a direct conduit of 6PPD-quinone into surface water particularly during road runoff events. According to the USEPA, 6PPD-quinone is an acute ecotoxin that has been shown to kill salmonids. I demand that the Roadless Rule remain unchanged. Moreover, I demand that an Endangered Species Act assessment be conducted before any proposed rule change. Thank you.

The true value of our natural resources in the United States of America cannot be fully understood and appreciated unless one has experienced these personally. Land, clean air, healthy trees, adequate and clean water, and wildlife that survive and thrive in our national forests deserve to be protected. Over past decades I have hiked in, boated in, skied, and camped in a number of our spectacular national forests: the Olympic National Forest, Mount Baker Snoqualmie NF, Okanagon-Wenatchee NF, the Cherokee NF in my native state, the Deschutes NF, the Finger Lakes NF, the Gifford Pinchot NF, the Huron-Manistee NF, the Idaho Panhandle NF, the Malheur NF, Mount Hood NF, the Pisgah NF, the Santa Fe NF, the Tongass NF, the Tonto NF, the Umatilla NF, the Umpqua NF, the Wallowa-Whitman NF, and the Willamette NF. In 2001 when the Roadless Rule was enacted, it allowed the NFS get somewhat caught up on maintenance of the 44.7 million acres of Inventoried Roadless Areas (IRAs). The 9.3 million acres of IRAs in the Tongass National Forest have also been better protected than prior to the RR. The claims being made in the Proposed Rule do not « hold water. » It was local control (one of the purported justifications for rescinding the 2001 RR) that led to enormous harm in the Wolverine Fire of 2015 in Washington state. Local pressure by regional fire departments persuaded the Director of the Firefighting Operations, a staffer brought up from the Tonto NF, ordered a CPL (Community Protection Line) that ended up a 50-mile long, 300-foot wide CPL and cut 40% of the critical habitat for the endangered Northern Spotted Owl. Over 930 log trucks hauled out logs, with one tree being so large that it was the only tree on one of the trucks. In my view, it was criminal to do that much damage. The scientist on the Oka-Wen NF tried to persuade the fire director that the fire was not heading in the direction of the CPL cuts. « Managers continued logging even after weather conditions turned rainy and cool, and objections were raised by their own staff, who saw no emergency, internal records and emails to The Seattle Times by US Forest Service showed. The fire never came anywhere near. » (Lawsuit over firelines to curb forest firefighting tactics, August 22, 2016) Another purported reason given for the Proposed RR Rescission is to reduce wildfire. This is not logical or rational. By allowing access to more roads in the roadless areas, there would be a greatly increased likelihood of experiencing human and vehicle-related forest fires. Strong scientific studies support this and argue strongly against opening up our roadless areas to more traffic for logging or other forest treatments. In fact, fires are four times more likely to occur near roads than in roadless (DEIS, p. 87) Good water quality is also more available in IRAs because of limited disturbance. « Retaining the RR ‘provides the greatest protection of water quality’ for municipal water supplies. » (DEIS, p. 122) For these reasons, and in the hope that science and good evidence about the superb values of Roadless Areas in our USFS will prevail, I strongly oppose the Proposed Rescission of the 2001 Roadless Rule. I would appreciate your serious consideration of my comments. Another

I am writing to support maintaining the Roadless Area Conservation Rule and urge you to choose Alternative 1 of the proposal. The Rule provides vital protections for public lands that are meaningful to me and my community. Roadless areas like Mount Hagen and McLennon Mountain in the Willamette National Forest safeguard my drinking water supply in the McKenzie River. I share roadless areas such as Echo Mountain, Gordon Meadows, Mount Washington West, Hardesty Mountain, Waldo-Fuji, Maiden Peak, Calf-Copeland, Mount Hebo, and the Oregon Dunes (in the Willamette, Siuslaw, Deschutes, and Umpqua National Forests) with colleagues and members of the public through educational hikes. The hiking guide I published in 2019 through Mountaineers Books includes trails in 26 different roadless areas, including Lost Lake in the Mt. Hood National Forest, the North Fork Malheur River in the Malheur National Forest, and Brown Mountain in the Rogue River-Siskiyou National Forest. I’ve enjoyed countless experiences with wildlife within roadless areas - places where birds, elk, wolves, and salmon find refuge and essential habitat. All of these values will be harmed by repealing the Roadless Rule. Such a decision will compromise clean water, fish and wildlife habitat, low-impact recreation and so much more. Rather than opening up new opportunities for exploitation of our roadless wild lands, I urge you to maintain the 2001 Roadless Rule for the many benefits they provide to the American people.

I am writing to express my support of roadless areas on our national forests and other public land throughout the United States of America. In my home state of Oregon, I find that I prefer to recreate and spend time in areas where motorized activity is limited and human development is at a minimum. I don’t need to visit the forest to find a road. Roadless areas offer I do not think it is in our best interests to build roads and develop untouched land. On the Malheur National Forest which is adjacent to our community, there are some of the highest road densities in the country on Forest Service (USFS) land. These roads were built to facilitate timber harvest and most of the logging roads remain open and serve no real purpose long after logging operations have finished. In these areas with high road densities and no travel management, hunting is poor because invasive plants thrive and wildlife are pressured by intense motorized use. During hunting seasons, wildlife such as elk often move out of areas with heavy motorized traffic on to adjacent private land where they damage crops. These roads are often built in areas that would be some of the most productive land for grazing, wildlife, and fisheries because the follow stream corridors. Each gravel road, is around 30 feet in width and renders that land that is now a road useless to livestock, wildlife, and timber. According to the USFS, there are 9,670 miles of road on the Malheur National Forest and we need more? If each road disturbs an average of 30 feet of land, these roads equate to 35,163 acres of land that no longer produces forage for livestock or timber to support logging operations on the Malheur Forest alone. Roads often block fish passage at culverts and alter stream hydrology through sedimentation, confining channels, and narrowing riparian areas all of which damage fisheries. Roadless areas are roadless for a reason. They often lack valuable timber to warrant the effort to build a road, or the topography is too rough to efficiently harvest the few good trees that are there. Roads and road building are expensive; I do not want my tax dollars spent destroying the miniscule amount of untouched land that remains. Logging is great and I wish there was more going on in our local forests but building more roads is not the issue. Timber harvest on the MNF was huge in the past century but for the most part the high quality timber has been harvested the remaining old growth is mostly adacent to a road anyway. It will take time to regrow the majority of the large trees on the MNF. Building roads will not revive the timber industry. The roads are there, most of the trees are small and for now, not sufficiently valuable for profitable harvest. In most cases, roads, logging, and grazing do not prevent wildfires or aid in wildfire fighting. We have had several very large fires in wilderness, heavily grazed areas, and roaded areas in our county, some human caused, some by lightning. When conditions are right there is simply no way to prevent these fires. I do not believe that roadless areas prevent us from accessing our public lands in fact I believe the opposite to be true. The maze of winding, endless, and purposeless roads on the MNF is astounding and easy to get lost in. A few roads are great and allow us to access areas that would be impossible to reach without a huge amount of effort but we need to be smart about how we build and use roads on our public land. The roadless rule was drafted with extensive public input and used science and reason to come to a conclusion. Rescinding this rule would be a huge misstep and would ignore the will of Americans that use and recreate on public land. There are plenty of roads out there. If you can’t find one you like just drive a little further.

As a transplant from a big city, working for the Forest Service and doing my own hiking in the wilderness area of the Malheur NF, opened up my world rather than just reading about it. This opportunity provided me with a lifelong appreciation of the beauty we all seek in the natural world. I will join other citizens in protecting our rights for our children and grandchildren to enjoy those same experiences. Building more roads in these roadless areas does NOT guarantee less wildfires, but in fact, increases the potential for human caused catastrophes. As an employee for the Malheur NF in the 80’s, I observed countless clear cuts of slow growing lodgepole pine, that scarred the landscape and created erosion problems. The roadless rule brought a positive significant change to the administration of forest management. The Malheur NF is a jewel with its high elevation lakes, trail system and unspoiled wilderness areas in one of the few east to west mountain ranges in the US. I implore the federal government to continue holding these protections in place for generations to follow.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Mcclellan Mountain (21,213 acres), Malheur NF, Oregon - Salmon - Huckleberry (17,570 acres), Mt. Hood NF, Oregon - Gifford Pinchot (213,000 acres), Washington I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I grew up in Oregon, a state with a rich and complicated forestry history. I learned how to walk on a backpacking trip with my parents in the Malheur National Forest. 30 years later I still hike and camp in the forests of Oregon and Washington every year, and I cannot imagine the futures of our states without these forests remaining intact in their current versions. Recently, in the Gifford Pinchot NF I was looking for mountain goats and woodpeckers on an ascent up to a peak. Pikas as well are always my favorite of the alpine wildlife. Living in Portland, we are lucky to have great quality drinking water from the Bull Run Watershed, which is part of the Mt Hood National Forest. Protecting the integrity of this National Forest is absolutely critical to protecting safe, bountiful drinking water for our metropolitan area. It is absolutely NOT ok to jeopardize such critical infrastructure and basic human needs such as drinking water by introducing more roads, fragmentation, forest fire potential in an already extremely vulnerable wildfire area, and higher sedimentation loading into streams. I work in drinking water quality and there is just no way that rescinding the roadless rule makes good public health sense. We all need clean drinking water. We rely on our government to help protect the natural assets that make it available. This would be a breach of that trust. The Salmon-Huckleberry wilderness is my favorite part of Mt Hood National Forest. It's just an hour away from where I live so I visit it throughout the seasons, hiking, camping, picking huckleberries. It's already a heavy-traffic and somewhat fragmented National Forest due to the PCT and its proximity to outdoors-loving Portland. We need to protect the forest parcels and their habitat interconnectivity that remains, so that critical ecosystem functions and the incredible natural beauty that is a cornerstone of our state's identity, economy, and history is protected. Hiking trails that take you into the forest and leave the road noise behind are the top reason a lot of my friends have moved here from California. We can't lose this, especially for an act that would have such low value in terms of taxpayer dollars and revenue. The forests as they are provide far more benefit than the proposed rule, which would cause irreversible damage. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Clare McClellan Portland, OR