Read the comments.

I oppose the rescission of the Roadless Area Conservation Rule and request that it be abandoned forthwith as a waste of taxpayer dollars, a dangerous flouting of established wildfire and water science, and a top-down, anti-democratic, anti-local forcing through of something that was overwhelmingly opposed at the NOI stage. I also protest the inadequate process surrounding the proposed rescission; if the rescission is not abandoned, the process must be corrected. Regarding process, the 2001 Roadless Area Conservation Rule received extraordinary public input, largely positive, through 2 60-day comment periods and over 600 public meetings drawing over 23,000 participants. This rescission proposal initially allowed only a 21-day comment period on the NOI and a 30-day comment period on the DEIS, inadequate to a broad rule that affects nearly 45 million acres all across the nation. Even with the DEIS comment extension, the total comment period is little half that of the original rule. If the rescission is not abandoned, the comment period should be extended another 45 days and it should include at least one meeting per forest—half of what was provided for the original rule. Communities surrounding the forests should have every opportunity to state their opinions and share the likely impact on their livelihoods and lifestyles. Also, although the USDA correctly determined that Tribal consultation is warranted by the proposal, it has held fewer than half of the requested consultations, per the TSIS has held no consultations since the DEIS has been released, and it misconstrued what consultation means. Sending line officers without decision-making power to record opinions before alternatives have been publicized is not the same as decision-makers meeting with Tribes regarding the actual impacts of proposed alternatives. The TSIS nonetheless shows that the majority of Tribes oppose the rescission, and yet this rescission is being forced through. Furthermore, alternatives proposed by Tribes were not analyzed in detail. If this rescission is not abandoned, government-to-government consultation should be correctly held with the requesting Tribes, a Tribally-proposed alternative should be analyzed in a supplemental DEIS, and an updated Tribal Summary Impact Statement should be issued for comment before the final rule. As for the impacts of the rule itself, as a tax-payer I am infuriated that the enormous backlog of deferred maintenance on current Forest Service roads is being passed over in favor of building new roads in areas that, if they were easy to build roads in, would already have them. I have recently traveled Forest Service roads in Mendocino National Forest, where my companions and I had to navigate a landslide and a washout. While fire trucks might have been able to navigate the landslide, after a delay for digging it out, the washout was barely navigable in a passenger vehicle. In the best case trying to get engines through there would have delayed fire response by forcing the engines to be rerouted; in the worst case it could have caused injuries or even deaths to our firefighters. Rather than attempt to build new roads, the backlog should be better funded and roads should be prioritized for repair according to their impact on public safety. Adding insult to potential injury, timber sales from areas newly opened to logging are unlikely to pay for themselves or the roads; essentially, they are a corporate giveaway. The rescission will not, as claimed, make it easier to manage fire in forests. I have seen fuels management in Caples Creek, one of my favorite inventoried roadless area, that successfully protected the area from the massive, severe Caldor Fire 2 years later, and the DEIS acknowledges that the 2001 Roadless Rule does not "meaningfully constrain hazardous fuel treatment activities". It also acknowledges that IRAs have far fewer ignitions than roaded lands. In other words, rescinding the rule—according to the DEIS—can be expected to increase ignitions without improving fuels management. Firefighters themselves state that in rugged areas air support is preferable to trying to get engines in, and point to delays caused by poorly maintained roads. More roads will not make this better. Adding more roads also decreases water quality at a time when fresh, clean water is of utmost importance and in short supply. Roads increase erosion and sediment, while maintaining forests captures sediment. Turbidity is a major, costly problem for downstream water users, who have to bear the indirect costs of the new roads. The DEIS barely addresses this impact other than to say that it likely exists. There are far more reasons to oppose rescinding a rule that preserves our forests and clean water for the generations to come. The rescission should be abandoned and our taxpayer dollars used for something useful like restoring the many fire fighter support personnel who have left the Forest Service.

This comment comes to you from an incensed member of the public. I am a US citizen and resident, a frequent visitor to federal public lands, and own property within some 30 linear miles - within the smoke/air quality, regulatory, and insurance impact zone - of the Mendocino National Forest. I have a lifetime of residence and outdoor recreation in three West Coast states whose biota would fall victim to the proposed action and the private plunder which is its point. The proposed rescission is nonsensical, arbitrary and capricious. Its primary stated goal of reducing wildfire risk is in fact contradicted by the data in its DEIS which notes, for example that bringing roads into intact forests in fact increases fires; 90% of US wildfires start within half a mile of a road; and inventoried roadless areas have already had wildfire risk addressed by treatment such as pile burning, tree cutting, and chipping at rates that are similar to other national forest lands. Because the proposal if implemented would in fact thwart its declared key goal and instead increase wildfires, the proposal is nonsensical, legally unsound, arbitrary, capricious, an abuse of discretion, and otherwise not in accordance with law; and should be immediately withdrawn.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The mountain bike trails and service roads I ride run through country that has seen enough loss already. Mendocino National Forest has taken hard hits from climate change and wildfires, and the Briscoe and Reister Canyon roadless areas, 7,212 and 5,897 acres respectively, are part of what remains of a vibrant wildlife area. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and to ask the agency to answer several specific questions its proposal has not adequately addressed. We need to protect and steward what little wild areas we have remaining. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule. It has held none to undo it. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions. They are the places I ride through, the forest I know, and the inheritance I think we owe to the next generation. On the wildfire question, the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Mendocino has already seen devastating losses due to climate change and wildfires. It does not make sense to build roads into a wildlife area when the agency's own findings show that roads increase fire risk, not reduce it. I ask that the agency explain why this proposal departs from those prior findings and how it reconciles the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. On the economics, the agency's proposal frames rescission partly in terms of timber and energy production. 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 is already $6.9 billion behind on maintaining the roads it has, with a road budget of roughly $73 million a year. Building new roads into country that has none, when the agency cannot maintain the roads it already has, does not make sense. The agency's own cost-benefit analysis 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. The agency should explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. On the state-by-state approach the proposal offers as a substitute, the record before the agency 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 agency has tried this before. The Ninth Circuit found deficiencies in that approach. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the same deficiencies. On the authority question, the proposal suggests the 2001 rule exceeded statutory limits. The court record does not support that framing. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency should explain the basis for any position contrary to the Tenth Circuit's holding that the 2001 rule fell within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and that it did not create de facto wilderness. These are not marginal concerns. The Briscoe and Reister Canyon areas are part of what I ride through, and part of what Mendocino still has left to lose.

I am a field biologist who regularly works on national forests containing inventoried roadless areas in California that would be impacted from the rescission of the 2001 Roadless Rule including: Stanislaus NF, Sierra NF, Plumas NF, and Mendocino NF. I also regularly visit Coronado NF lands containing inventoried roadless areas in Arizona, including the Chiricahua Mountains, Dragoon Mountains, Santa Rita Mountains, and Catalina Mountains. These lands and the communities that inhabit and rely on them, some of which are threatened and endangered species, are sensitive to further fragmentation and degradation from development. Their watersheds (which humans also rely on) are sensitive to the erosion and sedimentation caused by construction and maintenance of new roads and/or other development. I strongly oppose the recission of the Rule and list objections to the rationale for the Proposal and to the draft EIS below. One of the main stated rationales for rescission of the Rule presented in the Proposal is the need to return control of inventoried roadless areas to local FS authorities because the national 2001 Roadless Rule was too restrictive and burdensome to locally adapt, specifically regarding active management for fire and fuels. Yet, on page 14 of the draft EIS, Table 1., 2001 Roadless Rule exceptions (alternative 1) (36 CFR 294.12(b) and 294.13(b) (2001)), states: “Road construction, reconstruction, including temporary road construction, is prohibited in inventoried roadless areas, except when: 1) A road is needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property” Fuel reduction projects on FS lands in California have been actively taking place since the Roadless Rule went into effect. I know this because I have worked on these projects. I also know this because there is published research documenting these activities: “The findings in our analysis are consistent with other studies, including research supported by the Forest Service’s Rocky Mountain Research Station, which evaluated nearly twenty years of monitoring data, concluding that “a lack of roads in IRAs [Inventoried Roadless Areas] has neither prevented fuel treatment nor led to substantially more fire” (Trout Unlimited 2026). On page 24 of the draft EIS, Table 3., which shows comparison of effects under alternatives 1-3 divided by resource/topic, under Fire and Fuels Management, it states “Currently, the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands. Under alternatives 2 and 3, if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads.” This statement, along with statistics from other published, peer-reviewed, and agency-accepted studies regarding the topic (see below), refute the argument that adding additional roads would reduce fire risk by any meaningful amount. “Analysis of information about ignition source and location from the Forest Service fire occurrence dataset (USA.FireOccurrence) shows the occurrence of human-caused wildfire ignitions is strongly correlated with roads. Seventy-eight percent of human-caused fires on NFS lands nationwide start within ½ mile of a road” (Trout Unlimited 2026). References: Trout Unlimited, 2026. Roadless: Active Management and Fire A GIS data analysis and research review. September 2, 2026. Accessed October 5, 2026, online at https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa.

Dear Forest Service Leadership: As an outdoor enthusiast, I am filing these comments to observe that the proposed rescission of the 2001 Roadless Area Conservation Rule would not maintain the status quo — it would change it, in a direction that favors extractive uses over the landscape conditions upon which non-motorized public access depends, and that change, once initiated through road construction, cannot be undone. Regarding the Reister Canyon in the Mendocino National Forest, California: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Persistence after abandonment. Road impacts on hydrology persist for decades after roads stop being used. Forest roads in northern Idaho abandoned for 30–50 years still showed an order of magnitude lower saturated hydraulic conductivity than undisturbed forest floor (Foltz et al. 2009; Trombulak & Frissell 2000). — Foltz et al., 2009 (https://doi.org/10.1016/j.jenvman.2009.01.014); Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Trombulak et al., 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Rescinding the Roadless Rule would open the Reister Canyon, Mendocino National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. I want to protect the environment and prevent habitats from being destroyed. I'm not asking for anything unusual — just that the Department leave a working protection in place. That's my comment. With gratitude,

I strongly oppose rescinding the 2001 Roadless Rule. I urge the Forest Service to adopt the No Action alternative and keep national protections in place. I work in conservation finance and ecological intelligence, and I am cofounder of a conservation property in Costa Rica's Osa Peninsula. That work has taught me that intact forests are among the highest-value assets a nation holds. They deliver clean drinking water, flood and drought buffering, carbon storage, wildlife habitat, and recreation economies, year after year. Building roads to log or extract from these lands turns that permanent value into a short-term gain, and the change cannot be undone. A road is the first and most lasting step toward fragmentation. Once it is built, the ecological value it destroys cannot be bought back at any price. This is personal for me as a Californian. I have spent time hiking in the Mendocino National Forest, where I teach others about rare mushrooms and plants. Its remote, unroaded backcountry, including roadless land within the Berryessa Snow Mountain National Monument, is exactly what makes it irreplaceable. Wild places like this are rare within a few hours of the Bay Area, and they should stay that way for the next generation of hikers. National forests make up 20% of California and supply 50% of its runoff for drinking water. Roadless areas like those in the Los Padres, Inyo, and Mendocino National Forests protect that water and must stay protected. The Department justifies this action as reducing regulatory burden. The real burden falls on the public. Rescission would: •Increase costs to taxpayers. The agency already has a large backlog of road maintenance it cannot fund, and new roads add to that liability. •Increase wildfire risk. Roads bring more people and more human-caused ignitions into remote backcountry. •Degrade water supplies. Roadless areas protect headwaters that millions of downstream users depend on. •Fragment habitat. Unroaded forests are the last strongholds and climate refuges for many at-risk species. •Replace stable national protection with a patchwork. Forest-by-forest plans can be weakened one at a time. The public has spoken clearly. The August 2025 scoping period drew more than 220,000 comments, about 99% of them opposed to rescission. I also object to the process for this round. Before the rule was adopted, the agency held more than 400 public meetings after issuing the proposed rule. A brief comment period without comparable public meetings does not match the scale of this decision. These forests belong to all Americans, including future generations. Please keep the Roadless Rule intact.

I oppose USDA’s proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule under Alternatives 2 or 3 and strongly support Alternative 1, the No Action Alternative. Rescission threatens millions of acres of intact National Forest habitat, watersheds and wildlife corridors. California contains approximately 4.39 million Inventoried Roadless acres, Wyoming approximately 3.24 million, and Montana approximately 6.40 million. My attached comments identify several specific analytical gaps that I ask USDA and the Forest Service to address. California: Gray wolves are naturally recolonizing their ancestral range in northern California. CDFW reports eleven confirmed packs and recognizes that roads and human activity can negatively affect wolves. Has the Forest Service analyzed, at the individual National Forest and Inventoried Roadless Area level, how Alternatives 2 and 3 would affect wolf habitat, dispersal and mortality risk in the Modoc, Lassen, Plumas, Shasta-Trinity, Klamath, Six Rivers and Mendocino National Forest landscapes? How does the DEIS account for dispersing wolves outside currently mapped pack territories? Greater Yellowstone: Wyoming contains approximately 3.24 million roadless acres, including approximately 1.417 million acres in Bridger-Teton National Forest. Bridger-Teton and Caribou-Targhee directly adjoin Grand Teton National Park and contain habitat and corridors used by Greater Yellowstone wildlife. Has USDA quantified how many currently roadless acres of secure or potentially secure grizzly habitat in Bridger-Teton and Caribou-Targhee could become available for roads under Alternatives 2 and 3, and the resulting effects on secure habitat and motorized-route density? Most importantly, has USDA specifically analyzed female grizzly dispersal and establishment of reproductive home ranges? Future grizzly recovery depends not merely upon wide-ranging males appearing outside established recovery areas, but upon females successfully dispersing, surviving, establishing home ranges and reproducing. Roadless habitat in Bridger-Teton and Caribou-Targhee adjoining Grand Teton, elsewhere within the Greater Yellowstone Ecosystem, and beyond today’s designated recovery boundaries may be essential to future generations of grizzlies using ancestral corridors and recolonizing ancestral habitat. The Final EIS should analyze where grizzlies may need to disperse in the future—not simply where bears occur today—and determine whether new roads and motorized access would impair those corridors or increase human-caused mortality. Additional roads also mean habitat fragmentation, erosion and sedimentation, invasive-species pathways, human-caused wildfire ignition opportunities and additional taxpayer liabilities when the Forest Service already faces billions of dollars in deferred road and bridge maintenance. For these reasons, I oppose Alternatives 2 and 3 and support Alternative 1. Please retain the 2001 Roadless Area Conservation Rule in full. My complete substantive comments, specific questions, supporting information and sources are contained in the attached PDF and should be incorporated into the administrative record.

To the U.S. Forest Service Roadless Rule Docket: I'm writing because climate is on my mind, daily, in a way I didn't sign up for. The 2001 Rule has been quietly doing its part of that math since 2001. Leave it alone. This rule protects many of the remaining habitats for displaced and endangered species. We have an obligation to ourselves and future generations to protect these lands and the plant and animal species that rely on them for survival. Regarding the Reister Canyon in the Mendocino National Forest, California: The Rule should not fall; the Department should act to keep it in place. With thanks, CommentID: RLC-20261005-AZREET

Docket ID: FS-2025-0001 Subject: Support for the Rescission of the 2001 Roadless Area Conservation Rule Dear Secretary of Agriculture Brooke Rollins and the U.S. Forest Service, I am writing to express my strong support for the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Department of Agriculture and the Forest Service to choose Alternative 2 (the Proposed Action Alternative) to rescind this rule and return forest management back to local authorities. My perspective is shaped by two deeply connected roles: I am a structural and wildland firefighter with 30 years of service on the front lines, and my family has owned a summer cabin in the Mendocino National Forest that my grandfather built. Having spent decades both working in and living alongside these public lands, I have witnessed the devastating, real-world consequences of the Roadless Rule first hand: • The Loss of Vital Tactical Access: Forty years ago, the Mendocino National Forest had an established network of secondary roads. Under the 2001 rule, these roads were closed off and allowed to completely overgrow. When the largest wildfires in California's history tore through the Mendocino National Forest, the lack of access along these neglected corridors severely crippled initial attack times and containment efforts, allowing the flames to blow up into unmanageable megafires. • The Defunding of Critical Infrastructure: The current rule has severely throttled or eliminated the funding needed to maintain the few existing access roads that remain. Consequently, these routes have deteriorated into unsafe, unmanaged paths that trap fuels and hinder tactical movement rather than serving as safe, reliable lines of defense. • Severe Limitations on Responsible Management: Preventing or heavily restricting road reconstruction takes away the essential tools needed to responsibly care for the forest. Local managers are effectively blocked from getting heavy equipment into overgrown stands to perform the mechanical thinning, clearing, and fuel reductions required to keep the forest healthy and resilient against bugs, disease, and catastrophic fire. For thirty years, I have seen that wildfires are much easier to contain and keep small when suppression crews can use roads as defensible firebreaks and rapid ingress routes. Blanket mandates from Washington, D.C., have left our forests locked up and vulnerable. Local rangers and community stakeholders understand the unique ecology of the Mendocino National Forest and must be given the flexibility to manage it responsibly. I strongly urge the agency to move forward with the rescission of the 2001 Roadless Rule to restore safety, balance, and accountability to our national forests. Thank you for your time, your service, and your consideration of my professional and personal testimony. Sincerely, Chris Cushman Fire Captain, Livermore-Pleasanton Fire Department Lake Pillsbury Lot #25 Owner 6006 Silverleaf Drive, Foresthill, CA 95631

To whom it may Concern: My name is Tyler of Kelseyville CA, and this is my comment on the proposed changes to the “Roadless Rule”. I live near Mendocino National Forest, an immensely beautiful natural space which would be threatened under the proposed changes. I regularly hike, swim, and birdwatch there, my favorite memory in this Forest is when I heard a “robot” sort of sound to only realize it was an Anna’s Hummingbird. Mendocino National Forest provides a place for families to gather, fathers to fish and hunt with their kids, and a place to watch birds and other wildlife (which is now counted as one of the most common forms of recreation among a Americans, with 1 in 3 regularly watching wildlife. ) All while bringing economic Stability - as our area relies heavily on Ecotourism. Under the proposed changes to the "Roadless Rule", Mendocino National Forest would be opened for logging and other resource extraction, which would emperil my ability to hike, swim, and birdwatch - if not completely stop me from doing so. Currently, the logging of our National Forests costs taxpayers $2 Billion dollars annually*, on top of degrading water quality**. ( * 2019 report by the Center for a Sustainable Economy. ** 2023 report published by Dr. Muhammad Sharif.) It is for these reasons (and more) that I oppose any and all changes to the “Roadless Rule”.

I am writing in support of Alternative 1 for the Roadless Rule, the No Action Alternative, because I believe it is important to keep the Roadless Rule intact to protect the few remaining areas of true wilderness left in the United States. I have been an avid hiker and backpacker that has been fortunate enough to be able to spend time in some of the wilderness areas of most of the states west of the Mississippi, including my closest forest, the Mendocino National Forest(MNF). The Roadless Rule has helped to protect these areas from extractive industries and other development that would have negative effects on water quality, air quality, and wildlife habitat and connectivity, as well as on the recreational value of these few remaining relatively untouched areas. National Forests are a vital part of our public lands system that help support a 1.2 trillion dollar outdoor recreation economy and supplies 5 million jobs. The Forest Service has not been able to properly maintain many of the roads that it already controls in our National Forests. I am a member of FireScape Mendocino’s Core Group and hear how many roads in the MNF are in disrepair and often impassable. Some of the ones I travel have been closed due to landslides and fallen dead trees left over after the massive fires that have ravaged the area. Constructing new roads will only add to the workload and allow for impairment of vital watersheds. Building roads as a strategy to fight wildfires is counterproductive. The vast majority of fires are caused by people and start within a half a mile of an existing road. Building more roads is, therefore, likely to increase fires. Please leave the Roadless Rule unchanged in order to support the supply of clean drinking water to tens of millions of Americans, habitat for thousands of species of animals and plants, many of which are endangered or threatened and vital to the livelihoods of tribes and all of the other people who rely on them for sustenance, and recreational opportunities that improve the physical and mental well being of anyone that goes there. We need our wild places to remain wild. Thank you, Debra Sally

I am writing in support of Alternative 1, the No Action Alternative, for the Roadless Rule, because I believe it is important to keep the Roadless Rule intact to protect the few remaining areas of true wilderness left in the United States. I have been an avid hiker and backpacker that has been fortunate enough to be able to spend time in some of the wilderness areas of most of the states west of the Mississippi, including my closest forest, the Mendocino National Forest(MNF). The Roadless Rule has helped to protect these areas from extractive industries and other development that would have negative effects on water quality, air quality, and wildlife habitat and connectivity, as well as on the recreational value of these few remaining relatively untouched areas. National Forests are a vital part of our public lands system that help support a 1.2 trillion dollar outdoor recreation economy and supplies 5 million jobs. The Forest Service has not been able to properly maintain many of the roads that it already controls in our National Forests. I visit websites for these forests and see how many roads are closed to the public, especially after fires and heavy rains. Constructing new roads will only add to the workload of the poorly funded forest employees and allow for impairment of vital watersheds. Building roads as a strategy to fight wildfires is a bad idea too. The vast majority of fires are caused by people and start within a half a mile of an existing road. Building more roads is more likely to increase fires and numbers of acres lost. Please leave the Roadless Rule unchanged in order to support the supply of clean drinking water to tens of millions of Americans, habitat for thousands of species of animals and plants, many of which are endangered or threatened and vital to the livelihoods of tribes and all of the other people who rely on them for sustenance, and recreational opportunities that improve the physical and mental well being of anyone that goes there. We need our wild places to remain wild.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike and camp along the California Coast, across Mendocino and Sonoma Counties, and throughout the Sierras. I am opposing the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The Mendocino National Forest is part of that landscape. I have a direct stake in what happens to it. The agency justifies this rescission in part on wildfire and fuels management grounds. That justification is undercut by the agency's own record. 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." Opening roadless areas to new road construction in the name of fire safety directly contradicts that finding. The ignition data in DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain, in its own record and in plain terms, why the proposal departs from these prior findings and how it reconciles the rescission with the density data its own environmental review produced. The economic case for rescission is similarly thin. 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." Against that baseline, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million. A range that spans negative territory cannot establish a net benefit. Meanwhile the road system the agency would expand already carries a $6.9 billion maintenance backlog. The agency needs to reconcile the proposal with those numbers and explain how a course of action its own analysis cannot confirm as economically beneficial justifies adding to a deferred maintenance burden already measured in the billions. The proposal argues that state-specific approaches can replace a single national rule. The agency has tried that before and it did not survive judicial review. The record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." But the agency's own prior findings acknowledged that local decision-making can incrementally erode nationally significant roadless values, which is precisely why a national framework was adopted. The agency should explain how this proposal avoids the specific deficiencies the Ninth Circuit identified when the agency last substituted a state-by-state approach for the national rule. The proposal also questions whether the 2001 rule was within the agency's statutory authority. That question has already been answered in federal court. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. If the agency holds a contrary position, it must state the legal basis for that position in the record. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The people who drink that water, and who hike and camp in places like the Mendocino coast and the Sierras, are the public this agency is charged with serving. The record before the agency does not support rescission. I ask that the agency answer each of the points raised here before taking any final action. Sincerely, Anjelica Christon Petaluma, California

Dear Chief Tom Schultz: I am Abbreail, a novice birder, who has witnessed the compromised well being of birds and other invaluable species as a result of roads. I write as a wildlife observer to oppose the proposed rescission, and to ask the Department to weigh the rule's track record against what its sponsors are claiming about its costs. More experienced birders and ornithologist have inventoried roadless areas for twenty years and have shown that the rule is doing what it was supposed to do. When roads come birds die. Animals die. The chickadees, hawks, etc. now have to compete with yet another threat to their lives in various forms. This will undoubtably lead to a decline in various populations and cost these areas in so many ways. Regarding the Elk Creek in the Mendocino National Forest, California: 4.2 - Utility & service lines drives Slight or 1-10% pop. decline severity impacts across Pervasive (71-100%) scope for California Condor (Gymnogyps californianus, G1, E, XN) in the Elk Creek IRA, Mendocino National Forest. The intact, unroaded condition of Elk Creek is the functional mechanism that currently limits 4.2 - Utility & service lines to its assessed severity and scope. Road construction removes this constraint and permits escalation. The DEIS analysis of Elk Creek must incorporate NatureServe's standardized threat assessment data for California Condor (Gymnogyps californianus, G1), including the IUCN-CMP classification (4.2), Slight or 1-10% pop. decline severity rating, and Pervasive (71-100%) scope determination. "Road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 Let the roadless areas remain what they are. All the best, CommentID: RLC-20261005-1X2I67

Dear Department of Agriculture Leadership: I’m a 5th generation Californian who loves our state for its wilderness areas and wonderful wildlife. I love this area for its native flora and fauna The quiet of the forest as well as the abundance of birds. Regarding the Grindstone in the Mendocino National Forest, California: NatureServe threat assessment data document that Northwestern Pond Turtle (Actinemys marmorata, G2, PT) in the Grindstone IRA, Mendocino National Forest, faces 4.1 - Roads & railroads at Slight or 1-10% pop. decline severity across Large - restricted scope. Absent roads, Grindstone functions as a refuge where Northwestern Pond Turtle is buffered from 4.1 - Roads & railroads. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. If the DEIS does not evaluate how rescission affects Northwestern Pond Turtle (Actinemys marmorata, G2) in Grindstone with respect to 4.1 - Roads & railroads, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. "The expansion of road networks degrades the slope stability and further increases the susceptibility to landslides. Deforestation, infrastructure construction, and mining triggered about 16% of fatal landslides from 2004 to 2016. High overlap exists between landslide susceptibility and areas of endemism for mammals, birds, and amphibians, which means that forests protecting both biodiversity and landslide risks to human society are important conservation targets." — Proceedings of the National Academy of Sciences, 2022 The Rule should remain in full force; the Department is urged to decline the proposed rescission action. Best regards, CommentID: RLC-20260924-PJF6JR

I write in support of the Roadless Rule and against its reversal. More than 400 endangered or threatened animals and plants across our country will be pushed closer to extinction if the Roadless Rule that has kept bulldozers and logging roads out of wild lands and open spaces for decades is reversed. Creatures such as spotted owls, mysterious Humboldt martens, rare Pt. Arena mountain beavers and struggling Coho salmon rely on these unroaded forests and wild rivers to survive. The roadless areas also provide places to hike, birdwatch, fish and hunt — as well as clean water and air to all of us. For 25 years, roadless publicly owned lands have remained safe from clear-cutting, roadbuilding, mining, and oil-and-gas drilling. Now we must stop extractive industries from forcing their way back in. About half of California’s 4 million acres of roadless areas are found in Northern California. In Mendocino National Forest, nearly 30,00 acres of roadless lands border the Berryessa Snow Mountain National Monument. Another 154,332 acres surround the remote Yuki, Yolla Bolly and Sanhedrin wilderness areas that serve as critical wildlife corridors. Further North, more than 1 million acres of roadless habitat around Mt. Shasta and into the Trinity Alps allow bears, mountain lions, deer and other wildlife to thrive. The Klamath and Six Rivers National Forests hold tracts of redwoods and old growth along with free running rivers adding roughly another 1 million acres of roadless land. THE ROADLESS RULE MUST BE PROTECTED.

More than 400 endangered or threatened animals and plants across our country will be pushed closer to extinction if the Roadless Rule that has kept bulldozers and logging roads out of wild lands and open spaces for decades is reversed. Creatures such as spotted owls, mysterious Humboldt martens, rare Pt. Arena mountain beavers and struggling Coho salmon rely on these unroaded forests and wild rivers to survive. The roadless areas also provide places to hike, birdwatch, fish and hunt—as well as clean water and air to all of us. For 25 years, roadless publicly owned lands have remained safe from clear-cutting, roadbuilding, mining, and oil-and-gas drilling. We must stop extractive industries from forcing their way back in. About half of California’s 4 million acres of roadless areas are found within the Redwood Empire and North Coast where I live. In Mendocino National Forest, nearly 30,00 acres of roadless lands border the Berryessa Snow Mountain National Monument. Another 154,332 acres surround the remote Yuki, Yolla Bolly and Sanhedrin wilderness areas that serve as critical wildlife corridors. Further North, more than 1 million acres of roadless habitat around Mt. Shasta and into the Trinity Alps allow bears, mountain lions, deer and other wildlife to thrive. The Klamath and Six Rivers National Forests hold tracts of redwoods and old growth along with free running rivers adding roughly another 1 million acres of roadless land. I am writing to support continued roadless protection for lands in California and across the country in every state. I strongly oppose the reversal of the roadless rule.

Dear Brooke L. Rollins, I write in opposition to the proposed rescission as a birder who has watched the federal scientific literature on road-density effects accumulate across two decades, and who finds that literature dispositive against rescission. Time spend in the habitat and witnessing bird and inspect species is of great joy but also sorrow. Knowing that if we do not protect these spaces, we rob future generations. During the pandemic, taking my kids hiking for outdoor learning gave us much needed reprieve from learning on screens. It was a way to connect to each other, the land and wildlife. Briscoe Creek Regarding the Briscoe in the Mendocino National Forest, California: Conservation status G2 reflects the vulnerability of Northwestern Pond Turtle (Actinemys marmorata) in the Briscoe Inventoried Roadless Area, Mendocino National Forest, where 7.2 - Dams & water management/use acts at Serious - moderate severity across Pervasive (71-100%) scope. Absent roads, Briscoe functions as a refuge where Northwestern Pond Turtle is buffered from 7.2 - Dams & water management/use. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. If the DEIS does not evaluate how rescission affects Northwestern Pond Turtle (Actinemys marmorata, G2) in Briscoe with respect to 7.2 - Dams & water management/use, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. "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 “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 (https://doi.org/10.1007/s10980-025-02100-5)” Failure to Connect Species/Habitat Baseline to Rescission-Specific Impacts Analysis The species and critical habitat baseline in this DEIS is disconnected from any actual impacts analysis, which is a serious gap for a rulemaking that will determine road access across millions of acres of habitat. The document states that "the potentially affected environment provides habitat for more than 300 threatened, endangered, and proposed species" and lists 79 USFWS and 19 NMFS critical habitats, but nowhere connects these counts to how increased road construction, timber harvest, fragmentation, or sedimentation under the action alternatives would affect these species. Independent research confirms roads produce measurable habitat degradation extending up to 5 km from the roadbed, with cumulative effects on isolation and population viability; the DEIS does not engage this literature or explain why it is inapplicable here. Under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989), Neighbors of Cuddy Mountain v. U.S. Forest Service, 137 F.3d 1372 (9th Cir. 1998), and APA 5 U.S.C. § 706(2)(A), I request species-specific or habitat-guild-level analysis linking projected road and harvest increases to fragmentation and habitat-loss effects before this rule is finalized. Rescission would not be a reasoned policy choice on the record presented; the Department should not finalize it. Respectfully, CommentID: RLC-20260908-OTV7WU

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

I strongly disagree with the proposed rescission of the 2001 Roadless Area Conservation Rule. Mendocino National Forest is among the most beautiful places in the United States. Alternatives 2 and 3 of the rescission draft remove the protections granted by the Roadless Rule, destroying the beauty of not just Mendocino, but of nature across our country. Repealing the Roadless Rule allows new roads to be constructed through zones previously designated as 'Roadless Areas.' The rescission justifies this under the guise of preventing wildfires by expanding access to hard-to-reach places. One issue with this plan is that the vast majority of wildfires start within close proximity to roads (Aplet Hartger and Dietz 2026). Creating new roads will only increase the amount of wildfires, instead of reducing them, a critical oversight in the rescission. Furthermore, creating roads through roadless areas leads to habitat fragmentation (https://www.environmentalscience.org/roads#habitat-fragmentation). Roads destroy habitats by paving over them with asphalt, but also destroy ecosystems by permanently disrupting wildlife corridors. In an era where climate change and overdevelopment threaten the health and vitality of so many species of animals, it is imperative that we do not infringe upon the last habitats free of humans. Creating new roads through roadless areas will only negatively impact species living in these increasingly threatened habitats. The Roadless Rule also prohibits logging across 45 million acres of national forests. If the Roadless Rule were to be rescinded, logging would be permitted on this land. If logging were to take place in these protected areas, it would be catastrophic: these forests provide habitats for countless species of animals, many of which are endangered or threatened, like grizzly bears, gray wolves, and northern spotted owls. Logging destroys the habitats of threatened species, and would be detrimental to the biodiversity of the United States. Additionally, 9 million of the 45 million acres of forests threatened by the Roadless Rule are old-growth forests. Old growth forests, like much of the Tongass national forest, store massive amounts of carbon dioxide, that otherwise would be released into the atmosphere, contributing to climate change (https://sustainability.stanford.edu/news/shocking-carbon-discovery-swedens-forests). If these forests–irreplaceable because of their age–were to be logged, vast quantities of carbon dioxide would be released into the atmosphere. This undermines the original goal of the rescission, being climate conservation. I believe, along with countless other Americans, that rescinding the 2001 Roadless Rule takes steps in the wrong direction in the fight for nature conservation. The rescission does not prevent wildfires, as even though roads promote access, they also promote wildfires themselves. The rescission also reduces biodiversity by destroying the habitats of threatened and endangered species across the country through permitting logging and road-building. It also jeopardizes the sanctity of irreplaceable old-growth forests, and threatens to contribute to climate change by releasing trapped carbon dioxide into the atmosphere. On a personal level, I want to see the beauty of our national forests be preserved for future generations. I believe that the outcomes of rescinding the Roadless Rule would conflict with my hopes for the future of our forests. For these reasons, I strongly urge you to keep the Roadless Rule as it is, by following Alternative 1 - maintaining the existing Roadless Rule. Thank you.