Read the comments.

Please do NOT end the Roadless Rule in national forests and wilderness areas. I am a resident of Pocahontas county, West Virginia, where the great Monongahela NF is protected by the Roadless Rule. Thousands of people visit this forest every year to enjoy hunting, fishing, and other recreational activities. It generates essential tourism for the small local economy, and it is beloved by WV residents. You cannot hunt, fish, camp, and hike on a road. These areas are cherished for their lack of roads, not the other way around. Every road and logging project further divides the fragmented and precious Appalachian habitat, which is one of the most biodiverse places in the world. Please continue to conserve this wonderful place by maintaining the Roadless Rule as it exists today. Thank you.

I strongly urge the US Forest Service to retain the current Roadless Area rule as it exists and not be modified or eliminated. As a hunter and angler, I have enjoyed many roadless areas in the United States and especially within my home state of West Virginia. Such designated roadless areas as the Seneca Creek, North Fork Mountain, and Cheat Mountain roadless areas in the Monongahela National Forest and Sugar Knob area in the George Washington National Forests are among my favorite places in West Virginia to hunt, hike, camp, and fish. With a graduate degree in plant ecology, I can also attest that the forests in these areas are much healthier than adjoining federal lands managed for timber. This is to a large degree due to our Central Appalachian forests being heavily susceptible to invasive plant invasions which are often severe in managed lands but typically much less common in roadless areas. That is a simple reality that cannot be dismissed based on any sound science. Furthermore, roadless areas by definition are less fragmented than managed areas of the national forests. The Central and Southern Appalachians have many species that have great difficulty dispersing across roads, even relatively small forest roads. This is especially true for many if not most regional endemics such as land snails, lungless salamanders, and perennial plants. While highly mobile species like birds may often benefit from management actions, that is not the case for these other species that depend on these landscapes for survival. Considering the roadless areas occupy less than 1% of West Virginia, it is impossible for me to see how those of us that enjoy hunting, fishing, and hiking in these backcountry landscapes or the very large number of species that benefit from their existence would not be harmed by this proposed rule. I finally would like to say that I am a life-long, tenth-generation West Virginian. As a landowner and full-time resident within the Monongahela National Forest, I am disappointed that the Forest Service has proposed such a poorly justified rule change.

Spend time in any one of the countless National forests, like Dolly Sods Wilderness in the Monongahela National Forest here in the United States, and you will know how vital it is to preserve the Roadless Rule Act. Precious ecosystems, wildlife and water are just a few of the incredible benefits found within these national gems. Please support the Roadless Rule Act and all it protects for generations to come. Your National Forests and I thank you!!

I submitted comments to the proposed rule in Sept 2025. Attached below. Consider these integral to my current comments. I strongly oppose recission of the 2001 Roadless Rule. I served on the roadless rule Content Analysis Team (CAET) in 2000, we read and synthesized all comments. Sentiment strongly favored protecting roadless areas and benefits they provide: clean water, biological diversity, wildlife habitat, forest health, and recreation. Climate change and population growth have increased support for roadless areas. I worked on the WMPZ Forest Plan Revision Team for forests in Western Montana; Flathead, Lolo, and Bitterroot. Despite efforts and substantial expense by American taxpayers, these were shelved due to a national lawsuit. Courts ruled the 2005 planning rule was inconsistent with the National Forest Management Act. The Flathead National Forest completed its forest plan revision in 2018 under the 2012 planning rule. My September 2025 comments must be considered in conjunction with my current comment for 53828 Federal Register/Vol. 91, No. 160/Thursday, August 20, 2026/Proposed Rules, which states, “As resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service’s multiple-use mission.” NOTE: While the 2001 roadless rule constrains officials from exercising their absolute place-based discretion, it does not follow such discretion is needed to meet the Forest Service’s multiple-use mission. On the contrary, NFMA was driven by management skewed to commodity production over multiple use values: watershed, wildlife, wildlands, recreation. Conditions on the Bitterroot amd the Monongahela national forest were evidence a more balanced approach was needed, resulting in NFMA. “In addition, evolving national priorities and changed conditions have required more active management approaches. The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns.” NOTE: See pg 8 from my 2025 comments for a research being done. There are volumes that dispel lack of active management as a driver of forest health concerns. On the contrary, there is evidence forest management itself fosters such concerns. “This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 ……The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency’s land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit’s expected distinct roles and contributions to the local area, region, and Nation. “ NOTE: Interdisciplinary planning and consideration of landscape-level conditions was done on the Flathead NF and ongoing revision on the Lolo NF. Refer to my Sept 2025 comment using Flathead as an example. Of 500,000 roadless acres, fewer than 200,000 remained. The rest were assigned management areas based on conditions and public input. Decision-makers balanced conflicting uses and devised management area prescription for roadless areas. “At the same time, this planning approach allows for place- based, collaborative decisionmaking that is responsive to specific on-the- ground resource conditions, rather than a ‘‘one-size-fits-all’’ national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities.” Note: Yes, this is being done for revisions under the 2012 planning rule. Ironically, the Roadless Rule Recission is itself a blanket one-size-fits-all mandate that the rule dispesl. I requested the DEIS disclose forests that have done plan revisions, those in the process, and those not started. Only those that have not started could be subject to the recission. Those completed or undergoing revisions have engaged in place-based, collaborative decision-making responsive to on-the-ground conditions. The DEIS fails to respond to my request.

I strongly oppose the USDA's proposal to fully or partially rescind the Roadless Area Conservation Rule. I have lived in Tucker County, West Virginia for more than 40 years and spend time recreating in and around the Monongahela National Forest. A large part of Tucker County’s economy is driven by tourism as people flock to the state’s National Forest and Roadless Areas in particular. Professionally, I have provided place-based education opportunities and administered the building of multi-use trails within the Monongahela National Forest, including the Canaan Mountain Roadless Area. My life, and that of my family and community, are richer because we have the option of recreating, hunting, fishing, and seeking solace on these public lands. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Our national forests are public lands, and they should be protected for the benefit of everyone not opened to greater roadbuilding, more commercial logging, and expanded natural resource and mineral extraction. These lands are part of the public trust, and it is the government's charge and responsibility to be responsible stewards now and for future generations. The Roadless Area Conservation Rule, as it exists, helps protect and preserve the naturalness and wildness of these designated public lands as well as protecting the fish and wildlife habitats that are ALL Americans' birthright and that should not be used to financially benefit commercial industries and interests. The economics and reasoning for the rescission of the Roadless Rule simply do not add up. The Roadless Rule took away “industrial scale” logging, not forest health treatments; and it allows the Forest Service to meet its multi-use mission. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads. There is already over $6.9 billion deferred maintenance backlog according to the DEIS. Timber revenue typically does not cover the cost of the log itself, let alone pay forward to fund the maintenance or decommissioning of roads built to harvest the logs. Further, the DEIS estimates that eliminating the Roadless Rule would degrade roadless areas and backcountry access to millions of acres, resulting in a loss of $9 million in annual visitor spending in local communities. The Forest Service has argued that rescinding the Roadless Rule could help address wildfire risk, but recent peer-reviewed research suggests otherwise. A 2026 study found that wildfires are approximately four times more likely to ignite near roads than in roadless areas. Roads increase human access and human-caused ignition sources. More wildfire mitigation has occurred in Roadless Areas on USFS lands than in roaded areas since the Roadless Rule was put into place. According to Forest Service data, roadless areas represent 21% of the forested landscape in national forests, and yet 34% of the total fuel treatment activities. Opening intact backcountry forests to additional road construction is not a sound wildfire prevention strategy. The lands designated in 2001 by the Roadless Rule represented the best remaining public lands. Experienced foresters, ecologists, and land managers within the Forest Service widely agree that they have adequate decision-making authority to protect and manage their local lands within the Roadless Rule. In four western states alone, there are currently 15 million grazing allotments in Roadless areas; and Utah alone has 83,000 acres of mineral leases in Roadless areas. Political appointees overseeing the agency, who generally lack the land management experience and multi-use conservation understanding of veteran Forest Service employees, are simply trying to meet a political deregulation agenda. In 2001 when the Roadless Rule was enacted, over 1.6 million people commented during the NEPA process with 90% of those comments offering overwhelming support. In 2025 during the initial comment period, the vast majority of comments were against revoking the Roadless Rule. Don’t ignore the voice of the public and let this well-vetted and beautifully simple regulation be rescinded simply because of the current administration’s focus on deregulation when there is no rationale or USFS data to support its removal. These wild landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. please preserve the Roadless Rule to continue to protect our protect our shared public lands through this policy for future generations.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around the Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Having visited the Monongahela National Forest many times over the past 25 years, I have never felt that the Forest required greater or more extensive road access. The existing Forest Roads are more than sufficient to provide reasonable access for recreation and occasionally sanctioned commercial activity, and thus to expand road building on the Mon into previously undisturbed areas and sensitive plant and animal habitat would go against the entire rationale behind our National Forests and the Mon in particular. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Bradley Stephens 248 Franklin St Morgantown, WV 26501-6906 brad.w.stephens@gmail.com

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Heather Tuckman, and I live in West Chester, Pennsylvania. Public lands need protection from development, especially the destructive policies that installing roads and vehicular access to wild and remote places would create. I strongly value preserving public lands, and as a board member of the Friends of the Stateline Serpentine Barrens, I have worked to protect biodiversity. Moreover, I have responsibly recreated on public lands throughout my life, from a childhood spent camping, hiking, fishing, skiing, and appreciating the public lands in the Western US, to my adult life spent doing these activities throughout the Northeast. These activities are immensely important to me, and I want others to be able to continue to do them on public lands too, without the threat of further disturbance to these places. The Sierra Nevada, Great Basin, and the Monongahela National Forest are particularly significant places. I am very concerned about the impact of establishing roads in remote places, as this would introduce more noise and light pollution and damage water quality. Roads damage not only the land they are built on, but also the surrounding land, as they act as conduits that introduce invasive plants and pathogens into previously preserved spaces. I wholeheartedly oppose the Roadless Rule and the damage it would cause, and I ask that, for all the reasons listed above, Alternative 1, the No Action alternative, be followed. Please oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to ask the Department to select Alternative 1 (no action) in the final decision. I have spent time in the Monongahela National Forest, including Dolly Sods and the Cranberry Wilderness, as well as the George Washington National Forest. What makes those places worth the drive from Sharpsburg is precisely what this proposal would strip away: no road noise, intact headwater streams you can drink from with a filter, and backcountry where ruffed grouse, brook trout, and black bear still have room. Those areas are within two to three hours of the Baltimore-Washington corridor, which means they are some of the only large unroaded landscapes accessible to roughly ten million people. Opening them to road construction trades a permanent public asset for a short-term private one. I live in Sharpsburg, Maryland, in the Potomac watershed. The nearest inventoried roadless areas to my community sit in those same forests, whose headwaters feed the Potomac River that supplies drinking water to millions of people downstream, including in Washington County. Roadless backcountry protects water quality at the source by preventing the sediment, culvert failures, and runoff that come with new road construction on steep forest ground. Maryland does not have a national forest, but it lives downstream of several, and that is why this rule matters here. The DEIS does not justify a full rescission. The 2001 rule already contains exceptions for road construction needed for wildfire response, public health and safety, and other circumstances (36 CFR 294.12), so the claim that the rule blocks fire management does not hold up against the rule's own text or the agency's own history of approving treatments in roadless areas. If the Department believes specific areas need site-specific flexibility, the lawful path is a targeted amendment or state-specific rulemaking with full analysis, as Idaho and Colorado did, not a nationwide repeal that removes protection from roughly 45 million acres at once. Rescission would also commit the Forest Service to building and maintaining new roads it cannot afford. The agency already carries a road maintenance backlog measured in the billions of dollars. Adding mileage in remote terrain shifts cost to taxpayers while delivering most of the benefit to private extraction interests. The process itself has been inadequate. The original 2001 rule followed more than 120 days of public comment and hundreds of public meetings. This rescission was given roughly 30 days plus a 15-day extension, with no public meetings in the affected forests, for a decision affecting a quarter of the national forest system. The record from the 2025 scoping period, in which the overwhelming majority of more than 600,000 commenters supported keeping the rule, should be given real weight rather than treated as a formality. Please retain the 2001 Roadless Rule in full and adopt Alternative 1.

I am writing to oppose any revision to the Roadless Rule that would permit new roads, development, or commercial activity in the protected roadless areas of our national forests. I live in Maryland and travel regularly to national forests in other states to hike and backpack. Roadless areas shelter wildlife, protect clean water, sustain biodiversity, and store carbon. They also offer recreation and solitude that can't be recovered once development moves in. Two places in particular matter to me. I have backpacked on the west side of the Wind River Range in the Bridger-Teton National Forest [number of trips], most recently in [year]. [One specific Wind River detail.] The Bridger-Teton has roughly 1.43 million acres of inventoried roadless area that this rescission would affect. Closer to home, I hiked the Roaring Plains loop in West Virginia's Monongahela National Forest in 2025. It felt like raw wilderness, with abundant wildlife and some of the most diverse plant life I have seen on the East Coast. Together with neighboring Flatrock Plains, the Roaring Plains form the highest plateau in the eastern United States, yet when Congress designated the Roaring Plains West Wilderness in 2009, it protected only part of that high country. Roaring Plains North and Roaring Plains East still depend on the Roadless Rule. The agency's main justification for rescission is wildfire risk, but the 2001 rule already allows for that work. It permits cutting small-diameter timber to reduce the risk of uncharacteristic wildfire, and it permits road construction when needed to protect public health and safety from an imminent threat of fire. If the agency believes these exceptions are inadequate, it should identify the specific fuels reduction projects the rule has prevented. Removing protections from nearly 45 million acres is not a proportionate response to a problem the agency has not documented. The effects of a new road reach well beyond the road itself. Roads fragment habitat, cause erosion, carry invasive species into new places, and bring more people along with more pressure for further development. Once an intact forest has been opened up, its wild character and ecological value are very hard to bring back. National forests belong to all of us and should be managed for the public's long-term benefit. I ask the agency to select the no-action alternative in the draft environmental impact statement, keep the current Roadless Rule in place, and reject any proposal that would weaken protections for roadless lands.

I strongly oppose the proposed repeal of the 2001 Roadless Rule. Our national forests are public lands, our shared birthright, and they should be protected for the benefit of everyone, not opened to greater roadbuilding and commercial logging. In West Virginia, the Roadless Rule safeguards treasured places like Roaring Plains, Seneca Creek, Cheat Mountain, Canaan Mountain and Tea Creek, while protecting important buffers around the Dolly Sods, Otter Creek and Cranberry Wilderness Areas. Having visited the Monongahela National Forest many times over the past 25 years, I have never felt that the Forest required greater or more extensive road access. The existing Forest Roads are more than sufficient to provide reasonable access for recreation and occasionally sanctioned commercial activity, and thus to expand road building on the Mon into previously undisturbed areas and sensitive plant and animal habitat would go against the entire rationale behind our National Forests and the Mon in particular. These wild, unfragmented landscapes provide clean water, wildlife habitat and irreplaceable opportunities for outdoor recreation. Once they are lost, we cannot easily restore them. Please preserve the Roadless Rule and protect our shared public lands for future generations. Sincerely, Bradley W. Stephens Morgantown, WV

Dear Chief Schultz, Roadless forests in national and state parklands are inherently valuable resources that we have a duty to preserve. Spending time in forested areas like those near where I grew up in Virginia and West Virginia has been hugely influential in fostering my love for science and my appreciation for the complexity and importance of conservation. Protected forests harbor precious biodiversity and in turn provide essential ecosystem services for our future. I have spent countless summer days in Monongahela National Forest in WV, learning about nature, forming friendships, and fostering the confidence and environmental awareness of my peers and younger mentees. The lack of roads or interference from the outside world while experiencing these forests made the lessons learned, adventures had, and bonds formed infinitely more meaningful. I want my kids and the next generation of outdoor educators and workers to have the same access to protected, healthy, biodiverse roadless forests as I had. Regarding the Marlin Mountain in the Monongahela National Forest, West Virginia: Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing. Recreation disturbance has measurable effects on wildlife. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf) Rescinding the Roadless Rule would open the Marlin Mountain, Monongahela 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. National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species... — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205). Estimates and figures used by the forest service in their proposed recission of the roadless rule require correction and more detailed, correct explanation. The thousands if not millions of Americans who support upholding the roadless rule deserve to have their voices heard. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. “Unclosed Derivation of the 44.7-Million-Acre Baseline (58.2 less 9 less 4 equals 45.2) The Draft EIS derives the acreage baseline for its entire analysis in a single passage, and the derivation does not close.” “Superseded 58.5-Million-Acre Baseline Stated as Current in the Cost Benefit Analysis; Components Reconcile to Neither Total.” “Identifies the most "natural" (least human-modified) corridors between large protected areas in the U.S. Many of the highest-priority corridors fall within or overlap inventoried roadless areas, providing direct evidence that maintaining roadless protections is critical to climate-adaptation connectivity strategies for wide-ranging species. — Belote et al., 2016 (https://doi.org/10.1371/journal.pone.0154223)” Most respectfully, A Virginian

Hello. I am an engineer for the energy industry who (in addition to my engineering degree) also holds a degree in Wildlife Biology from a top agriculture University. In addition to my professional credentials, I have also contributed thousands of volunteer hours to the exploration & mapping of caves across the U.S., including those in the Grand Canyon NP, Mammoth Cave NP, Tonto National Forest, & Fern Cave Federal Wildlife Refuge. I have also volunteered as a citizen scientist assisting the collection of microbes caves. Those microbes are studied at top universities by labs focused on novel drug discovery, material science, & carbon sequestration. My recreational interests are extensive -- I cave, rock climb, backpack, day hike, overland/off-road, etc. throughout the United States. In the last 10 years, I have travelled to several dozen National Forests for these activities including the Chattahoochee NF, Bridger-Teton NF, Daniel Boone NF, Monongahela NF, Petrified Forest NF, & Shasta-Trinity NF. While doing so, I strive to shop locally, dine locally, & support the small rural towns. For me, the biggest draw to areas such as this is the remote & unbroken environment. As any wildlife biologist can attest, habitats change dramatically when the continuous forest is interrupted by open space such as those created by roads. Additionally, as any caver can attest, some of the most fragile ecosystems on the planet can be hiding in plain sight (often just under our feet). I am especially concerned about sedimentation caused by building roads & logging in areas that would have otherwise been roadless. Not only can such activities degrade drinking-water supplies on the surface, but it can also destroy underground conduits of water such as those found in karst landscapes. This impact wields a double-edged sword: both the humans & the habitats that are reliant on the underground water supply are jeopardized. This impact isn't limited to a few rural towns or scattered populations, either. Nearly 40% of the drinkable groundwater in the U.S. comes from karst aquifers! Professionally, I am no strange to Federal documentation. I frequently write supporting documents for nuclear power plants that are reviewed by the U.S. Nuclear Regulatory Commission. I draw upon this experience when I review the documentation "supporting" the proposal to rescind the Roadless Rule & I am deeply troubled by the gaps in supporting evidence as well as failures of adequate planning. Below is an example of such: The DEIS does not analyze a reasonable range of alternatives. The USFS states this itself: "The alternatives evaluated in detail in this DEIS focus on the geographic locations (boundaries) in roadless rulemaking" (DEIS p. 34). Alt. 1 retains the 2001 Rule's prohibitions; Alt. 2 removes them nationwide; Alt. 3 "would continue the existing Rule's exceptions and provides for locally led boundary modifications" (DEIS p. 35). No alternative analyzed in detail varies the prohibitions & exceptions themselves according to stated resource criteria. NEPA requires "a reasonable range of alternatives to the proposed agency action... that are technically and economically feasible, and meet the purpose and need of the proposal," 42 U.S.C. Sec. 4332(2)(C)(iii), & the DEIS cites the parallel requirement at 7CFR1b.7(h) on the same page where it describes its own range as boundary-focused. The rest of this comment is attached as a file because the online portal's character limit is preventing the discussion of the matter in full.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Herons & bald eagles over Dolly Sods plateau, the cold headwaters threading down through Cheat Mountain & Glady Fork, the spruce-bog country on the highest points of the Monongahela National Forest: this is what the rescission of the 2001 Roadless Area Conservation Rule would put at risk. I oppose the proposed rescission, and I ask the agency to answer the specific questions this comment raises. The Monongahela's 20 inventoried roadless areas total 174,885 acres & protect headwaters that feed the Potomac & eventually the drinking water of Washington, D.C. Across the Eastern region, which includes West Virginia, 286 municipal water intakes sit in watersheds containing affected roadless areas. I understand that runoff, sediment, & water quality after logging and roadwork greatly diminish the health and quantity of fish, if they do not kill them off entirely. The agency's own data holds that roads and their facilities can produce up to 90%of the sediment from a timber sale. Fewer than 12% of the watersheds fed by these roadless areas have impaired streams today. I ask the agency to explain, with specificity, what watershed protection it intends to substitute for the rule's current protections, and how it expects sediment loads in these headwaters to remain within safe limits without them. The DEIS cites the 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 spruce-bog ecosystems of the Monongahela, relics of the last ice age clinging to the highest ridges, support species found nowhere else in this region. The agency has not explained how the bird communities of these areas survive a road network that its own cited science says reduces their abundance and drives a third of their species away. I ask that the agency address this finding directly and explain what mitigation it considers adequate to offset documented, rule-cited losses to avian biodiversity in the affected areas. The proposal justifies rescission in part on wildfire and fuels management grounds, yet 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." The agency must explain why this proposal departs from its own prior findings on fire occurrence, and must reconcile the rescission with the ignition data in its own DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The agency carries a $6.9 billion maintenance backlog against a road budget of approximately $73 million a year. 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 this proposal with its own economic 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 that backlog serves the public interest when the agency's own Cost Benefit Analysis cannot establish a net benefit. The agency's record also 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 for this rule and found it wanting. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids those same deficiencies. Finally, the courts that reviewed the 2001 rule's statutory authority 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 must address the Tenth Circuit's holding that the 2001 rule was within the authority Congress granted and did not create de facto wilderness, and state plainly the basis for any contrary legal position it now advances. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. The agency owes the public clear answers to every question this comment raises. Sincerely, Sally Morrison Bentleyville, PA

Hello, I'm very strongly opposed to the repeal of the roadless rule because it will allow an easy pathway for extractive industry to permanently degrade the wilderness characteristic of our beautiful public lands. There's nothing I look forward to in this life more than getting far removed from the confines of civilization and completely separating myself from the artificial, human-constructed world. I'm not a spiritual person, but these places feel sacred to me, and the addition of human infrastructure to these wiped and untarnished places is an affront to the sanctity of these wild places. I'd happily pay significantly more for my goods and services and contribute more to taxes if it meant we could reserve more totally wild, untarnished land. I've spent many weekends and vacations exploring wilderness areas local to me and afar, including the Dolly Sods wilderness, Roaring Plains Wilderness, Monongahela National Forest, George Washington and Jefferson National Forest, the Great Dismal Swamp, and many other places both local and far away that are worth more than money to me. Hiking trails are are as much development as is appropriate for these places. It was extremely disheartening to witness the clear-cutting of forest off of Squirrel Gap Road near Wardensville West Virginia, that I can't help but respect was facilitated by the road that runs through the area. I can't help but lose hope for the future every time we move toward the removal of these wild places for some quick flash-in-the-pan monetary benefit. I'm an east-coaster from Maryland that spends a lot of time daydreaming of my trips out to the great, untamed American west, and I would very passionately support efforts to maintain minimally impacted wildlands with intact old growth forest and minerals beneath unspoiled ground. I will campaign vigorously against any politicians in my jurisdiction that is in favor of the repeal of the roadless rule. I will contribute financially to the campaigns of politicians that oppose this rule, no matter what party they come from. This is my single issue of concern.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 These forests are gifts from God for us to protect. I hike in the Monongahela National Forest in West Virginia, the Ocala National Forest in Florida, and the Francis Marion Forest in South Carolina. I go there for beauty and inspiration. I look for all wildlife, even squirrels and raccoons, because signs of wildlife are signs of a healthy ecosystem. There are so few wild animals left on the planet. They deserve a place to roam free, and we deserve to see them. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The Monongahela holds 174,885 acres across 20 inventoried roadless areas, protecting headwaters that feed the Potomac and the drinking water of Washington, D.C. Verified species there include the West Virginia northern flying squirrel, the Cheat Mountain salamander, the snowshoe hare, and the northern long-eared bat. These are not abstractions to me. When I walk those ridges and catch any sign of wildlife, I know the land is intact. The Ocala, which sits directly on top of the Floridan Aquifer, holds 4,855 acres across 2 inventoried roadless areas. Alexander Springs pumps 80 million gallons of crystal-clear water per day through karst limestone that makes road construction a direct contamination pathway to the drinking water supply of central Florida. Red-cockaded woodpeckers recovered there from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. The Florida scrub-jay, found nowhere else on the planet, depends on surrounding scrub that roads would break apart. These are the places I photograph, looking for beauty and inspiration. I ask that this agency explain in this docket how rescinding the rule is consistent with protecting the species and water supplies these specific forests shelter. The proposal invokes wildfire management as a reason for rescission. 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." I do not understand how opening these forests to new roads reduces fire risk when the agency's own findings say the opposite. The agency must explain why this proposal departs from those prior findings and reconcile 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. The economics do not justify what is being proposed 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'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, with a net present value spanning -$92 million to +$199 million. That analysis cannot establish a net benefit. Meanwhile the agency is already $6.9 billion behind on maintaining the roads it has, on a road budget of about $73 million a year. Maintain the roads already in place. It makes no sense at all to construct new ones when we cannot afford to maintain the ones we have. How does expanding a road system already carrying a $6.9 billion maintenance backlog serve the public interest when the agency's own numbers cannot confirm a positive return? Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. The Tenth Circuit resolved that question. Its holding states: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the rule was within authority Congress granted and did not create de facto wilderness. The agency must address that holding directly and state in this docket the legal basis for any contrary position. Our public lands should be managed and preserved for us to enjoy and for future generations. To destroy these forests is irresponsible and short-sighted. I urge the agency to withdraw this proposal. Sincerely, Katie Mulligan Myrtle Beach, SC

The views expressed in this comment are my own. I am submitting as an individual and do not speak for or on behalf of the University of Maryland Center for Environmental Science. I am a doctoral candidate at the University of Maryland Center for Environmental Science, Appalachian Laboratory in Frostburg, Maryland, where my research focuses on migratory bird conservation. I live in western Maryland and spend much of my recreational time in the forests and protected areas of neighboring West Virginia, including Monongahela National Forest. I ask that the environmental impact statement (EIS) examine the following issues: 1) Wildfire risk, the stated basis for this proposal. The Forest Service has justified rescission as a way to reduce wildfire risk, but the claim should be rigorously tested. A 2026 peer-reviewed analysis of national forest wildfires from 1992-2024 found ~8 ignitions/1,000 hectares within 50m of roads, compared with ~2/1,000 hectares in Inventoried Roadless Areas, roughly 4x as many. Ignition density fell with distance from roads (1). The authors conclude that building roads into roadless areas is likely to result in more fires due to increased human access and ignition sources (e.g., campfires, cigarettes, vehicle sparks). The EIS should weigh access benefits for suppression against increased ignition risk and road maintenance costs. It should also analyze eastern forests separately because central Appalachian fire regimes and fuels differ from those of western forests. 2) Habitat fragmentation and forest-interior birds. The central Appalachians hold breeding habitat for Birds of Conservation Concern, including Cerulean Warbler and Wood Thrush (7). Roads cause habitat loss, fragmentation, disturbance, mortality, invasive species spread, and changes to adjacent environments (5, 6). Traffic and industrial noise can reduce reproductive and pairing success in songbirds and alter bird communities near roads (2-4). The EIS should quantify how road construction, logging, or development in currently roadless areas would reduce interior forest habitat and affect declining species. 3) Migratory and flyway-scale effects. Large, intact Appalachian forests provide breeding and stopover habitat for birds moving along the Appalachian ridge corridor. The EIS should assess cumulative impacts on migratory birds protected under the Migratory Bird Treaty Act and how habitat loss on National Forest lands would compound pressures elsewhere in their ranges. 4) Headwater water quality. Monongahela National Forest contains headwaters of rivers that supply drinking water downstream (i.e., Potomac and Ohio River basins). Roads are a source of sediment and altered stream hydrology (6). The EIS should evaluate effects on cold-water streams, sensitive aquatic species, and source water for downstream communities, including those in Maryland. 5) Threatened and endangered species. Please assess impacts on federally listed Appalachian species, including Cheat Mountain salamander and Indiana bat, whose habitats depend on intact forests and clean water. Please include a “no action” alternative that keeps the 2001 Rule in place, along with alternatives that keep roadless protections at the state or regional level rather than rescinding them nationwide. Thank you for considering my comment. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Francis, C. D., Ortega, C. P., & Cruz, A. (2009). Noise Pollution Changes Avian Communities and Species Interactions. Current Biology, 19(16), 1415-1419. https://doi.org/10.1016/j.cub.2009.06.052 Habib, L., Bayne, E. M., & Boutin, S. (2007). Chronic industrial noise affects pairing success and age structure of ovenbirds Seiurus aurocapilla. Journal of Applied Ecology, 44(1), 176-184. https://doi.org/10.1111/j.1365-2664.2006.01234.x Halfwerk, W., M. Holleman, L. J., Lessells, M., & Slabbekoorn, H. (2011). Negative impact of traffic noise on avian reproductive success. Journal of Applied Ecology, 48(1), 210-219. https://doi.org/10.1111/j.1365-2664.2010.01914.x Kociolek, A. V., Clevenger, A. P., St. Clair, C. C., & Proppe, D. S. (2011). Effects of Road Networks on Bird Populations. Conservation Biology, 25(2), 241–249. http://www.jstor.org/stable/27976457 Trombulak, S. C., & Frissell, C. A. (2000). Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology, 14(1), 18-30. https://doi.org/10.1046/j.1523-1739.2000.99084.x U.S. Fish and Wildlife Service (2024). USFWS Bird Species of Concern [fact sheet]. https://www.fws.gov/media/usfws-bird-species-concern

To the U.S. Forest Service and Department of Agriculture, I am writing to express my strong opposition to the proposal to rescind or weaken the 2001 Roadless Area Conservation Rule. I am an outdoor enthusiast and outdoor educator based in Chardon Ohio, and public lands are an important part of both my personal life and my work. I hike extensively in national forests and regularly lead youth groups on outdoor experiences in the Allegheny National Forest, White Mountain National Forest, and Monongahela National Forest. These forests provide opportunities not only for recreation, but also for young people to develop a deeper understanding of the natural world and their responsibility to care for it. From my experience spending significant time in these forests, I value the opportunity to experience large, relatively undeveloped landscapes where people can hike, explore, and learn without the presence of extensive roads and development. Roadless areas also provide important habitat and help protect watersheds and the quality of our water. Expanding roads into these areas would fragment intact landscapes, affect wildlife habitat, and create long-term infrastructure and maintenance costs. The remaining roadless areas in our national forests are a valuable and limited public resource. Once roads and other development are introduced into these places, their character is difficult or impossible to restore. I urge the Forest Service to withdraw this proposal and maintain the protections provided by the 2001 Roadless Area Conservation Rule. Sincerely, Tatiana Yudovina Chardon, Ohio Sent from my iPhone

Dear Secretary Brooke L. Rollins, I am writing to demand that roadless areas remain protected. These areas are invaluable and cannot be restored once lost. Future generation deserve no less. Short-sighted greed cannot be allowed to take away our children's future. I have visited the Canaan Valley for over 50 years. The chance to be in roadless areas as a young person actually changed my life. I learned to listen, hear, see, and love. I learned how to be quiet and know what is good about this life. The Canaan Loop is one of the most valuable recreational areas in West Virginia. The recreation economy is essential for the area. The chance to be in the wilderness is essential for both West Virginians and others (perhaps native West Virginians, like me) from surrounding states. Regarding the Canaan Loop in the Monongahela National Forest, West Virginia: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Rescinding the Roadless Rule would open the Canaan Loop, Monongahela 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. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205)” “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Tongass roadless areas contain very large biomass and soil carbon stocks, underscoring old-growth protection as a critical climate solution with global significance. — DellaSala et al., 2022 (https://doi.org/10.3390/land11050717)” “On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction.” The forests covered by this Rule are irreplaceable. The Rule itself should be treated the same way. Yours truly, CommentID: RLC-20261006-OCPMQB

The Roadless Rule is what makes so many wilderness areas across the United States so special. Many Americans and tourists flock to these areas to get away from the hustle, breathe some fresh air, and take in these unique lands that make the U.S so special. The United States has a rich conservation history and should preserve these lands for generations to come. I grew up recreating in Monongahela National Forest and fell in love with the outdoors in Dolly Sods. The limited infrastructure and lack of paved roads is what makes the forest so special. I want my children and their children to be able to climb to the top of Lions Head and look out to see only the landscape I saw as a child. We need to protect the few remote and untouched areas we have left. Once developed, they will never truly be the same, and we will lose major pieces of our country's natural history. There is something special in knowing that the backcountry area you're in has only been changed by forces of nature and erosion, not human intervention. As more and more people are exploring our National Parks and Forests, we need to protect these lands so they still have somewhere to go. Thank you..

I support Alternative 1 to keep the 2001 Roadless Area Conservation Rule in place. I camp, hike, bike, hunt, and fish in the George Washington and Jefferson National Forests across Virginia and in the Monongahela National Forest of West Virginia. Wild, roadless places enhance these outdoor activities and are why I frequently visit these national forests. My tourist dollars help sustain small communities surrounded by these forests. The limited roads and development in these forests also help protect the drinking water supply for these same communities and other communities downstream. The U.S. Forest Service already can’t maintain the roads it has. Building more will only lead to worse sediment impact to waterways and forest fragmentation, both of which negatively impact outdoor recreation and water quality.