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My name is Susan Fedore and I'm a lifelong resident of Washington state and have hiked, biked, skied, and explored many of our native natural forests including those along the North Nooksack River and in the Mt Baker Wilderness and Mt Baker-Snoqualmie National Forest. I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule and am in full support of Alternative 1. By the Trump administration's own admission, rescinding the roadless rule would result in lost recreation and visitor spending, threaten our water supplies, undermine tribal interests, spread invasive species, and imperil wildlife. Yet US Forest Service Chief Tom Schultz claims that active forest management of these "unroaded" public lands is essential because more than 40 percent had “high or very high wildfire hazard potential” and just 5 percent of that ground had seen fuels-reduction projects the past dozen years, stating, “acting now, thoughtfully and decisively, is the best way to restore the balance, reduce wildfire risk, and secure the long-term health of our forests and neighboring communities." In reality, data from the National Interagency Fire Center found that only 3% of all mapped historical wildfire ignition points over the last 50 years have occurred within Roadless Rule areas. Research has found that roughly 90% of all wildfires [https://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf, see page 4] start within a half-mile of a road, and that 88% are human-caused — with roads acting as corridors for human error, including accidental sparks, unattended campfires, and other ignition sources that can spark blazes [https://www.nifc.gov/fire-information/fire-prevention-education-mitigation/wildfire-investigation]. A separate analysis of four decades of satellite data found that inventoried roadless areas have not burned at significantly higher rates or severity than "roaded" national forest lands, and that in the most recent decade, roadless areas burned at a slightly LOWER rate than forests with roads. Further, it has been well-researched and documented by internationally renowned forest ecologists that "there are substantial costs to ecosystems associated with large-scale forest removals from mechanical thinning. Depending on environmental context, scale, frequency, and type of removals, impacts include: (1) loss of ecological integrity in a key successional stage and degradation of habitat suitability for associated taxa; (2) increased susceptibility of thinned stands to fire spread from higher sub-canopy wind speeds and increased fine fuels (slash); (3) soil compaction from heavy machinery; (4) reduced resilience where thinning from above removes naturally competitive dominant trees that may contain adaptive gene complexes; (5) release of carbon stored in forest biomass and soils; and (6) an increase in flammable understory species, including the spread of invasive plants. Thinning requires an extensive road network that alters hydrology, especially where roads intersect streams and on steep erosive slopes. In addition, the relatively high financial costs of thinning may divert resources from other activities that are more cost-effective and restorative." Source: https://9a8e4068-0d04-454c-b575-a7a5de8f6dfa.usrfiles.com/ugd/9a8e40_9f43e4dd675d48a6a4b1e2f63caf2edb.pdf The Roadless Rule safeguards clean drinking water for millions of Americans. According to the DEIS, inventoried roadless areas typically have good water quality due to LIMITED disturbance,” noting “road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” The Roadless Rule provides vital habitat for threatened species. Eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. The list includes species such as Bull trout, Chinook salmon, Chum salmon, Coho salmon, Marbled murrelet, Northern spotted owl, Oregon silverspot butterfly, Oregon spotted frog, Sierra Nevada red fox, and steelhead, among others. The Roadless Rule sustains old-growth and mature forests that serve as critical carbon sinks. Chad Hanson, co-founder of the John Muir Project and principle ecologist, has noted at this stage it is not possible to overcome the most severe upcoming impacts of the climate crisis solely by shifting away from consumption of fossil fuels. We must also, with equal vigor, increase protections of our best carbon sinks, especially our structurally complex and old-growth forests, to draw down the dangerous excess of CO2 in our atmosphere. For all reasons stated above, I strongly support keeping the Roadless Rule intact to protect our country's legacy of public lands by following Alternative 1 (No Action).

To Whom It May Concern at the U.S. Forest Service: As an outdoor enthusiast, I am entering the record to observe that the 2001 Roadless Area Conservation Rule represents a considered administrative judgment that the public interest in roadless national forest — ecological, recreational, and watershed-related — outweighs the interests served by road-building authorization, and that the Department's proposed rescission has not offered a sufficiently developed basis for overturning that judgment. I’m an avid hiker, backpacker and naturalist who spends time in our public lands year round. Part of the enjoyment of hiking and backpacking deep in these wild places is the possible chance encounter or seeing evidence of animals that are important to these ecosystems. We spend a lot of money to protect species like salmon, restore spotted owl habitat and reduce their predators and to reintroduce animals native and natural to the proper functioning of these habitats. We need to protect our investment of both state and federal dollars. Don’t allow the extinction of our spotted owl by allowing further degradation of their already fragile patchwork of habitat, protect are remaining old growth. Regarding the Glacier Peak K in the Mt Baker-Snoqualmie National Forest, Washington: Habitat Fragmentation and Edge Effects Reducing Spotted Owl and Murrelet Populations — Road construction breaks the continuous old-growth forest canopy into smaller, isolated patches, creating hard edges where sunlight penetration increases understory density and predator access. Northern Spotted Owls and Marbled Murrelets require large, interior forest patches with minimal edge; fragmentation reduces the area of suitable habitat available to each pair and increases predation by corvids and other edge-adapted species that thrive in disturbed conditions. The loss of interior habitat is not reversible on a timescale relevant to species recovery—old-growth forest structure requires 150+ years to develop. Road-driven fragmentation therefore represents a permanent reduction in carrying capacity for these threatened species. The 11.7-mile corridor between Glacier Peak K and Boulder River sustains gene flow for 28 species, including Bull Trout (G3), Cascades Frog (G3), Marbled Murrelet (G3), Mount Rainier White-tailed Ptarmigan (T2), Northern Spotted Owl (T3), Suckley's Cuckoo Bumble Bee (G2), Whitebark Pine (G3). Road construction in either IRA severs this exchange, isolating populations that depend on movement between areas for genetic diversity and recolonization after local disturbance. Failure to analyze cumulative connectivity impacts between Glacier Peak K and Boulder River renders the DEIS inadequate under NEPA. Courts have consistently held that analyzing connected actions in isolation violates the cumulative effects requirement. The 28 species shared between these IRAs, including Bull Trout (G3), Cascades Frog (G3), Marbled Murrelet (G3), Mount Rainier White-tailed Ptarmigan (T2), Northern Spotted Owl (T3), Suckley's Cuckoo Bumble Bee (G2), Whitebark Pine (G3), document precisely the ecological connection that demands joint analysis. "Genetic diversity and inbreeding were influenced by the size of local populations depending on their degree of isolation, and genetic differentiation was positively related to isolation. We identified a minimum local population of 19 male territories and a maximum distance of 30 km to the nearest population as thresholds from which genetic erosion becomes apparent. We detected a critical distance threshold of 30 km above which inbreeding and differentiation would increase dramatically." — Méndez et al. 2014, Evolutionary Applications, 2014 “Loss of habitat connectivity due to housing and road encroachment impairs dispersal between habitat patches, diminishing habitat availability and preventing habitat recolonization after local extinction. Loss of connectivity can also reduce gene flow, which can lead to inbreeding depression and loss of genetic diversity, with consequent reduced fitness and reduced ability to adapt to environmental change. Although the species is known to persist in small metapopulations at moderate levels of habitat fragmentation, the models indicate that these populations become highly vulnerable to demographic decline, genetic deterioration, and local extinction under increasing habitat connectivity loss. — Ramalho et al. 2018, PLOS ONE, 2018 (https://doi.org/10.1371/journal.pone.0191190)” I oppose this rescission, clearly and without qualification. I'm asking the Department to withdraw the proposal. With thanks, Melinda Gage CommentID: RLC-20261006-XLAERE

To the Roadless Rule Rulemaking Docket: I have lived just outside the National Forest in the Nooksack River drainage of the Mount Baker Snoqualimie National Forest for 35 years. The forest forest keeps our water clean, provides homes to much of the wildlife that are our neighbors and keeps diversity alive in a landscape dominated by tree farms. The roadless areas are key to preserving all of these things I have been hiking, hunting and foraging in the Mount Baker area for decades. I value the land immensely as intact, diverse forest. If this rule is recinded I will loose spots that have been providing my family with wild mushrooms. I will also loose the security I feel that the forest is holding back water to reduce the impace of flooding in our neighborhood and the less likelyhood of a wildfire in roadless areas. Regarding the Mt. Baker North in the Mt Baker-Snoqualmie National Forest, Washington: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Runoff acceleration. Roads in mountain watersheds transform slow subsurface flow into rapid surface runoff. Cutslope interception can account for more than 79% of road overland flow, contributing 10–30% of total flood discharge in some basins (Kastridis 2020). — Kastridis, 2020 (https://doi.org/10.3390/f11111201) Rescinding the Roadless Rule would open the Mt. Baker North, Mt Baker-Snoqualmie 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. Washington State has spent many millions to preserve and restore salmon habitat. The Federal Government should do the same and do all they can to protect the salmon and create watersheds the help prevent flooding. The administrative record does not supply a reasoned basis for rescission; accordingly, the Department should decline to rescind. Best, CommentID: RLC-20261006-550ZHE

Dear Secretary and Chief: My water in Snohomish County, WA comes from the Glacier Peak K Roadless area. The Roadless Rule has protected this watershed since 2001. The proposed rescission would foreseeably degrade conditions in our upstream watershed. I respectfully submit that the 2001 rule should be retained. Spada Lake, the reservoir that gathers the snowmelt and precipitation for our county, is an easy drive from my home. I've stood above it many times. I grew up hiking in Glacier Peak K Roadless Area: Big Four Ice Caves as a kid and now with the next generation of children, or up to Vesper Peak or the other looming peaks of the area. I have boated down the Skykomish River that drains part of Glacier Peak K. My history as well as my water lives here. The taste of clear, cool water from the Cascades is better than any water I've ever tasted. I feel safe knowing this water comes from a roadless area because my family and I won't be exposed to water tainted by mining or sediment. Regarding the Glacier Peak K in the Mt Baker-Snoqualmie National Forest, Washington: The aquatic ecosystems of the Glacier Peak K IRA, Mt Baker-Snoqualmie National Forest, depend on the absence of road-generated fine sediment. Clean gravel substrates support macroinvertebrate production and fish reproduction. Intact riparian canopy maintains the cold water temperatures that govern dissolved oxygen levels and species composition. Roads eliminate both conditions. The combined effect of low infiltration capacity of road surfaces and interception of surface flow and throughflow by cutslopes is increased surface runoff, leading to frequent erosion from the road surface (many events per year) and periodic mass failures from the adjacent hillslopes. The ecological consequences of sediment chronically supplied from roads (press), may be more detrimental than from sediment periodically supplied from post-fire debris flows (pulse). — USDA Forest Service, Rocky Mountain Research Station, 2012 (https://doi.org/10.1016/j.geomorph.2011.06.021) I'm asking from the bottom of my heart – please retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. In earnest, Leah Scott-Zechlin

Dear Forest Service Leadership: I write as a Mental Health Counselor who has seen the impact the decimation of natural spaces has on mental health--impact that costs a lot of money elsewhere. I also write as a person dedicated to spirit, shaped by traditions that know the earth as inextricable from our safety and belonging. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Roadless areas anchor the highest-integrity watersheds. Within the National Forest System, watersheds with the highest ecological integrity scores tend to be dominated by wilderness and roadless areas — over 50 percent roadless or wilderness cover in 81 percent of the highest-integrity subbasins. Watersheds with the lowest integrity scores show the opposite pattern: little roadless cover and moderate to high road density (USDA Forest Service 2000). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf) Rescinding the Roadless Rule would open the Mt. Baker West, Mt Baker-Snoqualmie 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. We're at a time where many corporate and elected officials act like they've given up on accountability to the living earth and our reciprocity within these complex systems of life. Preserving these spaces aligns with so much that we know about holistic health. Moreover, I think stewardship and protections like that encompassed with the roadless rule aligns with all the mystery of what we don't yet know, but still pay a cost for our ignorance. Short sighted cash grabs need to end. Please be a part of saying no to this tide. I love Mt. Baker West. The Nooksack River in her different forks has been a source of some of the most profound healing and connection I've had. Protecting this lifespring from the run off and damage logging causes isn't just a general logical and moral imperative, it is personally meaningful. I remember sitting by the banks of the middle fork of the Nooksack and being reparented over a many month long process. These big healthy centers of power can help revision and recontextualize human and other than human challenges . My spiritual center feels linked with this land. Logging this land injures me and so many others. The Department is respectfully urged to allow the Rule to stand and to decline the rescission action now proposed. Most respectfully,

To the U.S. Forest Service: I am writing as someone who cares deeply about the health of my community, our country, our planet, wildlife, and the environment. We have a responsibility to care for and protect the precious natural resources and wildlife habitats. As a science teacher, one of the first units I taught my students was about the interconnectedness of living and non-living aspects of the environment, specifically the importance of salmon and the factors contributing to their declining populations. One of the studies we looked at the correlation between stormwater runoff and the number of salmon eggs that were able to survive and hatch. Removing the roadless protections will surely lead to greater water pollution and cause even more harm to salmon populations, which will affect the ecosystem and humans who rely on salmon as well as clean air and water. Regarding the Tolmie Creek in the Mt Baker-Snoqualmie National Forest, Washington: The Tolmie Creek IRA in Mt Baker-Snoqualmie National Forest drains into downstream floodplains where road-generated increases in impervious surface, runoff volume, and peak flows trigger the flood hazard evaluation mandate of Executive Order 11988. Road construction in the Tolmie Creek IRA, Mt Baker-Snoqualmie National Forest, converts permeable forest soils to compacted and paved surfaces, increasing impervious area, accelerating runoff concentration, and elevating peak flows in downstream floodplains. For the Tolmie Creek IRA, Mt Baker-Snoqualmie National Forest, the DEIS must demonstrate compliance with Executive Order 11988 by evaluating how road construction alters watershed hydrology, increases peak discharge, and affects flood hazard potential for downstream communities and infrastructure. "Completed and proposed activities have resulted in or would result in the temporary discharge of dredged and/or fill material into 39,203 linear feet (8.2688 acres) of streams and 13.6957 acres of wetlands, the temporary discharge of dredged and/or fill material into 3.7690 acres of PFO and PSS wetlands resulting in a permanent conversion of these PFO and PSS to PEM wetlands, and the permanent discharge of dredged and/or fill material into 2,207 linear feet (0.3494 acre) of streams and 0.4288 acre of wetlands. The Mountain Valley Pipeline Section 404 permit authorized a total of 35,554 linear feet of temporary stream impacts and 1,145 linear feet of permanent stream impacts across 620 resource crossings." — U.S. Army Corps of Engineers (Huntington, Pittsburgh, Norfolk Districts) These lands weren't developed for a reason. Keep it that way. Warm regards, CommentID: RLC-20261005-NE57EU

Dear Secretary Brooke L. Rollins, In my experience as a resident of Skagit County, the nearby roadless country is not just scenery — it's functioning habitat, clean water, and quiet. All of it tied to one condition. The City of Anacortes draws its drinking water from the Skagit River, the largest river system flowing into Puget Sound. Pressentin's roadless areas are very criticial to the watershed's health. We also eat and fish salmon frequently, and we will be harmed by salmon habitat loss. Lastly, when the Skagit floods, our insurance rates go up. Regarding some specific issues and research that should be addressed in Pressentin in the Mt Baker-Snoqualmie National Forest, Washington: Communities downstream of the Pressentin IRA, Mt Baker-Snoqualmie National Forest, receive clean water because this watershed has no roads. Municipal water supplies, agricultural irrigation, and recreational fisheries all depend on the sediment-free, thermally stable flows that the roadless condition delivers. Road construction transfers the cost of degraded water quality to every downstream user. Roads built in the Pressentin IRA, Mt Baker-Snoqualmie National Forest, would remove riparian canopy at every stream crossing, exposing channels to direct solar radiation. Stream temperatures rise measurably at these points. For cold-water aquatic species, temperature increases of even 1–2°C alter dissolved oxygen concentrations, metabolic rates, and competitive dynamics. The effect is cumulative across multiple crossings within a watershed. The DEIS must evaluate the cumulative effects of road construction in the Pressentin IRA, Mt Baker-Snoqualmie National Forest, on downstream water users, including changes to turbidity, temperature, and flow regime. The analysis must include the cost of increased water treatment required by downstream municipalities and the economic impact on downstream fisheries and recreation. "Erosion on roads is an important source of fine-grained sediment in streams draining logged basins of the Pacific Northwest. A heavily used road segment in the field area contributes 130 times as much sediment as an abandoned road. A paved road segment, along which cut slopes and ditches are the only sources of sediment, yields less than 1% as much sediment as a heavily used road with a gravel surface." — Water Resources Research (AGU/Wiley), 1984 I don't want to see these areas opened up. Keep the Rule. With respect,

Roadless Dear Secretary Brooke L. Rollins, As an outdoor enthusiast who regularly uses areas of national forest that retain their current character specifically because the 2001 Rule prohibits road construction within them, I respectfully submit that the Department's obligation under applicable statutes includes giving full weight to the public interest in those conditions before authorizing their alteration. Regarding the Clearwater in the Mt Baker-Snoqualmie National Forest, Washington: NFMA requires consistency between agency actions and the applicable forest plan. The Forest Plan for Mt Baker-Snoqualmie National Forest governing the Clearwater IRA was developed under the assumption that Roadless Rule protections would remain in effect. "Inventoried roadless areas provide large, relatively undisturbed blocks of habitat for a variety of terrestrial and aquatic wildlife and plants, including hundreds of threatened, endangered, or sensitive species. Many inventoried roadless areas function as biological strongholds and refuges for a number of species, and they play a key role in maintaining native plant and animal communities and biological diversity." — USDA Forest Service By eliminating Roadless Rule protections for the Clearwater IRA, Mt Baker-Snoqualmie National Forest, rescission authorizes activities — road construction, commercial timber removal, surface-disturbing development — that are inconsistent with the management direction the Forest Plan established for this area. “Inventoried roadless areas provide large, relatively undisturbed blocks of habitat for a variety of terrestrial and aquatic wildlife and plants, including hundreds of threatened, endangered, or sensitive species. Many inventoried roadless areas function as biological strongholds and refuges for a number of species, and they play a key role in maintaining native plant and animal communities and biological diversity. — USDA Forest Service (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-ssummary.pdf)” Faithfully, CommentID: RLC-20261001-F6LCJV

The Forest Service should not finalize the rescission of the 2001 Roadless Rule as proposed in this draft EIS. The document's Scope of the Analysis section flatly states that "none of the rulemaking alternatives propose specific actions that would cause irreversible or irretrievable commitments of resources," yet the same EIS discloses that the rescission is preliminarily found "likely to adversely affect" 327 ESA-listed species and 71 critical habitats, and that permanent road construction and old-growth timber removal are reasonably foreseeable. An agency cannot credibly disclaim any irreversible resource commitment while its own effects chapters predict exactly that. The draft EIS contains other unreasoned gaps. In the Hazardous Fuel Reduction discussion, the agency's own cited research (Healey 2020) found that "the 2001 Roadless Rule did not meaningfully constrain hazardous fuel treatment activities," directly undercutting the purpose and need's claim that the Rule caused the current forest-health crisis. The Potentially Affected Environment section shows that existing land management plans already restrict timber harvest on 66.5 percent of the potentially affected IRAs regardless of the Roadless Rule's status, so rescission may deliver far less new access than claimed. And the Vegetation and Forest Management section admits that IRA timber harvest has averaged only about 500 acres a year, "inconsequential to overall nationwide" levels, over the more than two decades the Rule has been in effect. I hike with friends and family frequently in the Mt Baker-Snoqualmie National Forest. Many of the trails we use overlap with abandoned Forest Service roads, no longer used because the cost to maintain is too great compared to the difficulty of extracting the timber. Most of our commercial wood is grown on private plantations which are far more cost-efficient than extraction from public lands. The agency should: (1) complete ESA Section 7 consultation and disclose the final Biological Opinion covering the 327 species and 71 critical habitats before finalizing this rule; (2) revise the Scope of the Analysis section to honestly analyze the irreversible and irretrievable commitments its own chapters describe; (3) reconcile the contradiction between the purpose and need's forest-health rationale and the Healey 2020 findings it cites; (4) quantify the marginal benefit of rescission given that land management plans already restrict two-thirds of the affected acreage; and (5) extend the comment period on this draft EIS, given that 99 percent of the 220,000-plus comment letters already received opposed the rescission.

Dear Mr. Schultz: As someone on public land most weekends, the Rule does what it says. Don't touch it. I hike in and commune with this and surrounding 'roadless areas' many weeks throughout the years over the past 30 years. I am committed to it's complete preservation. My first hike up Riddley Creek trail as a young wanderer opened my eyes to the shocking beauty that untouched (non-roaded) wilderness areas let us experience. I built a strong desire to stay close to and work to preserve that beauty with the whole of my efforts. I have seen over the years that no new roads being made here have helped to preserve what precious wilds we still have. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: Oregon Spotted Frog (Rana pretiosa, G2, T) — an imperiled species — is documented present in the Mt. Baker West IRA and ecologically associated with Pacific Northwest Dry Silver Fir Forest (North Pacific Dry-Mesic Silver Fir-Western Hemlock-Douglas-fir Forest) (GNR, 5.2% of the area, ~1,313 acres). A species ranked G2 by NatureServe cannot absorb the habitat degradation that road construction inflicts on its ecosystem in Mt Baker-Snoqualmie National Forest. "Roads dissect previously large patches into smaller ones and create forest edge habitat along both sides of the road. This can lead to a change in community composition because species that depend on particular interior habitat conditions would be removed. Three variables changed significantly with increasing distance from the road to the forest interior along wide roads: tree biomass, herbaceous plant biomass, and soil pH." — Springer Nature / Landscape Ecology, 2020 NatureServe documents Oregon Spotted Frog (Rana pretiosa, G2) as ecologically associated with Pacific Northwest Dry Silver Fir Forest (North Pacific Dry-Mesic Silver Fir-Western Hemlock-Douglas-fir Forest). Species presence data independently confirms the species occupies the Mt. Baker West IRA. Road construction breaks the link between these two documented facts by degrading the ecosystem the species depends on — fragmenting habitat, altering hydrology, and introducing disturbance into previously intact forest. The DEIS must use NatureServe's ecological association data linking Oregon Spotted Frog (Rana pretiosa, G2, T) to Pacific Northwest Dry Silver Fir Forest (North Pacific Dry-Mesic Silver Fir-Western Hemlock-Douglas-fir Forest) (GNR) when analyzing road construction impacts in the Mt. Baker West IRA. This peer-reviewed, publicly available evidence is part of the best available science the agency is obligated to consider. Rescinding the roaless rule would absolutely increase the possibilities of extractive entities to raze through our sacred forests, destroying the vital habitat that protects and connects us all. best, CommentID: RLC-20260926-GF9FVW

To the USDA Roadless Rule Rulemaking Team: I currently live in the rainforest in Washington State, and grew up in rural West Virginia near the Monongahela National Forest. With the time I’ve spent in my home in the forest and in the backcountry, I know what the roadless rule is, what it protects, and what it prevents. This rule was hard-won, and created from the practical need to protect lands that are invaluable to our watershed, air quality, and health. This rule matters, and it should remain intact. One of my favorite areas to visit is Glacier Peak in northern Washington — which is currently protected under the roadless rule. The magic of this natural area is clearly preserved by the limit on roads in the area. The work, time, and emersion in nature it takes to get into the Glacier Peak wilderness is what keeps me coming back. My first time on the Pacific Crest Trail many years ago — far from any roads and only accessible by trail, I remember cresting a ridge to be surrounded by volcanos! I could see Mt St Helens, Mt Adams, Mt Rainer, and Mt Hood in the vista around me. If this rule is receded, these beautiful, rich, and biodiverse places are put at great risk for development, logging, increased wildfire risk, and watershed degradation. Bulldozed roadbeds would be the end of our excursions into the backcountry. Regarding the Glacier Peak I in the Mt Baker-Snoqualmie National Forest, Washington: The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Healey, 2020 (https://doi.org/10.1088/1748-9326/aba031)” The rule works. The public wants it. Keep it. Thank you, Briana McElfish CommentID: RLC-20260928-D5Y8I2

Peter Siu Burien, WA 09/21/2026 Director, Ecosystem Management Coordination U.S. Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 RE: Comments on Proposed Rule to Rescind the 2001 Roadless Rule (Docket No. FS-2025-0001 / RIN 0596-AD66) Dear Director, I am writing to express my strong opposition to the U.S. Forest Service’s proposal to completely rescind the 2001 Roadless Rule. As an active user of public lands who regularly visits Mt Baker-Snoqualmie National Forest, I am deeply concerned about the long-term ecological and economic impacts of opening these remaining wild spaces to road construction and industrial logging. The Draft Environmental Impact Statement (DEIS) fails to adequately account for several critical factors: 1. Impact on Local Water Quality: Road construction severely increases soil erosion and sedimentation in municipal watersheds. In my local area, Snoqualmie watershed provides clean drinking water to thousands of residents. The agency has not fully evaluated how the degradation of roadless areas will increase water treatment costs for local communities. 

 2. Habitat Fragmentation for At-Risk Species: The proposed repeal threatens intact habitat corridors that are essential for the survival of species such as the salmon, owls, and bears. Fragmentation from new roads will disrupt migration patterns and reduce biodiversity, a consequence that the DEIS underestimates. 

 3. Economic Value of Outdoor Recreation: The DEIS relies heavily on projected timber revenues while undervaluing the permanent economic contributions of the outdoor recreation economy. Millions of Americans visit these backcountry areas for hiking, hunting, fishing, and camping, which directly supports small businesses in rural gateway communities. 

 Instead of a total repeal, I urge the Forest Service to select the "No Action" alternative and maintain the 2001 Roadless Rule protections. Thank you for your time and for considering these substantive comments. Sincerely, Peter Siu

Dear USDA Leadership: In my experience as an outdoor enthusiast who regularly accesses remote public land, I have come to understand that what roadless designation protects is not merely acreage but a particular condition of landscape — one that, once altered by road construction, does not return within any human timeframe. I was just backpacking in this area last weekend, and it is both easily accessible by carefully managed roads and incredibly beautiful in its wildness. Artist point is a very accessible trailhead, but the beauty of it is you can leave and go any amount of distance (a mile away or climb Mount baker or something in between) and once you are a few minutes from the parking lot it feels like you are fully in nature and can appreciate its beauty and size. Roads in this area would take away this feeling, which would ruin a beautiful and special area. If this rule is rescinded I would lose the ability to access some of the most beautiful parts of Washington in the quiet peaceful and awe-inspiringly beautiful way that they currently exist. Regarding the Mt. Baker North in the Mt Baker-Snoqualmie National Forest, Washington: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Microclimate buffering recovers slowly after clearcutting. A 2025 study of boreal forests found that even-aged stands took roughly 30 years to recover the temperature-buffering capacity of unharvested forest. During that recovery period, the cooling effect of intact canopy is eliminated — exactly when species most need it during summer heat extremes (Starck et al. 2025). — Starck et al., 2025 (https://doi.org/10.1016/j.agrformet.2025.110434) Rescinding the Roadless Rule would open the Mt. Baker North, Mt Baker-Snoqualmie 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. This is clearly an unpopular suggestion, to repeal the roadless rule, and I join with all the other commenters in demanding these lands stay roadless. I'm asking the Department to hold the line on the Roadless Rule. There's no good reason to let it go. With thanks, CommentID: RLC-20260921-CL1NYQ

I oppose the proposal to fully or partially rescind the roadless area conservation rule. I live in Kitsap County, and I recreate in the Olympic National Forest most weekends. My family loves to hike and ride our bikes in this area. We also love to travel to Mt Baker-Snoqualmie National Forest, Okanagon-Wenatchee National Forest, and Gifford Pinchot National Forest to hike, camp, swim, and paddle board. We love all the recreation opportunities in these areas, and rescinding the roadless rule would personally affect my family, friends, and my community. Here are some other ways that rescinding the roadless rule would affect local communities: 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. Eliminating the Roadless Rule would adversely affect 327 threatened and endangered species and 71 designated critical habitats for these species. Eliminating the Roadless Rule would impact water quality. Road construction and native surface forest roads results in a major source of water quality degradation. In addition, increased road construction and timber harvest are likely to introduce and spread invasive plant species due to ground disturbance. Also, the roadless rule currently safeguards forests from human caused wildfires. Research suggests wildfires are more likely to start nears roads than in roadless forests. Do not take away our public lands, forests, and waters. It will significantly and negatively affect my family and my community.

Dear Ms. Rollins, The direct experience of national forest that remains outside the road system has shown me, as an outdoor enthusiast, that what the 2001 Rule protects is not wilderness designation but something distinct — a category of managed national forest that has been maintained in a condition broadly accessible to the public yet free of road infrastructure, and that condition would not survive rescission intact. I live within 20 miles of Mt Baker West and love the healing environment that it provides for me and multiple friends and endless community members. We cannot afford to lose these wild places that help everyone to connect to nature and improve mental, physical and spiritual health. Please consider all of the life forms of these magnificent places. The concept of "human exceptionalism" is a dead theory as we know that we CANNOT survive without a healthy natural environment that regenerates us I have experienced multiple encounters with natural beauty and wildlife peacefully coexisting on wilderness trips in Washington and Alaska that would not have been possible had they been accessible via roads. I would personally lose the calm feeling of knowing that there are protected places for all of life. Places that have clean air, water and soil that benefits us all, whether we are in direct contact with the place or not. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: The threat mechanism classified as 7.1 - Fire & fire suppression (IUCN-CMP 7.1) is actively degrading habitat for Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2) in the Mt. Baker West Inventoried Roadless Area, Mt Baker-Snoqualmie National Forest, at Negligible or <1% pop. decline severity across Pervasive - large scope. The physical footprint of road construction — grading, drainage installation, stream crossings — destabilizes slopes and generates chronic sediment inputs that intensify 7.1 - Fire & fire suppression in the Mt. Baker West IRA. Failure to analyze 7.1 - Fire & fire suppression impacts to Suckley's Cuckoo Bumble Bee (Bombus suckleyi, G2, PE) in the Mt. Baker West IRA renders the DEIS inadequate under NEPA. The administrative record must address this species-threat-area interaction or the analysis is arbitrary. "Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term." — Conservation Biology (Wiley), 2013 My ask is simple: keep the 2001 Rule. Thank you for your consideration of ALL of life of which we are a small part. Please listen with heart and act with wisdom. Yours sincerely, CommentID: RLC-20260920-X4SSS0

Dear Chief Tom Schultz: My name is Ken Hardesty and I live in Whatcom County, Washington and I protesting the rescission of the Roadless Rule enacted by President Bill Clinton. I am 80 years old now and have lived in this area for over 50 years. I have hiked, camped, and photographed in these forests for all of those years. I have fished for steelhead, salmon and trout in the lakes, streams and rivers that are within these forests. I have hunted for deer, elk grouse, and ducks within these forests. I have hiked Lake Ann, Yellow Aster Butte, Goat Mountain, Cascade Pass, Table Mountain and many other trails within these forests Standing in awe of the beauty of Lake Ann as it sits below the flanks of Mt. Shuksan I have fished the Nooksack River for over 50 years. I have seen the returns of steelhead trout drop so much that some seasons there are no openings. The watersheds that are home to these beautiful fish have been devastated by logging, and the destruction of spawning areas. Overfishing and over population have also contributed to this decline. Regarding the Mt. Baker North in the Mt Baker-Snoqualmie National Forest, Washington: The Rule stays, as far as I'm concerned. Hopefully, CommentID: RLC-20260915-UINQJS

As an outdoor enthusiast, I respectfully direct the Department's attention to the fact that the proposed rescission of the 2001 Roadless Area Conservation Rule would shift the default management posture for 58 million acres of national forest from protection to potential development — a shift whose administrative justification, as presented, does not match its scale. Nothing brings me more peace than to sit in nature the way it was intended. Witnessing full grown trees and clear water will forever be priceless. If the roadless rule gets rescinded the clear water will go away. When I was in Silver Spring campground in Mt Baker-Snoqualmie National Forest, I saw the salmon swimming upstream and it was so beautiful. The salmon need streams like these to survive and breed. To put these species in jeopardy is to put our own use of these natural resources in jeopardy. Not just clean water for salmon but for us. Rescinding the Roadless Rule would open the Silver Creek, Mt Baker-Snoqualmie 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 forests supply drinking water to millions of people across most of the United States. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. https://www.federalregister.gov/d/01-726/p-60 Regarding wildfire suppression: “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” (Aplet et al., 2026). Rescinding the Roadless Rule will inevitably lead to more logging. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. https://www.federalregister.gov/d/01-726/p-62 Please keep the land as it is. Don’t take away the beauty this earth has created.

Dear Chief Tom Schultz, The sustained practice of traveling through roadless national forest has shown me, as an outdoor enthusiast, that what the 2001 Rule preserves is not preserved by default — it is preserved because the Rule creates a specific regulatory prohibition, and rescission would remove that prohibition across approximately 58 million acres. we camp and hike in this region and enjoy the Baker Lake trail through old growth forest, so quiet, and often see wildlife there. It is a treasure and would be ruined with a road. With a road and logging we would lose the oportunity to hike in the wonderful old growth forests. Regarding the Mt. Baker Noisy - Diobsud in the Mt Baker-Snoqualmie National Forest, Washington: Serious - moderate severity and Large (31-70%) scope characterize the impact of 8.1 - Invasive non-native/alien species/diseases on Whitebark Pine (Pinus albicaulis, G3) in the Mt. Baker Noisy - Diobsud Inventoried Roadless Area, Mt Baker-Snoqualmie National Forest — losses that the current Roadless Rule helps constrain. The physical footprint of road construction — grading, drainage installation, stream crossings — destabilizes slopes and generates chronic sediment inputs that intensify 8.1 - Invasive non-native/alien species/diseases in the Mt. Baker Noisy - Diobsud IRA. NEPA requires the agency to take a hard look at the effects of rescission on Whitebark Pine (Pinus albicaulis) in the Mt. Baker Noisy - Diobsud IRA. The DEIS fails this standard without site-specific analysis of 8.1 - Invasive non-native/alien species/diseases at the severity and scope documented by NatureServe. "Stream fragmentation is a leading threat to freshwater fish diversity and is often caused by the installation of impassable culverts at road–stream crossings. In the United States alone, millions of culverts contribute to this fragmentation. Emerging research suggests that smaller barriers, such as culverts, can have cumulative effects on riverine fragmentation that are comparable to those of large dams." — River Research and Applications (Wiley), 2026 There's a reason this rule has lasted this long. I'm asking the Department to respect that reason and keep it in place. With respect, CommentID: RLC-20260912-DIUWWQ

Dear Chief Tom Schultz, My husband's grandfather was a guide on Mt. Rainier, and our extended family visits the areas he loved every summer. We camp at White River and Ohanapecosh, and walk his favorite hikes in rememberance of him. We've encountered many bears and marmots, and we've noted the change in the alpine meadows flowers. The Nisqually glacier is drastically diminished from what it was 30 years ago. I live near Mount Baker-Snoqualmie Forest in Whatcom County, Washington. Rescinding the Roadless Rule would open the Mt. Baker West, Mt Baker-Snoqualmie 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. Headwater Cold-Water Refuge for Threatened Salmonids — The Upper Middle Fork Nooksack River and its tributaries (Clearwater Creek, Rocky Creek, Ridley Creek, and others) originate in Mt. Baker West's subalpine terrain, where glacial meltwater and high elevation maintain the cold water temperatures essential for bull trout (*Salvelinus confluentus*, federally threatened) and Dolly Varden (*Salvelinus malma*, proposed threatened under similarity of appearance). The Nooksack system currently experiences 27% lower August streamflow than natural conditions due to historical timber harvesting and glacial retreat. This roadless area's intact forest canopy and undisturbed riparian zones preserve the remaining cold-water pulse that these species depend on for spawning and rearing—a function that becomes increasingly critical as climate-driven warming reduces glacial contribution to late-summer flows. “Comprehensive assessment of the conservation value of all 240,000 km&sup2; of Inventoried Roadless Areas. The study finds IRAs would expand the U.S. protected-area system by 27% while disproportionately buffering its largest cores: adjacent IRAs add +29% to Greater Yellowstone, +38% to Central Idaho, +32% to the Bob Marshall, and +31% to the North Cascades. 96% of IRAs are wilder than the median of the contiguous U.S.; 93% lie within 10 km of an existing protected area, providing critical connectivity for climate-driven range shifts. 58% of the watersheds intersecting National Forest System lands supply drinking water to over 48 million people, and adding IRAs to the protected network would increase well-protected drinking-water watersheds by 60%. 74% of all Forest Service wilderness designated since 2000 was first an IRA — the rule is the proven pipeline for permanent congressional protection. The authors warn that because IRAs are an administrative designation, they remain vulnerable to degazettement. — Talty et al., 2020 (https://doi.org/10.1111/csp2.288)” These are public lands and making a radical change should include a serious public process should be sure to include the public. USFS's disclosures on roads and fire undermines the argument that building roads will protect forests. Very truly yours, CommentID: RLC-20260910-N4ESJF

Dear Secretary Rollins and Chief Schultz, As someone who has spent a substantial portion of recreational time on public land specifically because of the conditions roadless designation maintains, I am submitting these comments to urge the Department to conduct a more rigorous accounting of public value before rescinding the 2001 Roadless Area Conservation Rule. While I know the Mt. Baker Snoqualmie National Forest best, I have also spent significant time in some of the last wild places on Earth - including the salmon runs of Alaska, wonderfully intact and protected by the Roadless Rule. I continue to explore the Mount Baker Snoqualmie National Forest, and find it beloved and respected by others who frequent it. Time in the protected forest and proximity to it is one of the reasons I live and enjoy living in the Skagit Valley. I have made my life and livelihood here, and without it I would no longer feel at home. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — 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 Mt. Baker West, Mt Baker-Snoqualmie 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. Recission of the roadless rule would be devastating for me personally and for my community who love and respect the outdoors. Unquantified Roadless-Specific Forest Health Data Supporting Causal Rationale The DEIS asserts that 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 has contributed to challenges in addressing forest health concerns" (Rationale for the Proposed Rule, pp. 18-19), yet this three-step causal chain is offered with no acreage figures, no roadless-specific fire, insect, or disease incidence statistics, and no comparison of forest health outcomes between roaded and roadless lands. An agency asserting materially changed conditions must articulate a rational connection between facts found and the choice made, not a bare assertion, under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983), Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), and unsupported factual premises violate APA 5 U.S.C. § 706(2)(A). I request quantified, roadless-specific data on acres affected, fire risk indices, and treatment backlogs, with a direct roaded-versus-roadless comparison, before this rationale is relied upon to justify rescission. Failure to Provide Sensitivity Analysis for Acreage-Derived Percentages The Draft EIS's own acknowledged 0.4-million-acre discrepancy between the 44.7-million-acre IRA figure and the 44.3-million-acre National Forest System land figure is never carried forward into any of the derivative percentages presented in the Affected Environment section, including the 56 percent Tongass figure, the 66.5 percent timber-harvest restriction figure, the 54.5 percent road-construction restriction figure, and the 2.8 percent NWPS overlap figure (pp. 20-36). Having conceded uncertainty in the base acreage, the agency cannot present percentages calculated from it as precise without disclosing how that uncertainty propagates. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), an agency that identifies a data-quality problem must grapple with its implications for downstream conclusions rather than disclose it in passing. Presenting these figures without error bars is also arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request that the agency provide sensitivity ranges or error bars for every acreage-derived percentage in this section before finalizing the rescission. I oppose this rescission, clearly and without qualification. I'm asking the Department to withdraw the proposal. With respect, E Burnham CommentID: RLC-20260908-0HAQRV