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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Mountain biking and camping with my family in the Mt. Hood National Forest is not an abstract interest. I ride the Forest Road 44 trails. My kids come with me. That is the ground this comment stands on, and it is the ground this proposal puts at risk. The agency's own data on road infrastructure should stop this proposal before it starts. The Forest Service is already billions of dollars behind on maintaining the roads it has. Building new roads into country that currently has none compounds a maintenance burden the agency has not come close to meeting. The sensible course is to focus resources on improving current infrastructure, not extending it into areas that are still intact. I ask that the agency explain on the record why adding new road miles is justified when the backlog on existing roads remains unaddressed. Roadless watersheds feed the water supply for an enormous number of Americans, and the Forest Service's own analysis acknowledges that roads and their associated facilities can produce the large majority of sediment from a timber operation. Clean water is the best legacy we can leave the next generation. I want my kids to inherit that, and I want the agency to answer directly whether the sediment risk from new road construction in these watersheds has been weighed against whatever timber or resource benefit is claimed. The regulatory flexibility certification in this proposal does not hold up against what the supporting documents actually say. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The certification reaches its conclusion by distributing the projected expenditure loss across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not an assessment; it is an average used to obscure a real impact. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The proposal also invites public comment on reliance interests and then does nothing with them. "The proposal solicits 'any reliance interests in the current rule that could be affected by this proposal' (91 FR 53830-31), and the Cost Benefit Analysis weighs none." Families who have organized their recreation around roadless protections, outfitters who have built permit-dependent businesses under the existing rule, and communities whose water comes from these watersheds have all relied on the 2001 rule across more than two decades. Soliciting those interests and then leaving them unweighed in the economic analysis is not a lawful change of course. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. On fire, the agency's own numbers argue against the proposal. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The effects analysis itself concedes that road access could increase the number and frequency of wildfires. Opening these areas to road construction would move the ignition density inside them toward the much higher rate observed on roaded land. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this proposal can proceed. Finally, the proposal treats the most consequential downstream effects as outside its scope while simultaneously asking the public to comment on them. "The proposed rule concedes that subsequent land management plan amendments and revisions 'could increase the area where timber harvest and road construction would be allowed,' declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830)." Rescinding the rule without analyzing what plan amendments will follow is analyzing only half the action. The foreseeable plan-amendment scenario, including expanded timber harvest area, belongs inside this analysis, not deferred to a later process the public cannot yet reach. The Forest Road 44 trails, the watershed those forests feed, and the country I want my children to know the way I know it are what is actually at stake. The 2001 rule should stand. Sincerely, Emily Martin Hood River, Oregon

I'm writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I care deeply about our national forests. Mt. Hood National Forest has been one of many places I have been able to connect with the natural world, and is also an area I rely on staying protected to have clean drinking water. These lands are home to countless wildlife, and are sacred to many communities, including local Indigenous communities. I strongly oppose rescinding the 2001 Roadless Rule because of its environmental impacts, including impacts to wildlife and recreation. The Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. The Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. The science is clear: road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. Nearly 85% of wildfires are human-caused, and most ignite within a few hundred feet of roads. New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. The current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary. Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. Forested watersheds filter and store water more effectively than developed lands, reducing sediment and pollutants. Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. With climate change and development already fragmenting ecosystems, rescinding the Roadless Rule would jeopardize some of the last large, undeveloped tracts of land in the U.S. Only 3% of the world’s ecosystems remain intact. We can’t afford to abuse what little remains. The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale for rescission—addressing wildfire risk and giving states more decision-making power—rings hollow when no funding is allocated to meet those goals. Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. For all these reasons, I strongly oppose rescinding the 2001 Roadless Rule. I ask that before moving forward, the agency: Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; Guarantee that no watersheds will be negatively affected by rescission; Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. I urge you to take action to uphold the Roadless Rule. Please protect the United State’s remaining roadless areas for current and future generations. Thank you -Jahnavi Hastings

Dear USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule as an Oregon Certified Naturalist, since my retirement in 2012, a birder and teacher of the young people in my family for three generations. I have been volunteering in nature research studies and environmental education, working with State Parks, National Parks Service, Bird Alliance of Oregon and others to understand the forests and the many species there which I have enjoyed all of my life in Oregon and to teach others how to appreciate and protect our unique wild lands which are so important to us. I have shared the wonders of these areas with my own family as well as many other young people, in Outdoor School and other public education programs, adding to their enjoyment of growing up in Oregon and contributing to their understanding of the unique place we live, particularly in the Inventoried Roadless Areas around Mt. Hood in the Mt. Hood National Forest and those in the Gifford Pinchot National Forest. Inventoried Roadless Areas offer tremendous benefits to communities and ecosystems that would be threatened or destroyed by road building. Here are just a couple of examples I have witnessed personally of the benefits of retaining the Roadless Rule. Wildlife habitat: imperiled species like Northern Spotted Owls, Marbled Murrelets, and countless other birds rely on large, intact forests with undammed, unlogged streams and connected landscapes. Salmon, trout, elk, and other species are also threatened when habitat is fragmented. This became very clear to me when I participated with Bird alliance of Oregon in monitoring Marbled Murrelets in 2019, and could see how little nesting habitat is still accessible to them. Drinking water: 60 million Americans rely on national forests for drinking water; intact forests filter water naturally. Many inventoried roadless areas are important parts of watersheds. I was fortunate in 2014 to join a tour group from the City of Portland’s Water Bureau to take a field trip to tour several parts of the Bull Run Water Shed to learn firsthand how this is possible and came to appreciate the role such places play in supplying some of the purest cleanest drinking water in the state. Outdoor Recreation: Roadless areas offer abundant outdoor recreation opportunities such as hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands, and roadless areas contribute millions of dollars to local economies through the recreation industry. My family and friends have spent most of our vacations throughout our lives camping and hiking together in these places in Oregon, across the state. As a volunteer I always meet folks when I am conducting my wildlife surveys, who are happy to share that they love about who are happy to share how much they enjoy their time in these wild places, and how important it is to them. I urge you to keep the Roadless Rule in place as it is. Thank you for your attention to my request. Donna Acord

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I ask the Forest Service to honor the long-standing public consensus and keep strong protections in place by maintaining the 2001 Roadless Area Conservation Rule. The America of my dreams is wild, untamed, genuinely free, and the Mt. Hood National Forest is one of the places where that dream lives. Being able to walk among century-old trees with my son, hear the calls of the hermit thrush and the song of the water ouzel next to rapidly flowing waters, is the greatest blessing of my life. My children have learned personal responsibility, self-reliance, and the genuine spirit of the American Dream in the wilderness. Protecting these areas is nothing less than safeguarding the very soul of this country. Three wildfires burned in Mt. Hood National Forest this year. Two of them were caused by human activity, and that activity was enabled by butts in seats travelling on pre-existing roads. That fact is not incidental to this rescission proposal; it is the center of it, because the agency's own record says the same thing. The agency has found that "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 also concedes in its own effects analysis that "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The proposal nevertheless advances rescission partly on wildfire and fuels management grounds. The agency must explain, with specificity, why it is departing from its own prior findings on fire occurrence, and it must reconcile the rescission with the ignition data in DEIS Table 21, which reports fire density on roaded land at a level that dwarfs what occurs inside the roadless areas. Beyond that, I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that increase honestly against the claimed reduction in wildfire hazard before this proceeding advances any further. The economic analysis supporting this proposal is internally inconsistent in a way the agency has not addressed. The proposal certifies no significant impact on small entities, yet the DEIS names outfitters, guides, and tour operators as affected, and the agency's own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading an annual expenditure loss of $9 million across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency concedes that some of those firms may lose those receipts entirely. Certifying no significant impact under those conditions is not analysis; it is arithmetic designed to produce a predetermined answer. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas. There is a further procedural problem the agency has created for itself. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My family has organized our relationship to the national forests around the protections the 2001 rule provides. Hiking and backpacking into wilderness areas free from the noise of machinery is a year-long activity for us, grounded in the expectation that those areas remain unroaded. The rule was developed through more than 600 public meetings and 1.6 million comments. No comparable process has been offered to undo it. Under the legal standards governing agency reversals, an agency changing course must genuinely assess the reliance interests its prior policy created. Soliciting those interests in the Federal Register and then declining to weigh them in the cost-benefit record does not satisfy that obligation. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one, before any final action is taken. I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I urge the US Forest Service to select Alternative 1 (the No Action Alternative) in the Draft Environmental Impact Statement (DEIS). Sincerely, Preston Boyd Gresham, Oregon

Dear Secretary Rollins and Chief Schultz, I am writing to voice my strong opposition to rescission of the Roadless Rule--a very popular and flexible rule that has thus far successfully protected forests, wildlife, the climate, and communities across the country. I am particularly concerned about climate change and follow climate policy as a citizen. This rescission ignores the carbon implications it entails--a grave omission. The Roadless Rule matters to me. It respects the value of intact ecosystems and their role in maintaining health--not just of the forests themselves and the flora and fauna those forests contain--but our own human health. Roadless Rules protect clean air and clean water. They mitigate climate impacts. Geographic locations with roadless areas in place have even been shown to increase local revenue and standard of living. The Roadless Rule reflects human inclusion in the whole of the environment. I live in western Oregon and am always filled with awe when I hike in the forests here. The clean air, the smell of evergreen, and the silence always bring me a sense of peace and wholeness. We disturb these intact forests, through roads and industry, at our own peril. It makes me proud of my country when we decide to protect the beauty and sanctity of nature from unconstrained human development. Regarding the Eagle in the Mt. Hood National Forest, Oregon, near where I live: Without the Roadless Rule, the Eagle IRA in Mt. Hood National Forest loses the protection that currently maintains Pacific Northwest Lowland Mixed Hardwood-Conifer Forest (North Pacific Lowland Mixed Hardwood-Conifer Forest) (GNR, 1.1%, ~178 acres) as intact habitat for Oregon Sullivantia (Sullivantia oregana, G2,). The species is documented present and ecologically associated with this ecosystem through two independent data sources — rescission puts both at risk simultaneously. "70% of remaining forest is within 1 km of the forest's edge, subject to the degrading effects of fragmentation. A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time, with average species loss >20% after 1 year and >50% after 10 years." — PMC / Science Advances, 2015 Oregon Sullivantia (Sullivantia oregana, G2,) does not merely occupy the same space as Pacific Northwest Lowland Mixed Hardwood-Conifer Forest (North Pacific Lowland Mixed Hardwood-Conifer Forest) in Eagle — NatureServe documents an ecological dependency. Road construction that compacts soils, disrupts hydrology, opens canopy gaps, and introduces invasive species into this ecosystem directly undermines the habitat conditions this imperiled species requires for persistence. There are SO many reasons that rolling back the 2001 Roadless Rule is a bad idea. I have only commented on a few here but could have spent hours outlining countless more. I trust other citizens will have touched on these concerns. It strikes me from the research that I have done that the authors of the rescission have not fully addressed the myriad detrimental effects that opening further areas to roadbuilding will create. The Roadless Rule is a popular and successful rule, supported by individuals on both sides of the political spectrum. It is flexible, allowing for roads when they are truly necessary and allowing individual states to modify the guidelines as appropriate. Rescinding this rule, it seems to me, will benefit only the owners of the extractive industries who can take advantage of opened-up wild spaces, to the detriment all others. Even the argument that the rescission will help with fire suppression strikes me as unfounded based on studies showing that wilderness and inventoried roadless Areas have the lowest ignition densities of any land category studied. Please do not rescind this rule. With appreciation, Stacey A. Danner

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I care deeply about our national forests because I recreate in Mt. Hood National Forest, rely on forest watersheds for clean drinking water. I strongly oppose rescinding the 2001 Roadless Rule because of Environmental Impacts * The Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. * Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. * The Forest Service itself stated in the text of the Roadless Rule that conserving roadless areas was critical because road construction and logging were the activities “most likely to harm” the characteristics and values the agency is tasked with protecting. That remains true today. * The science is clear: road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. Fire * Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. * Nearly 85% of wildfires are human-caused, and most ignite within a few hundred feet of roads. * New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. * The current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary. * Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. Clean Water * National forests provide drinking water to 60 million Americans, including more than 1 million Oregonians who rely on Mt. Hood National Forest. * Forested watersheds filter and store water more effectivelythan developed lands, reducing sediment and pollutants. * Road building undermines these natural filtration systems and threatens millions of Americans’ access to safe drinking water. Intact Landscapes * With climate change and development already fragmenting ecosystems, rescinding the Roadless Rule would jeopardize some of the last large, undeveloped tracts of land in the U.S. * Only 3% of the world’s ecosystems remain intact. We can’t afford to abuse what little remains. Economic Considerations * The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. * The text of the Roadless Ruleitself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. * On the local level, Mt. Hood’s 2015 Travel Analysis Reportcalled for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. * The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale for rescission—addressing wildfire risk and giving states more decision-making power—rings hollow when no funding is allocated to meet those goals. * Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. Rescinding the Roadless Rule Contradicts Public Opinion * The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. * Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. * Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. * USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans.

To the USDA Forest Service: I strongly oppose the proposal to eliminate, weaken, or alter the Roadless Rule. As a resident of the Portland, Oregon area, I depend on the forests of Mt. Hood National Forest and the Bull Run watershed, and I urge the agency to select Alternative 1, the No Action alternative, and keep current roadless protections in place. Some changes can't be undone. Once roads and clearcuts fragment a roadless forest, the damage is permanent. These are some of the most intact, resilient ecosystems left in our country. They filter and store clean water, shelter vulnerable species, and serve as critical carbon sinks. A decision that can't be reversed deserves the highest bar of justification, and this proposal doesn't meet it. This is about the health of my neighbors. In the Portland area, our drinking water comes from the Bull Run watershed in Mt. Hood National Forest, which serves roughly a million people in my region. Protecting the forests that surround and feed our water supply is a public health issue. Road building and logging in these landscapes put at risk water that my family, my neighbors, and our community drink every day. Roads also bring more fire: research shows wildfires are four times more likely to ignite near roads. Fighting fires in remote areas is dangerous and costly, and it pulls resources away from protecting communities. The Roadless Rule already includes exceptions for emergencies such as wildfire, so rescinding it for this stated purpose is unnecessary and dangerous. The economics don't add up. New logging roads in remote backcountry are extraordinarily expensive and leave taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely used. Meanwhile, logging roadless forests degrades services our economy already depends on. Mt. Hood National Forest draws visitors from across the Portland metro area and beyond, supporting a multi-billion-dollar outdoor recreation industry nationwide, along with sacred sites, traditional foods, wildlife habitat, and carbon storage. Trading these for short-term logging profits is a net loss for communities and future generations. Americans have already made this decision. The original Roadless Rule came out of the most extensive public engagement process in the history of federal rulemaking, and over 95% of commenters supported strong protections. Last fall, over 600,000 people commented on the Notice of Intent, and over 99% opposed rescinding the rule. Now the agency is pursuing a rushed, abridged process that limits and ignores input from citizens, scientists, Tribes, and local communities. Overriding a clear, repeatedly expressed public mandate is undemocratic, and it is irresponsible for a decision of this consequence. For more than two decades, the Roadless Rule has balanced ecological, economic, and cultural values. Both Alternatives 2 and 3 would have severe consequences for wildlife, biodiversity, clean water, climate resilience, cultural resources, local economies, and outdoor recreation. I urge the USDA to abandon this effort, select Alternative 1, and maintain full Roadless Rule protections for the forests that protect my community's water and the wild places we all share. Sincerely, Timothy Wittig OR

I am writing to oppose the proposed partial or full recission of the Roadless Area Conservation Rule, which has protected our wild, roadless areas for a quarter of a century. As a resident of Oregon, I hike, camp, bird, and find immeasurable refreshment in roadless areas that could be adversely affected by such a recission. These areas include Larch Mountain in the Columbia Gorge (where I have seen many Great Horned Owls and Common Nighthawks), the Salmon River Trail in the Mt. Hood National Forest (which I hike with friends at least half a dozen times a year), and Lookout Mountain (the highest peak in the Ochoco Mountains of central Oregon and a thrilling, wild hike. But while I am concerned about the future of roadless areas I know and love, that concern extends to the almost 45 million acres of public land nationwide that could be affected. The actions proposed under this recission would, according to the Administration's DEIS, "adversely afffect" 327 endangered or threatened species and 71 critical habitats. But these wild areas are not just crucial habitat for the wildlife that is facing stressful conditions across the board. They also help to purify our water and air, and they provide first-class opportunities for recreation and relaxation in nature. Opening them to road-building, logging, and other forms of commercial development would damage them in ways that could not be repaired. Opening these roadless areas to road-building does not make environmental sense. Nor does it make economic sense. Road-building is costly and would add to the backlog of deferred maintenance, which is already nearly $7 billion. The public is being told that road-building is needed to combat the risk of wildfires. Not true. The Administation itself has said, "“Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” An article on fire ecology published in January 2026 examined three decades of data and found that fires are four times more likely to start near roads than in roadless areas. The Administration's DEIS also stated that road-building and increased logging will “introduce and spread invasive plant species due to ground disturbance.” Invasive plants are another factor that contributes to wildfires. “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations," says the Administration's DEIS, "and sediment delivered to surface waters is a major source of water quality degradation.” In addition to costing communities near roadless areas millions of dollars in lost revenue as recreational areas are degraded, rescinding the Roadless Area Conservation Rule would imperil the clean drinking water of communities such as LaGrande and Ashland here in my home state, and many other communities elsewhere. I urge the Forest Service to keep the Roadless Area Conservation Rule in full force. Thank you for your time and attention. Rebecca Stefoff, Portland, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Lake and Eagle roadless areas in the Mt. Hood National Forest are where I hike and camp. These are the places this proposal would put at risk, and that is why I am submitting this comment opposing rescission of the 2001 Roadless Area Conservation Rule. The agency's own record on wildfire undermines the core rationale for this proposal. The DEIS states plainly: "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 same record puts numbers to this: human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, drawn from DEIS Table 21 covering 2014 through 2024, and the DEIS further states that human-caused ignitions increase in abundance with proximity to roads. The proposal presents wildfire and fuels management as reasons to open these areas to road construction, yet the agency's own analysis describes the opposite dynamic. I ask that the agency explain why this proposal departs from its own prior findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions that would follow new road access in areas like Lake and Eagle, weighed against the claimed reduction in wildfire hazard. The regulatory flexibility analysis is equally difficult to defend. The proposed rule certifies no significant impact on small entities while, as the record makes plain, "the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification is reached by spreading the projected annual expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The supporting analysis concedes that some of those firms may lose these receipts entirely. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas, which suggests the scale of economic activity tied to these landscapes. The agency must withdraw the no-significant-impact certification and replace it with an assessment of the small entities actually operating in the potentially affected roadless areas, not a national average that dilutes the real exposure. There is also a straightforward legal problem the proposal does not address. Under the reasoning of Encino Motorcars and Regents, an agency that changes course must grapple with the reliance interests its prior policy created. The proposal itself acknowledges this obligation: it solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is itself such an interest. I hike and camp in the Lake and Eagle roadless areas because the rule has protected them, and my reasonable expectation that they would remain protected is exactly the kind of interest the solicitation invites and the analysis ignores. The agency must identify and weigh the reliance interests expressed in the comments it receives, including this one, before it proceeds any further. The agency has asked for reliance interests and then provided no mechanism to weigh them. It has cited wildfire risk as a reason for rescission while its own tables show fire density on roaded land running more than seven times higher than inside the affected roadless areas. It has certified no significant small-business impact while booking a minimum of $6.1 million in annual recreation losses. These are not peripheral inconsistencies. They go to whether the record can support this action at all. I urge the agency to withdraw the proposal. Sincerely, Scott Rower Hood River, OR

I am writing in opposition to the plan of rescinding the Roadless Area Conservation Rule. Wilderness areas without roads are precious and untouched land embodies the American spirit. The roadless rule protects national forests from logging and has preserved irreplaceable wildlife habitats, sources of clean water, and provided places for Americans to recreate. Repealing the Roadless Area Conservation Rule would destroy all of these protections, both now and for future generations. This would ruin American land, thus this proposal is downright un-American. National forests protect over 45 million acres of National Forest System land (according to the US Forest service). This includes beloved places such as Tongass National Forest, Mt. Hood National Forest & Payette National Forest. Visit these places even just once, and you will understand the need to preserve these lands. Land preservation begins with untouched wilderness. In fact, peer-reviewed evidence shows that roadbuilding increases wildfires with 80% of wildfires occurring within 800 meters of roads. This proposal will not act as a wildfire-prevention measure despite the proposal’s intended purpose. Additionally, cutting down large old trees to create roads or increase timber production increases wildfire chances as older trees are most resilient to wildfire. Ecosystems and old-growth trees take hundreds of years to regrow. This will impact carbon absorption as the trees standing in our forests today have power to lessen the effects of climate change. National Forests should not be a place used for industry. National Forests serve their own purpose as a National Forest- land to recreate. People use these lands to fish, get water, watch for wildlife, hike, backpack, canoe, camp and more. The National Forest land provides a window into the true American frontier, and allows us as modern citizens to experience America’s finest and truest form. Roads will ruin National Forests. Within the current protections, fire roads are allowed to be created and maintained, thus the addition of more roads will ruin and pollute our National Forests. Instead of rescinding the Roadless Area Conservation act, consider other methods of wildfire prevention, such as funding wildlife protection agencies. National Forests should remain land for all Americans, not only the timber industry. I urge you to keep the Roadless Rule in place to protect the true spirit of the American wilderness.

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. As a lifelong enjoyer of forests and all our nation’s beautiful natural areas, and as someone who has worked in local conservation and restoration for over a dozen years, I care deeply about our national forests and am intimately familiar with their benefits for recreation, the economy, wildlife habitat, and maintaining clean air and water. I strongly oppose rescinding the 2001 Roadless Rule for many reasons, among them because: • The Forest Service itself was founded to protect forests and watersheds from logging and development. We have scientific proof that roads fragment the landscape, causing myriad issues that taken all together are even more harmful than clearcuts • Road building disrupts wildlife, impair watersheds and makes adjacent stands much more vulnerable to fire. In fact, wildfires are four times as likely start in areas with roads. Roads also accelerate the spread of disease and highly damaging invasive pests that kill trees • Roadless areas protect habitat for over 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests that are hundreds of years old • The current rule in place now already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore completely unnecessary. • Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. • The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. • Here in my local region, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. • The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private and Tribal Forestry. USDA’s stated rationale for rescission— supposedly addressing wildfire risk and giving states more decision-making power—rings as hollow and absurd when no funding is allocated to meet those goals. • Forest revenues today come mostly from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. • The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. These comments were over 95% in support of keeping roadless protections. • Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. • Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. For all these reasons above, I strongly oppose rescinding the 2001 Roadless Rule. Before the agency moves forward, I ask that the agency: • Conduct a complete and thorough environmental analysis of roadless areas to assess the impacts of additional road building; • Guarantee that no watersheds will be negatively affected by rescission; • Develop and share out a detailed plan for addressing its existing backlog in road maintenance and repairs; • Commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. • Commit also to acting in accordance with the will of the public the agency works with and for. If the public opposes the rescission of the Roadless Rule, it should do the same. Please protect America’s remaining roadless areas for current and future generations.

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I live near and regularly recreate in the Mt. Hood National Forest, and rely on the adjacent Bull Run Watershed for my drinking water. I strongly oppose rescinding the 2001 Roadless rule. Leaving the rule in place is the most cost effective, simple, and responsible way to maintain the many benefits of roadless areas, including for the Mt. Hood National Forest. My primary concern is protecting clean drinking water for myself and my neighbors, and being able to trust that our local intact forest continues to filter and store our water safely into the future. As someone who hunts, fishes and forages wild foods, I know that roadless areas provide critical habitat and serve as nurseries for countless species, and that my opportunities to hunt, fish, and forage would be diminished by the construction of more roads on our public lands. I grew up hunting and exploring in wild, roadless areas in Montana, and my dad continues to hunt on and near his land there. The No Action Alternative is our best option for ensuring that these opportunities continue to be available for future generations, including my nephews. I'm also aware of the research making clear that wildfires are more likely to start near roads, and know that work to reduce and mitigate fire risk can and does happen successfully in roadless areas. The existing rule already provides flexibility for a variety of management activities including fuels treatment, with plenty of room for local jurisdictions to make plans and decisions in coordination with their communities that address the specific needs of different forests. Leaving the Roadless Rule as is will continue reducing fire risk, while saving tax dollars and ensuring the Forest Service prioritizes the maintenance of existing resources. Finally, as someone who works in local economic development supporting small business owners, I want to speak to the importance of roadless areas to my recreation industry clients and their peers. These include whitewater outfitters, outdoor gear manufacturers, and every restaurant, gas station, and lodging establishment in a rural community serving as a gateway to the backcountry. Roadless areas are vital to a thriving economy and the sustainability of small towns through their protection of opportunities for peace and solitude. All of us who camp, hike, mountain bike, climb, or paddle know that roads take us part of the way to where we want to be, but that getting off the beaten path is essential to the experience. On the way to our destinations and on the way back, we spend money that helps keep small businesses alive, creating and sustaining jobs and rural livelihoods for the entrepreneurs who make these communities vibrant places to live and to visit. For all these reasons - clean water, fiscal responsibility, fire safety, recreation opportunities, and economic development, I strongly oppose rescinding the 2001 Roadless Rule. I ask that the USDA take this and all the comments opposing rescinding the rule into consideration, and commit to a thorough analysis of roadless areas. In particular, any changes must guarantee that no watersheds will be negatively affected. Please protect our remaining roadless areas for all of us and future generations to benefit from. Jocelyn Furbush

2001 Roadless rule protects public lands from future roads being built through. I am in favor of counting to protect roadless public lands across the nation - including Mt. Hood National Forest.

As a Texan transplant, I found in Oregon the true majesty of the American birthright: public lands, roughly two million acres of which are protected as inventoried roadless areas here. If the roadless rule is revoked and these places are opened to commercial extraction, they will be profoundly and permanently changed for the worse. Beyond providing world-class recreation, they are critical wildlife habitat and a source of clean water for many communities. As a resident of Portland, I enjoy more protected land within an hour's drive than I could fully experience in a lifetime. I'm especially fond of the country on both sides of Highway 35, south of Hood River in the Mt. Hood National Forest, some of the finest terrain for bicycling in all of America. My time in these wild places has changed the course of my life for the better, and I consider putting them at risk for industrial development unacceptable. Public lands belong to all of us. I am also concerned about wildfire. Opening these areas to road building increases human access and the likelihood of human-caused ignitions, at a time when climate change is intensifying fire seasons. Oregonians would bear that added significant risk. Finally, the draft EIS itself acknowledges a $6.9 billion deferred maintenance backlog for the National Forest road system. The agency does not have the staff or funding to maintain the roads it already has. Building more will compound that backlog, add to the strain on forests that Oregonians and tribal nations depend on, and leave us all more exposed in the face of climate change. I urge the Forest Service to select the no-action alternative and retain the 2001 Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I have spent countless hours in, Mt. Hood, Gifford Pinchot, Deschutes, and many others across Oregon and Washington, are worth defending precisely because they remain what they are. The Salmon-Huckleberry Wilderness area, 17,570 acres within Mt. Hood National Forest in Oregon, sits inside a broader landscape I know well. Anything that strips these forests of their protections to serve corporate interests is, in my view, a massive mistake, and this proposal is exactly that. The Deschutes holds 11 inventoried roadless areas totaling 136,446 acres. Within that system, Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. The lower Deschutes holds one of only two national strongholds for federally threatened bull trout, and Big Marsh supports possibly the largest monitored population of federally threatened Oregon spotted frog anywhere in its range. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Oregon itself holds 211 inventoried roadless areas totaling 1,937,741 acres. Opening these landscapes to road construction is not an abstraction. It is a direct threat to the water, wildlife, and ecological integrity of places I value and use. The proposal attempts to substitute state-by-state approaches for a single national rule, but this is ground the agency has already lost in court. The record reflects that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. The Ninth Circuit found that substituting local decision-making for national protection incrementally eroded values that only the national rule maintained. I ask that the agency address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. The proposal also argues that the 2001 rule exceeded the agency's statutory authority, but a federal appellate court already answered that question. Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction. The Tenth Circuit held that the 2001 rule fell within the authority Congress granted and did not create de facto wilderness. The agency must explain on the record, with specificity, the legal basis for treating that settled question as open. On wildlife, the agency's own documents contain findings that the proposal never applies. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the document and then disappears. No projection follows for the 40.1 million acres of potentially affected environment. I ask that the agency apply the cited fragmentation range to those 40.1 million acres and show its work in the record. The same gap appears for big game. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. Verified species of the Deschutes, a forest I know, include elk alongside bull trout, Oregon spotted frog, northern spotted owl, white-headed woodpecker, and redband trout. Despite acknowledging what roads do to elk, the agency projects no population-level effects anywhere in the document. The agency must project the effects on big game populations and hunter opportunity before this proposal advances another step. The 2001 Roadless Area Conservation Rule should not be rescinded. The forests it protects, including every acre I have walked in Mt. Hood, Gifford Pinchot, and Deschutes National Forests, deserve the full protection of a rule the courts have upheld and the science has validated. Sincerely, David Roy Portland, OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests I care most about sit in the Pacific Northwest. Mt. Hood National Forest, Gifford Pinchot National Forest, and Salmon-Huckleberry National Forest are where I camp, hike, and photograph land formations, plants, trees, rivers, and lakes. I share those photographs with elders and others who cannot get out there themselves. I also watch birds and animals to see how they live and communicate in the wilderness. Those forests, and the wildlife in them, are what this comment is about. I oppose rescinding the 2001 Roadless Area Conservation Rule. Roads hurt birds. The agency's own record acknowledges this directly. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The birds I watch in these forests depend on the quiet that roadless protection provides. Rescission opens the door to road construction in areas where that protection currently holds. I ask the agency to explain on the record why it weighed this documented harm to bird communities as acceptable, and what mitigation it proposes. The agency's own fire data also cuts directly against the rationale offered here. The DEIS reports that Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. I hike and camp in these forests. I have a direct stake in whether they burn. The agency claims road access reduces wildfire hazard, but its own numbers point the other way. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh that increase against any claimed reduction in wildfire hazard, with that analysis made available for public review. The economic certification accompanying this proposal does not hold together. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The underlying flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, rather than looking at the outfitters and guides who actually hold permits in the affected areas. That is not an assessment of the affected entities. It is an average that obscures the harm to specific businesses. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the agency's treatment of future plan amendments is not defensible as analysis. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare a foreseeable consequence out of scope and ask the public to comment on it. That is asking commenters to perform the analysis the agency itself declined to do. The forests I visit in the Pacific Northwest could be directly affected by exactly the plan amendments the agency is refusing to evaluate. I ask that the agency analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this rulemaking action. The proposal also invites comment on reliance interests without ever analyzing them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have organized my recreation, my photography, and my practice of sharing the wilderness with people who cannot reach it around the protection this rule provides. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds further. I urge the agency to withdraw this proposal. Sincerely, Andree Nyary Portland, Oregon

Subject: Opposition to the Proposed Rescission of the 2001 Roadless Area Conservation Rule – Docket No. FS-2025-0001 To the U.S. Forest Service and the U.S. Department of Agriculture: I strongly oppose the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). As a resident of Portland, Oregon and an advocate for our nation’s public lands, roadless areas matter deeply to me. I frequently visit and recreate in Mt. Hood National Forest, Gifford Pinchot National Forest, Mt. St. Helens National Monument, Mark o. Hatfield Wilderness, Suislaw National Forest and other areas throughout the Pacific Northwest. I feel a special kinship with these areas, where I hike, forage (where permitted) and enjoy deep solitude. In fact, I moved to Oregon nearly 25 years ago when meeting friends on a camping trip in the Columbia Gorge. I fell in love on that trip; not with another person, but with the incredible natural beauty of Oregon and Washington. It's literally the reason I moved to Portland. These incredible natural landscapes are worth protecting, for several critical reasons: • Clean Water and Watersheds: Roadless areas safeguard essential headwaters and drinking water sources for downstream communities. This is especially true for the Portland metro area; the Bull Run Watershed supplies drinking water to nearly one million residents. • Wildlife Habitat: Roads fragment ecosystems, disrupting sensitive wildlife corridors. More roads are a threat to preserving or restoring biodiversity and protecting endangered species. • Climate and Resilience: Intact forests act as natural carbon sinks and are more resilient to severe disturbances than fragmented, heavily managed timber lands. Shifting management decisions to local forest plans without a national safeguard risks opening millions of acres of pristine backcountry to industrial/commercial logging and road construction. We have seen what happens when national protections are disregarded; wanton destruction of huge swaths of land with major downstream impacts to fish, wildlife, and even human habitation (when near poorly managed forests). I urge the Forest Service to select Alternative 1 (No Action) and maintain a continuation of full, nationwide protections for all designated inventoried roadless areas. This action would maintain current prohibitions against road construction, road reconstruction, and timber harvesting across roughly 44.7 million acres of inventoried roadless areas on national forest lands. Thank you for the opportunity to comment on this critical rule. Sincerely, Ü. Kleppinger Portland, Oregon, 97211

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I care deeply about our national forests because I recreate in national forests and rely on rely on forest watersheds for clean drinking water. I strongly oppose rescinding the 2001 Roadless Rule because of its environmental and economic impacts, well as impacts to wildlife and recreation. Environmental Impacts & Clean Water * The Forest Service was originally founded to protect forests and watersheds from logging and development. * Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. * Like more than 1 million Oregonians, I rely on Mt. Hood National Forest for drinking water. Road building undermines natural forested watershed filtration systems and threatens millions of Americans’ access to safe drinking water. * The science is clear: road building fragments habitat, disrupting wildlife and watersheds; increases pollution; facilitates damaging extractive industries; and worsens the spread of invasive species. Only 3% of the world’s ecosystems remain intact. We can’t afford to lose what little remains. Fire * Contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. * Nearly 85% of wildfires are human-caused, and most ignite within a few hundred feet of roads. * New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. * The current rule already allows road-building and logging of smaller trees to reduce fire risk and protect public safety. A full rescission is therefore unnecessary. * Given that the FY26 budget eliminates funding for wildfire suppression and management, USDA cannot claim this rule change is genuinely about mitigating fire risks. Economic Considerations * The Forest Service manages more roads than any other federal agency, yet already struggles to maintain them. The national forest system currently carries a $10.8 billion maintenance backlog. * The text of the Roadless Rule itself acknowledges that the Forest Service could not maintain its existing road system to safety and environmental standards. That reality has only worsened as budgets continue to shrink. * On the local level, Mt. Hood’s 2015 Travel Analysis Report called for decommissioning, not building, roads, citing risks to water quality and aging, unsafe infrastructure. * The Forest Service’s FY26 budget slashes agency funding by more than 60%, and zeroes out funding for Wildland Fire Management, the Wildfire Suppression Operations Reserve Fund, and State, Private, and Tribal Forestry. USDA’s stated rationale for rescission—addressing wildfire risk and giving states more decision-making power—rings hollow when no funding is allocated to meet those goals. * Forest revenues today come primarily from recreation, not logging. More roads would degrade recreation opportunities, undercutting the agency’s bottom line. Rescinding the Roadless Rule Contradicts Public Opinion * The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. * Elected officials and Tribes, including the Confederated Tribes of Warm Springs, whose ceded lands include Mt. Hood National Forest and whose reservation still borders that forest, have voiced strong support for the Roadless Rule. The Tribes emphasized that protecting unroaded areas is essential to the health of ecosystems, fish, wildlife, and native plants. * Polling confirms this support endures: a Pew Charitable Trusts survey found 75% of Americans support the Roadless Rule, while only 16% oppose it. * USDA calls itself “The People’s Department,” but rescinding the Roadless Rule directly ignores the will of the majority of Americans. Closing 
 For all the reasons listed above I strongly oppose rescinding the 2001 Roadless Rule. I ask that before moving forward, the agency: * Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; * Guarantee that no watersheds will be negatively affected by rescission; * Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; * And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Please protect America’s remaining roadless areas for current and future generations.

I urge the Forest Service to select Alternative 1 and keep the 2001 Roadless Area Conservation Rule in place. I live in the Portland area and know the Mt. Hood National Forest well. From 2014 to 2016, I served on a stakeholder group that advised the Forest Service on plans open to public comment, bringing together people with different interests, from recreation to conservation to local communities. In that work, I saw that decisions held up best when people with differing views were heard early. The Roadless Rule reflects that kind of broad public process, and rescinding it on a short comment window runs counter to it. Mt. Hood’s undeveloped backcountry helps protect clean water, wildlife habitat, and quiet recreation close to where millions of people live. Once roads are built into these areas, the damage is difficult and expensive to undo. Rescission is also unnecessary and costly. The Rule already allows thinning and hazard-reduction work where it’s needed, and Trout Unlimited has pointed out that the Forest Service’s own data undercuts the claim that it blocks forest health treatments. Meanwhile, the agency already manages roughly 370,000 miles of roads and carries about $10.8 billion in deferred maintenance, more than half of it for roads. Adding new road miles would only grow that burden. Finally, the public has already spoken. More than 600,000 comments were submitted in the first round, and the agency has acknowledged that 99 percent opposed rescission. This proposal should not move forward against that record. I ask that the agency keep the Roadless Rule intact. Tonya Moore Portland, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The serenity of a roadless area calms the soul, and living near both the Gifford Pinchot and the Mt. Hood National Forests, near large cities, I understand what it means for urbanites to have places to breathe clean air and step away from noise. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record under Docket FS-2025-0001. Being in nature without mechanical noise is something I value deeply. Watching wildlife, from large mammals to tiny insects, allows us to understand the interdependence of all of nature, and that understanding depends on having places left intact enough to show it. The Forest Service should manage roadless areas as they were originally designated: keep them wild and without human mechanization. That designation was made for a purpose, and it was not to make people rich. The agency's own analysis raises a concern I cannot set aside. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the areas at stake. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency also invites reliance interests and then does nothing with them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My own reliance on the Gifford Pinchot and the Mt. Hood remaining roadless is exactly the kind of interest the invitation describes. Families across the Pacific Northwest have arranged their relationship to public land around the expectation that these areas stay protected. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Roads and logging will affect drinking water. They cause erosion that sends sediment into streams and lakes that feed the watershed my drinking water comes from in the Mt. Hood National Forest. The Forest Service's own data is plain on the mechanism. The agency should explain how it reconciles the rescission with the water-supply consequences its own analysis acknowledges, and it should do so with specificity about the Mt. Hood watershed and others like it. On fire, the agency's own numbers argue against the proposal. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The effects analysis concedes that road access could raise the number and frequency of wildfires, yet no quantified projection follows. I ask that the agency calculate the expected increase in human-caused ignitions from new road access and weigh it honestly against any claimed reduction in wildfire hazard. The biodiversity data in the DEIS is similarly introduced and then left dangling. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is stated, and then no projection across the 40.1 million potentially affected acres follows. Every creature in those forests, from the large mammals I described to the insects, faces consequences that the agency has chosen not to calculate. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. The Forest Service today does not have the money or the personnel to maintain the roads it already has. Building new roads that will likely be left in poor condition once timber companies are finished with them destroys pristine areas permanently and spends taxpayer dollars doing it. These are the last unroaded third of the national forests. A logged stand grows back. A road does not. Each destruction of these forests by large commercial interests eliminates forever the opportunities of future generations to enjoy what is still untouched. I want my children and grandchildren to be able to continue to enjoy pure nature without the interference of human mechanization. Losing roadless areas would be a huge loss to the people and creatures that live and recreate there, and I expect the agency to answer each of the concerns raised here before it proceeds any further. Sincerely, Anonymous Portland Oregon