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To the U.S. Forest Service and the U.S. Department of Agriculture: I am writing to express my strong opposition to the proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). As a resident of Washington State and native who grew up hiking, camping, and backpacking through some of the most beautiful national forests in the world, the conservation and protection of these public lands and ecosystems is extremely important to me. As a frequent utilizer of our nation’s public lands, inventoried roadless areas matter deeply to me. I frequently visit and recreate in Nez Perce-Clearwater National Forest, Kaniksu National Forest and Snoqualmie-Mt Baker National Forest for backcountry solitude and peaceful escape. Protecting these unfragmented landscapes is vital for several critical reasons: • Clean Water and Watersheds: Roadless areas safeguard essential headwaters and drinking water sources for downstream communities. • Wildlife Habitat: Roads fragment ecosystems and disrupt sensitive wildlife corridors, threatening biodiversity and 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 logging and road construction. I urge the Forest Service to select Alternative 1 (No Action) and maintain full, nationwide protections for all designated inventoried roadless areas. Thank you for the opportunity to comment on this critical rule. Sincerely, Jennifer Burnham Spokane Valley, WA, 99206

As a former US Forest Service employee with extensive experience in and adjacent to Roadless Areas, I strongly object to rescission of the the Roadless Area rule. I worked on the Mt baker Snoqualmie National Forest from 1980 through 1991. I worked on the Nez Perce National Forest in 1978 I worked on the Silver Fire Recovery Forest in the Siskiyou National Forest in 1987. I worked on the Hurricane Hugo Watershed Recovery Project in the El Yunque National Forest in 1989 I currently live in PA and have traveled and recreated in the Allegheny National Forest. I lived in Alaska in 2010 and traveled in Se Alaska in 1982 and throughout Alaska during my work for the Alaska Center for the Blind and Visually Impaired. Many of the roadless areas especially on the Mt Baker Snoqualmie National Forest were in areas not well suited to timber harvest. They occupied steep landscapes in the Silver Fir zone, areas that did not recover well from timber harvest and were often subject to landslides in zero order drain ages and due to failure of roads in the steep unstable terrain. Timber removal in these landscapes resulted in negative impacts on salmon habitat, wildlife habitat and yielded relatively little value for the timber harvested with the cost of harvest. I dispute that removing the roadless area rule would return decision making for the management of inventoried roadless areas to the land management planning process at the individual national forest level.Each National Forest and Ranger District has been under timber harvest goals set at higher organizations, not because of the true ability of the land to withstand the impacts of road construction and timber harvest. The Darrington Ranger District of the Mt Baker Snoqualmie National Forest where I worked for nearly a decade is a prime example. Areas open to timber harvest had excessive road construction, often poorly maintained and subject to slope failures. Once the levels of timber harvest were reduced in Darrington and Monte Cristo the local economy developed more reliance and infrastructure to support recreation that utilized back country and front country resources. The areas proposed to be removed from the Roadless Area Rule in the Darrington Ranger District are generally adjacent to wilderness, on lands not well suited to road construction and timber harvest. They are far more valuable and suited for back country recreation, protection of fisheries and wildlife habitat. The Roadless Areas of the Nez Perce Clearwater National Forest Striking a balance between recreational enjoyment and the well-being of our wildlife is crucial for ensuring the long-term health of the Nez Perce-Clearwater National Forest. Roadless areas are designated for increased ATV, motorcycle, and snowmachine use, which will displace essential wildlife such as wolverines, mountain goats, grizzly bears, and elk. The absence of specific written directions in the plan to protect wildlife from increased motorized recreation raises questions about the sustainability of such expansion. Most named wildlife require extensive habitat. the absence of defined limits on the extent of motorized trails or riding areas leaves these critical zones vulnerable to an unlimited influx of motorized recreation. The roadless areas of the Nez Perce Clearwater like the Chugach Tongass and Mt Baker Snoqualmie National Forests are far more valuable for protection of salmon habitat than they are for timber harvest. The Chugach National Forest Roadless areas are located in areas not well suited to timber harvest. Much of the landscapes steep sloped areas with soil that is destabilized by road construction, posing a risk to the highly valuable fisheries resource. The Tongass National Forest in Alaska is well suited to insure the long term protection of the salmon and other fisheries, and wildlife. The Tongass not unlike the Higher elevation roadless areas on the Mt Baker Snoqualmie and Siskiyou National Forests does not support timber harvest and regrowth to justify the cost and environmental impact of that harvest. The EL Yunque National Forest has roadless areas. They are a vital resource for protecting critical wildlife habitat and watershed resources. There are ample areas of the El Yunque National Forest to serve the needs of the casual tourist. The Allegheny National Forest is a precious resource to Pennsylvanians. Opening up current Roadless areas to road construction and energy development would degrade the wildlife habitat and diminish precious backcountry recreation. The Roadless areas are adjacent to the Allegheny River, The Clarion Wild and Scenic River, within the Allegheny National Recreation Area and the Hickory Creek Wilderness. I strongly object to rescission of the Roadless Area Rule. These roadless areas are a unique and irreplaceable resource belonging the people of the United States. They are part of our heritage and should be retained in current condition.

Dear Secretary Brooke L. Rollins, As a scientist and avid user of public lands, I work extensively in a variety of ecosystems across the Western U.S.. I understand the value of our diverse natural resources, including roadless areas. This rescission is problematic for a number of reasons that are clear to me, colleagues working in research, forest management, and fellow hunters, anglers and recreationists. The rescission would also interrupt decades of research and work in roadless area. Outside of my work, I have joined multiple groups for stewardship trips in the Great Burn and another roadless areas in Montana and Idaho. The large number of people willing to dedicate their time, energy, expertise, and lots of sweat equity to this place shows the importance of roadless areas to the people who live nearby as well as to many who live much farther away. Although the Draft EIS suggests otherwise, an increase in road access does not improve wildfire control. It is well understood that the majority of wildfires in this area are started close to roads by humans, so more roads and easier access does not improve wildfire likelihood. And, having used many Forest Service roads throughout my life and career, I understand the challenge of maintaining existing forest roads. Federal efforts would be better spent on decreasing the backlog of maintenance (especially given reduced staffing and resources in the Forest Service) rather than building new roads. The Hoodoo area of the Nez Perce-Clearwater NF, ID and high-elevation habitat provides important headwaters protection for Bull Trout. These high-elevation streams maintain the cold water temperatures and clean spawning material that bull trout need for reproduction. The roadless condition preserves intact riparian forest (mostly dominated by subalpine fir and mountain hemlock) which shades these streams and prevents high temperatures that stress or kill developing trout eggs and juveniles. Rescinding the Roadless Rule would open the Hoodoo, Nez Perce-Clearwater National Forest to road construction and associated ground disturbance. I strongly oppose rescinding the 2001 Roadless Rule and the nearly 45 million acres affected in Montana alone. These areas are an essential part of the West's character, way of life, and natural, social, and economic value. This rescission would alter roadless areas for hundreds of years into the future, a change that cannot be undone. Please consider the long-term effects on human safety, livelihoods, values, as well as the needs and continued existence of wildlife species in your decision. Please say no to the rescission. Sincerely, CommentID: RLC-20261006-69E29C

I am writing in support of the proposed rescission of the 2001 Roadless Area Conservation Rule. I am a forester in Clearwater County, Idaho, working with the Idaho Department of Lands under the Good Neighbor Authority program on the Nez Perce-Clearwater National Forest, with direct involvement in implementing forest health and fuels treatment projects on National Forest System lands. My comments address four substantive issues: (1) the de facto prohibition that results from litigation risk regardless of Idaho's state-petitioned rule; (2) the direct consequences I observed during implementation of the Dixie-Comstock Community Protection Project, where burned roadless areas adjacent to communities could not be treated; (3) the severely diminished working land base on the Nez Perce-Clearwater and its cascading economic and workforce impacts; and (4) the need to rebalance the multiple use mandate that has shifted persistently toward preservation at the expense of forest-dependent communities. My full comment is attached as a PDF document. Docket: FS-2025-0001 | RIN 0596-AD66 Jarel Bruce Good Neighbor Authority Forester Idaho Department of Lands — Nez Perce-Clearwater National Forest

I oppose this proposal to rescind the 2001 Roadless Area Conservation Rule and open millions of acres of national forest to road construction and logging. My reasons: --Wildlife habitat fragmentation. Roads are one of the most disruptive forces in forest ecosystems — they split animal populations, block migration and access to food and mates, and create corridors for poaching and disturbance. Grizzly bears have historically suffered most near roads not from vehicle strikes but from the human activity roads bring into their habitat. --The wildfire-risk justification is contradicted by the evidence. The agency argues this rule change will reduce wildfire risk, but the data points the opposite direction. A 2025 Wilderness Society analysis found that wildfire density is lowest in wilderness and protected forest areas, and highest in the areas near roads. This isn't incidental: roads themselves are a documented wildfire cause. Expanding road networks into currently roadless forest is more likely to increase ignition risk than reduce it. --Watershed and soil damage. Logging roads chronically erode, dumping sediment into streams that harms fish spawning and water quality. Reporting in Smithsonian magazine (Ben Goldfarb, "The Case for Destroying Old Forest Roads," March 2024) notes that, in 1995, storm-triggered landslides tied to old logging roads in Idaho's Nez Perce-Clearwater National Forest produced more than 900 landslides that buried streams under more than 50,000 dump trucks' worth of sediment — a preview of the kind of long-term damage new road construction risks recreating elsewhere. For these reasons, I urge the Forest Service to withdraw this proposal and retain the Roadless Rule's protections.