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I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in the Methow Valley in Washington state and I spend significant time on the surrounding public lands hiking, hunting, climbing, and adventuring. These forests are not simply areas on a map to me—they are the places that makes this valley an incredibly special place to live. The remaining roadless areas around the Methow provide wildlife habitat, clean and intact watersheds, opportunities for hunting and other backcountry recreation, and places where people can experience public land without the constant presence of roads and motorized access. I am particularly concerned about what rescission could mean for the large Inventoried Roadless Areas surrounding the Methow Valley, including the Sawtooth, Long Swamp, Tiffany, and Pasayten Rim areas. The Okanogan National Forest contains hundreds of thousands of acres of Inventoried Roadless Areas, including approximately 122,000 acres in the Sawtooth area and 66,000 acres in Long Swamp. These landscapes are directly connected to the places where local residents like me hunt, hike, fish, camp, and recreate. I value having some public lands where road access remains limited and wildlife can move through relatively intact habitat. Once a permanent road is constructed into an undeveloped landscape, its impacts—fragmentation, increased human access, erosion, maintenance needs, and changes in wildlife use—cannot simply be undone. I understand the Forest Service's concern about wildfire, forest health, and the need for active management. However, I do not believe rescinding a nationwide protection for roadless lands is necessary to accomplish those goals. The existing rule already contains mechanisms for exceptions and management activities, and the Forest Service has other tools available to address hazardous fuels and forest health where treatment is genuinely warranted. Removing the Roadless Rule would instead eliminate an important safeguard for the remaining undeveloped portions of our national forests and place decisions about these landscapes increasingly at the project level. The Forest Service itself acknowledges that the proposed rescission would remove the existing national prohibitions and return these decisions to individual forest planning and local project decisions. As a Methow Valley resident and public-land hunter and backcountry user, I ask the Forest Service to retain the 2001 Roadless Area Conservation Rule. The Methow Valley already has extensive roads and developed access; what is increasingly scarce are large, intact landscapes where wildlife habitat, watersheds, hunting opportunities, and quiet recreation can persist with minimal additional fragmentation. These lands belong to all Americans, including future generations. Please do not trade away their roadless character for short-term flexibility. I urge the Forest Service to choose the No Action alternative and maintain the protections provided by the 2001 Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Baker River and its tributaries, the alpine lakes throughout the region, the Liberty Bell area: these are not abstractions to me. I work in restoration, and I have watched what road creation does to water. Sedimentation, degradation of habitat, increased water temperature. I have seen these things. Rescinding the 2001 Roadless Area Conservation Rule will produce more of them, and the agency's own analysis makes that plain while declining to follow the logic through. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number is stated and then left hanging. No projection of sediment delivery follows it. Across the Pacific Northwest region alone, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. People downstream of those intakes are drinking that water. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas and explain in the final record how that delivery is controlled under the proposed rescission. The drinking water problem runs deeper than sediment. The DEIS states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." The document then asserts that forest plans address public drinking water, but it does not identify a single enforceable provision in any of those plans equivalent to what the rule currently requires. We have a responsibility to manage our public lands for people, water quality, and habitat. That responsibility cannot be discharged by a general reference to forest plans that are never examined. The agency must identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. I hike and ski in the Liberty Bell area frequently. It is a gorgeous zone that would be completely changed if roads were allowed. Liberty Bell sits within the Okanogan National Forest and covers 108,495 acres. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and what happens to the rule happens to all of them. On the biology The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is wide enough to span catastrophe, yet no projection across the 40.1 million acres of potentially affected environment follows it. The Liberty Bell area has a character that comes precisely from its freedom from roads and the development roads enable. The agency should apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what outcome it considers acceptable. On the economics, 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 guides and outfitters who work in areas like Liberty Bell are not a national average. Spreading an expenditure loss across every small firm in the sector to reach a no-impact conclusion does not assess the firms actually holding permits in the affected areas. The certification should be withdrawn and the impact assessed for the small entities actually operating in the potentially affected roadless areas. One further point: I don't think it makes sense to build more roads when the agency can't keep up with maintenance of the roads it already has. The agency is aware of its maintenance backlog. Building new roads into country that currently has none, while that backlog grows, transfers a long-term liability to the public and to the watersheds those roads will drain into. The final record should address this directly. Sincerely, Walker Brown Bellingham, WA 98225

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001. 50 years living in NCDE & Yellowstone Region has given me solace based in truth so cannot tolerate rescission in exchange for marketization of public lands. RR means protections not their removal.RR lands mean connectivity for species survival. Rescission displaces threatened species. ESA listed grizzly bear requires best science. Rescission shuns it and will prove fatal for grizzly populations. Cited lands mirror grizzly DPS compliance. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, specifically inventoried RR areas: Lost Water Canyon (9,251 acres), Custer NF, MTBurnt Mountain (10,698 acres), Custer NF, MT Black Butte (871 acres), Custer NF, MT Red Lodge Creek Hellroaring (17,210 acres), Custer NF, MTOkanogan-Wenatchee NF (1,006,000 acres), Okanogan NF, WAGifford Pinchot National Forest (213,000 acres), Gifford Pinchot National Forest, WAMt. Baker-Snoqualmie NF, WALiberty Bell (108,495 acres), Okanogan NF, WACuster Gallatin NF (848,000 acres), Custer Gallatin NF, MTBob Marshall Wilderness Complex (1,483,000 acres),Bob Marshall Wilderness Complex, MT Paine Gulch (7,875 acres), Lewis & Clark NF, MTMt. High (33,484 acres), Lewis & Clark NF, MTMcgregor - Thompson (27,211 acres), Lolo NF, MTDeep Creek (7,669 acres), Lolo NF, MT Trout Creek (30,851 acres), Kootenai NF, MTCataract (9,442 acres), Lolo NF, MTBlue Slide (17,505 acres), Wenatchee NF, WA Mt. Baker-Snoqualmie NF (415,000 acres), Mt. Baker-Snoqualmie NF, WA , Okanogan NF,Pasayten Rim (17,074 acres), Okanogan NF, WASawtooth (15,693 acres), Lewis & Clark NF, MTwin Sisters (13,051 acres), Colville NF, WA Bridger-Teton National Forest (1,417,000 acres), Bridger-Teton National Forest, WyWest Pioneer (248,631 acres), Beaverhead-Deerlodge NF, MTBear - Marshall - Scapegoat - Swan (344,022 acres), Lewis & Clark NF, MT Bob Marshall-Scapegoat-Swan (334,275 acres), Flathead NF, MT East Pioneer (145,082 acres), Beaverhead-Deerlodge NF, MTWest Big Hole (133,563 acres), Beaverhead-Deerlodge NF, MTMadison (127,859 acres), Gallatin NF, MTSelway-Bitterroot (114,953 acres), Bitterroot NF,MTHoodoo (105,162 acres), Lolo NF, MTAllan Mountain (104,184 acres), Bitterroot NF, MTSnowcrest Mountain (97,649 acres), Beaverhead-Deerlodge NF, MT Freezeout Mountain (97,305 acres), Beaverhead-Deerlodge NF, MT Middle Mtn. / Tobacco Roots (96,487 Beaverhead-Deerlodge NF, MTTuchuck (17,730 acres), Flathead NF, MTThompson Seton (52,235 acres), Flathead NF, MTMt. Henry (13,603 acres), Kootenai NF, MTOlympic National Forest (86,000 acres), Olympic National Forest,WASapphires (66,619 acres), Beaverhead-Deerlodge NF,MTBear Creek (8,123 acres), Beaverhead-Deerlodge NF, MT MTLittle Bighorn (133,949 acres), Bighorn NF, WyoSleeping Child (x1074) (21,433 acres), Bitterroot NF, MT, Bitterroot NF, MTDry Canyon Breaks (4,821 acres), Colville NF, WANorth Absaroka (21,063 acres), Custer NF, MTCrazy Mountain (82,093 acres), Gallatin NF, MTBridger (45,059 acres), Gallatin NF, MTHyalite - Porcupine - Buffalo Horn Wilderness Study Area (143,991 acres), Gallatin NF, MTGallatin Fringe (51,571 acres), Gallatin NF, MT Cabin Creek Wildlife Management Area Ocd (35,048 acres), Gallatin NF, MTWAHellgate Gulch (16,821 acres), Helena NF, MTBig Snowy Mountains Wsa (88,003 acres), Lewis & Clark NF, MTCastle Mountains (29,409 acres), Lewis & Clark NF, MT Crazy Mountains (24,942 acres), Lewis & Clark NF, MT Box Canyon (12,584 acres), Lewis & Clark NF, MT- Big Snowies (9,258 acres), Lewis & Clark NF, MT North Fork Smith (8,444 acres), Lewis & Clark NF, MT Tenderfoot - Deep Creek (85,614 acres), Lewis & Clark NF, MT Eagle Park (5,912 acres), Lewis & Clark NF, MT- Calf Creek (10,108 acres), Lewis & Clark NF, MT- Pilgrim Creek (44,608 acres), Lewis & Clark NF, MT Highwood Baldy (15,305 acres), Lewis & Clark NF, MT Highwoods (24,378 acres), Lewis & Clark NF, MT- TW Mountain (8,388 acres), Lewis & Clark NF, MT Granite Mountain (10,338 acres), Lewis & Clark NF, MT Lewis & Clark NF, MT Middle Fork Judith Wsa (81,131 acres), Lewis & Clark NF, MT Bluff Mountain (38,060 acres), Custer NF, MtLine Creek Plateau (24,825 acres), Custer NF, MT, Custer NF, Mt Shoshone NF, WyoWilderness Study Area (51,961 acres), Targhee NF, Wyo- West Slope Tetons (47,448 acres), Targhee NF, Wy- Silver King (64,289 acres), Beaverhead-Deerlodge NF, Montana, - Selkirks (95,967 acres), Idaho Panhandle NF, Idaho-Grizzly Peak (7,441 acres), Kootenai NF, Montana I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects threatened species and of climate change.I ask that the agency respond to each of them.I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Dan Sullivan Chanhassen, MN

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Mandy Walters and I live in Spokane, Washington. As an avid hiker, skier, and backpacker, many of the lands within current roadless areas that I love will be impacted by the potential recission. One of my great joys is hiking on the Pacific Crest Trail with my son, who has become a great lover of the outdoors over the years. We go on a trip together annually to enjoy the vast wilderness and backcountry areas, primarily located on Forest Service land. I hope that one day, we can hike the entire trail. Yet over 10% of the PCT runs through areas that are protected by the Roadless Rule. Lands in the Gifford Pinchot National Forest, the Mt. Baker-Snoqualmie National Forest, the Wenatchee National Forest, and the Okanogan National Forest all have the potential to be negatively impacted, thereby negatively impacting the PCT. In addition to losing these pristine landscapes, placing roads in these areas will increase fire risk. Studies show that fires are 4 times as likely to start in areas near roads, meaning rescinding this rule will put our forests at a higher likelihood of fire at a time when we can least afford to do so. Again, I would like to state that I am opposed to the proposal to fully or partially rescind the Roadless Area Conservation Rule and favor Alternative 1, the No Action alternative.

We favor leaving the existing roadless rule in place. (Alternative 1) We hike, bike and ski in many of these areas on the Colville National Forest and surrounding areas like the Okanogan NF. Some of our favorite places are: Mt Bonaparte (Okanogan NF), Bangs Mountain, Hoodoo, Bald Snow, South Huckleberry, Abercrombie Hooknose, and Profanity peak

I am writing today in support of Alternative 1 – No Action, 2001 Roadless Area Conservation Rule. Keeping the status quo will continue to protect these roadless public lands and conserve fresh water and forests for people and wildlife. Currently, 94,000 miles of rivers are protected by the rule. Rolling back the rule will put the supply of drinking water for more than sixty million Americans at risk. Five of the eight species of western native trout rely on roadless areas for more than half of their habitat. Native Gila Trout use roadless areas for 99% of its habitat. Roadless areas provide safe habitats and migration routes for grizzly bears, wolves, elk and mule deer. The Tongass National Forest has 800-year-old trees and over fifty million fish. This is a critical habitat that sequesters carbon, provides recreational activities, and contains important cultural sites. I live in the state of Washington where several areas are protected by the roadless rule including Olympic National Park, Gifford Pinchot National Forest, Mt. Baker-Snoqualmie National Forest, Okanogan National Forest, Olympic National Forest, Umatilla National Forest, and Wenatchee National Forest. These are pristine areas that provide habitat for a wide range of animals. They also provide recreational opportunities for hiking, fishing, hunting, and to simply enjoy nature. People travel from all over the country and even the world to enjoy these areas. The spending from this tourism provides ongoing jobs in rural areas where employment opportunities are few. The 2001 Roadless rule was developed after a lengthy and thorough process that included robust input from the public and tribal nations. The Forest Service held 600 public hearings and received 1.6 million comments on the rule. The current process includes NO public meetings and an extremely short comment period. The alternatives proposed by Tribal Governments were not included in the DEIS. The DEIS states “Timber Harvest and road construction in inventoried roadless areas could significantly alter Tribal access to treaty-reserved resources, sacred sites, and other culturally significant sites.” Stating that one of the purposes of this rule recission for fire management seems to be a scare tactic. Many fires are started by vehicles and people using roads in forested areas. An analysis of data from the U.S. Forest Service for the period of 1992 to 2024, shows that within 50 meters of a forest road there is a 4x greater chance of a fire starting than in roadless areas. These areas should remain roadless for the protection of these pristine lands to preserve the forest and waterway.

To Whom It May Concern: The Roadless Area Conservation Rule needs to remain in place and I am opposed to it being rescinded. It does appear that some modifications to correct mapping errors would be a useful effort. I have lived in the Wenatchee-Okanogan National Forest District for 33 years and have experienced the benefits of roadless areas. I have also used USFS roads for access to trailheads or for camping and know that the Forest Service does not have the funds to keep them properly maintained. The pressures to put in more roads for the benefit of the extraction industry is immense, I'm sure, but short sighted. We need to preserve as much clean water and soil as we can. Fires are a main component of our reality now, and allowing for more vehicles in the National Forest will only increase the likelihood of a fire. Studies have shown that the likelihood of a fire starting by vehicles (95% of fires are started withing 1/2 mile of roads). The impetus for this proposal needs to be transparent and the details subject to more public hearings. I live in an area that has been greatly impacted by fires and the recreational economy has been hurt significantly, not to mention the health risks and fear that we have all experienced due to fires. The Forest Service does not have the budget to even maintain the roads that is currently has,so why add more burden to the system? The proposal to eliminate the RACR is ill researched, has short sighted goals and does not reflect the views of the people that live and work with and in the National Forest. Thank you, Gina Monteverde Winthrop, WA

To Whom It May Concern at the U.S. Forest Service: For an outdoor enthusiast, "roadless" isn't a bureaucratic category - it's a description of what makes a place worth going to. The best part about these areas is that they are the only place I can truly show my children what being in nature is truly about. So they can appreciate it and teach others. My kids' favorite part of a trip is tallying how many animals and species they have seen. I fear on some trips this will be the last time they see them. The ability for my children to enjoy these areas with their children. Regarding the Granite Mountain in the Okanogan National Forest, Washington: Headwater Protection for Bull Trout and Cold-Water Fisheries - The Upper Beaver Creek headwaters and associated drainage network (Beaver Creek, Blue Buck Creek, North Fork Beaver Creek) originate in this high-elevation subalpine terrain, where snowmelt and groundwater maintain the cold, clear water conditions essential for bull trout (Salvelinus confluentus), a federally threatened species with designated critical habitat in this watershed. The intact riparian buffers and undisturbed streamside vegetation in this roadless area - particularly the subalpine fir and lodgepole pine forests - shade streams and regulate water temperature, preventing the thermal stress that would otherwise drive bull trout away from spawning and rearing habitat. Loss of this headwater protection would degrade water quality and temperature conditions throughout the downstream drainage network, directly threatening the species' survival in the region. Forest roads generate sediment from every constructed surface: the compacted road prism sheds runoff instead of absorbing it, cut slopes expose bare soil to erosion, fill slopes slump into drainages, and ditchlines concentrate and accelerate flow. In the Granite Mountain IRA, each stream crossing becomes a direct delivery point where this sediment enters the channel and degrades habitat for Pacific Lamprey (Entosphenus tridentatus). The DEIS cannot defer analysis of road construction impacts on Pacific Lamprey (Entosphenus tridentatus, G4) in the Granite Mountain IRA, Okanogan National Forest, to future project-level review. Rescission is the decision that enables road construction, and NEPA requires the agency to analyze the consequences of that enabling decision - including quantified sediment yield, modeled thermal impacts, and assessed flow regime changes - at the programmatic stage for a G4-ranked aquatic species. "For age-0 bull trout, the upper lethal temperature is 70 F (20.9 C), and optimal growth occurred at 56 F (13.2 C); feeding declined significantly above 61 F (16 C). As stream temperatures rise, dissolved oxygen content decreases. Salmon, trout and other cold water fish, and many aquatic invertebrates require cool and well-oxygenated water." - Washington Department of Fish and Wildlife, 2001 The DEIS supplies the mechanism the conclusion has to survive. Two sentences earlier, on the same page, it states: "Roads pose the greatest risk to fish resources on the Tongass, partly because they pose the largest risk of management-caused sediment input to streams." The DEIS cannot both identify road-caused sediment as the greatest risk to Tongass fish resources and rest a "minimal effects" conclusion on a set of protections from which it has deleted the prohibition on road construction in the highest-value salmon watersheds. Let the Roadless Rule stand.

To the Department of Agriculture and the Forest Service: I am writing to express my deep concern for the proposed rescinding of the Roadless Rule. As someone who lives near and recreates in multiple roadless areas I can’t express how strongly I feel about the negative impacts this will have. One area in particular is the Sawtooth area, which connects two valleys that hold great importance to me - the Chelan and the Methow. This is one of the main areas I can easily access by foot to quickly escape into nature. The lack of roads in this area provides a peaceful, serene environment that would be destroyed if roads were allowed here. If roads were to come into this area I would lose my most sacred spaces in which I am able to retreat and tend to my mental and physical health. Regarding the Sawtooth in the Okanogan National Forest, Washington: Slight or 1-10% pop. decline severity and Small (1-10%) scope characterize the impact of 6.1 - Recreational activities on Mount Rainier White-tailed Ptarmigan (Lagopus leucura rainierensis, T2) in the Sawtooth Inventoried Roadless Area, Okanogan National Forest — losses that the current Roadless Rule helps constrain. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 6.1 - Recreational activities on Mount Rainier White-tailed Ptarmigan. Analysis of 6.1 - Recreational activities effects on Mount Rainier White-tailed Ptarmigan (Lagopus leucura rainierensis) in Sawtooth must reference the species' T2 conservation status and the documented Slight or 1-10% pop. decline severity. The DEIS lacks scientific integrity without this baseline data. "On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches)." — Iranian Journal of Environmental Health Science & Engineering (PMC), 2013 Failure to Substantively Respond to Content of Majority-Opposition Comments The Notice of Intent section reduces overwhelming public opposition to a bare percentage, stating that "approximately 99 percent were generally opposed to the proposed rule recission, while approximately 1 percent were generally in support," without any accompanying discussion of what those commenters actually said. No substantive response section addressing the content categories raised — water quality, carbon storage, invasive species spread — appears associated with this passage. Independent research the agency should engage directly documents that roads cause "increased mortality from road construction," "spread of exotic species," and sediment delivery that is "long-lasting and cumulative and cannot be effectively mitigated" (Trombulak & Frissell 2000). Did the agency consider comments raising these documented mechanisms, and if so, where in the record is that consideration explained? Reducing majority opposition to a percentage without engaging its substance violates the requirement that agencies give reasoned consideration to public comment under Vermont Yankee Nuclear Power Corp. v. NRDC, 435 U.S. 519 (1978), and is arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request a substantive, topic-by-topic response to the content of majority-opposition comments before this rescission is finalized. People travel from all over the world to visit our country because of the incredible wild, beautiful spaces we are lucky to live among. We have protected these places for great reason and the vast majority of people in this country do not want to see this change, myself included. Twenty-plus years of protection shouldn't end here. Keep the Rule. Sincerely, CommentID: RLC-20260908-92QQJG

I believe every state should have their own rules for managing their forests. Not all forests are the same. Yes, we need responsible logging: NO clear cutting. Clear cutting sets up a scenario for loss of top soil and increases the potential for flooding. It was clear cutting that set up the town of Oso, WA which resulted in the deaths of many as well as the loss of the town. Clear cutting is not in the native wildlife's best interests. Clear cutting sets up the potential for fires in the future. A wet spring allows large areas of grass to grow, if there are no cows to eat the grass and summer is exceedingly dry, the scenario is set for lightning to start fires. Leave very mature trees, trim them up so fire passes through instead of torching the trees. Mature trees have more ability to withstand fires. Allow cows back into the guests to keep the grasses down. To worry about the methane gas produced by manure is just ridiculous considering what how many motor vehicles are producing toxic gases. We need thinning and cleaning again. It helps reduce risks of fire, especially when the piles are cleaned up. Allow people to remove the cut timber for firewood. Allow companies to remove what is too small and shred it for mulch. It opens up areas for more moisture which is better for the wildlife as well as the greenery. Protecting the native wildlife is important to local populations, not just for hunting but simply for people to enjoy and photograph. Allowing more roads actually increases problems in regards to fire, loss of wildlife by vehicles and more areas littered. Not just regular trash but old appliances, old furniture and machines people do not want to take to a transfer station for proper disposal. All.of these reasons are why each state should be allowed to set their own rules. Keeping it local insures that local populations benefit. Keeping it local provides jobs for local populations. Keeping it local provides more businesses hiring local populations. I have lived next to the Okanogan National forest for 42 years and watched plies of trash being thrown out, or just dumped. People not properly putting out their campfires. There's a hunting camp not far from my house and we go up every year after hunting season or holidays to make sure their campfires are COLD to the touch. Respectfully, Karen Ercolani Wines