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I oppose rescinding the 2001 Roadless Area Conservation Rule. Please retain its protections for inventoried roadless areas. Freshwater matters to me because the Olympic national Forest is one of my favorite spots in the Pacific Northwest to go and hike around and it holds a ton of memories for me. Along with Mount Saint Helens and Mount Rainier. Mount Saint Helens was a place of refuge for me as a teenager living in a really small town and honestly that place saved my life. I would hate to see it destroyed because of this. I am concerned that removing restrictions on road construction and timber harvesting could increase erosion and sediment entering streams, harming water quality and the aquatic habitat for fish I care about. Please fully evaluate these effects on watersheds and downstream communities. I urge the Forest Service to retain the Roadless Rule and prioritize clean water in its decision. Thank you.

To the Roadless Rule Rulemaking Docket: As someone who has explored public land in roadless and roaded areas, I can tell you they are not comparable. I've spent many days and nights exploring many roadless areas in Washington, and it's difficult to describe the spiritual and emotional connection I have to these places. It is such a critical part of what makes the wilderness in Washington pristine and second to none. Setting aside all of the environmental benefits of untouched wild places on the watershed and carbon capture and wildlife, the serene beauty of these places is a priceless resource that we will never fully get back once it is lost Exploring the Notch Pass trail with my wife was such a special experience. We saw a pair of bald eagles soaring above the trees, and the beauty of the dense vegetation around the whole green mountain area is nothing short of a fairy tale. These types of places would not be the same with roads cut through them. Regarding the Green Mountain in the Olympic National Forest, Washington: Population-level impacts of Moderate or 11-30% pop. decline severity across Restricted (11-30%) scope are documented for Cascades Frog (Rana cascadae, G3,) in the Green Mountain IRA, Olympic National Forest, driven by 6.1 - Recreational activities. "Frequent human disturbance caused by mining development and road construction in the Kalamaili Mountain Ungulate Nature Reserve (KNR) — inhabited by >80% of Chinese khulan (Equus hemionus) — has interfered with or completely blocked their movement and access to parts of the reserve. The habitat of khulan in KNR went from a good natural habitat in 2005 to deterioration due to mining development in 2011. In 2019, road construction likely hindered its recovery to pre-mining levels. Our study revealed the significant impacts that mining development and road construction have had on the distribution of core habitats, ecological corridors, and movement of khulan." — Biological Conservation (ScienceDirect), 2022 The persistence of Cascades Frog in Green Mountain under current threat levels presumes continued roadless conditions. Road construction fundamentally alters this baseline, converting the landscape from one that constrains 6.1 - Recreational activities to one that accelerates it. Roadless wilderness areas are truly one of our most precious resources for all to enjoy, and once they are disturbed with roads cut through and commercial operations, they can never be returned to their natural beauty again. I beg you to please protect these places. They mean so much to so many people. Most respectfully, Denali Jones

I am a Seattle outdoor enthusiast who has spent years hiking and photographing scenery and wildlife in Washington's national forests, including inventoried roadless areas of the Olympic National Forest and many other places around our beautiful state. I urge the Forest Service to withdraw this proposal and retain the 2001 Roadless Area Conservation Rule. These roadless tracts are some of the last large, connected, unfragmented habitats in the Pacific Northwest, which are the corridors that wide-ranging species like spotted owls, marbled murrelets, and Cascade carnivores depend on, and that I enjoy documenting firsthand through my iNaturalist observations. The agency's stated rationale, local flexibility for wildfire and forest-health work, does not require rescinding the existing rule: roads themselves are ignition sources, and most of the fuels-reduction work the agency wants to do happens near communities, not deep in the backcountry. A much better solution would be more rangers who can spend more time on patrol, enforcing existing rules and burn bans - which I see violated on a regular basis even while being outside is not my fulltime job. If I had the ability to issue tickets to people being reckless in the backcountry, we'd probably fix the national deficit. And, obviously, the issue isn't even always behavior - cars themselves can ignite fires when conditions are hot enough. Rescission trades in a 25-year conservation framework for speculative management benefits that individual forest plans can already achieve without this harmful step. I think we know why the government is pushing for this, and the stated rationale is quite clearly a pretext to hide the real motivations behind rescission. Please retain the existing rule.

I live in Lambertville, NJ and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking. This country is unique in its beauty and wilderness and draws people from all over the country and beyond to appreciate it. If we do not preserve it in the most aggressive of ways, we will lose this treasure. Mount Zion is one place that has shaped my views on this proposal. It is within the Mount Zion Inventoried Roadless Area in Olympic National Forest. The serenity is next to god. I am concerned about wildlife habitat and landscape connectivity. Without protection the nature will be lost. I am concerned about increased timber-development pressure in currently roadless areas. We need as many trees as possible in this world, and many countries cannot resist the money of developers. We can! Before rescinding the national rule, I would like USDA to answer this question: How would USDA ensure that roadless values are protected through individual forest plans and project-level decisions if the national rule is removed? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

**Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001** The forests I hike and camp in, across Washington, California, and many other states, belong to all of us and to our children. The proposal to rescind the 2001 Roadless Area Conservation Rule would betray both. I am filing this comment in opposition to Docket FS-2025-0001. The agency's own findings on wildfire make the rescission's logic collapse on itself. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless uses wildfire and fuels management as a justification for opening roadless areas to new roads. Areas like the Upper Skokomish, 9,311 acres inside Olympic National Forest in Washington, and South Quinault, 11,081 acres in the same forest, sit within the 2,014,832 acres of inventoried roadless land Washington holds across 139 areas. Routing roads through terrain like this, terrain the agency's own data says carries far lower human-ignition density than roaded land, would not reduce fire risk. It would increase it. I ask that the agency explain in this proceeding why the proposal departs from its own prior findings, and reconcile the rescission with the ignition data in its own draft environmental impact statement, specifically DEIS Table 21, which documents the contrast between fire occurrence on roaded and unroaded land. The economic case for rescission is similarly unsupported by the agency's own numbers. The record acknowledges: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal supply figure, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million per year, set against recreation losses of at least $6.1 million per year and a net present value ranging from negative $92 million to positive $199 million, a range so wide it cannot establish that any net benefit exists. Meanwhile the road system the proposal would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with those numbers and explain how an action whose own analysis cannot confirm a positive return justifies adding infrastructure costs to a system already in deficit. The proposal also argues that state-by-state approaches can replace a single national rule. But the agency's own record recalls "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 has already reviewed what happens when the agency substitutes local decision-making for national protection of roadless values: it found that approach legally deficient. Washington's 1,522 municipal water intakes sitting in watersheds containing affected roadless areas, a figure drawn from DEIS Table 35, cannot be protected piecemeal. The agency must explain how this proposal avoids the same deficiencies the court identified then. It is incredibly disturbing that we would consider taking this away, particularly the water protections these areas provide. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and fewer than 12 percent of the watersheds fed by roadless areas have impaired streams today. Those two facts together are a reason to hold the rule, not discard it. The agency must address the Tenth Circuit's holding that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and it must state clearly the legal basis for any position to the contrary. Public land managed for all people and for our children cannot absorb the costs this rescission would impose on water quality, fire safety, fiscal integrity, and settled law. I urge the agency to withdraw the proposal. Sincerely, Erika Francks

I am writing to urge the US Department of Agriculture to NOT rescind the 2001 Roadless Areas Conservation Act. This act is hugely popular across the United States, with citizens, conservationists, recreationists, hunters, scientists, and political groups. When passed in 2001 it had broad support from Americans, as proven by the 600 public hearings held nationwide, and the 1.6 million comments received - the most comments any rule had received by that point in history. It also had bi-partisan support- issued during the Clinton administration and implemented & upheld by the Bush Administration. As a Washington State resident, I understand the importance of healthy ecosystems in our forest lands and mountain regions. Opening up 2 million acres of currently protected Washington land to potential logging or other for-profit activities is a short sighted and harmful decision that will have irreversible impacts on the health of our state's ecosystem, and the wildlife we share it with, particularly in the Olympic National Forest. Humans need to be good stewards of the land- that requires acts of long-term responsibility. Rescinding this rule will open up 45 million acres of precious habitat and ecosystem across the United States for potential long-term, irreversible destruction in the name of financial favor and gain. There is no emergency in America's domestic markets to warrant increased timber harvesting, mining or drilling in protected lands. Rescinding this rule will be yet another step in dismantling America and selling it for parts to opportunistic corporations and wealthy individuals, creating long term harm to all Americans while creating short term profit for greedy corporate interests. Prior administrations recognized the value of keeping America's lands natural and protected and did their part to be good stewards of America's lands with this rule. Do your part to keep America the Beautiful by keeping the 2001 Roadless Area Conservation Rule in effect for all 45 million acres.

Continued: 4. Fire is a part of the ecosystem. To the extent that the rationale is reducing fire, the rationale is wrong, as other commenters have pointed out and as the rationale points out, that more roads lead to more fire activity. But also the entire proposal is misplaced — because the most effective way to address fires of increasing intensity is to address climate change. That is the real national priority that needs to be addressed that the government is completely failing to address. Roads in forests are not a recognized wild-land fire management policy, as other commenters have pointed out. *** Put simply, the repeal of the Roadless Rule is a step backwards in public lands management. It effectively takes public lands out of the hands of the people they are set aside for — the American public — and hands them to special interests who are willing to pay for them. This is not the mandate that the USFS has been given by Congress. The mandate is the manage these lands for multiple uses. Creating new roads in forests prioritizes only one use, timber harvesting, over all others. *** My experience in this comment is drawn from recreating at the following USFS properties: Little Missouri National Grassland; Buffalo Gap National Grassland; BigHorn National Forest; Chequamegon-Nicolet National Forest; Hiawatha National Forest; Ottawa National Forest; Huron-Manistee National Forest; Superior National Forest; Chippewa National Forest; Shoshone National Forest; Custer-Gallatin National Forest; Flathead National Forest; Bridger-Teton National Forest; Caribou-Targhee National Forest; Gifford Pinchot National Forest; Olympic National Forest; Okanogan-Wenatchee National Forest; Mount Baker-Snoqualmie National Forest; Colville National Forest; Medicine Bow-Routt National Forest; Arapaho National Forest; White River National Forest; Black Hills National Forest; Thunder Basin National Grassland; Unit-Wasatch-Cache National Forest; Sierra National Forest; Stanislaus National Forest; Lincoln National Forest; and Shawnee National Forest. My major takeaway from all these experiences is that these Forests already have more roads than most people could explore in a lifetime. There is quite simply no practical or logistical need, from a recreational perspective, for more under the rationales that the USFS has proposed in this rule change.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless areas are some of the few places where we can witness - and enjoy - the true majesty of unexploited nature. I oppose rescission of the 2001 Roadless Area Conservation Rule because the agency's own record does not support the action, and because the forests I have traveled, paddled, and camped in since childhood will bear the consequences. Wildfire. The DEIS states: "A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If roads increase ignition, the agency must explain why expanding the road network into 40.1 million acres of protected land advances fire management rather than undermining it, and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land. Economics. The DEIS acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production." Its analysis projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, while the Forest Service road system already carries a $6.9 billion maintenance backlog. The agency should explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system in that condition. Fish and wildlife. I have rafted the Main and Middle Forks of the Salmon River through the Salmon-Challis National Forest, home to the largest roadless complex outside designated wilderness in the lower 48: 58 inventoried areas totaling 2,264,064 acres. The Salmon supports the longest salmon migration in North America, over 900 miles. The DEIS acknowledges that removing riparian vegetation can raise stream temperatures beyond what cold-water species tolerate, and that the affected area includes Essential Fish Habitat managed by NMFS. It also cites findings that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet never applies that range to the 40.1 million affected acres. The agency should do so before proceeding. Existing exceptions. The rule already accommodates the burdens the agency cites: it "generally banned road building subject to limited exceptions," including reserved or outstanding rights and construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The agency has not identified which operational burdens fall outside these exceptions. It should identify and quantify them on the record rather than treating administrative complexity as grounds to eliminate protections that have stood for over two decades. Born and raised in Idaho, I have camped, hiked, backcountry skied, and backpacked in Oregon's Wallowa-Whitman National Forest since childhood. If its 515,000 roadless acres are opened to roads and logging, that backcountry will not recover in any timeframe meaningful to the backpackers, anglers, hunters, and skiers who contribute more to the regional economy than logging ever could. Species that depend on these corridors, including Chinook salmon, steelhead, bull trout, wolverine, mountain goat, bighorn sheep, and gray wolf, need intact buffers around protected roadless areas. Our public lands should be managed for all citizens, not sold off to the highest bidder, and preserved for future generations, from the Salmon-Challis to the Wallowa-Whitman to the Olympic National Forest, already hemmed by clear-cuts visible from Hurricane Ridge. I urge the agency to withdraw the proposed rescission. Sincerely, Tracy Andrews Portland, Oregon

I strongly object to the U.S. Forest Service proposal to rescind the 2001 Roadless Area Conservation Rule. The Roadless Rule wisely blocks roadbuilding, logging, drilling, and mining on 45 million acres of national forests, about a third of our national forest system. This is critical because these lands provide clean air, clean water, important and necessary carbon storage, and critical fish and wildlife habitats including habitats for threatened and endangered species. In Olympic National Forest, where I have worked, hiked, gathered firewood and enjoyed nature, spectacular roadless areas such as Rugged Ridge, Lower Gray wolf, Middle Dungeness, Jupiter Ridge, Lena Lake, South Fork Skokomish and South Quinault Ridge are all well deserving of Roadless Area designation. All of these areas offer protection to upper and middle watersheds including domestic water supplies. All buffer existing wilderness areas, Buckhorn, The Brothers, Mt. Skokomish, Wonder Mountain, and Colonel Bob wildernesses and nearby Olympic National Park, a UNESCO Biosphere Reserve and World Heritage site. And nearly all are included in U.S. Senator Murray's and U.S. Representative Emily Randall’s Wild Olympics Wilderness and Wild and Scenic Rivers Act, currently being considered by Congress. Roadless areas contain less than a quarter of one percent of the nation’s timber and an even smaller fraction of oil and gas reserves. They are more fire resistant than roaded areas, where the majority of fires occur. However this proposal would throw them open to road building and polluting extractive industries for private profit at the public’s expense. The Forest Service's EIS for this project is wholly inadequate and fails to consider the environmental and economic benefits roadless areas provide or the costs incurred in rescinding roadless rule protections. These lands are much more valuable for the public benefits they provide: clean air, clean water, critical carbon storage, fish and wildlife habitats and recreation opportunities for present and future generations than for the meagre and fleeting benefits to be gained by developing them. I endorse the arguments included in Washington Wild's comment letter, which was signed my multiple parties including Olympic Park Advocates, of which I am a long-time member.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The national forests of Washington State are where I go to connect with friends, family, and nature. Hiking and camping across Washington is, as I think of it, a home for my soul, and the roadless areas that make that possible, places like Eagle Rock in the Mt. Baker-Snoqualmie, and Green Mountain, Jupiter Ridge, Mt. Zion, Quilcene, Jefferson Ridge, and the other inventoried roadless lands of the Olympic National Forest, are the foundation of that experience. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. I am asking this agency to leave them intact and to withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. Washington already has a great deal of working forest land, land that grows trees for industry and is accessible by road. We do not need more land converted to that condition by opening roadless country to new construction. The right approach is to maintain and make the best use of the lands with roads that already exist. No need to build more forest roads. The agency's own data makes the maintenance argument for me: "Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a deferred maintenance backlog of $6.9 billion for roads and bridges, with supplemental funding expiring." Building new roads into country that currently has none, while that backlog sits unaddressed and the budget to address it has shrunk by so much, is not a coherent plan. I ask that the agency name the specific funding source for any new road construction and maintenance that rescission would enable, and state in the record the projected change in the deferred maintenance backlog that would result. The fire calculus in the agency's own analysis points in the same direction. "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 Eagle Rock area, the Olympic roadless units, and the other places where I hike and camp are safer from human-caused fire precisely because they are roadless. The agency must quantify the expected increase in human-caused ignitions that would follow from new road access in these areas and weigh that increase honestly against any claimed reduction in wildfire hazard before this proposal advances. The economic accounting in the supporting documents 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 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, and then concedes some of those firms may lose these receipts anyway. That is not a finding of no significant impact; it is an averaging away of a real impact on specific people. The agency should withdraw the small-business certification and conduct a genuine assessment focused on the small entities actually operating in the potentially affected roadless areas. This comment is itself a reliance interest of the kind the agency invited and then declined to weigh. "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." I have organized my outdoor life in Washington around the existence of roadless protections. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas, and countless people beyond me have made similar choices premised on these protections remaining in place. The agency must identify and weigh the reliance interests described in the comments it receives, including the one expressed here, before it can lawfully change course. These are public lands. The Forest Service held more than 600 public meetings and received 1.6 million comments to write the rule that protects them. It has held none to undo it. Any change of this magnitude requires an expansive public process, not a quiet reversal. The agency should deny this rescission. Arvia Morris Seattle, Wa.

I am writing to oppose rescission of the Roadless Rule. As an avid outdoor hiker and angler, I appreciate the solitude and peace of the undeveloped backcountry. Roadless areas are significant for multiple reasons: 1. Provide pristine waters for fishing and provide clean drinking water for millions of Americans. 2. Provide protection for critical wildlife habitat and safe migratory corridors, uninterrupted by roads. 3. There is currently a $10.8 billion maintenance backlog for the current road system; adding more roads will only make this worse. 4. America’s roadless areas are some of the most beautiful backcountry in the world. 5. Fires are 4 times more likely to start within 1/4 mile of a road; we do not need more wildfires with climate change worsening. 6. I love Olympic National Forest and do not want to see it logged. 7. Old growth forest stores incredible amounts of carbon. I ask that the FS follow the no action alternative in the current DEIS.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Olympic Peninsula is where I take a deep breath and life doesn't feel as heavy. It is where my favorite childhood memories live, where I have been present with friends and family in some of the most beautiful places I know. Now that I am in college in California, it is what I think of as home, and I crave to go back. I am writing to oppose Docket FS-2025-0001 because rescinding the 2001 Roadless Area Conservation Rule would put the 86,000 acres of inventoried roadless area in Olympic National Forest, Washington, and places like it, at permanent risk, and because the agency's own record does not support what it is proposing to do. Driving around Washington this past summer, I kept seeing stumps where I had not seen them as a child. The land looked dead. There were no animals. It was distressing in a way I did not expect, and it confirmed something I already believed: we have done enough damage to natural habitats. We need to start protecting them, and that begins with the ecosystems and the land itself. A logged stand can grow back over many lifetimes, but I do not want children to inherit fewer of these places than I did, or to watch their parents drive through land they loved and find stumps where trees used to stand. A road, once built, does not grow back. If a road went into the Olympic roadless area, it would no longer hold the same peace it currently does, and that loss would be permanent in any meaningful human timeframe. The agency argues that rescission supports wildfire management, but its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I have lived through many fire seasons. I have seen plans canceled, seen those without somewhere to go struggle, felt the weight on my lungs going outside, and watched temperatures change dramatically. The agency must explain why this proposal departs from its own prior findings, and must reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I now live in California, a state that holds 381 inventoried roadless areas totaling 4,389,760 acres, with 1,034 municipal water intakes sitting in watersheds containing affected roadless areas. Growing up in Seattle, I did not fully understand that clean, fresh-tasting drinking water was a privilege until I left. It is not, and it should not be treated as one. It is a necessity everyone relies on multiple times every day, and the agency should address how replacing a single protective rule with a patchwork of state-by-state approaches guards water quality in places like the Pacific Southwest at anything like the same level. The record states 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 agency should explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time it substituted local decision-making for the national rule, given its own prior finding that local approaches can incrementally reduce nationally significant roadless values. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority, a question courts have already resolved. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency owes a direct explanation of the basis for any position contrary to the Tenth Circuit's holding that the 2001 rule fell within authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The Olympic Peninsula is magical because of the plants and animals and the unbroken land that makes it what it is. I want to protect it, and I want the agency to answer these questions squarely before proceeding any further. Sincerely, Rosalee Meyer Seattle, Washington

I oppose rescinding the 2001 Roadless Area Conservation Rule either fully or partially. The inventoried roadless areas under the jurisdiction of the Forest Service are amazing and irreplaceable places, and we should continue to protect them from roadbuilding and resource extraction. I live in Washington where roadless areas are some of the most spectacular and distinctive locations in the state. In June, the Teanaways, part of Okanogan-Wenatchee National Forest, have usually just melted out and it's possible to scramble gentle red rock peaks such as Bean or Earl and have a view of the stunning Stuart Range. Mount Dickerman in Mount Baker-Snoqualmie National Forest is where my friends scattered the ashes of their beloved golden retriever, and we go up around fourth of July every year to commemorate what a great dog he was. I love the lower Graywolf River in Olympic National Forest, which is accessible all winter and runs blue and clear through a valley lined with ferns and mosses, and I also love ascending Mount Townsend, which on a clear day lets you see five volcanoes at once across the sound. These places make Washington an exceptional place to live and they are also distinctive, important ecological communities that shouldn't be fragmented or disturbed any further. Has the proposed action to rescind the Roadless Area Conservation Rule adequately considered the ecological impact of the change? Has relevant scientific research been considered, particularly with respect to fragmenting and disturbing habitat? I oppose rescinding the Roadless Area Conservation Rule because I do not believe we can undo the fragmentation and loss that will be triggered by lifting these protections, and we should not make this mistake. I support Alternative 1, the No Action alternative.

I am writing because I oppose the USDA's proposal to rescind the 2001 Roadless Rule I live near the Olympic National Forest and we use our national forest as a place to gather mushrooms, hike, and camp. But more than any recreational purpose, the forest is the place that protects my water source, the salmon in our rivers, and that keeps our air clean. I have seen the effects of roads and commercial logging on WA Department of Natural Resource and commercial timberland in our area. Logging does some damage, but it is often the roads that cause the most damage. They leave devestation in their wake. The benefits of the Roadless Rule include: * The protection of watersheds for current and future generations. * Biodiversity: countless plant, animal, and fungal species * fire prevention (since most fires start near existing roads) * food gathering: hunters, anglers, and foragers benefit from food produced by healthy forests * recreation and tourism: spending time in intact forests feeds our souls and nourishes our mental and physical health. Repealing the roadless rule would do irrevocable harm to wild lands that are our greatest national treasure. Protecting our public lands and keeping forests healthy keeps us healthy. I urge the USDA to listen to the public and keep the Roadless Rule fully intact

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The rivers and lakes of Washington are some of the greatest things I have ever experienced. I walk them for the beauty of nature, and I photograph everything I find, bugs and deer alike, because they all matter and they all play a part. I photograph them so that my future children and the people I love can see the importance of them all. These places and creatures shaped how I see the world, and the roadless areas of the Olympic National Forest, places like Jupiter Ridge, Jefferson Ridge, Green Mountain, Lightning, Upper Skokomish, and Mt. Zion, are the kind of country that makes all of it possible. I am opposed to rescinding the 2001 Roadless Area Conservation Rule. The wildfire rationale for this rescission contradicts the agency's own findings, and I want that contradiction addressed. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I have been fortunate enough not to live through a fire season myself, but I know how important old forests are for fire prevention. When the agency's own data in DEIS Table 21 shows far higher fire density on roaded land than inside the affected roadless areas, the agency must explain on the record why the proposal departs from those findings and how opening these areas to roads serves any honest fire management goal. The deer I photograph and watch in these forests face a documented threat from new roads that the agency itself has identified. The DEIS cites research finding that roads built for extraction may have altered deer migration routes and increased their movement speed, and the agency's own Tribal record credits the rule's protections with the recovery of deer populations in Alaska by preserving old-growth winter shelter. Washington holds 2,014,832 acres across 139 inventoried roadless areas. Deer and every other creature using that unroaded country depend on it staying that way. I want the agency to explain what happens to those populations when that security is removed. The economics of this proposal do not hold together, and I want that explained too. The agency's own record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency is already $6.9 billion behind on maintaining the roads it has. They are stretching themselves too thin just to make people who do not understand the importance happy. The agency must reconcile the proposal with its own Cost Benefit Analysis, which cannot establish a net benefit, and explain how expanding a road system already carrying that maintenance backlog is justified by figures this small. Clean water is one of the most important things for people and animals alike, and the roadless rule protects it. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of those watersheds have impaired streams today. That record needs to be weighed against this proposal, and I ask that the agency explain what specific protection replaces the rule for those watersheds. My future children should inherit more of these places than I did. I want us to find better ways to coexist with nature rather than bulldoze everything for parking lots and roads. Going the other direction will burn the world and take us all down with it. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That asymmetry alone demands a full and honest answer.

I live in Shelton WA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking, hunting or fishing, camping, and living in or near a National Forest community. I highly value visiting natural spaces where access is hike-in only. Areas north of Brown Creek CG and LaBar horse camp are places that has shaped my views on this proposal. It is within the Wonder Mountain Wilderness Inventoried Roadless Area in Olympic National Forest. There is something so different about this area vs other parts of the ONF, wildlife is abundant and the understory is more navigable. I am concerned about the cost of expanding the National Forest road system. It is clear that the current roads are barely maintained in these areas. Private companies are allowed to completely block well established FS roads for their own personal benefit at the cost of tax payer dollars. I am concerned about clean water and healthy watersheds. I have seen time and time again the struggle of the current road system failing to be properly maintained, passing on the cost to the tax payer for upgrading poorly executed drainage and waterways. Roadless areas matter to me for recreation and the experiences they provide. It is ultimately our responsibility to protect remote area recreation for future generations. I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. Road access makes wild fire risk higher, ignition points can be a hot exhaust, a smoker tossing a cigarette out of their window, sparks from a poorly maintained motorbike exhaust system or reflective ignition from convex glass or metal debris/garbage. I am concerned about increased timber-development pressure in currently roadless areas. Private interests for logging will bend the rules to meet production demands. The lack of staffing/enforcement to inspect logging operations have caused the hightened wildfire risk with the higher concentration of stumpage and debris. Years of this buildup have created a tinderbox waiting to have some form of ignition to set it ablaze. Before rescinding the national rule, I would like USDA to answer this question: How would USDA account for the long-term cost of maintaining, reconstructing, and eventually decommissioning additional roads? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

Olympic National Forest has always been my backyard: I grew up on the Olympic Peninsula, and I now live in Seattle. Over the years while hiking, camping, and exploring, I have had many magical encounters with Roosevelt elk, Olympic marmots, and all the salmon who also count these places as their home. My family has visited Lake Quinault every winter for almost as long as I can remember, and nothing compares to the foggy, frigid peace of the rainforest in winter. (The South Quinault roadless area, 11,081 acres inside Olympic National Forest, is one of the areas that will be affected by rescinding the 2001 Roadless Area Conservation Rule.) The agency has failed adequately consider the impacts rescinding the Roadless Rule would have on recreation, water access, ecosystem preservation (particularly where the ONF acts as a “buffer” to Olympic National Park), and wildfires (one of the most pressing issues facing our forests today, as we now see every summer). This is not what responsible forestry looks like. I oppose this rescission and support proceeding with Alternative 1 - No Action.

I live in Los Angeles, CA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes wildlife watching, living in or near a National Forest community, and operating or working for a business connected to public lands. As a concerned American citizen AND a health care professional, I know that spending time in wild, undeveloped places is extremely good for a person's physical and mental health. And I know that protecting roadless and undeveloped National Forest lands benefits wildlife and the climate and all of us! Mount Zion is one place that has shaped my views on this proposal. It is within the Mount Zion Inventoried Roadless Area in Olympic National Forest. Stunning, beautiful, humbling and reassuring. I am concerned about wildlife habitat and landscape connectivity. Roads increase human infringement into crucial species habitat. I am concerned about clean water and healthy watersheds. The health of our ecosystems and of all Americans depends on clean water and healthy watersheds which can be severely disturbed by poorly maintained roads. Before rescinding the national rule, I would like USDA to answer this question: Why are the Roadless Rule's existing exceptions insufficient to meet legitimate wildfire, public safety, and forest-management needs? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I live in Seattle, WA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking. I want to experience a healthy, undisrupted natural ecosystem of flora and fauna, for long stretches without engines or other signs of human development. Mount Zion is one place that has shaped my views on this proposal. It is within the Mount Zion Inventoried Roadless Area in Olympic National Forest. I value the clarity of the waters and skies, the non-mechanical quiet, and the size and variety of the trees and other vegetation. I am concerned about clean water and healthy watersheds. The infrastructure of a built environment, including drainage systems, culverts, stream crossings and maintenance of roads can contribute sediment to streams, affect aquatic habitat, and have downstream effects for the entire ecosystem. Before rescinding the national rule, I would like USDA to answer this question: How would USDA ensure that roadless values are protected through individual forest plans and project-level decisions if the national rule is removed? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting in the woods with friends, breathing clean air in the campgrounds of Oregon and Washington, watching the recovery continue on the slopes of Mount St. Helens. These are the things I am asking you to protect when I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. Being out in the woods is good for the soul. The beauty of wild places and the animals in them is unmatched. I also spend time in state and national campgrounds in Oregon and Washington for the clean air, the quiet, and the enjoyment of nature away from the noise of city life. It is affordable vacation for many people. I want my children and grandchildren to have wild places with old-growth trees to revere and experience. I do not think they should inherit fewer of these places than I did. The Siuslaw National Forest holds the Oregon coast range, the dunes, fresh water, and salmon. Salmon depend on cold water, and the agency's own record states that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and that warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, with the affected area including Essential Fish Habitat and critical habitats managed by NMFS. The Siuslaw's roadless areas amount to 52,000 acres of coast range forest that the agency would open to new road construction. I ask the agency to address what specific protections replace those lost for cold-water fish habitat in the Siuslaw if this rule is rescinded. The Deschutes National Forest is a high desert place of calderas and ancient formations, fantastic and unlike anywhere else. Bend and the surrounding area get their water from this forest, and this should not be threatened. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The Deschutes holds 136,000 acres of inventoried roadless area, and the lower Deschutes holds one of only two national strongholds for federally threatened bull trout. I ask the agency to explain how rescinding federal roadless protections over these watersheds is consistent with its obligations to communities and to listed species whose strongholds sit inside them. The Olympic National Forest is magical. Having no roads through the middle of the peninsula is a true treasure. The 86,000 acres of roadless area there, with their old growth and pure water, must be maintained. The agency argues that new roads serve wildfire management, yet its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency reconcile this proposal with that finding and explain what ignition data now overrides it. The agency also argues that opening these areas generates economic benefit. Its own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million. The agency already carries a $6.9 billion road maintenance backlog on a road budget of about $73 million a year. No new roads. The Gifford Pinchot National Forest, with Mount St. Helens and its continuing recovery, holds 213,000 acres of roadless area I have visited since childhood. The agency now argues that state-specific management can replace the national rule, yet its own record shows: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit already rejected the last attempt to substitute local approaches for a national rule, finding that piecemeal local decisions can erode nationally significant roadless values. Leave the little remaining old growth alone. Leave the natural water sources alone. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That process failure alone demands a full answer before this rescission moves any further. Sincerely, Kristina Rheaume Portland, Oregon