Read the comments.

October 2, 2026 Director, Ecosystem Management Coordination USDA Forest Service 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Re: Docket FS-2025-0001, Special Areas; Roadless Area Conservation, Draft Environmental Impact Statement. Comment in opposition to rescission; support for Alternative 1 (No Action) Dear Director: I oppose the proposal to rescind the Roadless Area Conservation Rule, and I urge the Forest Service to select Alternative 1, the No Action alternative, in Docket FS-2025-0001. I live in Las Vegas and spend a large part of every year backpacking, hiking and occasionally rappelling in remote country across the western United States. I am a user of the backcountry, not a visitor to its trailheads, and the experience I value most is the one roadless land exists to protect: a place with no motor vehicle noise, no sign of other people, and a view of land that looks as it did centuries ago. That experience is rare and cannot be rebuilt. In Washington I hiked 20 miles into the Olympic wilderness and looked out over untouched country to the horizon. In Idaho's Sawtooth range I hiked deep into old-growth forest and slept under skies with no light pollution. Idaho has its own roadless rule, which this proposal leaves in place, so I raise the Sawtooth only to show what intact backcountry offers. I am asking that the same protection stay in place in the states where it is now at risk. Those states include the places I visit most. In Arizona, the Arizona National Scenic Trail crosses the Mazatzal and Boulder roadless areas of the Tonto National Forest, part of roughly 1.17 million acres of inventoried roadless land in the state. Near my home, Nevada has more than 3 million acres of inventoried roadless land across the Humboldt-Toiyabe and Inyo National Forests and the Spring Mountains National Recreation Area. In Washington, roadless lands on the Olympic National Forest border the park and shelter salmon spawning habitat. In Utah, about 4 million acres of national forest would lose protection. A road, a clear-cut or a mine ends solitude and quiet for every later visitor, and no restoration brings them back. The Draft EIS does not justify that loss, for these reasons. Roads increase wildfire ignitions. Research in Fire Ecology found that fires are about four times more likely to start near a road than in a roadless area, and the agency's own analysis acknowledges that human-caused wildfires could become more frequent if roads open this terrain to vehicles and campfires. The rescission would add ignition sources to remote forest where fire response is slowest. The benefit is small and the cost is large. As reported from the agency's own figures, rescission would raise national timber harvest by only about 5 to 10 percent, while the Forest Service already carries a road maintenance backlog of billions of dollars. Adding roads to the least accessible land in the system adds to a bill the agency cannot pay. The Final EIS should weigh that cost against the recreation economy that depends on undeveloped backcountry. Wildlife and water depend on intact habitat. Roadless areas provide core habitat and connecting corridors, and road construction is a leading source of sediment in streams. The Final EIS should state the effect on threatened and endangered species and on salmon streams, area by area. The public process is too short. The comment period is a fraction of the time the 2001 rule received, and the Draft EIS concedes that full rescission carries the greatest potential for adverse effects on Tribal rights and interests. The 2001 rule has worked for 25 years and still leaves room for fire management and local decisions. I ask the Forest Service to retain it, to select Alternative 1, and to respond in the Final EIS to the specific concerns above. Respectfully, Avid Outdoorsman

Director, Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Re: Comments on Proposed Rescission of the 2001 Roadless Area Conservation Rule Docket No.: FS-2025-0001 / RIN: 0596-AD66 Dear Director, I am writing to submit substantive comments opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. As an active recreational user of inventoried roadless areas (IRAs) across the Sierra Nevada, Olympic, Okanogan-Wenatchee, and Huron-Manistee National Forests, I have direct experience with the vital ecological and public values these unroaded landscapes provide. I urge the agency to select the No Action Alternative and retain the 2001 Rule. The proposal to open IRAs to commercial road construction relies on flawed fire risk assumptions, ignores severe maintenance liabilities, and understates irreversible impacts to critical watersheds. My specific technical objections to the Draft Environmental Impact Statement (DEIS) are: 1. Inadequate Analysis of Human-Caused Ignitions vs. Mitigation The agency's premise that road construction reduces catastrophic wildfire risk through thinning is contradicted by fire science data. Road networks are primary vectors for human-caused ignitions. In drier ecosystems like the eastern Okanogan-Wenatchee and lower Sierra Nevada, surface disturbance from road building facilitates the spread of invasive fine fuels like cheatgrass, which significantly increases fire return intervals. Furthermore, the 2001 Rule already contains explicit exceptions (36 CFR § 294.13) for hazardous fuel treatments near wildland-urban interfaces. The DEIS fails to demonstrate why these existing exceptions are insufficient. 2. Failure to Account for Maintenance Backlogs and Lifecycle Costs The Forest Service currently carries a multi-billion-dollar deferred maintenance backlog on its existing 370,000-mile road network. Adding temporary or permanent routes in steep, unstable terrain—such as the high-precipitation zones of the Olympic NF—generates long-term erosion, culvert replacement, and maintenance liabilities. The DEIS lacks a comprehensive lifecycle cost-benefit analysis comparing the short-term economic yield of timber harvest against the long-term capital liability of road maintenance and decommissioning. 3. Cumulative Watershed and Hydrological Risks IRAs serve as high-integrity anchor watersheds. In the Olympic and Okanogan NFs, IRAs encompass headwaters vital to threatened salmonid species (e.g., bull trout, Chinook). Road construction and timber haulage increase stream sedimentation and degrade spawning gravels. In the Sierra Nevada, canopy disruption from road corridors alters snowpack retention, exacerbating late-season water scarcity. In the Huron-Manistee NF, fragile sandy soils and groundwater-dependent cold-water trout streams are exceptionally vulnerable to runoff and nutrient loading from unpaved corridors. 4. Degradation of Backcountry Recreation Economies Converting remote roadless tracts into industrial zones permanently degrades their primitive character. This violates the balanced multiple-use mandate by shifting economic value away from growing local outdoor recreation economies that rely heavily on quiet, non-motorized backcountry access. Requested Actions: Adopt the No Action Alternative, maintaining the uniform national protections of the 2001 Roadless Rule. Utilize existing administrative exceptions within the 2001 Rule to execute targeted, community-adjacent hazardous fuel treatments without permanent road construction. Address localized fuel concerns through site-specific NEPA analyses within existing forest plan revisions, rather than a sweeping national repeal. Sincerely, Albert Karl Henning, PhD Palo Alto, CA