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Allowing more roads and logging in Apalachicola National Forest, Osceola National Forest and Ocala National Forest in Florida would threaten endangered wildlife and plants. With development swallowing more and more land, our conservation areas are a much needed refuge and possibly the only thing standing between endangered species and extinction.

I'm a 61 years of age native Floridian I started going to the Osceola national Forest when I was 11 years old. Except for the 15 years I lived in Texas and after I was forced to medically retire from the ft worth Police department due to injuries suffered on the job, I have hunted that forest and camped in the same campground since I was 11 years old with my dad one of my brothers and many others. I have watched the forest and the campgrounds be decimated by logging companies and their machinery .not only would they come through public campgrounds at 4:00 in the morning tearing the roads up, they would block entrances to the camps, they would leave their trash everywhere, they tore down trees they weren't supposed to.wherever they logged,it would be a complete ecological disaster.just one big mud hole with dead trees everywhere. multiple times we observed dead animals. the camps used to be full of people where you could even find a camping spot unless you went really early even before the season even started .the last few years we were there we'd be the only ones, except for some homeless people that would make problems even worse .each year we would spend thousands and thousands of dollars in the local economy and so would everyone else because most of us in the campground came from other cities. we would come from spring Hill 175 mi South .other people came from Orlando ,St Augustine, many from Jacksonville some from Georgia each and every year and because of the problems and the issues they all stopped coming little by little. the last couple years we were there you had hundreds of people blocking the main road through the forest having illegal street car racing.they would block off all the roads including the campgrounds,with illegal dangerous street car races. dog hunters would be hunting in the still hunt area, theft was starting to become rampant it was simply disgusting and disturbing at the same time hundreds of species of animals and plants are going extinct every year and we are only making the problem worse.it's ironic that the federal government and the State of Florida wants people to spend money hunting and camping and fishing and enjoying the outdoors yet they take away the very areas that people need access to to do those things.it is the future generations that will pay the price and pay for our stupidity God help us all

RE: Docket #FS-2025-0001; RIN 0596-AD66 I urge the U.S. Department of Agriculture to keep the 2001 Roadless Area Conservation Rule in place and withdraw the proposal to rescind it. For 25 years, this rule has protected crucial Florida habitat for more than 130 threatened and endangered plant species and nearly 40 animal species. Rescinding it to allow new roads and logging would do lasting harm. It would fragment the habitat of the Florida scrub jay in the Ocala National Forest. It would pollute the lakes and ponds where the Suwannee alligator snapping turtle lives in the Osceola National Forest. And it would threaten the state's largest population of red-cockaded woodpeckers in the Apalachicola National Forest. These losses could not be undone. Once a road is built, it brings erosion, runoff, invasive species, and human disturbance for decades. Habitat broken into pieces does not recover on any timeline that matters for species already at risk. The existing rule already allows fuel reduction to lower wildfire risk and road access in public safety emergencies. Removing these protections is not needed to manage Florida's forests responsibly. I grew up in Florida, and have seen so much of what makes this state a treasure lost to development. Please leave the Roadless Area Conservation Rule in place.

I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. I care deeply about our national forests and strongly oppose rescinding the 2001 Roadless Rule. Here where I live in the state of Florida it would be a disaster for our wildlife and the people here, while development continues to close in from every side. Our untouched forestlands in the Ocala, Osceola and Apalachicola National Forests would be opened to logging and more road building. That could fragment the habitat of the Florida scrub jay in Ocala National Forest; it could pollute lakes and ponds that house the Suwannee alligator snapping turtle in the Osceola National Forest; and it could threaten the state’s largest populations of red-cockaded woodpeckers in the Apalachicola National Forest. More broadly, the Forest Service was originally founded to protect forests and watersheds from logging and development. Scientists have since determined that roads fragment the landscape in ways that are even more ecologically harmful than clearcuts. Roadless areas protect habitat for 1,600 at-risk species, safeguard clean drinking water for 60 million Americans, and preserve old-growth forests hundreds of years old. As our Florida springs and other waterways experience reduced water flows and we experience extended periods of extreme drought, I'm especially concerned about actions that would reduce Floridians' access to clean drinking water. On top of that contrary to USDA’s claim that this rescission will help the agency reduce fire risk, more roads are likely to mean more fires. New research shows wildfires are four times more likely to start in roaded areas than in unroaded tracts. In this era of increasing wildfires we need to prioritize strategies that reduce the likelihood of wild fires, not increase it. The Roadless Rule is the most popular rule ever implemented in USDA’s history. When it was first proposed in 2001, the Roadless Rule received 1.6 million public comments—more than any rule in U.S. history at that time. Over 95% of these comments supported keeping roadless protections. For all these reasons I strongly oppose rescinding the 2001 Roadless Rule. Please protect America’s remaining roadless areas for current and future generations. Laura Oldanie

Dear Chief Schultz: I research endangered herpetofauna. Specifically, I work with treasured animals like the endangered Eastern Indigo Snake and threatened Gopher Tortoises, both of which are negatively impacted by road mortality and habitat fragmentation. I have spent considerable time searching for these animals in roadless areas and have grown to appreciate the immense beauty of the undisturbed habitat that only exists there because roads have not been allowed to mar the landscape. Road networks would rob these pristine places from me. More importantly, allowing roads in these areas would steal vital habitat from the animals I care about the most. They would not survive the habitat fragmentation, road mortality, or inevitable logging that they would assuredly face if the Roadless Rule is repealed. As a researcher, I think it's worth stating directly: the Department is proposing to undo a rule grounded in empirical science with a proven track record and replace it with a rationale that isn't. They will destroy natural areas that the public holds dear. Regarding the Pinhook in the Osceola National Forest, Florida— one of these such places near me: "Road networks are a common disturbance on the landscapes that cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 On a broad scale, the proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Additionally, as the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. On a smaller yet equally important scale, the incredibly charismatic, ecologically important, and endangered Eastern Indigo Snakes that I work with will be particularly vulnerable: “The mortality of wildlife resulting from collisions with vehicles is considered one of the main negative effects of roads on numerous species. Roadkill can increase the risk of local extinction by reducing effective population size and genetic diversity, while also limiting demographic and genetic rescue mechanisms. Estimates can reach to 340 million of birds killed on the roads in USA, 194 million birds, 29 million mammals in Europe and 17 million of birds and mammals in Latin America. — Scientific Data (Nature), 2024 (https://doi.org/10.1038/s41597-024-04207-x)” Conservation status G2 reflects the vulnerability of Eastern Indigo Snake (Drymarchon couperi) in the Pinhook Inventoried Roadless Area, Osceola National Forest, where 7.1.2 - Suppression in fire frequency/intensity acts at Slight or 1-10% pop. decline severity across Pervasive (71-100%) scope. For Eastern Indigo Snake in Pinhook, the connection between road construction and 7.1.2 - Suppression in fire frequency/intensity is direct: roads deliver the disturbance vectors — sediment, access, fragmentation — that NatureServe identifies as driving Slight or 1-10% pop. decline severity impacts on this population. Failure to analyze 7.1.2 - Suppression in fire frequency/intensity impacts to Eastern Indigo Snake (Drymarchon couperi, G2, T) in the Pinhook IRA renders the DEIS inadequate under NEPA. The administrative record must address this species-threat-area interaction or the analysis is arbitrary. I'll just end with this: the Department should maintain the Roadless Rule. The forests, and the public who values them, are better off with it in place. Warmly, CommentID: RLC-20261007-TKT648

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I wanted to state that clearly in case these are only skimmed over or read for the first few thoughts. My name is Kaitlyn Schirard and I'm from Florida. The wild spaces I care most about cannot speak for themselves. That is the point. Whether I am exploring the scrublands and wetlands of Ocala National Forest, watching deer move through the pinelands, or catching sight of scrub jays along the way, what makes those moments possible is the simple fact that those lands remain intact. Alexander Springs Creek and Farles Prairie in the Ocala, and the Pinhook tract in Osceola National Forest, are places whose value lies precisely in what has not been done to them. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and this letter asks the agency to answer for what its own record says before it acts. The Ocala sits directly over the Floridan Aquifer, and Alexander Springs, a first-magnitude spring inside the forest, moves water through karst limestone where any road construction becomes a direct contamination pathway for the drinking water supply of central Florida. Florida holds 9 inventoried roadless areas totaling 50,482 acres under the current rule's protection, and across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions. The deer I watch in these forests, and the scrub jays that exist nowhere else on the planet, depend on landscape conditions that roads fragment and degrade. The agency's own record acknowledges that road construction may alter deer migration routes and increase movement speed, citing research on exactly that disruption, and credits roadless protections with the recovery of deer populations in other regions by preserving unroaded winter habitat. I ask that the agency explain, specifically and concretely, how the proposed rescission accounts for those documented harms to wildlife that its own analysis has already identified. On wildfire, the agency argues that rescission is partly justified by the need for fuels management access. But the agency's own text 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." That sentence is in the agency's own draft environmental impact statement. I ask the agency to explain why the proposal departs from that prior finding, and to reconcile the rescission with its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's 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." Against that baseline, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. The agency cannot establish a net benefit from its own numbers, while the road system it proposes to expand already carries a $6.9 billion maintenance backlog. The proposal also argues that state-by-state approaches can replace a national rule, but the agency's record acknowledges: "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 tried this before, and courts rejected it. I ask the agency to address how this proposal avoids the deficiencies the Ninth Circuit identified the last time a state-by-state framework was substituted for national protection, and to explain its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, the rule as written already accommodates the administrative concerns the agency raises. The agency's own text confirms: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Before claiming the rule is too rigid to function, the agency must identify which specific burdens fall outside those existing exceptions and quantify them in the record. A gross twisting of land stewardship is how I would describe an action that cannot survive scrutiny of its own supporting documents.

The U.S. Forest Service is attempting to rescind the 25-year-old conservation National Forest Roadless Rule in its entirety, removing protections from nearly 45 million acres of wild, unfragmented forest lands across 37 states. In Florida, eliminating this rule would threaten protected lands in the Ocala National Forest, Osceola National Forest, and Apalachicola National Forest that are critically important for the protection of valuable fish and wildlife habitat, water quality, drinking water, and recreational opportunities. There are ZERO benefits --except to helping private businesses access and profit off our public lands-- and 45 million benefits to keeping the rule in place. Do NOT change this regulation. Keep the protection in place.

I am writing in strong opposition to the proposed repeal of the Roadless Rule. I am a biologist who has dedicated my career to conserving threatened and endangered and imperiled species, many of which are dependent upon healthy, intact forests. I am a member of many environmental organizations (e.g., the League of Conservation Voters, the Center for Biological Diversity, Earthjustice) because protection of the environment is extremely important to me. The Roadless Rule is one of the most important safeguards we have to protect our national forests from corporate development. In Florida, more than 50,000 acres in three national forests are included in the federal roadless-area inventory. My family and friends enjoy spending time in Apalachicola National Forest, Ocala National Forest, and Osceola National Forest. We use the forests for passive recreation, mainly camping and to observe wildlife. We do not want to see the forests further degraded by additional logging and needless openings for disturbances. There are already plenty of roads in Florida's forests, and national forests in general. Roads affect much more land than the relatively small footprint they occupy. More roads can: fragment wildlife habitat and create new forest edges; increase unnecessary vehicle access and human disturbance in previously remote areas; alter natural drainage patterns; increase runoff, erosion, and impacts on water quality; provide pathways for invasive plants and other nonnative species to spread; disrupt wildlife movement and ecological connectivity. Rescinding the Roadless Rule would open the door to road-building, logging, and industrial development, jeopardizing our nation’s most treasured old-growth forests and threatening the health and safety of communities across the country. It is not necessary. It is short-sighted and wasteful. We cannot risk losing the protections that the Roadless Rule offers. Please help keep our forests, climate, and communities safe — do not repeal the Roadless Rule. Sincerely, Paula Halupa

I am writing in strong opposition to the proposed repeal of the Roadless Rule. I am a biologist who has dedicated my career to conserving threatened, endangered, and imperiled species, many of which are dependent upon healthy, intact forests. I am a member of many environmental organizations (e.g., the League of Conservation Voters, Center for Biological Diversity, Sierra Club, Earthjustice) because protecting the environment is important to me. The Roadless Rule is one of the most important safeguards we have to protect our national forests from corporate development. In Florida, more than 50,000 acres in three national forests are included in the federal roadless-area inventory. My family and friends enjoy spending time in Apalachicola National Forest, Ocala National Forest, and Osceola National Forest. We use the forests for passive recreation, mainly camping and to observe wildlife. We do not want to see the forests degraded by additional logging and needless openings for disturbances. There are already plenty of roads in Florida's forests, and national forests in general. Of the approximately 1.2 million acres of national forest land in Florida, about half - 500,000 to 600,000 acres - are already open to logging or timber harvest in some form. More than 500,000 acres of Florida's national forests are also wetlands. There is absolutely no need to open up more areas of forest to unnecessary roads - in Florida or anywhere else. Roads affect much more land than the relatively small footprint they occupy. More roads can: fragment wildlife habitat and create new forest edges; increase unnecessary vehicle access and human disturbance in previously remote areas; alter natural drainage patterns; increase runoff, erosion, and impacts on water quality; provide pathways for invasive plants and other nonnative species to spread; disrupt wildlife movement and ecological connectivity. Florida’s continuing loss and fragmentation of wildlife habitat make remaining intact public lands increasingly important. There are 36 federally threatened or endangered animal species that live in Florida's national forests (Apalachicola, Ocala, and Osceola). Rescinding the Roadless Rule would open the door to road-building, logging, and industrial development, jeopardizing our nation’s most treasured old-growth forests and threatening the health and safety of communities across the country. It would destroy and degrade important wildlife habitat, especially for forest-dependent species. We cannot risk losing these protections. Help keep our forests, climate, and communities safe — do not repeal the Roadless Rule. Thank you.

I am writing to oppose the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule. I urge the Department to keep these protections in place for Florida's national forests and for roadless areas nationwide. Florida's roadless areas are small, about 50,000 acres across the Apalachicola, Ocala, and Osceola National Forests, and that is exactly why they matter. Southwest Florida, where I live and work, is losing wildlife habitat to development every year. Across the state, intact public land is becoming the last refuge for species with nowhere else to go. Florida's national forests support more than 130 threatened and endangered plant species and nearly 40 listed animal species. Some of those populations exist nowhere else. The risks are specific. New roads and logging in the Ocala National Forest would fragment habitat for the Florida scrub jay, a species found only in Florida. In the Osceola National Forest, road construction and timber harvest would increase runoff into the lakes and ponds that support the Suwannee alligator snapping turtle. The Apalachicola National Forest holds the largest red-cockaded woodpecker population in the state, and that population depends on mature, undisturbed pine forest. Roads don't only remove habitat. They cut what remains into pieces, bring in vehicle traffic that kills wildlife, and open the way for invasive species, illegal dumping, and poaching. I understand that the Department has framed this rescission as a wildfire safety measure. That reasoning does not fit Florida. Our fire-adapted pine forests are managed largely through prescribed burning, which does not require new permanent roads. The 2001 rule also already allows road construction when needed to protect public health and safety from fire, flood, or other catastrophic events. It also allows some tree cutting to restore natural fire regimes. In addition, new roads can increase human-caused ignitions, and they add to a Forest Service road maintenance backlog that is already far beyond what the agency can fund. Once a road is built and a forest is logged, the intact habitat it replaced cannot be recovered on any timescale that matters to a declining species. A national rule that has protected these lands for 25 years should not be discarded in exchange for short-term timber access. I respectfully ask the Department to withdraw this proposal and retain the Roadless Area Conservation Rule in full.

I am writing as a Florida resident to register my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. Stripping these protections threatens to open roughly 50,000 acres of Inventoried Roadless Areas (IRAs) across Florida’s three national forests—Apalachicola, Osceola, and Ocala—to destructive road construction and commercial timber harvesting. Florida’s landscape is experiencing unprecedented population growth and rapid private land development. In this environment, our national forests serve as irreplaceable ecological refuges. Carving new roadways through these contiguous forest blocks causes irreversible habitat fragmentation, alters delicate hydrology, and introduces invasive species. Rescinding the Roadless Rule poses direct threats to Florida’s public lands: Apalachicola National Forest: Harboring approximately 25,000 acres of roadless forest, this land supports Florida's largest population of the federally endangered red-cockaded woodpecker. These birds depend on undisturbed old-growth longleaf pine savannas that commercial timber sales and heavy equipment traffic severely compromise. Ocala National Forest: Road construction through roadless scrub disrupts the federally threatened Florida scrub-jay, a species entirely endemic to Florida that requires unfragmented scrub oak habitat. Roads also bring high-speed vehicle traffic, causing direct wildlife mortality. Osceola National Forest: Industrial timber cutting and road runoff degrade water quality in wetlands, streams, and ponds essential to vulnerable aquatic species, including the Suwannee alligator snapping turtle. Flora and Biodiversity: Statewide, Florida’s national forests shelter more than 130 threatened or endangered plant species and nearly 40 protected animal species that cannot withstand industrial forest disruption. The Forest Service's claim that roadless protections prevent effective fire and forest management does not hold in Florida. Federal and state agencies routinely conduct successful prescribed burns and ecological restoration in these ecosystems without needing new commercial logging roads. Roadless areas protect our drinking water recharge zones, safeguard biodiversity, and provide open spaces that cannot be replaced once paved or cleared. I urge the Department of Agriculture and the U.S. Forest Service to withdraw this proposed rollback entirely and maintain the 2001 Roadless Area Conservation Rule in full.

To Whom It May Concern: I am writing as a Florida resident to register my strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. Stripping these protections threatens to open roughly 50,000 acres of Inventoried Roadless Areas (IRAs) across Florida’s three national forests—Apalachicola, Osceola, and Ocala—to destructive road construction and commercial timber harvesting. Florida’s landscape is experiencing unprecedented population growth and rapid private land development. In this environment, our national forests serve as irreplaceable ecological refuges. Carving new roadways through these contiguous forest blocks causes irreversible habitat fragmentation, alters delicate hydrology, and introduces invasive species. Rescinding the Roadless Rule poses direct threats to Florida’s public lands: Apalachicola National Forest: Harboring approximately 25,000 acres of roadless forest, this land supports Florida's largest population of the federally endangered red-cockaded woodpecker. These birds depend on undisturbed old-growth longleaf pine savannas that commercial timber sales and heavy equipment traffic severely compromise. Ocala National Forest: Road construction through roadless scrub disrupts the federally threatened Florida scrub-jay, a species entirely endemic to Florida that requires unfragmented scrub oak habitat. Roads also bring high-speed vehicle traffic, causing direct wildlife mortality. Osceola National Forest: Industrial timber cutting and road runoff degrade water quality in wetlands, streams, and ponds essential to vulnerable aquatic species, including the Suwannee alligator snapping turtle. Flora and Biodiversity: Statewide, Florida’s national forests shelter more than 130 threatened or endangered plant species and nearly 40 protected animal species that cannot withstand industrial forest disruption. The Forest Service's claim that roadless protections prevent effective fire and forest management does not hold in Florida. Federal and state agencies routinely conduct successful prescribed burns and ecological restoration in these ecosystems without needing new commercial logging roads. Roadless areas protect our drinking water recharge zones, safeguard biodiversity, and provide open spaces that cannot be replaced once paved or cleared. I urge the Department of Agriculture and the U.S. Forest Service to withdraw this proposed rollback entirely and maintain the 2001 Roadless Area Conservation Rule in full. Sincerely, Kathryn Henderson

All three of Florida’s national forests—Apalachicola, Ocala, and Osceola—contain inventoried roadless areas: Apalachicola National Forest — 24,890 acres Clear Lake, Gum Bay, Long Bay, and Savannah Ocala National Forest — 4,855 acres Alexander Springs Creek and Farles Prairie Osceola National Forest — 20,737 acres Impassable Bay, Natural Area WSA, and Pinhook Altogether, 50,482 acres in Florida’s three national forests are included in the federal roadless-area inventory. Fragment wildlife habitat and create new forest edges. Increase vehicle access and human disturbance in previously remote areas. Alter natural drainage patterns. Increase runoff, erosion, and impacts on water quality. Provide pathways for invasive plants and other nonnative species to spread. Roads permitted in this change will disrupt wildlife movement and ecological connectivity.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Photography pulled me into the forests of Florida, and the forests kept me there. I go looking for anything and everything beautiful to photograph. It is a way for me to memorialize the things I find beautiful, and the roadless areas of Osceola, Ocala, and Apalachicola National Forests are where I find them. Woodpeckers, storks, sparrows, and really any birds I can locate on the trails I walk. Rescinding the 2001 Roadless Area Conservation Rule would take that from me, and I am filing this comment to say it must not happen. The strongest reason to keep the rule is fire, and the agency's own record says so. 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." The proposal justifies rescission in part on fuels management grounds, yet that language is sitting in the agency's own draft environmental impact statement. The agency must explain why its proposal departs from those findings, and it must reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Birds are why I hike. Losing road protection in these forests is not a neutral trade. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. At Alexander Springs Creek in Ocala National Forest, paddling the river and listening to the birds and watching the wildlife is the whole point. If I lost that place I would not have access to a nature spot to just enjoy nature's music. Natural Area Wsa and Impassable Bay in Osceola National Forest hold migratory birds and federally protected animals I can see nowhere else near me. The Ocala National Forest specifically recovered red-cockaded woodpeckers from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads. Florida scrub-jays, found nowhere else on the planet, depend on the surrounding scrub. I ask the agency to explain in the record how opening these forests to roads is compatible with those documented bird outcomes. The economic case for rescission also does not hold. The agency's own 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." The agency must reconcile the proposal with its own Cost Benefit Analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and it must say plainly how an action whose own numbers cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Pinhook, 15,405 acres in Osceola National Forest, is part of old Florida and what makes Florida, Florida. Farles Prairie in Ocala, 1,901 acres, is a hidden gem that combines water and trees. Gum Bay, 11,645 acres in Apalachicola National Forest, is serene, with springs and rivers I want to explore. These are the places I rely on. 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. The agency is required to identify and weigh the reliance interests described in the comments it receives. This comment is one of them, and it deserves a real accounting. Florida holds 9 inventoried roadless areas totaling 50,482 acres, and the Ocala alone sits directly above the Floridan Aquifer, where road construction is a direct contamination pathway to the drinking water supply of central Florida. Across the Southern region, 378 municipal water intakes sit in watersheds containing affected roadless areas. We need to protect our environment. The rescission should be withdrawn. Sincerely, A born and raised Florida Native

I am writing to officially oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. Currently, I live in Sarasota, Florida, and there are many public lands in the surrounding areas, so this issue is close to home for me. These include the Ocala National Forest, Osceola National Forest, and Apalachicola National. I enjoy hiking and seeing the beautiful wildlife of these forests. It would be of great disappointment to see these wild lands becoming industrialized. Additionally, the Ocala National Forest’s roadless areas help protect the St. Johns River’s health, while nearby national forests safeguard valuable habitat, water quality, and drinking water. Protecting these forests is extremely crucial in maintaining clean drinking water. The more road construction and human activity that surrounds this river, the more our rivers will suffer from pollutants and contaminants from nearby traffic leading to unsafe drinking water. I understand that a major focus on the rescinding of the Roadless Rule is focused around wildfire management. However, expert environmentalists around the country firmly argue that industrializing these areas will impose more of a fire risk than just leaving it alone. In fact, wildfires are four times more likely to start in areas with roads than without (Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). To further back this evidence, many wildland firefighters, such as Shaun Opp, a retired wildland firefighter, oppose the efforts to erase the roadless rule. He says “after years of serving as a firefighter, I know what works and what doesn’t. Rescinding it [the roadless rule] won’t prevent a single fire or save a single home. It will increase fire risk, waste taxpayer money, and make fire prevention and suppression even harder.” For the many reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake. I oppose rescinding the Roadless Rule.

The forest nearest me, Osceola National Forest, is about 19 miles away with 2,543 acres of roadless area. That's unheard of in this part of Florida! Water from forest country in the larger Southern Region reaches as many as 2,911,200 people downstream. Right now that water is clean because so few watersheds have impaired streams. But skid roads, trails and log landings that come with timber harvest are the main cause of soil erosion and can contribute up to 90% of the sediment generated by timber sale activity. Clean water is important to me, so I oppose 0596-AD66.

Dear USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing today in opposition to rescinding or altering the Roadless Area Conservation Rule. I am a teacher, birder, and environmentalist and I am joining millions of Americans of all backgrounds in support of the Roadless Rule. Having grown up in Florida visiting Osceola National Forest and Apalachicola National Forest, and now living in Oregon visiting Mt Hood National Forest, intact forests have shaped my love of nature since I was a child. Unfragmented forest habitats help not only the animals that live in them, but also the humans and businesses around them. Inventoried Roadless Areas offer tremendous benefits to communities and ecosystems that would be threatened or destroyed by road building. Here are just a few examples of the benefits of retaining the Roadless Rule. Wildlife habitat: imperiled species like Northern Spotted Owls, Marbled Murrelets, and countless other birds rely on large, intact forests with undammed, unlogged streams and connected landscapes. Salmon, trout, elk, and other species are also threatened when habitat is fragmented Drinking water: 60 million Americans rely on national forests for drinking water; intact forests filter water naturally. Many inventoried roadless areas are important parts of watersheds. Wildfire risk: wildfires are 4x more likely to start near roads; roughly 90% of wildfires are human caused and start within half a mile of a road — these facts directly contradict one of your agency’s main stated rationales for rescinding the rule. Old growth & carbon storage: mature and old-growth forests are a critical buffer against runaway climate change. We should be protecting more forests, not gutting their protections. Additionally, these forests are far more resilient to wildfires than commercially logged forests. Outdoor Recreation: Roadless areas offer abundant outdoor recreation opportunities such as hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands, and roadless areas contribute millions of dollars to local economies through the recreation industry. Fiscal Responsibility – Roads are costly. Building new logging roads in remote backcountry areas is extraordinarily expensive, leaving taxpayers with billions of dollars in long-term maintenance costs for roads that are rarely, if ever, used (the existing road network already carries an $8.5+ billion maintenance backlog). The road network throughout national forests is already massive and should be reduced instead of expanded. I urge you to keep the Roadless Rule in place as it is. Thank you for your time.

I (Abigale Augugliaro) am writing to officially oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. Currently, I live in Florida and work as a full time nurse. Public lands in Florida such as the Ocala National Forest, Osceola National Forest, and Apalachicola National Forest are all places I depend on to decompress after stressful days at work. I enjoy hiking and seeing the beautiful wildlife that surrounds these forests. It would be of great disappointment to see these wild lands becoming industrialized. Additionally, the Ocala National Forest’s roadless areas help protect the St. Johns River’s health, while nearby national forests safeguard valuable habitat, water quality, and drinking water. Protecting these forests is extremely crucial in maintaining clean drinking water. The more road construction and human activity that surrounds this river, the more our rivers will suffer from pollutants and contaminants from nearby traffic leading to unsafe drinking water. I understand that a major focus on the rescinding of the Roadless Rule is focused around wildfire management, however, environmentalists around the country firmly argue that industrializing these areas will impose more of a fire risk than just leaving it alone. In fact, wildfires are four times more likely to start in areas with roads than without (Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). To further back this evidence, many wildland firefighters, such as Shaun Opp, a retired wildland firefighter, oppose the efforts to erase the roadless rule. He says “after years of serving as a firefighter, I know what works and what doesn’t. Rescinding it [the roadless rule] won’t prevent a single fire or save a single home. It will increase fire risk, waste taxpayer money, and make fire prevention and suppression even harder.” For the many reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a great mistake. I oppose rescinding the Roadless Rule. Abigale Augugliaro

I am writing to officially oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. Currently, I live in Florida and work as a full time nurse. Public lands in Florida such as the Ocala National Forest, Osceola National Forest, and Apalachicola National Forest are all places I depend on to decompress after stressful days at work. I enjoy hiking and seeing the beautiful wildlife that surrounds these forests. It would be of great disappointment to see these wild lands becoming industrialized. Additionally, the Ocala National Forest’s roadless areas help protect the St. Johns River’s health, while nearby national forests safeguard valuable habitat, water quality, and drinking water. Protecting these forests is extremely crucial in maintaining clean drinking water. The more road construction and human activity that surrounds this river, the more our rivers will suffer from pollutants and contaminants from nearby traffic leading to unsafe drinking water. I understand that a major focus on the rescinding of the Roadless Rule is focused around wildfire management, however, environmentalists around the country firmly argue that industrializing these areas will impose more of a fire risk than just leaving it alone. In fact, wildfires are four times more likely to start in areas with roads than without (Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). To further back this evidence, many wildland firefighters, such as Shaun Opp, a retired wildland firefighter, oppose the efforts to erase the roadless rule. He says “after years of serving as a firefighter, I know what works and what doesn’t. Rescinding it [the roadless rule] won’t prevent a single fire or save a single home. It will increase fire risk, waste taxpayer money, and make fire prevention and suppression even harder.” For the many reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a great mistake. I oppose rescinding the Roadless Rule. Sincerely, Abigale Augugliaro

I am an environmental scientist and hunter living in Jacksonville, Florida. I strongly oppose fully or partially rescinding the 2001 Roadless Area Conservation Rule. I support smart development, small businesses, American manufacturing, and growth in American GDP. Those priorities require fiscal discipline and responsible stewardship. Rescinding roadless protections is short-sighted, and the projected timber revenue does not adequately justify the potential public costs. USDA estimates $5.2–$11.4 million in additional annual revenue to the Treasury and Forest Service, plus $4.6–$10.6 million to the timber industry. Yet the agency acknowledges that the harvest scenario underlying these estimates is unlikely to be fully realized because of budget, operational, and market constraints. The same proposal estimates potential losses of $6.1 million annually in economic benefits to recreationists—equivalent to approximately 54%–117% of the projected federal timber receipts. These are different economic measures, but their relative size demonstrates why timber revenue alone cannot establish a net public benefit. USDA also identifies a $6.9 billion deferred-maintenance backlog for roads and bridges. The projected additional annual federal timber revenue equals just 0.075%–0.165% of that backlog, before considering new obligations. Adding roads requires a credible accounting of construction, maintenance, erosion control, restoration, and eventual decommissioning costs—and an explanation of who will pay them. Hunting and fishing already support substantial economic activity. The U.S. Fish and Wildlife Service reports that Americans spent $99.4 billion on recreational fishing and $45.2 billion on hunting in 2022: $144.6 billion combined. Wildlife watching generated another $250.2 billion in expenditures. These nationwide figures are not attributable solely to roadless lands, but they demonstrate the economic importance of healthy habitat and quality outdoor experiences. Forests also provide services that never appear on a timber-sale receipt. Forest Service research estimates that national forests and grasslands contribute 5.2 trillion gallons of surface water annually to public water supplies, with an estimated $47 billion in annual value associated with avoided treatment, dredging, and water-quality violation costs. This system-wide estimate is not a forecast of losses from rescission. It shows why watershed protection belongs in a complete economic assessment. USDA should quantify the incremental risks to these benefits rather than treating benefits that are difficult to price as worth zero. It should also distinguish gross receipts from net fiscal returns and evaluate cumulative costs over the full life of any resulting development. This issue is personal. I routinely hunt and take pleasure in the Osceola National Forest, just west of Jacksonville. Forest Service inventory figures identify approximately 20,737 acres of inventoried roadless areas there, including Pinhook, Impassable Bay, and the Natural Area Wilderness Study Area. These places are part of the landscape I know and value. The opportunity to hunt and experience quiet country away from roads, vehicles, and heavy equipment cannot be fully captured by spending statistics. Access matters, but so does the character of the place being accessed. Development can diminish the very qualities that make a landscape worth visiting. If there is one thing America has no shortage of, it is roads. The Forest Service’s infrastructure assessments describe approximately 370,000 miles of them. We should maintain existing infrastructure while conserving places where Americans can still experience undeveloped country. Wildlife and wild places also have intrinsic value beyond their commercial uses. The North American Model of Wildlife Conservation recognizes wildlife as a public resource managed on behalf of all citizens. That responsibility extends to future generations and the habitats wildlife needs to survive. As Theodore Roosevelt stated: “I recognize the right and duty of this generation to develop and use the natural resources of our land; but I do not recognize the right to waste them, or to rob, by wasteful use, the generations that come after us.” Please retain the Roadless Rule and reject full or partial rescission that weakens its protections. Protecting clean water, wildlife, outdoor traditions, and our shared natural inheritance is sound stewardship and responsible economic policy.