Every public comment on the proposed rescission of the Roadless Rule, sorted by what it talks about. Pick a topic, then narrow by position, by how hard the comment is for the agency to set aside, or by how substantive it is. Each comment is shown in full, as filed. How comments are classified and scored is explained in the Comment Analysis.
19 unique comments24 submissions
Position
Opposes rescission 94.7%
Supports rescission 5.3%
Answerability
A1 strong 2
A2 moderate 0
A3 weak 3
A0 none 5
Substance /24
Median 8.5middle half 7–11.5 · 10 scored
Topics raised
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Position
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Substance /24
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19 unique comments naming Plumas National Forest· showing 1–19Clear all filters
This is not needed. I've been a seasonal USFS worker doing road surveys for Plumas NF. There are so many roads that exist, they can't all be maintained at the current inventory. Keep wilderness areas as they are and do not approve this rule.
Dear Department of Agriculture,
I write as a former wildland fire technician, fly fishing guide, and businessman who has worked and recreated on national forests from California to Montana, and I write in opposition to the proposed changes to the Roadless Rule. As someone born on the Plumas National Forest who has camped, fished, and made a living on public lands, I've never had trouble finding an existing Forest Service road to reach my destination, and I've cherished the solitude roadless areas provide. I wish to address the Department's stated reasons for this proposed change and illustrate why I think it's crucial to keep the quarter of total acreage the Forest Service oversees subject to the national guidelines the roadless rule protects.
First, the Department can only cite the current President's executive orders and declarations as the purpose behind this proposal. Ultimately the federal government exists through funding from and a social contract with its citizens, yet their voices are notably absent from this proposal. Nowhere do we hear from loggers, anglers, hunters, backpackers, foresters, firefighters, ranchers, or the myriad of other stakeholders who could inform the proposed changes. Second, the Department estimates the proposed rule change could lead to an increase in revenue of $5-10 million dollars for the Treasury and Forest Service, a sliver of the $12 billion net spending for the Forest Service last year. The current document fails to provide solid background in support of the proposed change, and any revenue will vanish in the increased cost of maintaining more roads and litigating the myriad of lawsuits sure to follow this change.
Second, I would suggest existing roadless areas offer more value than they cost in the form of habitat, biodiversity, and recreational opportunities that attract people precisely because these areas are roadless. At a time when it feels impossible to escape the spread of cities and screens, roadless areas provide an unparalleled opportunity for citizens to experience the United States as it existed during a time of awe, wonder, and respect for this land's wealth of habitats, a tradition passed down through President Theodore Roosevelt. A change of this nature can only lead to one outcome: more roads. For more on the impact more roads will have on game, fish, and wildfire proliferation, see Ben Goldfarb's book called Crossings.
As a former wildland fire technician, I witnessed the vast majority of human-caused fires start in parts of the national forest accessible by road. Where humans go, fires follow. Making it easier for people to access unburned forest will not reduce the risk of wildfire; if anything, it may only increase it. While the proposal purports to empower local Forest Service officials, the purpose of a federal rule is to provide stability and measured stewardship to public lands free from the partisanship and influence of local politics (of any persuasion) that can infiltrate local ranger stations.
We have a saying in Montana: if it ain't broke, don't fix it. The Roadless Rule isn't broken, and the fix is to leave it the way it is.
To whom it may concern,
I write to strongly oppose rescinding (in full or partial) of the Roadless Area Conservation Rule. It would devastate what little protected wilderness we have left in our country. This action would have an irreversible disastrous effect on the wellbeing of our environment which would compound in effect on the wellbeing of American people.
I live in San Francisco, CA but grew up in a small town in Plumas County, CA where much of my childhood and adulthood were spent in the national forests. I spent weekends hiking through Bucks Lake Wilderness in the Plumas National Forest and snow days sledding the slopes of the Sierra Nevadas.
Removing these protections would enable the destruction of the last remnants environmental beauty we have in America. Frankly I’m disgusted that this is even up for discussion. The consequences of rescinding this rule will effectively be permanent. We cannot regrow old growth forests within our lifetime nor the lifetime of our decedents. We cannot allow these environments to be destroyed and taken from future generations of Americans.
Please to do not take part in the ongoing destruction of America for corporate profits. The actions taken here will be remembered in history and I hope you are on the right side of it.
I favor reduced government regulations with regard to businesses, but I am strongly opposed to this proposal to rescind the 2001 Roadless Rule. I am a resident of Sacramento California, where I retired 5 years ago to enjoy the outdoors including national forest lands. Those National Forest lands are especially important to me because we can take our dog with us when hiking or camping. That's not allowed in the vast majority of National or State Parks. I chose to live near the Sierra Nevada and multiple national forests from El Dorado National Forest in the south through Tahoe NF to Plumas NF north of Lake Tahoe. But I am within fairly easy driving distance of Inyo NF to the southeast, and Klamath, Shasta Trinity and Six Rivers NF's in the northern part of the state. In the former 3 NF's I see this rescission fragmenting beautiful forest lands that will devalue the forests for biking, fishing, hiking and hunting alike. At the same time easier access for people from an expanded road system (not necessarily loggers and others) will increase the likelihood of increased fire danger. But in the latter four forests the even higher percentage of areas being proposed to allow new roads goes beyond devaluing the forest and approaches fragmenting them into a small number of microforests that destroy the existing wilderness. This does not seem well thought out and has no new budget for supporting an even larger road system (neither construction or maintenance). It is also likely to shift current control from a single government unit to conflicting state and local jurisdictions. Therefore, I am strongly opposed to the proposal to rescind the 2001 Roadless Rule.
Opposes rescissionA1 strongSubstance 15/24Owed an answerOct 6, 2026FS-2025-0001-583995
PLACESTANDDOCGAPEVIDASKALTLAW
Small family — One letter sent by 3 to 9 people, copied or lightly reworded. See the letter, its submissions and topics.This comment stands for all 3 submissions in its group.
I am a field biologist who regularly works on national forests containing inventoried roadless areas in California that would be impacted from the rescission of the 2001 Roadless Rule including: Stanislaus NF, Sierra NF, Plumas NF, and Mendocino NF. I also regularly visit Coronado NF lands containing inventoried roadless areas in Arizona, including the Chiricahua Mountains, Dragoon Mountains, Santa Rita Mountains, and Catalina Mountains. These lands and the communities that inhabit and rely on them, some of which are threatened and endangered species, are sensitive to further fragmentation and degradation from development. Their watersheds (which humans also rely on) are sensitive to the erosion and sedimentation caused by construction and maintenance of new roads and/or other development.
I strongly oppose the recission of the Rule and list objections to the rationale for the Proposal and to the draft EIS below.
One of the main stated rationales for rescission of the Rule presented in the Proposal is the need to return control of inventoried roadless areas to local FS authorities because the national 2001 Roadless Rule was too restrictive and burdensome to locally adapt, specifically regarding active management for fire and fuels.
Yet, on page 14 of the draft EIS, Table 1., 2001 Roadless Rule exceptions (alternative 1) (36 CFR 294.12(b) and 294.13(b) (2001)), states: “Road construction, reconstruction, including temporary road construction, is prohibited in inventoried roadless areas, except when:
1) A road is needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property”
Fuel reduction projects on FS lands in California have been actively taking place since the Roadless Rule went into effect. I know this because I have worked on these projects. I also know this because there is published research documenting these activities: “The findings in our analysis are consistent with other studies, including research supported by the Forest Service’s Rocky Mountain Research Station, which evaluated nearly twenty years of monitoring data, concluding that “a lack of roads in IRAs [Inventoried Roadless Areas] has neither prevented fuel treatment nor led to substantially more fire” (Trout Unlimited 2026).
On page 24 of the draft EIS, Table 3., which shows comparison of effects under alternatives 1-3 divided by resource/topic, under Fire and Fuels Management, it states “Currently, the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands. Under alternatives 2 and 3, if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads.”
This statement, along with statistics from other published, peer-reviewed, and agency-accepted studies regarding the topic (see below), refute the argument that adding additional roads would reduce fire risk by any meaningful amount.
“Analysis of information about ignition source and location from the Forest Service fire occurrence dataset (USA.FireOccurrence) shows the occurrence of human-caused wildfire ignitions is strongly correlated with roads. Seventy-eight percent of human-caused fires on NFS lands nationwide start within ½ mile of a road” (Trout Unlimited 2026).
References:
Trout Unlimited, 2026. Roadless: Active Management and Fire A GIS data analysis and research review. September 2, 2026. Accessed October 5, 2026, online at https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa.
I am commenting from a position as a lifelong user of our public lands. I grew up in Inyo County and the Eastern Sierra was my backyard. I backpacked, fished, hunted throughout the Sierra and Inyo/White mountains. I also worked for the Inyo NF first on a YACC crew, later a trail crew and also as a seasonal firefighter, so I feel have a lot invested in this issue. I have experienced access shrink on the Inyo NF and local BLM areas probably about 50 percent. Areas designated "wilderness areas" that have two track roads with ruts up to your knees, posted now as wilderness with no access (Inyo Mt Wilderness) and many other closed roads with no real input from local users. I've experienced the same thing on other forests where I also recreated and worked (Lassen NF, where I worked on a road crew) Plumas NF, and Shasta/Trinity NF while living in Lassen County.
Over the years (decades actually) I've experienced our access to public lands through two track, minor roads, fire access and otherwise roads not considered maintained two lane roads. These roads have impacted land management and fire access which have created an extreme fire danger is many areas where the fire danger and intensity have resulted in millions of acres of severe loss of resources. Many of the fires have burned so hot that the soils have been virtually destroyed through sterilization and creating a water repellent surface. I have personally seen extensive erosion from these conditions and the lands will take decades if not centuries to recover.
Let's move on to access.
There are many folks who aren't able to walk in to sites that have existing roads that are closed due to administrative access restrictions with no real explanation as to the reason other than it's being studied or because the district ranger "said so". The citizens who actually own these lands are being shut out of them by kowtowing to special interest groups and the "sue and settle" process they use to force their will on everyone. This process impacts those people who are the least able to access these lands by means other than walking. The government strives to conform to ADA requirements but tends to shut out folks with mobility issues other than highly developed and very crowded areas.
These roadless areas also impact those who have grazing, mining and logging leases which make it much more difficult to manage and rehabilitate the lands they have as a lease agreement. It seems that the heavy handed government land managers in many places (not all) are using roadless areas as a tool to erase years and decades of lands which are stated to be "multiple use" public lands. We need to have reasonable oversight and re-open these lands which have been "studied" for 3 to four DECADES! It is high time to open these lands again for public use and start managing these public properties. Locking up land and leaving it alone which increases fuel loads, lose access to prevent of fight fire, arrest erosion, and allow grazing lease holders to improve water catchment, fencing and range (feed) management.
Thank you for considering my points towards re-opening restricted "roadless" areas, many which have existing roads but were redefined during the Clinton Administration to make it easier to close access to previously open areas.
Randal Stevenson
Opposes rescissionA3 weakSubstance 12/24Owed an answerSep 28, 2026FS-2025-0001-485447
PLACESTANDDOCGAPEVIDASKALTLAW
I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. I care deeply about our national forests. I have hiked and fished extensively in Plumas National forest, Stanislaus National Forest, Tahoe National Forest, El Dorado National Forest, Inyo National Forest, Los Padres National Forest and Sequoia National Forests over the past 50 years. In addition to recreating in these forests, I have lived significant parts of my life in areas where the clean drinking water flowing from our taps originated in national forests.
The Roadless Rule has protected important areas of our national forests and their ecosystems for 25 years. The Forest Service, in the text of the Roadless Rule, states that conserving roadless areas was critical because road construction and logging were the activities most likely to harm the values and characteristics the Forest Service is tasked by statute with protecting. The science is clear; road building fragments habitat, disrupts wildlife and watersheds; increases siltation and other pollution and worsens the spread of invasive species.
The science is also clear that, contrary to USDA's claim in its Notice, more roads will not reduce the risk of fire, it will increase that risk. Over 80% of wildland fires are human caused, and more roads means more people. Most fires ignite within a few hundred feet of roads. New research shows wildfires are four times more likely to start in roaded areas than in unroaded areas. Both the Rim Fire in 2013 and the Donnell Fire in 2018 in Stanislaus National Forest were caused by unattended campfires near roads.
The current administration has significantly reduced the number of forest service personnel including those providing wildfire prevention, suppression and management. These policies make it clear that this rule is not genuinely about mitigating fire risk. Indeed the reduction in forest service personnel will make it impossible for the forest service to manage either additional roadbuilding activities or the added persons coming on to the newly opened areas in our national forests. The forest service has not been able to adequately maintain its existing road network to safety or environmental standards.
For all of the above stated reasons, I strongly oppose the arbitrary and capricious action of the USDA in proposing rescinding the 2001 Roadless Rule. USDA, before moving forward, should undertake a thorough environmental analysis of roadless areas to assess the impact of additional road building, guarantee that no watersheds will be negatively impacted by rescission, and develop and share a detailed plan for addressing its current backlog of road maintenance and repairs. USDA should also commit to providing a transparent and complete accounting of how public comments were considered and concerns addressed in any revised rule.
Ken Strong
Roadless areas are key to wildlife security, and as a hunter, I have witnessed the critical role they play in providing quality hunting opportunities. I grew up in Quincy, California, a small town surrounded by the Plumas National Forest in rural Northern California. The Plumas National Forest has an extremely high road density, and learning to hunt there meant driving around the 4,000+ miles of roads and trails searching for blacktail deer. There were very few opportunities to hike more than a few miles without encountering another Forest Service road.
It wasn’t until I moved to Montana that I realized many national forests in the West do not have this same level of road density. These forests can provide a better hunting experience for those willing to hike while also providing critical security habitat for big game.
Once roads are built, the land is altered forever. It is critically important to maintain the remaining areas that support non-motorized users and wildlife. Some of my favorite places in the world, including the Lolo and Helena-Lewis and Clark National Forests in the Upper Blackfoot River watershed, would be at risk.
Please thoughtfully consider keeping these roadless areas protected.
Docket ID: RIN 0596-AD66
Title: Keep the 2001 Roadless Rule Intact!
I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. I urge the U.S. Forest Service to maintain the 2001 Rule.
I have lived in the West since I was four years old, surrounded by our public lands. They have shaped my identity, interests, and professional pursuits for over 50 years. Now, in my retirement, I am dedicating much of my time to defending the wild places around where I currently live in Meadow Valley, California, in the heart of the Plumas National Forest.
Over the last 20-plus years, catastrophic wildfires have affected me and my neighbors more intensely and frequently. The Plumas National Forest is already heavily roaded due to its extensive logging and mining history. At least 4,500 miles of system roads are on the Plumas NF, leaving only 6% of the forest as designated Inventoried Roadless Areas (IRA’s). Rescinding protections on these remaining mostly unroaded 65,000 acres will not solve our wildfire crisis. Instead, bringing roads into these steep, backcountry zones will dramatically increase the risks of human-caused ignition right in my backyard.
More roads and more motorized human access increases wildfire ignition risks. Data consistently shows that humans are the source of roughly 90% of all wildfires in California. Introducing roads into currently IRAs significantly elevates the risk of accidental or intentional fires from vehicle use, equipment, and public access, endangering human and natural communities. The 2001 Roadless Rule already allows for fire suppression and public safety emergency responses.
Rescinding this rule will degrade critical watersheds, and the Upper Feather River Watershed is the primary headwaters for the California State Water Project, supplying clean drinking water to over 27 million Californians and agricultural irrigation to 750,000 acres of farmland.
Rescinding this rule would increase habitat fragmentation and impact wildlife. Roads cut through critical wildlife corridors, fragmenting the continuous habitat that wildlife needs to migrate, reproduce, and forage. Preserving large, contiguous blocks of forest is essential for maintaining biodiversity and ecosystem resilience, especially under changing climate conditions.
The Inventoried Roadless Areas that I know best on the Plumas National Forest are:
•Middle Fork & Bald Rock IRAs (29,278 acres) – the steep, rugged canyons that flank the Middle Fork of the Feather River, one of America’s original Wild and Scenic Rivers, is just a few short miles from my home. I regularly hike and backpack into this IRA. Keeping heavy machinery out of the canyon is so important to protect the plant and wildlife communities and recreational experiences like the ones I cherish. I have taken students to Bald Rock IRA for an overnight field course over a dozen times. We hiked in to spend the night in this sacred place, and learned about plant communities, geology, and myth. Allowing roads would ruin the unique character of Bald Rock IRA.
•Adams Peak IRA (5,283 acres) – I have hiked Adams Peak, reveling in the challenge of route-finding, bushwacking, and breathless views of the Great Basin, Southern Cascades, and Northern Sierra Nevada received as a reward for the effort. The plant diversity is exceptional due to the junction of these ecoregions.
•Grizzly Peak (6,222 acres) – The soaring views and opportunities for bird watching, hiking, swimming, and botanizing are what make this IRA special for me.
There are so many places where vehicles are able to get on the Plumas National Forest. I urge you to maintain a few that are relatively roadless in order prioritize clean water, community safety and wellness, and ecosystem integrity. Please maintain the nationwide protections of the 2001 Roadless Rule.
Sincerely,
Darla S. DeRuiter
Dear Chief Moore and U.S. Forest Service Review Team,I am writing as a California resident to express my strong opposition to any rollbacks, exemptions, or modifications that would weaken the protections of the 2001 Roadless Area Conservation Rule.As an avid outdoor enthusiast, I regularly use California’s National Forests for hiking, fishing, camping, and mountain biking. Inventoried roadless areas across forests like the Inyo National Forest, Plumas National Forest, and Shasta-Trinity National Forest provide the backcountry trail systems, pristine scenery, and quiet solitude that make these activities meaningful.Opening these intact wildlands to commercial logging and road construction would directly harm the recreational infrastructure and natural values I rely on:Impacts on Fishing and Water Quality: Road building is a primary driver of erosion and sedimentation in forest streams. This degradation ruins the clean, cold water habitats necessary for native trout populations, directly threatening California’s world-class backcountry fisheries.Degradation of Hiking and Camping Experiences: Developing these areas destroys the remote character that hikers, backpackers, and campers seek out. Once a road is built, the wild character of the landscape is permanently fractured.Wildfire Risks: In California, we face severe, climate-driven wildfire seasons. Extensive research shows that building new roads introduces more human activity deeper into the forest, statistically increasing the risk of human-caused wildfire ignitions.Fiscal Responsibility: The Forest Service already suffers from a multi-billion-dollar backlog in existing road maintenance. It is fiscally irresponsible to dedicate resources to new commercial logging infrastructure when our existing trail networks and recreation sites desperately need maintenance funding.A uniform, national standard is necessary to protect these irreplaceable public treasures from piecemeal commercial exploitation. I urge the Forest Service to maintain the 2001 Roadless Rule in its entirety to preserve California's natural heritage for current and future generations.
I am a photographer and a forest landowner.
This email is in opposition of agency's efforts to repeal the Roadless Rule I am a photographer and a forest landowner. I am asking USFS to respond in the record to each of the issues raised in this email.
It is well documented that forests with road access are more likely to burn. We also know that old growth forests are more fire-resilient. Instead of opening new areas to access, the USFS should be addressing the innumerable areas with roads that the USFS is neglecting to manage at all. According to your own fire data, only 23.5% of road miles are used for containment and you have a $6.9B deferred maintenance backlog for these roaded areas.
I know this from personal experience with our property in the Plumas National Forest that was destroyed by the 2019 North Complex Fire. The surrounding forest owned by the Forest Service had been severely neglected despite the easy access by logging roads. When a climate-change induced fire started, the USFS' lack of stewardship exacerbated the situation and contributed to the severity of the fire.
There is no need to open up additional areas of untouched habitat and ecosystems to further human impacts. Clearly before opening new areas to roads you need to take forest stewardship more seriously and need a larger budget to manage the current roaded areas.
The Roadless Rule has been extensively deliberated, is overwhelmingly popular with the public, and must be left in place.
Thank you for scrapping this terrible effort to repeal the Roadless Rule.
Thank you.
Sincerely,
Thomas Bachand
Oakland, CA 94611
I am writing as both a student and former contract United States Forest Service land surveyor to formally express my strong opposition to the United States Department of Agriculture’s proposed rule to rescind the “Roadless Rule” (2001 Roadless Conservation Rule). Rescinding this rule and removing protections for 58.5 million acres of Inventoried Roadless Areas across 39 states could endanger water supplies, destroy habitats for endangered species, and scar the old-growth forests I have come to know in my time as a land surveyor.
These areas and the 2001 Roadless Rule are important for all Americans. According to Olden et al. (2026), watersheds protected by the Roadless Rule supply critical drinking water to tens of millions of Americans and protect vital river ecosystems nationwide. Timber harvest and the construction of roads will create erosion, produce runoff pollution, and sedimentation, which threaten will water supply quality.
Opening up these tracts of land can create irreparable damage to federally protected species like grizzly bears, Canada Lynx, and various native fish (Spivak, 2026). Additionally, these roadless areas protect over 300 species listed under the Endangered Species Act. Some of these animals are found nowhere else in the world, and we should be good stewards of our forests to ensure the survival of these species, as well as protecting our own from the harms of wildfires.
Human-started wildfires account for 84% of all wildfires and 44% of the total burned area across the United States, expanding fire activity directly along road networks (Balch et al., 2017). I saw this firsthand as part of a crew tasked with scanning the remnants of the Moonlight Fire in Plumas National Forest. While that case never went to trial, Sierra Pacific Industries did settle out of court for a value of at least $125 million (U.S. Attorney’s Office, Eastern District of California, 2017). Opening these vast stretches of forest for timber can spark more wildfires.
Having personally worked in United States National Forests, including Eldorado, Plumas, Lassen, Cleveland I know how important these forests are for wildlife and the devastation they can suffer when they are host to wildfires. Most of the work I have been contracted for was post-wildfire, where I could see the damage these forces can do; this is part of what troubles me about the potential for rescinding the Roadless Rule. I’ve experienced the beauty of the United States' forests and have been witness to the scarred landscapes wildfires have wrought, I hope the USDA will reconsider its efforts to rescind the 2001 Roadless Area Conservation Rule.
Opposes rescissionA3 weakSubstance 9/24Owed an answerSep 21, 2026FS-2025-0001-453266
PLACESTANDDOCGAPEVIDASKALTLAW
I am a fisherman who regularly fishes streams flowing through roadless areas, including the Middle and North Forks of the Feather River, Deer Creek, Mill Creek, Nelson Creek, and Chipps Creek on Plumas and Lassen National Forests. Trout have survived in these waters because they are relatively clean and cold, unpolluted by sediment from roads. I am concerned about the potential damage to these fisheries and increased fire risk that will result from new road construction if the roadless rule is repealed.
The Plumas National Forest (PNF), near where I live, already has a huge network of 3854 miles of roads. This comes out to approximately 2 miles of road per every square mile of national forest land. Over 380,000 miles of roads have already been built on national forests land across the country. The Forest Service has not been able to maintain this existing road network due to inadequate appropriations (Forest Service appropriations cover less than 10% of annual road maintenance needs). The problem has only gotten worse with recent staff cuts. The maintenance backlog for the existing Forest Service road network is estimated at over $6 billion. More road construction will swell this backlog. The Forest Service does not have the staff and funding to maintain the current road network; the idea that they will be able to maintain an even larger network is ridiculous.
Over 80 percent of wildfires are human-caused, and Forest Service research shows that human-caused fires are three times more likely adjacent to roads than in roadless lands. So increasing human access by road would increase, not reduce, fires. The Roadless Rule allows hazardous fuel reduction projects, which have been conducted on millions of acres in roadless areas, so repealing the rule would not improve fuel management. The rule also does not prevent wildfire suppression. So the claim that rescinding the rule would improve fuel hazard management and fire suppression is a fabrication. The roadless rule as written already provides the necessary management flexibility for these areas, while reducing the risk of severe wildfires that increases with the presence of roads.
Roads have numerous other negative effects. One of the most important is sedimentation of streams, which smothers fish and eggs, warms water which deprives trout and salmon of oxygen, and pollutes drinking water. This problem gets worse when roads can’t be maintained. This will increase if even more roads are built and added to the maintenance backlog.
Maintaining areas as roadless means less worry for forest managers about fires in these areas, so that they can concentrate their efforts on the wildland-urban interface, where fuel reduction is most important. Elimination of the Roadless Rule would worsen forest, stream and watershed management. Please retain the existing rule.
I was a USFS forester in timber management on the Plumas NF and Ouachita NF culminating my forest management career of 31 years as a Forest Measurements Specialist (Mensurationist) for SE US for Region 8. Timber planning cooperated extensively with engineering for road development and maintenance. Heavy road building in years past put a difficult burden for road maintenance backlogs that affected our ability to plan for future timber removals without significant monetary mitigation needs to protect downstream water values. In fact engineering routinely did not get adequate funding to maintain the roads that existed from previous sales year in to year out. Rescinding the Roadless Rule will simply exacerbate this dilemma likely leading to more downstream erosion if the Rule elimination leads to even more road building on even more extreme rocky steeper terrain.
The areas that were inventoried and designated as part of the Roadless Rule are typically areas with higher recreational values (scenic and hiking), water quality headwater needs, and wildlife values very difficult or rocky terrains than a significantly identified timber resource value or the remote possibility that there are valuable mineral resources to mine.
Sec Rollins has often said she wants to return the decision-making back to the "land managers". These Roadless Areas, contrary to what she has said, were actually identified by the actual land managers (Forest Supervisors and District Rangers), and their specialists such as timber specialists, biologist, hydrologist, soil scientists and planners that actually worked and lived in the villages and towns that they served not some distant planners at a Regional or DC headquarters. We involved our communities in the discussions and the planning just like we did in developing individual timber sales. A majority of our publics were strongly in favor of a light touch or no touch conservation approach for these set asides.
I'd also warn that creating more access to extreme terrains by rescinding the Roadless Rule is likely to make for more man made fire ignitions in places you don't want to send firefighters into. Fires in those terrains are more erratic and endanger their lives. You've already lost 5 lives this year.
In regards to the Tongass NF. I do not know all that went into their effort for their Roadless area but I know 2 significant elements on the Tongass. They have an enormously unique ecosystem in the temperate rainforest throughout the designated Roadless area. You simply cannot find that any where else in the US. It includes enormous water resources for wildlife and downstream users. My friends that used to work there would tell me how they worked very closely with the native tribes to manage the resources for their communities as part of the unique ecosystem. My fear is that Sec Rollins and our current FS Chief have designs on doing industrial clearcut logging. That would be ruinous and moving ahead with such a plan without concurrence from their publics, the tribes in particular, will likely result in endless lawsuits.
Thank you for your time.
Secretary Brooke Rollins
Acting Director of Ecosystem Management Coordination Joshua White
US Department of Agriculture
Docket ID: RIN 0596-AD66
Title: Keep 2001 Roadless Rule Intact
Dear Secretary and Chief:
As a resident whose property is adjacent to the Plumas National Forest, there are two grave dangers to rescinding the 2001 Roadless Rule that will directly impact me. First, increasing the number of roads in the forest will only increase our already extremely high fire risk. The second is that increasing the number of roads in an already highly fragmented landscape will result in more negative impacts on nearby plant and animal communities that contribute to ecosystem integrity that already suffers from issues related to roads.
It is incorrect that building additional roads in this area will reduce wildfire risk. The Plumas National Forest contains over 4,500 miles of roads. That means, in our little corner of the world, with a population of only about 20,000 people there are enough roads to drive from San Francisco to New York and halfway back again. Nevertheless, the 2021 Dixie Fire burned nearly one million acres despite the presence of these roads. More roads are obviously not the answer.
Most forest fires are human-caused, and very often they are started along the side of a U.S. Forest Service Road. The 2017 Minerva and associated fires on Plumas National Forest were started by an arsonist driving around on USFS Roads. I would not want to experience the results of an arsonist driving up to Grizzly Peak Inventoried Roadless Area only 8 miles from our property.
More roads mean a more highly fragmented forest with the consequent increase in threats to plant and animal species, including nesting songbirds, goshawk, and mule deer. These impacts include noise, dust, physical disturbance by humans and their pets, encroachment of invasive species, impaired water quality, erosion, and increased risk of fire.
In addition to these concerns, increasing the number of roads will only widen the scope of resource extraction on our forest and contribute to climate change.
Rescinding the 2001 Roadless Rule will increase the risk of forest fires on Plumas National Forest, increase impacts of forest fragmentation, facilitate an increase in mining and logging on the forest, and contribute to climate change. Our public lands within the 2001 Roadless Area designation are invaluable and must be protected. Please maintain the nationwide protections of the 2001 Roadless Rule.
Opposes rescissionA1 strongSubstance 10/24Owed an answerSep 7, 2026FS-2025-0001-323719
PLACESTANDDOCGAPEVIDASKALTLAW
I am submitting this comment in opposition to the Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule.
I am a graduate student in the Rangeland, Wildlife, and Fisheries Management program at Texas A&M University, studying plant ecology and restoration. I've also spent a fair amount of time in national forests as a backpacker and climber, including trips through the Sawtooth National Forest and Plumas National Forest, and I've seen firsthand how much of the ecological function and character of these places depends on the fact that they remain unroaded.
Several points from the proposed rule and its own supporting documents concern me directly:
The wildfire rationale doesn't match the mechanism. The 2001 Rule already permits timber cutting to reduce fuel loads and restore ecosystem structure where doing so maintains roadless character (36 CFR 294.13(b)(1)), and it allows emergency road construction to protect public health and safety during imminent wildfire threats (36 CFR 294.12). What the rule actually restricts is new permanent roads and commercial-scale timber harvest — not the fuel treatments cited as the justification for rescission. If active-management capacity has been limited, that points to budget and staffing constraints (the Department's own analysis cites a $6.9 billion road maintenance backlog), not a regulatory barrier.
Roads themselves can elevate fire risk. Independent research, including a 2026 study in Fire Ecology, has found substantially higher ignition density near roads. Opening these areas to new road construction could work against the stated wildfire-reduction goal rather than support it.
Watershed and wildlife values. These 58.5 million acres are some of the last large, connected blocks of intact habitat and clean-water source areas remaining in the National Forest System. Fragmenting them with roads has well-documented consequences for water quality and species connectivity that the draft EIS should weigh more heavily against the comparatively modest projected timber and revenue gains (an estimated $5–11 million per year system-wide).
Recreation. Inventoried roadless areas carry an outsized share of the backcountry trail and climbing access in the National Forest System. The draft EIS itself estimates roughly $6.1 million per year in lost recreation-economy value from the rescission — a cost borne by hikers, hunters, anglers, and the outfitting businesses that depend on these places staying wild.
Tribal consultation. USDA's own Tribal Input Received summary documents that the majority of Tribes consulted oppose this rescission and have raised serious concerns that consultation has not met government-to-government standards. That opposition, from the Department's own record, deserves far more weight than the current timeline allows.
I urge USDA to withdraw this proposal and retain the 2001 Roadless Rule (the "No Action" alternative), or at minimum to substantially extend the review process to fully address the concerns raised by Tribal governments and the public.
Thank you for considering my comment.
Zack Shelley. Auburn, California
Dear US Department of Agriculture, this is Mike Pease and I run a fly fishing guide business in the Plumas National Forest. I have been fishing and hiking in this area for over 60 years, and my business depends on the health of the fisheries.
The 2001 Roadless Rule is important for maintaining the health of the Middle Fork of the Feather River since opening up these areas to road construction would trigger severe soil erosion, alter natural runoff and degrade critical native trout habitats.
I ask you to please keep the Roadless Rule intact for the sake of many generations of anglers to come.
Sincerely,
Mike Pease
Mike Pease Adventures Fly Fishing
I am writing to express my opposition to rescinding the Roadless Rule. This rule has been in effect since 2001, and has been effective in preventing large swaths of PUBLIC land from being fractured and splintered by mazes of road that disrupt wildlife, devastate riparian and forest ecology. The one and only purpose to rescinding this rule is to open more areas of our splendid National Forest to extraction and profiteering. We already have ample areas designated to these industries. We must preserve our lands for our children and their children, the wildlife who call it home, the simple beauty of unspoiled landscapes. I am fully aware many people do not find value in these things, but it is YOUR job as stewards of our PUBLIC lands to ensure they are protected. This rule has been overwhelming supported by the public since it's inception nearly 25 years ago. By rescinding this rule, you are flagrantly failing to do your job to protect America's heritage. And may I remind you: once roads are created, they require maintenance, which costs money; a lot of it. What transpires is that all the trees cut to make the road in the first place, do not regenerate quickly. An unmaintained road quickly is overrun by secondary shrubs, which choke out tree growth, creating the perfect condition for fast burning wildfires. Our forests are already at tremendous risk for devastating wildfires. I don't need to tell you about the mammoth costs of suppression. Our forests are not healthy, and face an already uncertain future. By implementing large scale destruction of roadless areas you are literally throwing gasoline on a fire. It is time for the Forest Service to do the job it is supposed to do: Protect our forests . Sit down with the Public and tribes and reach sustainable solutions.Rescinding the Roadless Rule is literally letting the fox run wild in the chicken coop, resulting in short term profits ending in serious long term consequences. The Roadless Rule is doing the job it was designed to do. Leave it in place. I stand in complete opposition to rescinding the Roadless Rule. I have lived near Plumas National Forest in Northeastern California for over 50 years, and have seen first hand the benefit of the Roadless Rule.
Opposes rescissionA3 weakSubstance 12/24Owed an answerAug 23, 2026FS-2025-0001-259669
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Dear Forest Service Leadership:
As someone whose climate-attention is sustained and whose source materials are federal rather than partisan, I write to register opposition to the proposed rescission of a Rule the record establishes as a contributing instrument to forest-carbon retention and wild fire suppression.
I am a Biology teacher of 29 years, with an emphasis on Ecology. I am also the daughter of a mother who has had to evacuate her Plumas Forest home 3 times.
One occasion in particular illustrates what that relationship means in practice.
The wonder of a roadless forest was witnessed by my mother and I as we hiked into the back country around Bucks Lake and observed a Bald Eagle consuming a salmon that it had taken from the nearby creek. The peace and solitude of a roadless area gave this moment an unmatched solemnity.
The combination of long association and specific experience set out above is directly within the range of interests the Rule was designed to protect.
Regarding the Bucks Lake in the Plumas National Forest, California:
In the Bucks Lake Inventoried Roadless Area, Plumas National Forest, California Spotted Owl (Strix occidentalis occidentalis, T2,) faces documented threat from 7.1 - Fire & fire suppression at Serious - moderate severity across Pervasive - large scope.
The roadless character of Bucks Lake currently prevents the infrastructure penetration that initiates 7.1 - Fire & fire suppression. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for California Spotted Owl.
Analysis of 7.1 - Fire & fire suppression effects on California Spotted Owl (Strix occidentalis occidentalis) in Bucks Lake must reference the species' T2 conservation status and the documented Serious - moderate severity. The DEIS lacks scientific integrity without this baseline data.
"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
“A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Research - Fire Safety”
“Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Research - Fire Safety”
“Comprehensive assessment of the conservation value of all 240,000 km² of Inventoried Roadless Areas. The study finds IRAs would expand the U.S. protected-area system by 27% while disproportionately buffering its largest cores: adjacent IRAs add +29% to Greater Yellowstone, +38% to Central Idaho, +32% to the Bob Marshall, and +31% to the North Cascades. 96% of IRAs are wilder than the median of the contiguous U.S.; 93% lie within 10 km of an existing protected area, providing critical connectivity for climate-driven range shifts. 58% of the watersheds intersecting National Forest System lands supply drinking water to over 48 million people, and adding IRAs to the protected network would increase well-protected drinking-water watersheds by 60%. 74% of all Forest Service wilderness designated since 2000 was first an IRA — the rule is the proven pipeline for permanent congressional protection. The authors warn that because IRAs are an administrative designation, they remain vulnerable to degazettement. — Research - Conservation Value”
The interests of roadless area conservation, sound administrative practice, and the integrity of the rulemaking record are best served by the Department's decision to keep the 2001 Rule in place.
Very truly yours,
Michele Naber, MAT
CommentID: RLC-20260823-V937VI
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