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Dear USFS, I'm asking you to reconsider rescission of the Roadless Rule. I am a hiker and researcher who spends a great deal of time in wilderness. In areas where there are roads, the character of the forest is completely different and cannot be studied in the same way as areas that have not been trammeled by humans. I also lost my home in the 2020 Castle Fire, and so I speak as someone well aware of fire and the effects on the landscape. I witnessed first hand how the wind-driven fires simply blew through areas with roads that were supposed to act as fire breaks. Sequoia National Forest is already overrun by grazing (cows are squashing brand new sequoia seedlings that came up post-fire) and logging. There is so little intact forest left, especially old growth, and these areas need to be left alone. Rescission would harm me by further disabling my ability to do research and documentation as well as personal enjoyment. I am deeply connected to the sequoias, especially the more remote groves, and implore you to keep these few remaining areas wild. Thank you, Kim Dicso

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests where I hike are not abstract. I go to Ocala National Forest to see pristine wild landscapes, and when I visit family in California we hike in Sequoia National Forest to breathe clean air. These are not amenities. We live in an ecosystem, and the lands inside it should be preserved for the long-term survival of our children and our nation. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly that, and I oppose it. The Ocala sits directly on top of the Floridan Aquifer. Alexander Springs, a first-magnitude spring in the heart of the forest, pumps 80 million gallons of crystal-clear water per day through karst limestone that makes any road construction a direct contamination pathway to the drinking water supply of central Florida. The forest holds 4,855 acres across 2 inventoried roadless areas. Red-cockaded woodpeckers recovered here from 7 breeding pairs to 98 family groups because the longleaf pine stands they need have never been fragmented by roads, and Florida scrub-jays, found nowhere else on the planet, depend on the surrounding scrub. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The scale of what this rescission puts at risk is not speculative; the agency's own inventory makes it legible. On wildfire, the proposal justifies rescission in part on fuels management grounds, yet the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency explain why this proposal departs from that prior finding, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. This response is even more timely, given the increased fire frequency driven by climate change induced drought. On economics, the proposal also relies on timber and employment benefits, but 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." The same record 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, with a net present value spanning -$92 million to +$199 million, while the existing road system already carries a $6.9 billion maintenance backlog. How does an action whose own cost-benefit analysis cannot establish a net benefit justify expanding that backlog? On the state-by-state approach, the proposal argues that local decision-making can substitute for a national rule, yet the record shows the agency itself once stated: "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 must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. Finally, on statutory authority, the proposal questions whether the 2001 rule exceeded the agency's legal power. The reviewing court answered that question: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must explain, with specificity, the legal basis for any contrary position before proceeding further. Cyrene Schweitzer Plantation, FL

I am a conservationist, multi-state, multi-generational landowner, Master Naturalist, and former Georgia Native Plant Society President and wish to present my objection to the consideration of removing the 2001 Roadless Area Conservation Rule that has stood firm across multiple circuits and implemented by both parties. Protecting the biodiversity of these pristine areas is paramount to me as a voting citizen whose parents taught me to love, respect, respect science, and cherish our land and wild places and the value in education. I strongly oppose rescinding the Roadless Rule in its entirety based as wildfire protection. I am well aware that fire suppression has degraded fire-dependent ecosystems. A century of aggressive fire suppression — made possible by road access — has transformed fire-adapted forests like longleaf and ponderosa pine. This is why we are planting long leaf and potentially Montane Long Leaf on our farms once we have completed our controlled burns and invasive removals. We understand that without periodic low-intensity fire, fuels will accumulate as they have most recently with Helene and forest structure shifts toward conditions that support catastrophic, stand-replacing fires (USDA Forest Service 2001). — USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf) We are well aware that fire suppression has degraded fire-dependent ecosystems. A century of aggressive fire suppression — made possible by road access — has transformed fire-adapted forests like longleaf and ponderosa pine. This is why we are planting long leaf and potentially Montane Long Leaf on our farms once we have completed our controlled burns and invasive removals. We understand that without periodic low-intensity fire, fuels will accumulate as they have most recently with Helene and forest structure shifts toward conditions that support catastrophic, stand-replacing fires (USDA Forest Service 2001). — USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf). We have personally experienced that roads are where most wildfires start. A 2026 study covering 30 years of wildfire data across the entire National Forest System found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied (Aplet et al. 2026). — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2). Most ignitions near roads are also human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2). Best practices we personally witnessed in the Sequoia National Forest is done by workers using manual tools to collect and create burn pyramids to be left in tack until winter when conditions are right for controlled burns. We do not need to introduce roads which are proven to result in soil quality reduction to forest edges; introduction of invasive species and diseases to all areas through use of skid steers and other logging equipment; increased sedimentation in streams and rivers polluting water quality and impacting all aquatic lifeforms but also natural aquifers from which humans draw their drinking water; they create barriers to aquatic and terrestrial movement, increase potential for landslides and disturbances to forest roots and slope stability; introduction of cattle and other agricultural animals will lead to soil erosion, disease, invasive plant expansion and much more I can expand upon. Road construction in roadless areas is the primary cause of ecosystem destruction and endangering wildlife. For these reasons, in addition to the aesthetic loss of our national treasures, we vehemently oppose rescinding the Roadless Rule. Facilitating energy, mineral, and timber production “to the maximum possible extent” on public lands will cost our nation far more in ecological desecration than will be compensated by short-term revenues they generate. Now that the Endangered Species Act no longer defines what is "harmful", we absolutely must protect the habitats of our biodiverse habitats in our public spaces. Wildfires are without doubt attributed to roads and public interaction with our wilderness spaces. I urge you to support H.R. 3930, the Roadless Area Conservation Act, to provide lasting protection for inventoried roadless areas within our treasured National Forest System. With hope, Melanie Pollard

No to the Roadless Rule rollback. By opening these areas, we have little way to protect the Natural environment and habitats that will be greatly affected negatively. Species will loose their native habitat and possibly become extinct- down to the smallest critters necessary to promote forest health. Another major issue is Forest fires. My family and I live inside the Sequoia National Forest. On a yearly basis we see what human traffic does to our forests. Careless and accidental fires threaten the our home every year. I hear arguments for opening these roads using the excuse that firefighters will be able to access the fires quicker. I beg to differ. First, our Fire crews are understaffed due to Trumps firings. We currently don't even have the manpower to fight the fires, dig fire lines, etc...with roads being open there now adds the problem of additional people to evacuate. We will need more first responders which are not readily available in rural areas- I doubt that has been considered. Maintenance, who will maintain these roads- again, they were fired and the Forest Service hasn't restaffed. In our particular areas we sit on the Kern and Tulare county line, rarely do we see Forest service patrolling this area. They close the State campgrounds but people still camp there leaving massive, I mean tremendous amounts of garbage, leftover food, human waste. All this adds up and it doesn't just go away- it floats downstream, it is carried off by birds, dropped wherever. Ingested and potentially poisonous. There are many more reasons these roads need remain closed. The future of our protected forests needs to be sustained by keeping human traffic regulated and from many areas restricted. With my utmost hope for our Country's future.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Roadless Rule has protected millions of acres of backcountry that I depend on. I live near Sequoia National Forest and have backpacked and hiked extensively in Inyo National Forest as well as national forests in Washington, Oregon, Montana, Wyoming, and New Mexico. What draws me to these places is old growth forest and relatively untouched ecosystems. I do not enjoy hiking or camping in clear-cut forests or in areas easily accessible to motorized vehicles, and the Roadless Rule is precisely what keeps those areas from becoming the latter. The agency's own record undermines its wildfire rationale for this rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency is offering wildfire management as a justification for opening roadless areas, it must explain how that argument survives its own findings. I ask that the agency explain why this proposal departs from those prior findings and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is similarly thin. The agency's own record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that backdrop, the Forest Service is already $6.9 billion behind on maintaining the roads it has, operating on a road budget of roughly $73 million a year. It seems like a great waste of taxpayer money to build new roads into country that has none. I am strongly opposed to my taxes being used to build roads that have no benefit to anyone but timber companies. The agency's own Cost Benefit Analysis 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. How does an action whose own analysis cannot establish a net benefit justify expanding a road system already carrying that maintenance backlog? The agency must answer that question with specificity before this rule moves forward. The regulatory flexibility analysis contains a related problem. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading projected losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Finally, the proposal itself 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. This comment is one such interest. I have organized my recreational life around public lands protected by the Roadless Rule, choosing where to hike and backpack based on the understanding that those places would not be opened to roads and extractive industry. An agency that invites statements of reliance and then accounts for none of them in its analysis has not discharged its obligations when changing course. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. I am extremely disappointed that despite broad public support for keeping the Roadless Rule, the USDA has continued efforts to repeal it. This is clearly not what the American people want or feel is in their best interest. The agency should explain on the record why it is placing the preferences of extractive industries above those of the public it is charged with serving. Sincerely, Jessica Henning Visalia, CA

As a California resident living near the Sequoia National Forest, I strongly oppose rescinding the Roadless Rule. Allowing road‑building, logging, and development in Inventoried Roadless Areas would cause widespread and irreversible harm to some of the most intact public lands remaining in the National Forest system. Rescinding the Roadless Rule would: • Remove protections from 45 million acres of the wildest, most intact National Forest lands, including millions of acres across the West. These areas represent some of the last large, connected landscapes still functioning under natural ecological processes. • Open currently protected Roadless Areas to road construction, development, and commercial logging. These activities would fundamentally change the character and ecological integrity of places that have remained largely undisturbed for decades. • Increase wildfire risk in backcountry forests. Roadless areas are naturally more fire‑resilient and less prone to human‑caused ignitions. Studies show fires are four times more likely to start near roads than in roadless forests, and logging can further elevate fire hazards by increasing fuel loads and drying out forest conditions. • Threaten clean drinking water sources. Roadless areas protect critical watersheds relied upon by millions of people. Expanding road networks and logging would increase sedimentation, degrade water quality, and undermine the natural filtration these forests provide. • Degrade habitat for sensitive species and fragment resilient ecosystems. Roadless areas contain some of the best remaining habitat in the National Forest system—places still shaped by natural processes that wildlife evolved with. Opening them to development would create more fragmented, degraded habitat at a time when intact ecosystems are already scarce. • Harm Indigenous cultural values and access to traditional foods, fiber, and medicines. According to the draft EIS, most Tribal governments consulted expressed opposition to rescinding the rule. • Increase taxpayer burden. The National Forest road system already faces a $6.9 billion deferred maintenance backlog. The Forest Service does not have the staff or funding to maintain existing roads, and adding more would only deepen this backlog and strain limited resources. • Disregard longstanding public sentiment. The original Roadless Rule received over a million supportive public comments—one of the largest responses to any federal administrative proposal at the time. More recent comment periods have shown overwhelming support for keeping these protections in place. For communities like mine near a national forest, roadless areas are essential for clean water, wildlife habitat, climate resilience, and the quiet, undeveloped character that defines our landscape in America. I urge the Forest Service to retain the Roadless Rule and continue protecting these irreplaceable landscapes.

I would like to express my disagreement and disappointment with the U.S. Forest Service proposed rule to rescind in its entirety the National 2001 Roadless Area Conservation Rule. My family and I are avid nature lovers. We would rather be outside than inside. We prefer to experience the wonders of our nation's outdoors in their natural surroundings. We walk, hike, backpack and camp using Leave No Trace ethics. We admire the changes in nature during the 4 seasons: the new life of Spring, the active growth of Summer, the preparations of Fall, the resting time of Winter. I remember seeing more than 2 dozen varieties of wildflowers blooming during the last week of March on a Spring Break camping trip in Hoosier National Forest, IN. During a Summer backpacking trip in Superior National Forest, MN, I watched the emergence of a dragonfly crawling out from its final stage and making its way to a rock, where it rested and dried itself in the sunshine, gaining strength to fly away. Having grown up in the Chicago Metro area, my first trip to Shawnee National Forest in downstate IL was a wonderful awakening to the fact that Illinois is not made up of just farmland and cities...Downstate IL is Forest! My family has traveled throughout all 50 United States. From White Mountain National Forest, NH, across to Sequoia National Forest, CA, up to Chugach National Forest, AK, over to the Forest Reserves of Hawaii, and many forests in between, our National Forests provide us with un-surpassing beauty, solitude, diversity, and peace. The busy National Parks are crowded with tourists visiting the wonders of our country. Many National Forests border these Parks, providing undisturbed habitat and access to the land. Our children, grandchildren, and future generations deserve the opportunity to seek out the amazing wonders of our unique natural spaces in solitude and peace. My husband and I recently spent time camping and hiking in our nation's first National Forest, Gila NF, NM. The strip mining area outside Silver City, NM, is an ugly example of what happens when the forest and land are destroyed. Opening up NF land to the possibility of new roads being built and private business taking over is not in our nation's best interest. We have an unknown number of species that have not yet been discovered and cataloged. Their survival depends on unique characteristics and habitats found only in the small amount of pristine, untouched, old growth forests we have left. When their habitats are destroyed, species we have never observed will be gone from Earth forever. We can't get them back. Please do not rescind the National 2001 Roadless Area Conservation Rule. Thank you

RE: Support for Rescission of the Roadless Rule, Docket FS-2025-0001, RIN: 0596-AD66 Dear U.S. Forest Service: As an OHV enthusiast and public-land recreationist, I strongly support rescission of the 2001 Roadless Area Conservation Rule. As a avid user of the Sequoia National Forest for recreational motorcycle riding with my family, I support returning management decisions for inventoried roadless areas to local Forest Service officials who can evaluate actual forest conditions, wildfire risk, community needs, recreation demand, and environmental resources through forest-level planning. As a member of the Stewards of the Sequoia’s and a participant in trail maintenance I strongly believe recession can restore important tools for hazardous-fuels treatment, vegetation management, habitat restoration, wildfire response, and responsible public access. Roads and trails also provide critical access for firefighters, OHV recreation, camping, hunting, fishing, families, older Americans, and people with disabilities. Importantly, rescission does not mandate road construction or timber harvest. Future projects remain subject to applicable forest plans and environmental laws. Rescission simply removes an additional nationwide prohibition and returns these decisions to appropriate local planning. I urge the Forest Service to finalize rescission of the 2001 Roadless Rule and direct all national forest units to immediately re-evaluate land management, travel management, and project-level Plans to restore access routes that have been closed or restricted as a result of the Roadless Rule. Sincerely, Tim Nowak Yorba Linda , CA

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Selma California and frequently visit the Sierra and Sequoia National Forest to hike, camp and backpack. Shut Eye Peak, Kings River, Dinkey Lakes, San Joaquin River and Devils Gulsh are a few of the local areas that will be impacted. Local mountain communities depend on outdoor recreation economies far more than logging at this point. Roads are where fires start. Human-caused ignitions run higher on roaded national forest land, than roadless areas. Human caused ignitions increase in abundance with proximity to roads and road access could increase the number and frequency of wildfires. The Central Sierra has been devastated by recent wild fires. The Forest Service doesn't have the capacity to manage the roads that already exist or to create policy to protect the delicate ecosystems and water sheds that the Roadless Rule currently protects. For the 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 the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, Ann

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. Though I live in the Mojave desert, I care deeply about the health of U.S. National Forests. My family has hiked in Sequoia National Forest many times as well as other National Forests and Parks throughout the U.S. These lands are for all Americans, whether they live near or far, and for both current and future generations. We go there for exploration, wonder, and quiet rest that can only be found far from the hum of modern life. The Roadless Area Conservation Rule protects what little is left of the vast wild beauty that used to cover our country from further habitat fragmentation. Experts agree that roadless areas protect wildlife habitat, biodiversity and migration corridors, help keep invasive species at bay, prevent pollution and soil erosion into streams and boost climate resilience. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13% to 75%, and its own words on wide-ranging mammals like the grizzly, "...have suffered habitat loss and the extirpation or fragmentation of their populations." The agency's own record undermines the wildfire argument being used to justify this action. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency needs to explain, in plain terms, why the proposal departs from that prior finding, and reconcile the rescission with the ignition data in its own draft environmental impact statement, which the record shows far higher fire density on roaded land than inside the affected roadless areas. Clean, fresh water has become more important than ever, especially as droughts have become more widespread across the country. The DEIS shows that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Allowing activities that could greatly befoul watersheds used to obtain municipal water does not make sense. The agency must address on the record how it intends to protect the integrity of drinking water sources if the rule that currently shields them is removed. The economics do not hold up either. Agency record acknowledges that ,"...the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." To me, this indicates we would be destroying what cannot be replaced fully within our lifetimes for very little gain. Against projected timber revenue of $5.2 to $11.4 million a year, the Forest Service's analysis projects recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. This doesn't convey certainty of benefit. Building roads into places where they are neither wanted nor needed by the public, when the government does not maintain the roads it already has, does not make sense. The agency must reconcile this proposal with a cost-benefit analysis that cannot establish a net benefit, while the road maintenance backlog already sits at $6.9 billion. The proposal suggests state-by-state approaches can substitute for a national rule. The agency tried that substitution before and a federal court found it wanting. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the national rule was replaced with a patchwork of state petitions. My understanding of the data is that it does not support elimination of this rule. The Roadless Area Conservation Rule was developed through more than 600 public meetings and drew from the record the agency built over that process. It is what the public asked for and what the public deserves. These unspoiled lands are an inheritance for all Americans, not meant to be exploited by a single generation for money. Words cannot fully describe how old-growth forests call to the spirit and connect us to the land, animals, and people that came before and those who come after. More roads leading to mining and logging would only break that connection. In summary, I find the reasoning for rescinding the 2001 Roadless Area Conservation Rule to be insufficient as well as contradictory to findings. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, Alyse Dannenberg Ridgecrest, CA

As a California resident living near the Sequoia National Forest, I strongly oppose rescinding the Roadless Rule. Allowing road‑building, logging, and development in Inventoried Roadless Areas would cause widespread and irreversible harm to some of the most intact public lands remaining in the National Forest system. Rescinding the Roadless Rule would: • Remove protections from 45 million acres of the wildest, most intact National Forest lands, including millions of acres across the West. These areas represent some of the last large, connected landscapes still functioning under natural ecological processes. • Open currently protected Roadless Areas to road construction, development, and commercial logging. These activities would fundamentally change the character and ecological integrity of places that have remained largely undisturbed for decades. • Increase wildfire risk in backcountry forests. Roadless areas are naturally more fire‑resilient and less prone to human‑caused ignitions. Studies show fires are four times more likely to start near roads than in roadless forests, and logging can further elevate fire hazards by increasing fuel loads and drying out forest conditions. • Threaten clean drinking water sources. Roadless areas protect critical watersheds relied upon by millions of people. Expanding road networks and logging would increase sedimentation, degrade water quality, and undermine the natural filtration these forests provide. • Degrade habitat for sensitive species and fragment resilient ecosystems. Roadless areas contain some of the best remaining habitat in the National Forest system—places still shaped by natural processes that wildlife evolved with. Opening them to development would create more fragmented, degraded habitat at a time when intact ecosystems are already scarce. • Harm Indigenous cultural values and access to traditional foods, fiber, and medicines. According to the draft EIS, most Tribal governments consulted expressed opposition to rescinding the rule. • Increase taxpayer burden. The National Forest road system already faces a $6.9 billion deferred maintenance backlog. The Forest Service does not have the staff or funding to maintain existing roads, and adding more would only deepen this backlog and strain limited resources. • Disregard longstanding public sentiment. The original Roadless Rule received over a million supportive public comments—one of the largest responses to any federal administrative proposal at the time. More recent comment periods have shown overwhelming support for keeping these protections in place. For communities like mine near a national forest, roadless areas are essential for clean water, wildlife habitat, climate resilience, and the quiet, undeveloped character that defines our landscape in America. I urge the Forest Service to retain the Roadless Rule and continue protecting these irreplaceable landscapes.

To the USDA and Forest Service, I am writing as a concerned citizen, a resident of a community east and downstream of the Washington & Jefferson National Forest, a former resident of Mount Hood National Forest, and as a parent who loves hiking, camping, and creating memories in the wild areas of National Forests across the U.S. with my children. I urge you to maintain the Roadless Rule. Rescinding it is not only environmentally damaging but also fiscally irresponsible. My opposition is rooted in personal experience with the devastating economic and human costs of road-facilitated disasters, infrastructure neglect, and the loss of the wild spaces that define our quality of life. 1. The Economic Impact of Human-Caused Fires I have personally witnessed the scars of human-caused wildfires in National Forests. In 2015, I drove through Yellowstone and saw the lingering damage from the 1988 North Fork Fire that started near a road inside the adjacent Targhee National Forest and destroyed over 400,000 acres. Even 25 years later, the area was a monoculture of lodgepole pines rather than a resilient ecosystem. The logger that started the fire by tossing a lit cigarette, only had access because logging roads allowed him into vulnerable, drought-stricken stands. Without those roads, that ignition would have been impossible. Roads invite human presence into deep wilderness, exponentially increasing ignition risk. The problem is only getting worse, and the economic toll is staggering: - The 2020 Creek Fire (Sequoia NF, CA): Sparked by an overheating vehicle catalytic converter on a roadside, this fire burned 380,000 acres and cost $193 million to suppress, destroying 63 homes. - The 2026 Oregon Wildfire Season: Record-breaking suppression costs reached an all-time high of $1.4 billion statewide. Localized blazes near Mount Hood, such as the 94,000-acre Grasshopper Fire, destroyed 8 homes and 25 minor structures, heavily disrupting the regional recreation economy. 2. Personal Impact on Mount Hood Communities I owned a cabin on Mount Hood and personally felt the fear communities experience when forest fires threaten their homes. I saw our local businesses suffer as tourists stayed away. But it’s not just fires that drive tourists away; it’s also the polluted rivers caused by road runoff and the fragmented, clear-cut landscapes that replace our wild forests. These factors directly harm the recreational tourism that drives the local economy and supports rural livelihoods. The Mount Hood NF and the broader Columbia River Gorge region alone normally generates $500–$600 million annually. 3. Water Security and Fiscal Responsibility I have seen rivers that once ran clear turn brown from road runoff. Failed roads & poor drainage are leading sources of sediment and pollution in National Forest waterways. This sedimentation chokes fish spawning beds, threatens food security for communities relying on fish, and destroys the recreational fishing tourism that drives local economies. Furthermore, roadless areas protect 354 municipal watersheds across the US, supplying drinking water to millions and saving communities millions in filtration costs. The community where I lived in the Mount Hood National Forest relies on a community well for drinking water. Rescinding the rule weakens these protections, directly threatening the quality and affordability of my water. As a resident downstream of the Washington & Jefferson National Forest, I also understand how vital intact forest landscapes are for maintaining water quality & flood control for downstream communities. 4. The Forest Service Road Maintenance Backlog There is already an estimated $19.3 billion backlog for the existing 220,000+ National Forest roads. The Forest Service is chronically underfunded & forced to prioritize fire suppression over infrastructure maintenance. Maintaining existing roads costs approximately $3.8 billion annually. I believe it is fiscally irresponsible to build new roads when existing ones are deteriorating. These crumbling roads pose safety risks to my family and the public. In my Mount Hood community, the fire department is all-volunteer. I watched our community burn & saw volunteer firefighters work 24-hour shifts to protect our homes. Poorly maintained roads impede emergency access & increase erosion, complicating recovery efforts. In conclusion, I do not believe more roads should be built when the existing system is failing. I want to ensure my children inherit a legacy of clean water & wild, unfragmented forests, not a multi-billion dollar maintenance backlog. The Roadless Rule is the only thing standing between our children & a future where “wild” is just a memory. Please do not rescind the Roadless Rule.

I strongly oppose the repeal of the Roadless Area Conservation Rule. My name is Melissa and I live in San Mateo, CA. I am a chemist and volunteer with California Search and Rescue, PHS/SPCA Wildlife Care, and MidPeninsula Regional Open Space. My husband and I also own property in South Lake Tahoe and Kennedy Meadows South as well as an inholding in Sequoia National Forest. I see no benefit to increasing the number of roads through our national forest. 90% of wildfires start within 0.5 miles of a road and 88% of them are human-caused. By adding more roads we are likely to increase the risk of accidental fires rather than reduce risk. Let's focus instead on maintaining the roads we already have. In 2025 I consulted with Sequoia National Forest regarding roads to my in-holding and was surprised to learn that they were unaware of many of the roads in the area, even those that are clearly mapped by OnX. I have encountered so many forest service roads in Sequoia National Forest and Inyo National forest that are unpassable even with 4WD and high clearance. This significantly inhibits recreation and enjoyment of the area. Let's focus on maintaining the roads we already have and preserve the roadless areas! These areas provide habitat for 1600+ threatened species, provide clean drinking water for 60 million Americans, and store 20% of all carbon in the US National Forests. The national forests are for all Americans and small timber sales are not going to move the needle on the budget. Let's preserve these roadless areas for future generations!!

The roadless rule creates an environment in which in-tact segments of undeveloped land remain so, providing space for recreating, hunting, fishing, and pursuit of other activities in areas with the character of wilderness. These lands are not inaccessible, only they require effort and adventure to do so. Development and fragmentation is the default direction in which our nation moves. Therefore, it takes purposeful restraint to preserve the status quo. This is the essence of conservative governing. We choose to place restraints on government in order to protect, or conserve, a certain way of life and to protect liberties. It stands to reason that such restraints should also be embraced in the course of federal land management. The roadless rule is such a restraint. While proponents of its repeal argue that the rule restricts access to land and resources, it’s needless reversal merely serves to permanently restrict access to a resource which cannot be recovered once lost: the right and ability to enjoy public lands with true wilderness character. Arguments for repeal often stress greater resource management ability, including fire response. While such arguments sound credible and laudable in their face, they are shortsighted at best, and without merit or detrimental at worse. It is well documented that the vast majority of wildfires, around 85% according research by this very agency, are human caused. Upwards of 90% of wildfires occur within 1/2 mile of a road according to other research. One can reasonably conclude that greater road access to public lands will only serve to increase fire danger. Fire response resources are already taxed and insufficient for current needs. The argument of greater access simply does not bear out without much greater depth of analysis. Access to these fires simply is not the factor which leads to the lack of ability to control them. While this commenter agrees with many proponents of the rule’s repeal that aggregate management factors have increased fire risk, the repeal of the roadless rule does not on its own solve this issue, or anywhere near it. However, it does succeed at increasing risk in the short term, with zero guarantee that necessary management changes will follow in suit. As a former wildland firefighter in a remote area of the Sequoia National Forest, I can attest that access is not the factor that leads to out of control wildfires. Rather, overall conditions, both in and out of human control, dictate a fire’s fate. Repeal if the roadless rule does not solve for those within our control. The government bears a significant burden of proof when the consequences are this high, and the proper action until that burden is met, if it can be met at all, is to take no action. The roadless rule should remain in place.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I backpack in many areas of the national forest. My first backpacking trip was in the national forest, and I now backpack with my children in places like Mill Creek, Rincon, Channell, and Greenhorn Creek in the Sequoia National Forest. I want these wild places available for their children and their grandchildren. The memories we create in nature are lasting and build resilience. We need a resilient generation now and later. That is why I oppose rescinding the 2001 Roadless Area Conservation Rule. The agency's own record on fire makes the case against this proposal better than I can. The rule's own supporting analysis 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." If the agency now proposes to open areas like Moses, Slate Mtn., and Dennison Peak to new roads in the name of wildfire management, it owes the public a full explanation of how that position squares with what its own DEIS Table 21 found about fire density on roaded versus unroaded land. I ask that the agency reconcile this proposal with those numbers before it proceeds. I am not interested in allowing more roads for logging, and the agency's own economic record does not make a compelling case that anyone should be. The rule's analysis concedes that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency projects timber revenue to itself of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value that its own Cost Benefit Analysis cannot pin above zero. When we don't have funding to maintain what is already there, how can we afford to build more roads? The Forest Service carries a $6.9 billion maintenance backlog on a road budget of roughly $73 million a year. The agency must explain how opening areas like Chico, Lion Ridge, and Black Mtn. to new roads serves the public interest when its own numbers cannot establish a net benefit. The proposal argues that state-by-state approaches can substitute for a national rule. The record shows that argument was tried before. The agency's own prior rulemaking process acknowledged "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." California alone holds 381 inventoried roadless areas covering 4,389,760 acres, and 1,034 municipal water intakes in the Pacific Southwest region sit in watersheds containing affected roadless areas. Piecemeal state decisions cannot protect values of that scale. The Ninth Circuit already found that local decision-making can incrementally erode nationally significant roadless values, and the court rejected the state-by-state substitute. How does this proposal avoid those same deficiencies? The proposal also suggests the 2001 rule exceeded the agency's authority. That question was litigated. The Tenth Circuit held, exercising jurisdiction under 28 U.S.C. Section 1291, that it would "REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court found the rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must state plainly, on the record, what legal basis it believes supports a contrary position now. My daughter once attended a camp for diabetic children where campers hiked into the national forest, showing them their condition does not define who they are or what they are able to do. I want that available to others. These are the places that do that work. Nature is healing, and I want to keep our public land clean, cared for, and free of further development. I urge the agency to withdraw this proposal. Sincerely, Carrie Kears Visalia, California

I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. Since 2001, the Roadless Rule has contributed to America’s greatness in a variety of ways. From supplying over 120 million people with clean water to protecting lands from wildfires as observed and researched by governmental groups and peer-reviewed studies. In addition, these untouched lands provide countless memories for Americans and non-Americans alike. The Roadless Rule has shown to be a tried-and-true legislative action that not only preserves nature but also provide common ground for all people to gather and protect through various efforts for everyone to enjoy. With that said, I strongly oppose the rescission of the Roadless Rule Millions of people who live in the United States rely on public water systems and most of that water comes from forested lands. The Roadless Rule has been a monumental act which provide millions of Americans with daily fresh drinking water while protecting many habitats and allowing for native plants and species to thrive. Finally, the Roadless Rule has consistently shown that this is a great law for America since the water quality tends to be better and higher when protected within the Roadless Rule areas. As recent as 2020 from the Forest Service, they stated that “a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System.” 2 Since this has come from the Forest Service itself, the reasoning to repeal the Roadless Rule per Secretary Brooke Rollins is incorrect. Further, in a 2025 public comment where 4 former Forest Service Chiefs signed off on a letter that stated, “We remain convinced that repealing the 2001 Rule will not be in the long-term interest of the American people, Forest Service employees, and the communities they serve” 3 These former leaders have overseen and managed the National Forests with extensive knowledge and experience. To dismiss their words and still move forward to remove the Roadless Rules means dismissing the evidence, observations, and experience of Mike Dombeck, Dale Bosworth, Tom Tidwell, and Vicik Christiansen; these 4 stewards who oversaw much of America and know its lands better than most. I highly recommend re-reading their letter and reconsider the removal of the Roadless Rule. Lastly, the Roadless Rule has offered countless adventures and trials throughout my life. Living near the Cleveland National Forest has given me the opportunity to appreciate Southern California in many ways. Being in that forest and hiking through the various areas discovering various creeks and seeing what Southern California really looks like with the diverse plants and animals is a stark contrast to being in the city and seeing absolutely little to no diversity or animals. The ability to be at a place where no one is around is a peace that few are able to enjoy and experience. Of course, going through Sequoia National Forest where I would walk amongst giants is a sight to behold. Once you’re off the road and hike a couple kilometers away, you forget that this is also part of California. This Roadless Rule offers a glimpse into the history of each state and what they used to look like before and gives an opportunity for future generations to also appreciate and conserve these lands. I’ve been to several National Forests and I always make it a point to hike on or through areas where vehicles cannot go in order to experience nature in its untouched form. Cleveland, Sequoia, Lolo, Snoqualmie, Gallatain, and Yellowstone are some of the National Forests I have been to and I can honestly say, that’s America in its rawest form and that’s the shock and awe that a documentary can’t do justice when you see the same scenery in-person. Seeing the power of a waterfall on a screen versus hearing and feeling that power in-person is an incomparable feeling one must experience in a lifetime. I hope to still hike these forests where no roads will run through and I urge the agency to: - Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; - Guarantee that no watersheds will be negatively affected by rescission; - Commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Regards, Quang Thai References: 1. Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538 2. Sean P Healey 2020 Environ. Res. Lett. 15 104023 (2020) Long-term forest health implications of roadlessness 3. https://forestpolicypub.com/wp-content/uploads/2025/09/Chiefs-9-15-25-Comments-to-Roadless-NOI.pdf

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Dispersed camping in the national forests is what I go to these areas for, and I want to be plain about what I stand to lose. The roadless areas of Sequoia National Forest, including Black Mtn. at 15,102 acres, Lion Ridge at 5,265 acres, Greenhorn Creek at 28,226 acres, Slate Mtn. at 12,299 acres, Chico at 39,836 acres, and Mill Creek at 27,643 acres, are places I go to escape. They are also places I photograph, and the wildlife that makes them worth photographing depends on the quiet that roads would end. Roads bring traffic, trash, and people in volumes that these areas were never built to absorb. They scatter wildlife and disrupt the natural ecosystems that give these landscapes their value. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record for Docket FS-2025-0001. The agency frames this proposal partly as a wildfire and fuels management measure. Its own analysis does not support that framing. 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." If the agency now proposes to build roads into inventoried roadless areas as a fire-management tool, it must explain how that squares with its own finding that roaded lands carry a dramatically higher ignition rate, and it must reconcile that departure with the fire-density data in DEIS Table 21. The economic case for rescission is just as weak. The agency's record already acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency's own Cost Benefit Analysis projects timber revenues to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. It cannot establish that this action produces a net benefit. Meanwhile, the Forest Service is already carrying a $6.9 billion road maintenance backlog. Rescinding the rule to add roads to a system the agency cannot currently maintain, in pursuit of commodity outputs that represent a fraction of a percent of national production, is what I mean when I say this opens opportunities for unsustainable corporate greed to take over our public lands. The agency must explain on the record how a proposal whose own analysis fails to demonstrate a net benefit justifies expanding that backlog further. The agency argues that state-by-state approaches can replace a single national rule. That argument has already been tested. The agency's record reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected the state-petition approach that followed. California alone holds 381 inventoried roadless areas totaling 4,389,760 acres, and the Pacific Southwest region, which includes California, has 1,034 municipal water intakes sitting in watersheds containing affected roadless areas. Piecemeal state processes have already proven inadequate to protect values at that scale. The agency must explain how this proposal avoids the legal deficiencies the Ninth Circuit identified when the agency last walked this path. Finally, the agency questions whether the 2001 rule exceeded its statutory authority. A federal appellate court already answered that question. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court found the rule within the authority Congress granted under the Organic Act and MUSYA and held that it did not create de facto wilderness. The agency owes a direct explanation of what legal basis it believes supports a contrary position today. The roadless rule already accounts for management of these forests. Rescinding it does not improve management. It removes a protection that courts have upheld, that the agency's own data shows reduces fire ignition, and that stands between the remote places I value and the damage that roads reliably bring. Sincerely, J Fry Visalia, CA

I'm writing to express my strong opposition to the proposal to rescind the 2001 Roadless Area Conservation Rule across our National Forest System lands. The Roadless rule is vital to both the preservation of ecosystems, as well as to ensuring future generations can enjoy these lands as I have over the years. I urge you to maintain these critical protections. Inventoried roadless areas represent some of the last remaining intact ecosystems in our country. They provide irreplaceable habitats for wildlife, safeguard critical migration corridors, protect old-growth forests, and secure pristine watersheds that supply clean drinking water. Allowing road construction and commercial timber harvesting in these areas risks fracturing these fragile habitats beyond repair at a time when ecological resilience is more critical than ever, and for what? So that a handful of people can profit while citizens lose access? These wild undeveloped areas belong to all Americans. They provide unique opportunities for quiet recreation, backcountry hiking, hunting, fishing, and outdoor heritage that disappear once roads are cut and industrial activities begin. I live near the gateway to the southern Sierra Nevada and deeply value having access to untamed landscapes like the Kings River and Mill Creek roadless areas in the Sequoia National Forest. Further, it is my belief that the generations that come after me should get to enjoy that access as well. We are but stewards of this land. While I understand the critical importance of wildfire mitigation and forest health, rolling back a foundational, nationwide conservation rule is a disproportionate measure. Prohibiting new road construction does not prevent fire management; rather, it ensures that management is done sustainably without permanently damaging the wild character of our public forests. Please protect the integrity of our shared natural heritage, respect the decades of public support for these protections, and reject this proposed rollback. Sincerely, Cyntia Medrano Visalia, CA

The 2001 Roadless Rule should not be rescinded. The purpose of the Roadless Rule was to protect "roadless areas and the clean water, biological diversity, recreational opportunities, wildlife habitat, and other public benefits," (Forest Service 2001). The Forest Service claims that the rule should be repealed for "wildfire management" (Forest Service 2026). However, wildfires commonly ignite along roads, and while there is a need to treat forests in proximity to communities with thinning and prescribed burning to reduce wildfire risk, the Forest Service does not have the budget or resources to complete these activities even in the areas that have roads (Congressional Research Service 2023). It is clear that the true goal of the decision to repeal the Roadless Rule is not to "increase local management flexibility" or "allow for active management" (Forest Service 2026), but instead to abuse valuable natural landscapes for their timber and other resources. The current administration has explicitly stated its intentions to exploit the timber of our beautiful National Forests (Office of the Secretary 2025) and in the announcement of the Roadless Rule rescission, economic opportunity was offered as an important reason (Forest Service 2026). On its face, the rescission is presented to the public as necessary for active wildfire management, but rescinding the rule will remove a defense against clearcutting and mining that will damage ecosystems, water sources, wildlife habitat (Olden et al. 2026), and the fundamental beauty of our National Forests. Repealing the Roadless Rule would be a grave mistake and a huge loss to the American people. It is well known that roads increase the likelihood of ignitions (Aplet 2026), which may lead to more extreme wildfire events. According to Aplet et al. 2026, there is a much higher density of ignitions along roads than in Inventoried Roadless Areas. The Forest Service claims roads are needed to suppress fires (Forest Service 2026), but building roads would open up areas to far more human-caused ignitions, making the wildfire problem they are trying to solve far worse. And to be clear, the forests in the American West have a natural history of fire, which the Forest Service has altered through past management. Intelligent Indigenous burning -- intended to promote certain plants like berries (Lake and Christianson 2020) -- as well as fires ignited by lightning strikes, were important drivers of forest structure, and actually prevented extreme wildfire by consuming fuels on the ground before the forest could become dense (Agee 1993). Over the past hundred years, the Forest Service held a policy of fire suppression, allowing the forest to grow crowded with fuels. Climate change is also leading to hotter, drier, longer summers in the West, drying out the vegetation (Abatzoglou 2016). Adding ignitions to a forest system that has not experienced fire in a century, that has dense vegetation and debris, that has longer and drier summers every year, is simply a recipe for disaster. If the economy is the only value we care about, repealing the Roadless Rule would not even benefit the timber industry because building roads in areas like the Tongass National Forest would be far too expensive compared to the returns from the timber harvest. In 1995, building a road in the Tongass cost $160,000 per mile (Groenig 1995). Ignoring other factors, with inflation that would cost about $350,000 per mile today. This does not consider costs of transporting logs to sawmills, many of which have closed in the last 30 years (Crandall et al. 2025). Repealing the Roadless Rule is not good for the environment, nor is it good for the timber industry. One may ask, if there is no profit in clearcutting roadless areas, why not repeal the Roadless Rule? I would argue that just because logging is not profitable in wilderness does not mean it will never be profitable. The value of wood could increase, new technology could make road building less expensive, and repealing the Roadless Rule would remove a safeguard against short-sighted logging and mining. This is why we need the Roadless Rule, to protect remote areas that provide wildlife habitat, water and air filtration, carbon sequestration, and a host of other services that cannot be measured in dollars, but are essential to our economy and wellbeing. I have listed scientific reasons why the Roadless Rule should not be rescinded, but culturally, the rule should not be rescinded because it preserves American heritage and legacy. Once the wilderness is logged and mined out of existence, it will be gone, never to be enjoyed by future generations. Americans take great pride in the incredible landscapes that we have access to, from the immense trees in the Sequoia National Forest to the dramatic beauty of the Tongass. Rescinding the Roadless Rule, which protects numerous unique landscapes from extractive practices, will be at the cost of Americans’ legacy.

I strongly oppose the proposal to rescind in part or in full the Roadless Area Conservation Rule. I am a landscape photographer and adventurer who visits public lands any chance I get. I see the impacts of human activity with the roads we already have across lands in Inyo National Forest, Los Podres National Forest, Sierra National Forest, Sequoia National Forest, Fishlake National Forest and many others throughout California, Nevada, Utah and beyond. These places are special. I oppose to changing this because more roads will lead to more fires as fires are way more likely to start from human activity near roads than in the wilderness alone. Existing rules already allow for roads in service of fire prevention. The ground disturbance would allow for more invasive species which are a greater fire risk as described in the draft EIS. I’m opposed to allowing commercial logging deeper into wilderness areas when there is plenty of other land already available. It’s unnecessary. The logging activity will disrupt drinking water sources and scar the landscape for short term gains that cause bigger long term losses. The roadless areas can remain roadless and areas can still be logged in a responsible manner. For these and many more reasons, I am opposed to any rescinding of the Roadless Rule in full or in part. Please adopt Alternative 1 (No Action)