Read the comments.

I have worked in and recreated in our national forests most of my life. I spent summers hiking the Blue Ridge Mountains, lived and worked in the Shasta-Trinity National Forest collecting water quality data and the Tahoe National Forest surveying wildlife. Some of that put me in the backcountry for days at a time, hiking into headwater streams and camping miles from any road. I’ve packed in, fished, and photographed wildlife and the night skies. I've talked to other people on the trails that love and treasure these places. That experience is why I’m asking you to oppose any rescission or weakening of the Roadless Rule. The peace and quiet in a roadless area is something you can’t manufacture. Many of us need that at times in our lives. The smell of the trees, the clear, clean air and water and the peace of it all that restores our souls is true recreation. Everybody deserves to experience that. It is our birthright as Americans. Roadless areas are our heritage. Once you road them, you don’t get them back. Now, the cleanest, coldest water I've ever seen came from roadless basins in the Tahoe, California area. But I've also waded streams in the Shasta-Trinity that were so clear I could count the fish at the bottom of plunge pools. I’ve also seen what a road does after a storm, ditches cut, culverts plug, and sediment slugs downstream. That mud smothers spawning gravel and costs downstream communities money to treat. Roadless areas aren’t just scenery. They are the headwaters that fill our rivers and reservoirs. Building roads in these watersheds will impact water quality and fishing which will cost citizens and businesses in treatments and reduced recreation dollars. My survey work showed me, of course, that these areas are source habitat for wildlife. They’re where species that need space and quiet still hold on - native trout, steelhead, salmon, elk, ringtails, mountain lions etc. Roads fragment all that. They bring noise, poaching access, and edge effects that dry out the land, increase temperatures and fire exposure, stress vegetation and animals, fragment habitat and wildlife, and create conditions for invasive species and predators. I’ve seen numerous survey sites where the difference between a roaded and unroaded drainage was like night and day. You can’t replace that with a mitigation plan. Rescinding the Roadless Rule will harm fish and wildlife that need room without roads. And I have lived and worked in fire country. The roadless old growth and unroaded backcountry often burn cooler and patchier. It's pretty obvious that most of the fires, and the worse fires, have been in the roaded areas. More roads don’t suppress fire, they give us more ignition sources and create conditions on the ground ideal for fire via vehicle access and edge effects. If we want to protect communities, we should focus on defensible space and home hardening, not carving new roads into the last quiet places. Finally, I've spent money in nearby communities. The outfitters, guides, fly shops, motels, and cafés in towns drawn and depend on the people who come for the backcountry. Roadless areas are an economic asset. They bring hunters, anglers, hikers, and wildlife watchers. That’s real revenue and real jobs. I've seen what happened in towns like Hayfork, California that depended on logging. The sustainable future for those communities is in continuing to foster recreation opportunities, not more boom-to-bust activity. Rescinding the Roadless Rule is going to harm existing small businesses and leave local populations worse off down the road. So when you consider rescinding the Roadless Rule, please don’t think of it as a map line. Think of the millions of visitors that seek these places out. Think of the clean water they generate for everyone downstream. Think of the fish and wildlife that depend on them. Think of the small towns that rely on people like me. Think of the quiet that took a century to grow. I urge you to oppose any effort to rescind or weaken the Roadless Rule.

Dear Chief Tom Schultz: As an outdoor enthusiast, I respectfully urge the Department to consider that the 2001 Roadless Area Conservation Rule represents a policy conclusion reached after one of the most extensive administrative processes in Forest Service history — and that overturning such a conclusion requires a comparably rigorous administrative basis, which the proposed rescission has not yet provided. I live in and love this area, and I want to be able to continue to visit and bring my children in the future! Trails and bodies of water, like Castle Lake, are precious venues for the public to connect with and appreciate nature. Threatened species, such as the California condor, Monarch Butterfly, Northern spotted owl, and Rufous Hummingbird rely on these lands for habitat. Regarding the Castle Crags A in the Shasta-Trinity National Forest, California: Roadless forests provide undisturbed nesting, stopover, and wintering habitat for migratory birds protected under the Migratory Bird Treaty Act. Roads concentrate nest predators near edges. Predation by edge-following predators — Blue Jays, raccoons, snakes — is concentrated near roads, clearings, and forest edges. Distance to unpaved road was the strongest predictor of nest survival in a study of 463 nests across 17 songbird species. Nest predation, not parasitism, accounts for 75 to 100 percent of nest failures in most studies (DeGregorio et al. 2014; Akresh et al. 2024). — DeGregorio et al., 2014 (https://doi.org/10.1002/ece3.1049); Akresh et al., 2024 (https://doi.org/10.5751/JFO-00481-950212) Rescinding the Roadless Rule would open the Castle Crags A, Shasta-Trinity National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Losing federal protection for roadless areas threatens the very future of those areas. Please act to protect them for future generations.

I vehemently oppose the repeal of the Roadless Area Conservation Rule. As an avid outdoorsman and research ecologist the repeal of the Roadless Rule will directly and dramatically impact the places and wildlife that I care about and study. In my opinion we should be increasing, not decreasing, the protection of the nation's roadless areas from industrial forestry and resource extraction interests. Specifically, very near my home in Mt. Shasta CA, there are several roadless areas where I frequently recreate (hike, backpack, botanize, and trail run) that would lose protection if this short-sighted repeal goes into effect: The Mt. Eddy IRA (7,232 acres); the Mt. Shasta B IRA (2,809 acres); Castle Crags B IRA (1,619 acres); West Girard IRA (37,515 acres); and the East Girard IRA (27,893 acres). The Mount Eddy IRA is of particular personal importance to me: this area includes the Mount Eddy Research Natural Area (RNA) on the Shasta-Trinity National Forest (Cheng, 2004). Within the Roadless Area, the RNA is extremely diverse supporting nearly 300 species of plants, providing critical habitat for 8 California Native Plant Society Listed plant species, and including one of the highest quality and most intact stands of the high-elevation Foxtail Pine (Pinus balfouriana) on Earth. This is a precious and irreplaceable ecosystem. In addition to destroying habitat, repealing the Roadless Rule would negatively impact my community, change its character, threaten our clean water and air, and damage our economy (dominated by tourism-associated recreation a $730 Billion dollar / year industry in the US, far greater than the timber industry). If the Roadless Rule is repealed, the watershed that provides clean water to my town will be exposed to additional resource extraction and degradation and new roads will increase our risk of wildfire, thereby threatening the very existence of our town. Finally, repealing the Roadless Rule will impact all of the citizens of the United States, not only those in my small town. For instance, Roadless Areas provide drinking water to approximately 60 million Americans and development in these watersheds threatens the integrity, safety, and quality of our water. Furthermore, the landscapes protected by the Roadless Rule provide critical habitat for over 1600 threatened species across the country. Please listen to the will of the majority of concerned Americans and preserve the Roadless Area Conservation Rule. Sincerely, Shane Lishawa Citation: Cheng, S., 2004. Forest service research natural areas in California. Gen. Tech. Rep. PSW-GTR-188. Albany, CA: Pacific Southwest Research Station, Forest Service, US Department of Agriculture. 338 p., 188.

Hello. I am an engineer for the energy industry who (in addition to my engineering degree) also holds a degree in Wildlife Biology from a top agriculture University. In addition to my professional credentials, I have also contributed thousands of volunteer hours to the exploration & mapping of caves across the U.S., including those in the Grand Canyon NP, Mammoth Cave NP, Tonto National Forest, & Fern Cave Federal Wildlife Refuge. I have also volunteered as a citizen scientist assisting the collection of microbes caves. Those microbes are studied at top universities by labs focused on novel drug discovery, material science, & carbon sequestration. My recreational interests are extensive -- I cave, rock climb, backpack, day hike, overland/off-road, etc. throughout the United States. In the last 10 years, I have travelled to several dozen National Forests for these activities including the Chattahoochee NF, Bridger-Teton NF, Daniel Boone NF, Monongahela NF, Petrified Forest NF, & Shasta-Trinity NF. While doing so, I strive to shop locally, dine locally, & support the small rural towns. For me, the biggest draw to areas such as this is the remote & unbroken environment. As any wildlife biologist can attest, habitats change dramatically when the continuous forest is interrupted by open space such as those created by roads. Additionally, as any caver can attest, some of the most fragile ecosystems on the planet can be hiding in plain sight (often just under our feet). I am especially concerned about sedimentation caused by building roads & logging in areas that would have otherwise been roadless. Not only can such activities degrade drinking-water supplies on the surface, but it can also destroy underground conduits of water such as those found in karst landscapes. This impact wields a double-edged sword: both the humans & the habitats that are reliant on the underground water supply are jeopardized. This impact isn't limited to a few rural towns or scattered populations, either. Nearly 40% of the drinkable groundwater in the U.S. comes from karst aquifers! Professionally, I am no strange to Federal documentation. I frequently write supporting documents for nuclear power plants that are reviewed by the U.S. Nuclear Regulatory Commission. I draw upon this experience when I review the documentation "supporting" the proposal to rescind the Roadless Rule & I am deeply troubled by the gaps in supporting evidence as well as failures of adequate planning. Below is an example of such: The DEIS does not analyze a reasonable range of alternatives. The USFS states this itself: "The alternatives evaluated in detail in this DEIS focus on the geographic locations (boundaries) in roadless rulemaking" (DEIS p. 34). Alt. 1 retains the 2001 Rule's prohibitions; Alt. 2 removes them nationwide; Alt. 3 "would continue the existing Rule's exceptions and provides for locally led boundary modifications" (DEIS p. 35). No alternative analyzed in detail varies the prohibitions & exceptions themselves according to stated resource criteria. NEPA requires "a reasonable range of alternatives to the proposed agency action... that are technically and economically feasible, and meet the purpose and need of the proposal," 42 U.S.C. Sec. 4332(2)(C)(iii), & the DEIS cites the parallel requirement at 7CFR1b.7(h) on the same page where it describes its own range as boundary-focused. The rest of this comment is attached as a file because the online portal's character limit is preventing the discussion of the matter in full.

As a PCT'19 alumni and wildands advocate, I oppose the repeal of the Roadless Area Conservation Rule. There are 63 roadless areas along 288 miles of the PCT in California, Oregon and Washington. These miles represent roughly 11% of the trail. Roadless areas provide clean drinking water to 60 million Americans. This also provides connected wildlife corridors and undisturbed natural connected ecosytems. These undeveloped lands are critical to our nation’s ecological health.  These areas store 20% of all carbon in U.S. national forests. Roadless areas offer abundant outdoor recreation opportunities such as hiking hunting, fishing, camping and other activities. Every year, millions of people take advantage of the free (or extremely affordable) access to these public lands. The outdoor recreation economy generates $730 billion annually, far more than timber sales. Roadless areas are crucial habitat for 1,600+ threatened species. We already have 370,000 miles of forest roads with a multi-billion dollar maintenance backlog. Studies show wildfire ignitions are 4x more likely near roads than in roadless areas Please keep these roadless areas roadless! Deep Creek IRA—San Bernardino National Forest: On the north slope of the San Bernardino Mountains about 60 miles east of Los Angeles. Starting at 6,200 feet above sea level, the stream through the IRA drops about 3,000 ft through dramatic canyons in its 22-mile course before flowing into the East Fork of the Mojave River. It includes deep pools and hot springs and is a popular spot for day hikers. South Sierra IRA—Inyo National Forest: On the PCT and near the South Fork of the Kern River. San Joaquin IRA—Inyo National Forest: Red’s Meadow is a beloved respite along the PCT and a starting point for horse packers at the Agnew Meadows Pack Station. Dardanelles IRA—Lake Tahoe Basin Management Unit: Nearly the entire PCT from Carson Pass to Echo Summit is in this roadless area. Granite Chief IRA—Lake Tahoe Basin Management Unit: Heading north from Barker Pass, the PCT, and the contiguous Tahoe Rim Trail climb to dramatic ridgelines, yielding dreamlike views of Lake Tahoe amidst red fir and hemlock forests. Further north, the trail enters Granite Chief Wilderness and intersects the Western States Trail. Areas between Granite Chief Wilderness and Donner Pass are within this IRA, jeopardizing views enjoyed by thru-hikers, day hikers, and even skiers who use Olympic Valley, Lake Tahoe’s largest ski park. Mount Eddy IRA—Shasta-Trinity National Forest: Just across the valley from Mount Shasta, Mount Eddy is the tallest peak along the Trinity Divide, and the tallest peak in CA west of I-5. This subrange of the Klamath Mountains features a unique landscape of towering granite spires, lush evergreen forests, and alpine lakes deep in glacier-carved cirques. The area is under the jurisdiction of the U.S. Forest Service and was established as a Research Natural Area (RNA) to study its ecological significance, serving as the headwaters for the North Fork Sacramento River. Grider IRA—Klamath National Forest: This is a popular area for campers and day hikers along the creek, which feeds the Klamath River. Severely burned in the 2014 Happy Camp Complex, the regrowing brush gives way to large stands of surviving trees, and the sound of rushing water is a constant along the trail. The area has already been the subject of a legal fight over logging. Norse Peak IRA—Okanogan-Wenatchee National Forest: Next to Mount Ranier National Park, Sheep Lake is a picturesque alpine lake and a welcome destination for families for swimming, backpacking and camping. The hike to the lake is a gentle, 1.8-mile climb past summer wildflowers and red huckleberry plants in the fall, with great views of the Rainier fork of the American River, Mount Rainier, and Naches Peak. Liberty Bell IRA—Okanogan-Wenatchee National Forest: Some 30 miles of the PCT from Rainy Pass to Harts Pass, including the popular day hike to Cutthroat Pass, are within this large IRA. Situated in the heart of the North Cascades, this area is home to the mighty Methow River, many alpine passes, and some of the highest elevation stretches of the PCT in Washington.

I'm writing to oppose rescinding the Roadless Rule, either in whole or in part. The proposed rule would remove the Roadless Rule’s protections against destructive commercial logging and road building from nearly 45 million acres of forests on public lands that belong to all Americans. Alternative 3 does not offer a meaningful alternative to a full rescission, as it would remove roadless designations from more than 30 million acres of forest. Rescinding the 2001 Roadless Rule would irreparably harm our nation’s most important resources, which your agency under the current administration has started to disrespect and attempt to sell off, privatize, and ruthlessly extract from, all of which are egregious departures from the Forest Service's original intent when the agency was established. Roadless areas experience some of the lowest rates of fire ignition across the national forest system. While many of the USDA’s statements regarding the rule’s rescission have asserted a need to cut roads into these intact forests to prevent wildfires, the latest scientific information effectively dispels that myth. The DEIS itself belies those assertions, finding that fire ignitions are four times more common near roads than in roadless areas; it states that “ignition density is approximately four times greater on other NFS lands compared to potentially affected IRAs and wilderness.” More roads will only heighten wildfire risk. And fuel treatments and forest health initiatives are already taking place across roadless areas. The forests protected by the Roadless Rule play a vital role in sustaining wildlife, providing habitat for 57% of vulnerable terrestrial wildlife. Intact mature and old-growth forests, many of which are protected by roadless areas, serve as essential refuges for wildlife facing mounting pressures from climate change, wildfire, and human development. It is our responsibility to safeguard these species and the forests they call home. Additionally, forests protected by the Roadless Rule provide habitat for many endangered species, protect and promote biodiversity, and provide the conditions many wildlife species need to survive. The biological assessments accompanying the proposed rule identify 327 threatened and endangered species and 71 critical habitats as being likely to be adversely affected by rescinding the Roadless Rule. This is unacceptable. The Roadless Rule protects over 80,000 miles of streams and rivers. Building roads through these currently protected forests would cause diversions of rainwater's natural path across the landscape, cause sediment buildup in streams and rivers, and increase the possibility of landslides and other stability issues caused by runoff. Pollution from road traffic and toxic byproducts accumulate on the road’s surface, further degrading the water quality entering rivers and streams and directly threatening sensitive aquatic life, including native fish species. Additionally, our Roadless forests protect the headwaters of many rivers and streams. At least 25 million Americans rely directly on roadless area-influenced watersheds for their drinking water. Commercial logging, which is a major motivation for rule rescission, directly degrades water quality by increasing sedimentation, turbidity, and nutrient runoff, effectively driving up water treatment costs for millions of customers in downstream municipalities. The only option is to take the No Action alternative and keep the Roadless Rule intact. Further, the outdoor recreation economy brings in more money than commercial logging. One report estimated that the Roadless Area Conservation Rule brings $24 billion dollars of benefits each year across habitat, scenic, and recreation values. Hunting, fishing, and wildlife-watching alone contribute nearly $400 billion to the U.S. economy, while the broader outdoor recreation economy generates over $1.3 trillion annually. A potential 5-10% increase in Forest Service timber production from IRA logging would yield just $5.2-11.4 million of revenue to the federal government. This potential logging revenue would not add to the economic value of these forests. Rather, it would degrade the scenic beauty and other environmental values that drive our recreation economy. I live near many protected roadless areas, including the Shasta-Trinity National Forest, the Lassen NF, and the Klamath mountains. Rescinding the Roadless Rule would negatively impact my love and enjoyment of these lands. I stand for the protection of our roadless areas and the beauty of the American landscape. I oppose rescinding the Roadless Rule and urge the Forest Service to take the No Action alternative.

I strongly oppose rescinding the 2001 Roadless Area Conservation Ruel. As a resident of a remote community surrounded by National Forest System lands, including Shasta-Trinity National Forest, Six Rivers National Forest, and Klamath National Forest, I am deeply concerned about the severe, localized impacts such a sweeping policy change would bring to my local economy and our natural heritage. I urge the USDA and the Forest Service to maintain the 2001 Roadless Rule protections based on the following three points of impact: 1) The Severe Economic Impact on Ecotourism: My rural community depends directly on a thriving outdoor recreation and ecotourism economy. Visitors travel here precisely because these roadless areas offer pristine, unfragmented natural landscapes for hiking, wildlife viewing, and backcountry recreation. Stripping these protections to allow industrial timber harvesting and road building will permanently degrade the visual and environmental integrity of these lands, directly harming local small businesses, guiding services, hospitality, and our municipal tax base. 2) Irreversible Habitat and Wildlife Fragmentation: The preservation of intact, roadless ecosystems is vital for local wildlife conservation. Constructing new roads and introducing commercial logging operations will fragment critical migration corridors, further disrupt fragile habitats, and degrade water quality in local watersheds. Once these pristine areas are developed, the ecological damage to biodiversity cannot simply be reversed. 3) Aggravated Wildfire Risks Near Infrastructure: While the administration cites wildfire defense as a rationale for local thinning, peer-reviewed data consistently shows that roads frequently serve as a primary vector for human-caused wildfire ignitions. Introducing miles of new road infrastructure deeper into our national forests increases, rather than decreases, the long-term wildfire threat to nearby wildland-urban interface (WUI) communities like mine. National forests should be managed to protect local community stability, biological diversity, and sustainable outdoor recreation. Rescinding the 2001 rule contradicts these values and directly threatens my community's livelihood. Please withdraw this proposed rescission and uphold national roadless area protections. Thank you for considering my comments.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Creatures that need protection: bison, wolves, elk, moose, hummingbirds, and even spiders are all part of our natural world and deserve a clean, safe home. I have ridden my bicycle on trails in nearly every state in the country. Our natural places are one of the greatest things we have going for us. They need protecting. Rescinding the 2001 Roadless Area Conservation Rule would threaten both, and I oppose it. The roadless areas I am most concerned about are the South Fork area of 16,786 acres and the Underwood area of 3,046 acres in the Shasta-Trinity National Forest, and the Cow Creek area of 1,271 acres in the Six Rivers National Forest, all in California. 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. These are not abstractions. On wildlife: the DEIS itself documents that habitat fragmentation reduces biodiversity by 13 to 75 percent, that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter. The agency's own words acknowledge that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations." The elk I hope to see in places like South Fork depend on exactly the kind of habitat this rule protects. The agency's own sources found that elk survival rates rose during a road closure and fell again when the gates were removed, and that ideal summer elk habitat is unroaded land with cover and forage. For moose, the DEIS notes they are drawn to road corridors for road salt, increasing human-moose conflict, and the agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter. Building roads into these areas would directly harm the animals I care about. I ask the agency to explain specifically how it reconciles these findings with the proposal to lift protections. The agency's small-business analysis cannot be reconciled with its own cost figures. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, not the outfitters and guides actually holding permits in the affected areas. People who lead bicycle tours and wildlife trips through these forests are exactly the small businesses that would feel this loss first. 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. The agency invited reliance interests and then declined to weigh them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My own riding and my own wildlife watching in these forests are reliance interests. An agency changing course must account for what its prior policy encouraged people to count on. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. The agency's treatment of future plan amendments is internally contradictory. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). Inviting comment on a scenario the agency refuses to analyze is not a substitute for analysis. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred to a later process that commenters cannot yet reach. Finally, the agency's own fire data undermines the proposal's safety rationale. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The trails I ride and the animals I look for do not survive catastrophic fire any better than they survive bulldozers. The agency has not quantified the expected increase in human-caused ignitions that would follow new road access, nor weighed that increase against any claimed reduction in wildfire hazard. That calculation belongs in this record before any final decision is made. Sincerely, Molly Martin Eureka, California

I am writing from Siskiyou County, California, to ask the Forest Service to withdraw its proposal to rescind the 2001 Roadless Area Conservation Rule. My husband and I have driven through California, Oregon, Arizona, Texas, Florida, Nevada, and Colorado to be in our public lands, and nothing has shaped how we see this country more. We live a few miles from the Shasta-Trinity National Forest. Heart Lake, where we take our daughter, is safe inside the Castle Crags Wilderness. The forest around it is not, and that is the forest this rule protects. I am raising a daughter and expecting a son. I want them to walk into a living forest and learn how it works: the water, the animals, the old trees, the whole system running on its own. That is an education no classroom can give, and it cannot be put back once the roads and the clearcuts or partialcuts arrive. The Department says this is about wildfire. But the rule already permits fuel reduction near communities, roads are a leading cause of human-caused ignitions, and the agency has lost roughly a fifth of its staff. Opening 58.5 million acres to roads and logging does not make my family safer. It makes the forests we love easier to take apart. This rule came out of a long public process and still has the public behind it. Please leave it standing, for my children and for everyone's.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My daughter is only 3 years old. I am writing this comment because I want her to inherit these mountains, these rivers, and this country intact, and because the agency proposing to rescind the 2001 Roadless Area Conservation Rule has not held a single public meeting to justify doing so, after the Forest Service held more than 600 public meetings and received 1.6 million comments to write it. I live in Siskiyou County. I live here because I can drive literal minutes to recreate in beautiful wilderness zones that surround my home. The West Girard roadless area in the Shasta-Trinity National Forest covers 37,516 acres, and I have hiked the PCT through that country many times. The Siskiyou roadless area in the Klamath National Forest covers 54,039 acres of mountains and forests that host a vast amount of wildlife. That area may be underrepresented in human population, but it is an important source of life nonetheless. The Castle Crags B area matters both for its geology and wildlife and for its Native American ties. This is not abstract public land to me. This is, as I can only say it, truly my backyard. The wildfire rationale offered to justify this rescission is flatly contradicted by the agency's own findings. The Forest Service's 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 must explain why its current proposal departs from that finding, and must reconcile the rescission with the ignition data in its own draft environmental impact statement at DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. I photograph the plants, animals, and geology of this home zone because I love the richness and diversity here. Roads are not a neutral tool in that landscape. On water: my house gets its water from a well, and I also swim and paddle in the rivers and lakes of this region. It is all interconnected. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. California holds 381 inventoried roadless areas totaling 4,389,760 acres. The agency's own analysis establishes that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. What the proposal does not explain is how adding roads into currently unroaded watersheds that are feeding wells, rivers, and intakes serving this region serves any legitimate public interest. I ask the agency to answer that question directly in the final record. The permitting burden rationale is undercut by the rule itself. The existing rule states it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The agency must identify which specific burdens are not already addressed by those exceptions, including those for community wildfire protection and existing mineral leases, and must quantify those burdens with specificity rather than assertion. In an administration that claims to care about waste and fraud, the small-business certification accompanying this proposal cannot stand without scrutiny. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The agency reached its no-impact conclusion by averaging losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency should withdraw that certification and assess the impact on the firms actually operating here. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is exactly the kind of reliance interest the agency invited. I chose to live in Siskiyou County, to raise my daughter here, and to build my life around access to this country as it is. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it acts. Sincerely, Nicole Dove Mount Shasta, California

Forty years of bass and trout, starting when I was a kid, and two decades of hunting in the Shasta-Trinity National Forest: that is what is at stake for me personally in this proceeding. I also camp at Castle Lake with my family, the same place I first camped with my dad. I am opposing the proposed rescission of the 2001 Roadless Area Conservation Rule. The agency's stated rationale for rescission rests on a forest health argument that its own document undermines. At the section titled Rationale for the Proposed Rule, the agency states: "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Yet the same document cites research finding that the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. The waters I fish and the land I hunt sit within this forest. I need to know how the agency squares its central justification with findings in its own record that point the other way. The agency must reconcile that contradiction before this rule goes any further. The wildlife concern is equally serious. In the section on ESA-Listed Species and Regional Forester Sensitive Species, the agency discloses that its preliminary findings resulted in a “may affect, likely to adversely affect” determination for 327 species and 71 designated critical habitats, yet formal Section 7 consultation with the Fish and Wildlife Service and NOAA Fisheries has not been completed. The trout I have fished for since childhood, the game I hunt, the birds I watch at Castle Lake: all depend on habitat that a final Biological Opinion could evaluate very differently from a preliminary assessment. Finalizing a nationwide rule before that consultation is complete means the public has no way to know whether a jeopardy finding, required mitigation, or alternative measures will be needed. The agency should complete ESA consultation and make the resulting Biological Opinion available before it finalizes anything. These are public lands, supported by public money, and the Shasta-Trinity is part of my life. I expect the agency to provide full, substantive responses to both points above.

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 voter in Anderson, California. I frequently hike, camp, picnic and recreate in the Shasta-Trinity National Forest, the Lassen National Forest, the Six Rivers National Forest, and the Klamath National Forest. I raised my children in these forests, and now as young adults they also frequently recreate there. I am writing to express my strong opposition to the proposal to rescind the nation's landmark roadless rule. This action would open nearly 45 million acres of pristine national forests to road construction, logging, and other development. The consequences of this decision would be far-reaching and devastating for our environment, wildlife, and communities. * Biodiversity: The roadless rule has been instrumental in preserving biodiversity and habitat. These untouched forests provide critical habitat for over 500 imperiled species. * Water Quality: The roadless rule protects millions of acres that serve as the headwaters for major rivers that supply drinking water to more than 60 million people across 33 states. By allowing road construction, we risk introducing significant water pollution to these vital water sources. * Fire Protection: Contrary to the administration's claims, rescinding the roadless rule would actually increase wildfire risk. Scientific studies have shown that wildfires are four times more likely in areas with roads compared to roadless forest tracts. This fact directly contradicts the justification being used to push this harmful proposal forward. My Northern California home area is acutely aware of fire danger: we've lived through massive, devastating wildfires the last several years. Any action that increases fire danger is a direct attack on citizens' lives and property. Top findings from the fire study cited below (Aplet, Hartger, & Dietz): 1. From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1,000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1,000 ha). 2. The highest wildfire-ignition density was in lands within 50 meters of roads (7.99 fires/1,000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1,000 ha). 3. The results show that ignition density is much higher near roads than away from them. Across the National Forest System and in every region examined, the density of wildfire ignitions within 50 meters of a road is higher than in wilderness, Inventoried Roadless Areas, or other national forest lands, often by quite a bit. I implore you to stand against the rescission of the roadless rule. Protect our national forests, endangered species, clean water, and the interests of the millions of Americans who benefit from these pristine wilderness areas. The legacy of our public lands and the health of our environment depend on your action to preserve the roadless rule. Sources/references: U.S. Fish and Wildlife Service, “USFWS Threatened & Endangered Species Active Critical Habitat Report,” Environmental Conservation Online System (ECOS), updated August 7, 2025, accessed April 29, 2026, https://ecos.fws.gov/ecp/report/ table/critical-habitat.html. NOAA Fisheries, “National ESA Critical Habitat Mapper,” updated February 18, 2025, accessed December 8, 2025, https://www.fisheries.noaa.gov/resource/map/national-esa-critical-habitat-mapper U.S. Forest Service, “Water Facts,” https://www.fs.usda.gov/managing-land/national-forestsgrasslands/water-facts. Southern Environmental Law Center, “For Virginians, Roadless Areas Mean Clean Drinking Water,” December 18, 2025, https://www.selc.org/news/for-virginians-roadless-areas-mean-clean-drinking-water; Friends of Shenandoah Mountain, “Water Quality,” accessed March 31, 2026, https://www.friendsofshenandoahmountain.org/water-quality.html U.S. Department of Agriculture Forest Service, “Summary of Public Water Systems and Populations Receiving Surface Drinking Water Supply From National Forest System Land,” GTR WO-100 (September 2022), https://www.fs.usda.gov/ research/publications/gtr/gtr_wo100/GTR-WO-100-Sup1.pdf Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2

Regarding the review of the Roadless Rule established decades ago, I support Alternative 1: The “No Action Alternative." As a citizen who enjoys living in a community surrounded by the Shasta-Trinity National Forest, I feel the nation should keep the Roadless Rule intact and protect our public lands for the benefit of current and future citizens. Keeping the Roadless Rule intact keeps options open for Congress to consider the management of these lands in the future. I understand we need trees for lumber, but locally there is plenty timber from the logging occurring on private timberland. Roadless areas help protect critical upper watersheds for the Trinity, Shasta, and Sacramento Rivers, as well as critical tributaries like Castle Creek. They serve as the ecological backbone of our national forest lands that supplies California’s drinking and irrigation waters. I hike extensively on and off trail in the USFS lands along the Trinity Divide in Siskiyou, Trinity, and Shasta counties. There are small springs and pocket meadows, too many to count, that are critical to providing late summer water for these rivers. Outdoor recreation, including backcountry hiking, backpacking, horseback riding, mountain biking, camping, angling, and hunting, is increasing rapidly on our public lands. Polls show the majority of citizens support strong protections for our collective public lands. Roadless areas shelter imperiled species. Here locally, the roadless areas near the Castle Crags Wilderness have been documented to support two Northern Spotted Owl breeding ranges with annual nesting success. Studies repeatedly show that more roads within our forests means more wildfire risk. Most wildfires are caused by humans and most human-caused fires occur near roads. Additionally, the USFS has hundreds of thousands of mile roads and can't properly maintain the existing road network. Unmaintained roads continue to erode and add sediments to our rivers and stream, degrading water quality. We don't need more poorly maintained roads. The large roadless areas on Mount Eddy in the Shasta-Trinity National Forest need to remain intact. Congress did not include Mount Eddy in the national Wilderness System during the previous rounds of wilderness review due to the numerous private land inholdings within the roadless area. In the past couple of decades, the USFS has been actively acquiring the private land inholdings on Mount Eddy through Land and Conservation Fund purchases and by large land trades with the timberland companies. These lands need to be retained as roadless until Congress can consider them for inclusion in the Wilderness System. Please move forward with the No Action Alternative 1: Keep the Roadless Rule intact.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to adopt the No Action Alternative. I grew up in Weaverville, in Trinity County, California, and took my first backpacking trip into the Trinity Alps at twelve years old. That was more than thirty years ago. I have backpacked, hunted, and fished on public land ever since, and I am raising my children to do the same. The Trinity Alps Wilderness is protected by statute. The country around it is not. The Shasta-Trinity National Forest contains roughly 320,000 acres of inventoried roadless area — steep watersheds and ridges that buffer the Wilderness boundary, hold secure habitat for deer and native trout, and drain into the headwater streams feeding the Trinity River and, through it, the Klamath. Those are among the watersheds that determine whether there is an ocean salmon season on the California coast. The fiscal analysis does not support this action. The agency manages roughly 370,000 miles of road and carries an estimated $10.8 billion deferred maintenance backlog, more than half attributable to roads. The proposed rule projects additional timber industry revenue of approximately $4.6 to $10.6 million per year. Rescission would enable new permanent road miles, each carrying a long-term maintenance obligation, within a system the agency already cannot maintain. The DEIS does not adequately account for that cost. The wildfire rationale is also unsupported. The existing rule already permits hazardous fuels reduction, prescribed fire, and habitat restoration in inventoried roadless areas; it has never barred that work. Recent research found wildfire ignitions roughly four times more likely near roads than in roadless forest, consistent with the fact that most ignitions are human-caused and occur near road access. Building roads to reduce ignition risk is not supported by the record. Public sentiment has not shifted. The 2025 scoping period drew more than 220,000 comments, approximately 99 percent opposed. I am open to targeted, locally informed reform of the Roadless Rule. Rescinding protections across more than 44 million acres in 37 states is not reform. I urge the Forest Service to reject Alternatives 2 and 3 and adopt the No Action Alternative.

I am writing to oppose the complete removal of the 2001 Roadless Rule. I understand some of the reasons behind the proposed change, especially when it comes to wildfire prevention and giving local forest managers more options to manage their forests. I live in rural Northern California near the Shasta-Trinity National Forest, so wildfire is something I take very seriously. I definitely think forest managers need to be able to thin forests, remove hazardous fuels, and access areas when it is necessary to protect communities. However, I don't think we need to completely remove the Roadless Rule to accomplish that. The rule currently protects roadless areas from most road construction and timber harvesting, while still allowing some exceptions. There are protected roadless areas right here in the Shasta-Trinity National Forest, so this isn't an issue that feels very far removed from where I live. I would rather see exceptions made when there is a clear need for wildfire prevention, emergency access, or forest health instead of removing the protections altogether. I think there needs to be a balance. Living in Northern California, I understand that leaving every forest completely untouched isn't necessarily the answer, especially with the wildfire risks we face. At the same time, removing protections from millions of acres seems like a much bigger change than what is needed to address that problem. I would support keeping the Roadless Rule while allowing local forest managers to make exceptions when they can show that access is actually necessary for wildfire prevention, emergency response, or forest health. I hope the Forest Service will consider an option that allows us to actively manage forests and protect communities without completely giving up the protections that have kept these areas roadless. Thank you for your time and consideration.

I’m part of a small rural community on the Shasta-Trinity National Forest, and I urge the Forest Service to choose Alternative 1 (NO ACTION) and maintain the existing 2001 Roadless Rule for the following reasons: On the Shasta-Trinity NF, many of the recent catastrophic wildfires have been human-caused: the Carr, Delta, and Hirz Fires. Our public lands in northern California are no different than other public lands across the West. Dry and prone to wildfire. Natural causes, like lightning strikes, are at least predictable and allow responders to forecast and allocate resources. Not true for human-caused wildfires. More roads introduce more risk. Rather than introducing more risk into our community, I urge you to support more wildfire mitigations of our public lands: * Invest and increase frequency of prescribed fire - I’ve watched very successful, large-scale prescribed fire on and around Lake Shasta Reservoir - in roadless areas. This good fire, more regularly executed, allows for lower-intensity, mosaic-patterned fire on the land, and notice to mitigate any loss of life or structures. Far less risk than the Delta wildfire, which scorched everything in its path and sterilized the earth. * Working with timber inholders to responsibly log and maintain their parcels - the effects of commercial logging introduce greater wildfire risk than treated (prescribed fire) public lands. Invest in responsible commercial logging of existing parcels allocated for these purposes. * Preserve the few Old Growth forests we have left and allow mature stands to reach this potential. These lands are far more fire-tolerant and, in roadless areas, provide significant benefits to our watersheds, backcountry recreation, and local habitat and biodiversity. I have spent 66 years of my life surrounded by these public lands. I was an active participant in the I-5 Corridor Fuel Mitigation project that took nearly 20 years to be approved due to a lack of investment in the local Forest Service workforce. Start there. Rather than reducing the red tape to introduce more roads and increase wildfire risk on an already overly taxed and ravaged workforce, invest in stabilizing the workforce, streamlining the process for approval of fuel mitigation projects, and providing them with the resources to use sound science and practices in the areas where roads and highways already exist.

As a wildlife biologist, I have surveyed areas managed under the 2001 Roadless Rule in Six Rivers National Forest, Shasta-Trinity National Forest, Sierra National Forest, and Sequoia National Forest. It is critical that these lands retain their roadless character. Roads cause severe soil erosion, facilitate the spread of invasive species, and fragment essential habitat for wildlife requiring untrammeled environments. I strongly encourage the USDA Forest Service to retain the full protections afforded under Alternative 1 to safeguard these vital ecosystems.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roads cause a lot of erosion and are costly to maintain. The roadless rule should not expand especially in the Shasta Trinity National Forest. Mt Eddy is special for me and my family, since we live outside Montague, CA. I have hiked extensively in the Mt Eddy area and it is unique in its biodiversity. I would hate to see that place be degraded further by roads I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about Mt. Eddy (7,232 acres), Shasta-Trinity National Forest, California. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Twenty-four million people’s drinking water is asserted away Clean water matters to me, and my own tap may trace back to this country. I do not accept assurances in place of analysis. Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired. The DEIS says forest plans address sources of public drinking water without identifying one enforceable provision. I ask that the agency identify, forest by forest, which plan provisions are equivalent to 36 CFR 294.12 and 294.13 for municipal watersheds. Issue 2: Road sediment is quantified and then set aside Clean water matters to me, and sediment is not an abstraction when it is headed for water people drink. The agency quantifies the risk and then walks away from it. The DEIS: skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and “can contribute up to 90 percent of the sediment generated by timber sale activity.” The number appears in the document; no projection of sediment delivery follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Issue 3: Unmaintained roads damage water, by the agency’s own admission Clean water matters to me, and roads nobody maintains do not stay harmless. The agency admits as much in its own analysis. “Lack of maintenance commonly has detrimental effects on water quality. Insufficient maintenance funding is a key reason for the lack of adequate road maintenance.” The same document proposes adding road mileage against a maintenance shortfall it identifies as a cause of water quality damage. I ask that the agency reconcile the proposed increase in road mileage with the maintenance shortfall its own analysis identifies as a water quality cause. Issue 4: Foreseeable plan amendments are placed beyond scope I am naming a place because the agency has not looked at what this proposal means for it, and its own rule concedes what could follow there: The proposed rule concedes that subsequent land management plan amendments and revisions “could increase the area where timber harvest and road construction would be allowed,” declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. Issue 5: Reliance interests are invited and never assessed The place I name here is one I rely on, and this comment is exactly the reliance interest the agency asked to hear about. Its own proposal invites what its analysis then ignores: The proposal solicits “any reliance interests in the current rule that could be affected by this proposal” (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, [Your Name] [Your City, State]

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I appreciate all wildlife in these Roadless Areas. Many species of wildlife need pristine areas such as these to thrive. I hike, backpack, camp and trail run in Wilderness and Roadless Areas, mostly on the Klamath and Rogue River National Forests. These unspoiled areas are important to me. National Forests are required to be managed for multiple use. This does not mean that every acre must be roaded and logged. The best use for our remaining Roadless Areas is to remain roadless. There are abut 300.000 miles of roads in the Forest Service system. The roads on the Klamath National Forest are in terrible shape, and I suspect this is true nationally. There are more roads than the agency can maintain, and there are more roads than are necessary for administration and public use. It makes no sense to add yet more roads to a broken system. Roadless areas are necessary to maintain clean water for municipal water supplies and for the survival of the fish and wildlife that depend on them. Roads, mining and logging are pollution sources. We don't need additional sources of pollution. I am a retired wildland firefighter. In my experience, Roadless Areas are not a significant impediment to fire suppression. Roadless areas tend to be healthier and more fire resistant. They provide an opportunity to let wildland fire play its natural role in forested ecosystems. Most fires start along roads. Roadless Areas tend to be in high elevation areas, which means that they are cooler, wetter, and fires that do start there tend to be near the tops of the mountains and so are less destructive; most roadless areas on the Klamath National Forest have burned several times over the past 50 years and so are no longer burdened with unnatural fuel loads. I commented on this subject last year and never got a response. It seems that, as with many other similarly destructive projects, the agency is just going through the motions and is not seriously considering public opinion. I have been to many roadless areas, and I value both the ones I am familiar with and the ones I have never visited. To me, more roads would be a symbol of the agency's managerial, ecological, political and moral bankruptcy. There is a reason that roadless areas are roadless. They are not economically valuable for commodity production. They are not needed for motorized recreation. They have been analyzed several times over the past 50 years or so and there was never any need to road them. Nothing has changed. Leave them alone. The Pacific Crest Trail passes through the Grider roadless area, which is quite wild and scenic. The Tom Martin roadless area is near the historic Lake Mountain Lookout, which I have been to many times. I have backpacked in and around the Boulder Roadless Area. Roads in this general area have had to be abandoned because of the instability of the terrain. The Shackleford Roadless Area is adjacent to the Marble Mountains Wilderness, which I have visited many times. The Mt. Eddy roadless area is adjacent to the Pacific Crest Trail and is a very popular area for hiking and backpacking. The McDonald Peak Roadless Area is adjacent to the Pacific Crest Trail and is a very popular area for hiking, trail running and backpacking. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Grider (10,647 acres), Klamath NF, California - Tom Martin (9,031 acres), Klamath NF, California - Boulder (435 acres), Klamath NF, California - Shackleford (1,679 acres), Klamath NF, California - Mt. Eddy (7,232 acres), Shasta-Trinity NF, California Mcdonald Peak (9,431 acres), Rogue River NF, Oregon Chips Creek (42,029 acres), Plumas and Lassen National Forests, California I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each of these areas, including the effects of the road construction and timber harvest it would newly allow. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule’s protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency’s own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Jeffrey Stone Yreka, CA