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These comments are submitted on behalf of Prairie Rivers Network and 658 people who signed a petition (the petition signers are named in the attached PDF) related to the U.S. Department of Agriculture's proposal to rescind the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). The majority of our signers are Illinois residents who are particularly concerned about the impacts to the Shawnee National Forest in Southern Illinois. Prairie Rivers Network is an Illinois environmental nonprofit, and we are the state affiliate of the National Wildlife Federation. Our mission is to protect water, heal land, and inspire change. Protect Shawnee's Roadless Areas: Keep the Roadless Rule in Place We oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Shawnee National Forest, where the forest is already highly fragmented. The 10,666 acres of important roadless areas in the Shawnee provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. Opening up areas of the Shawnee to more road construction means the spread of invasive species, further habitat fragmentation, erosion and sedimentation into pristine streams, as well as direct impacts to threatened and endangered species and all wildlife. We urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place.

I love taking my child to explore shawnee national forest. We camp there few times a year. We also like traveling and seeing new forests. Please protect our beautiful forests and land. We want to see it be preserved and respected

Continued: 4. Fire is a part of the ecosystem. To the extent that the rationale is reducing fire, the rationale is wrong, as other commenters have pointed out and as the rationale points out, that more roads lead to more fire activity. But also the entire proposal is misplaced — because the most effective way to address fires of increasing intensity is to address climate change. That is the real national priority that needs to be addressed that the government is completely failing to address. Roads in forests are not a recognized wild-land fire management policy, as other commenters have pointed out. *** Put simply, the repeal of the Roadless Rule is a step backwards in public lands management. It effectively takes public lands out of the hands of the people they are set aside for — the American public — and hands them to special interests who are willing to pay for them. This is not the mandate that the USFS has been given by Congress. The mandate is the manage these lands for multiple uses. Creating new roads in forests prioritizes only one use, timber harvesting, over all others. *** My experience in this comment is drawn from recreating at the following USFS properties: Little Missouri National Grassland; Buffalo Gap National Grassland; BigHorn National Forest; Chequamegon-Nicolet National Forest; Hiawatha National Forest; Ottawa National Forest; Huron-Manistee National Forest; Superior National Forest; Chippewa National Forest; Shoshone National Forest; Custer-Gallatin National Forest; Flathead National Forest; Bridger-Teton National Forest; Caribou-Targhee National Forest; Gifford Pinchot National Forest; Olympic National Forest; Okanogan-Wenatchee National Forest; Mount Baker-Snoqualmie National Forest; Colville National Forest; Medicine Bow-Routt National Forest; Arapaho National Forest; White River National Forest; Black Hills National Forest; Thunder Basin National Grassland; Unit-Wasatch-Cache National Forest; Sierra National Forest; Stanislaus National Forest; Lincoln National Forest; and Shawnee National Forest. My major takeaway from all these experiences is that these Forests already have more roads than most people could explore in a lifetime. There is quite simply no practical or logistical need, from a recreational perspective, for more under the rationales that the USFS has proposed in this rule change.

Dear Secretary Rollins and Chief Schultz, Inventoried roadless areas are, in my experience as a wildlife observer, the units in which species persistence remains most legible; the 2001 Rule is what has preserved that legibility, and I oppose the proposed rescission. Another opportunity to be better stewards of the only world we ever will have. Once a species is gone it’s never coming back. We can do better and we should. Regarding the Eagle Creek in the Shawnee National Forest, Illinois: By proposing to rescind the Roadless Rule, the agency initiates a federal action that may affect Whooping Crane (Grus americana, E, XN) in the Eagle Creek IRA, Shawnee National Forest. This triggers the ESA Section 7 formal consultation requirement — a statutory obligation the agency cannot bypass through programmatic analysis or tiered review. Road construction in the Eagle Creek IRA introduces impervious surfaces, sediment delivery, and noise into currently undisturbed habitat. Timber harvest alters stand composition and microclimate. These are precisely the activities the Roadless Rule prevents — and precisely the activities that may affect Whooping Crane (Grus americana, G1, E, XN). The formal consultation obligation for Whooping Crane (Grus americana, E, XN) in the Eagle Creek IRA, Shawnee National Forest, is species-specific. The agency cannot satisfy it through a generic programmatic consultation or a blanket finding covering all listed species across all roadless areas. Each species in each area requires its own consultation finding and its own determination of effect. "The Services have largely ignored section 7(a)(1), despite the potential for this provision to lead the way toward threatened and endangered species recovery. While over the decades agencies have spent extensive attention to complying with their consultation obligations under section 7(a)(2), much less effort has been focused on their recovery obligations under section 7(a)(1). This imbalance is seen by some as a missed opportunity since 7(a)(1) is likely a more important mechanism for species' conservation." — Frontiers in Conservation Science, 2021 The Roadless Rule belongs on the books. Regards, CommentID: RLC-20261007-FGG399

I oppose the rollback of the Roadless Area Conservation Rule. For more than two decades, this rule has protected much of the wildness that remains in our national forests. The protections have been particularly vital in the Shawnee National Forest, where the forest is already highly fragmented. The 10,666 acres of important roadless areas in the Shawnee provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. Opening up areas of the Shawnee to more road construction means the spread of invasive species, further habitat fragmentation, erosion and sedimentation into pristine streams, as well as direct impacts to threatened and endangered species and all wildlife. I urge you to stop rolling back protections for our public lands and leave our last wild forests intact. Please keep the Roadless Rule in place. Sincerely, A Concerned Biologist

I live in Southern Illinois and have spent the last 40 years exploring the 289,000 acre Shawnee National Forest. It is one of the most biologically diverse places in the U.S. It is a fragmented forest transected by many roads. We have 3 Roadless areas that could be impacted by the repeal of the Roadless Area Conservation Rule. No more roads should be built in the SNF. Roads are be built for extraction of natural resources, logging and mining. We have so little public land in Illinois and other Midwestern states. We should not lose one acre of forest to build roads in the SNF. Illinois lost 22 million acres of tallgrass prairie. Driving from Southern Illinois to Chicago mile after mile is covered with 100% corn. No more pastures or hedgerows. Most of Illinois is devoid of insects, birds, and native plants. We must protect what we have. The U.S. National Forest road system is the largest in the entire world. NO MORE ROADS on any U.S. public land. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I am deeply concerned about proposed changed to the Forest Service's Roadless Area Conservation rules, especially with respect to the Shawnee National Forest. A roadless area area within this Forest was the site of a significant experience for my family that brought us all together.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The outdoors is my cathedral, and time spent there is sacred. Places like Bell-Smith Springs and the Lusk Wilderness areas in Shawnee National Forest are not always free of other visitors, but a trip there is restorative nonetheless. I also visit Mark Twain National Forest when I can. The areas I am most concerned with are inventoried roadless units in Shawnee: Burden Falls, Clear Springs, and Ripple Hollow. Illinois holds 6 inventoried roadless areas totaling 10,673 acres. That is not much. More roads would severely detract from those spaces that still feel wild, and it would be a shame to create more inroads into them and ruin the solace they provide. I am also an amateur birder whose senses still awaken with the spotting of a Cardinal or some woodpecker. And I roadtrip to the western United States nearly annually to photograph landscapes I do not see in the Midwest, places like the Badlands, Capitol Reef, Bryce Canyon, and Zion. The joy is in the discovery. Public land needs to be managed in the interest of my grandchildren's grandchildren. My children need this land to unplug and maintain their sanity as much as I do. On the wildfire justification: the proposal points to fuels management as a reason to rescind the rule and open roadless areas to new construction. The agency's own record states that "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding belongs to the agency, not to its critics. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and 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. On economics: the agency's own record states 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." There is no fiscal sense in spending money on new roads before fixing those already in existence, and any new road construction should carry public budgetary oversight. The agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue 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 a $6.9 billion maintenance backlog? On water: across the Eastern region, which includes Illinois, 286 municipal water intakes sit in watersheds containing affected roadless areas. Building new roads in that context is, as my grandfather would have said, pissing in your Cheerios. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and fewer than 12 percent of those watersheds have impaired streams today. The agency should state plainly what it projects will happen to that figure under the rescission, and it should do so in the record. On the state-by-state approach: the proposal argues that local rules can replace a national one, but the agency's own prior record shows it 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." The Ninth Circuit already reviewed a state-by-state replacement and found it wanting. On statutory authority: the proposal suggests the 2001 rule exceeded what Congress authorized. A federal appellate court resolved that question. Its holding reads: "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 fell 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 state, with legal grounding, the basis for any position contrary to that holding. Burden Falls is partly protected by the difficult road required to reach it. The falls themselves only flow during or after heavy rain. I have never seen them with water, but the area is still worth climbing through. That kind of place, earned by effort and left largely as it is, is worth keeping. A logged stand grows back. A road does not. Sincerely, [Your Name] [Your City, State]

Please do not recind the Roadless Rule for National Forests! We live near the Shawnee National Forest in Southern Illinois and are not in favor of allowing roads for cutting down trees.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Quiet, peace, nature, and water: those are the things I go to the woods and lakes for, and the 2001 Roadless Area Conservation Rule has protected the places where I find them. I oppose its rescission. I paddle Lake Michigan and Lake Superior. I hike and camp near lakes in Northern Wisconsin and have traveled to Shawnee National Forest in Illinois. The roadless areas I care about most directly, including Bear Swamp in the Huron-Manistee National Forest in Michigan, the island and lake units of the Chequamegon-Nicolet National Forest in Wisconsin, and the Burke Branch, Ripple Hollow, Burden Falls, Bay Creek, Eagle Creek, and Clear Springs areas in the Shawnee, are public land. They are for the public to enjoy, not for logging or mining. That is not a slogan; it is the conclusion I have reached after traveling to these places repeatedly over the years. The agency justifies rescission in part on wildfire and fuels management grounds, but its own record directly contradicts that argument. The agency's prior findings state: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That sentence does not describe a fringe position; it is the agency's own language, drawn from its own environmental review. Bear Swamp sits within Michigan's 16,124 acres of inventoried roadless land, and the Eastern region, which includes Michigan, contains watersheds holding 286 municipal water intakes inside the affected areas. Opening those landscapes to road construction would increase ignition risk precisely where the agency's own data says roaded land burns harder. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's own record 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." Against that marginal gain, the agency's own Cost Benefit Analysis projects timber revenue of $5.2 to $11.4 million a year to the Forest Service, set against recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a span so wide it cannot establish a benefit. The Forest Service already carries a $6.9 billion road maintenance backlog. I ask that the agency reconcile the proposal with those numbers and explain how it justifies expanding a road system that the agency cannot currently maintain, when its own analysis cannot confirm a net gain. The permitting burden rationale fares no better under scrutiny. The rule as written already provided that 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 exceptions for public health, safety, existing mineral leases, and community wildfire protection are already in the rule. The agency has not identified, with specificity, which burdens those provisions fail to address. I ask that the agency name the particular burdens the existing exceptions do not resolve, and quantify them on the record. Finally, the regulatory flexibility analysis certifies no significant impact on small entities, but the record itself names outfitters, guides, and tour operators as affected, and books a minimum recreation benefit loss of $6.1 million a year. The certification is reached by spreading expenditure losses across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in these specific roadless areas. The Thornapple and Le Roy Creek areas in the Chequamegon-Nicolet, along with the Shawnee units I named above, all support recreational use that feeds exactly those small businesses. A certification built on a national average rather than on the affected permit holders is not an analysis; it is an assumption. The agency must withdraw that certification and assess the impact on the businesses actually operating in these areas. These places belong to the public. Rescission serves none of the purposes the agency claims for it, and the agency's own record says so. I urge that the 2001 Roadless Area Conservation Rule be retained without modification. Sincerely, Katrina Burmeister Sleepy Hollow IL

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

Please DO NOT rescind the Roadless Rule. This administration has shown time and time again through budget and staff cuts an unwillingness to protect and preserve our public lands. Please do not open other avenues to destruction. Shawnee National Forest is very dear to us, as we drive from the opposite end of the state at least once a year for excellent hiking and wonderful hospitality of the nearby towns. Protect our public lands!!

Please keep the wild places wild. We need More areas, like the Shawnee National Forest, not less. These places should be treasured, not exploited.

I oppose the full or partial rescinding of the Roadless Area Conservation Rule. I live in Illinois and have enjoyed hiking and birding in both the Shawnee National Forest (Illinois) and the Chequamegon-Nicolet National Forest (Wisconsin) for most of my life. I will focus my comments on Shawnee, as it's in my state, but the same concerns apply to the Chequamegon-Nicolet. The Shawnee National Forest is Illinois' primary wilderness sanctuary and lifting the roadless rule would permanently degrade the silence and blessed isolation that greets hikers and birders like me, and the vast uninterrupted blocks of old-growth and mature trees that protects our native and migratory bird populations. Adding roads into the Burke Branch and Ripple Hollow sections of the Shawnee would fundamentally ruin its recreational use. Additionally, the loss of vegetation for road construction and industrial access would increase water run-off, flash flooding, and erosion. These changes put hikers and birders at risk and permanently impact the ecosystems that native and migratory birds depend on for survival. Rescinding the roadless rule would carve out nearly 11,000 acres of bird habitat in the Shawnee. Birds like the Cerulean Warbler and Northern Perula require vast, uninterrupted high-canopy, old-growth interiors, and Ovenbirds and Kentucky Warblers, low-understory nesters, depend on well insulated, dense forest interiors that avoid forest edges where they are vulnerable to predators. Predators hunt prey along forest edges where open, linear clearings like forest roads, lie. Rescinding the roadless rule will result in habit loss, environmental degradation, and lost breeding grounds. Rescinding the roadless rule will bring increased noise, pollution, industrial activity, and predator access. Rescinding the roadless rule will make the Shawnee flora and fauna vulnerable to invasive species and disease which would have far reaching, unintended consequences. My brother grew up in the Boy Scouts and was a Boy Scout leader for three decades. In all that time the most anticipated, and memorable, annual overnight adventure was to the Shawnee. This land, along with every other at risk by this rescission, must be saved for the generations ahead of us: The hikers, the birders, the Boy Scouts, and our families and neighbors. Our National Forests are our heritage and they belong equally to all of us to enjoy and keep for future generations. I want to continue to wander these trails, be thrilled at the site of an elusive Cerulean Warbler, and drink in the vastness of Shawnee's Garden of the Gods. Please keep roadless land intact and take NO ACTION. Thank you for your help in protecting and preserving our natural lands.

My name is Valerie, a young adult who recently obtained their masters degree in Sustainable Design. I believe that the Roadless Area Conservation Rule should not be rescinded or altered because it is an important governmental check and balance for maintaining our American forests. I outline some of my reasoning for this below: One of the objectives of the Forest Service is to mitigate fire hazards in our forests through prescribed burning. This prescribed burning reduces flammable organic matter and minimizes the risk of uncontrolled fires. What once was a fire reduction tactic out West in arid regions has now migrated to the temperate hardwood forests where I live. You can see The Forest Service's push for prescribed burning in the attached image "Good Fire" which I took outside of Bell Smith Springs state park in Southern Illinois. While the ecological benefits of this prescribed burning are controversial in Eastern forests, what is not is the fact that uncontrolled fire outbreaks are more common in forests with logging and roads. The DEIS states "as the density of roads increases, so does the probability, number, and frequency of fire ignitions". Rescinding the roadless rule would result in a higher probability of wildfires in temperate regions, directly contradicting the current initiatives of the Forest Service to reduce uncontrolled fires through prescribed burning. The rescinding of the roadless rule therefore represents an unfaithful and non-reflective act with the potential for legal consequences should the proposal be accepted. While a majority of the roadless rule protected areas occur out west, there are approximately 11,000 acres of protected roadless sites in the Shawnee National forest of my home state of Illinois (USDA, 2026). These areas of the shawnee are within the watersheds of the Ohio and Mississippi river, meaning that the excess pollution from the resulting work sites and water runoff on bare ground would directly impact the drinking water quality for thousands of people (amrivers, 2026). The Shawnee national forest is a hidden gem of the mid-west, and its importance to the local people of Southern Illinois and surrounding areas cannot be understated. I personally enjoy hiking and climbing at places such as Bell Smith Springs, the Lusk creek wilderness, Jackson Falls, and Burden Falls. These places are of high environmental and cultural value to myself and their surrounding communities and some of them will come under direct scrutiny with the rescinding of the roadless rule. There are currently activist groups working to make the Shawnee forest into a national park (Shawnee National park, 2026) which alludes to the high value of the remoteness of these wilderness areas which would be ruined by the construction of roads within them. Illinois as a state has already had a lot of its ecosystems fragmented by industrial agriculture and urban development. Building roads would further fragment the forested ecosystems of Southern Illinois, rendering yet another part of the State negatively impacted by humans. It is therefore critical that we stand up to protect what little forests and remote areas we have left in our state, and I hope that Illinois does not fall victim to the reinstatement of roads in its forests. Works Cited: amrivers. (2026). American Rivers Geospatial Data . Inventoried Roadless Areas and Drinking Water . https://amrivers.maps.arcgis.com/apps/mapviewer/index.html?webmap=af68acd394e340c0b32750e3075edbda¢er=-97.668341%2C39.658533&scale=18489297.737236 Shawnee National Park . Shawnee Park And Climate Alliance . (2025, February 21). https://www.shawneentlpark.org/ USDA. (2026). Roadless Rule Geospatial Project Record. 2001 Roadless Rule Rescission Draft Environmental Impact Statement Data Web Viewer. https://experience.arcgis.com/experience/c6122042b4ae46c9b323306912e8b40e/page#data_s=id%3AdataSource_1-19c06a59ad6-layer-13%3A1000

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Katharina Andrews-Carter. I am an American citizen and Illinois resident. I am also an avid hiker. Just 3 weeks ago, I headed out on a hiking trip with my dog out to Montana. I specifically chose the Flathead Forest region as our destination for the remoteness and ability to see wilderness that we do not have in the Midwest. It was an amazing experience. Jewel Basin was like nowhere I've ever been before. Should this the Roadless Rule be altered or rescinded, then it is entirely possible that other Americans will not be able to have the experience that my dog and I enjoyed so very much. We made it to a lake where we were entirely alone and the only noise was the splash of fish. A different trail I wanted to go to was not accessible during the week due to logging activity. Increasing roads through our wilderness will not help prevent forest fires, it will simply make this situation all the more common and ruin that peace of the lakes in Jewel Basin and many other places. Studies show that fires are 4 times more likely to begin near a road than in a roadless area. This and the logging could ruin the local economies based on tourism to these wilderness areas and prevent other taxpaying Americans from accessing public lands in the interest of the profits of private companies. This is unacceptable. Creating more roads would also increase the burden on taxpayers while failing to address the $6.9 billion of deferred maintenance to existing US Forest Service infrastructure. None of this is in the public interest. In Illinois we only have one area protected by the Roadless Rule, the Shawnee National Forest. It is a lovely area and for my mother's 60th birthday next week, she booked lodging so that all of her family can join her in enjoying the Shawnee National Forest area. If we lose the Roadless Rule then this activity would also be at risk of being disrupted by unnecessary road construction and logging. My family and I are extremely fond of these areas and seek them out when planning special occasions. Please do not fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS and eliminate the protections for 45 million acres of wilderness that we would like opportunities to explore further in the future. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative.

My name is Matthew, a young adult working in water resources engineering. I believe that the Roadless Area Conservation Rule should not be rescinded or altered because it is an important governmental check and balance for maintaining our American forests. I outline some of my reasoning for this below: One of the objectives of the Forest Service is to mitigate fire hazards in our forests through prescribed burning. This prescribed burning reduces flammable organic matter and minimizes the risk of uncontrolled fires. What once was a fire reduction tactic out West in arid regions has now migrated to the temperate hardwood forests where I live. You can see The Forest Service's push for prescribed burning in the attached image "Good Fire" which I took outside of Bell Smith Springs state park in Southern Illinois. While the ecological benefits of this prescribed burning are controversial in Eastern forests, what is not is the fact that uncontrolled fire outbreaks are more common in forests with logging and roads. The DEIS states "as the density of roads increases, so does the probability, number, and frequency of fire ignitions". Rescinding the roadless rule would result in a higher probability of wildfires in temperate regions, directly contradicting the current initiatives of the Forest Service to reduce uncontrolled fires through prescribed burning. The rescinding of the roadless rule therefore represents an unfaithful and non-reflective act with the potential for legal consequences should the proposal be accepted. While a majority of the roadless rule protected areas occur out west, there are approximately 11,000 acres of protected roadless sites in the Shawnee National forest of my home state of Illinois (USDA, 2026). These areas of the shawnee are within the watersheds of the Ohio and Mississippi river, meaning that the excess pollution from the resulting work sites and water runoff on bare ground would directly impact the drinking water quality for thousands of people (amrivers, 2026). The Shawnee national forest is a hidden gem of the mid-west, and its importance to the local people of Southern Illinois and surrounding areas cannot be understated. I personally enjoy hiking, climbing, and camping at places such as Jackson Falls. Places like Jackson Falls are of high environmental and cultural value to myself and their surrounding communities and some of them will come under direct scrutiny with the rescinding of the roadless rule. There are currently activist groups working to make the Shawnee forest into a national park (Shawnee National park, 2026) which alludes to the high value of the remoteness of these wilderness areas which would be ruined by the construction of roads within them. Illinois as a state has already had a lot of its ecosystems fragmented by industrial agriculture and urban development. Building roads would further fragment the forested ecosystems of Southern Illinois, rendering yet another part of the State negatively impacted by humans. It is therefore critical that we stand up to protect what little forests and remote areas we have left in our state, and I hope that Illinois does not fall victim to the reinstatement of roads in its forests.

"Divide and Conquer." This is the strategy of a war, not of stewardship. My name is Jacob, a recent graduate with a bachelor's degree in Natural Resources and Environmental Sciences. I believe that the roadless rule is an essential statute to preserve the limited wildlands once abundantly present across our country; further, the proposal of repealing this act is as misguided as it is There are few areas of the USA which have seen little development. Repealing the Roadless Rule would ensure fragmentation and disturbance in these areas, and would mark the starting point for a slow deterioration of the final American frontiers into barren commercial lots. The economic incentive for opening these areas to commercial logging, drilling, mining, and construction is undeniable. But what do we lose in the process? Shawnee National Forest is the largest public land in Illinois, and contains 11,000 acres of land affected by the proposed change. The Shawnee is a bastion of nature in an otherwise altered state. I, and my friends, enjoy frequenting Jackson Falls, Bell Smith Springs, and Garden of the Gods; all of which may suffer under this change. The threats this would reintroduce endanger not only these sites, but any and all adjacent land to which fire, invasive species, or man may travel. Before this proposal, the inherent environmental significance, ecological uniquity, and cultural value of the Shawnee was already being fought for. Attempts have been made to create the into as a National Park, under which designation current logging practices would be forced to cease, thereby preserving the character of this ecologically rich region. While this is unlikely to become a reality, that is no reason to take two steps back with an influx of commercial development. I was born, raised, and have spent all of my life in Illinois. Those with an upbringing similar to mine are no stranger to ecosystem fragmentation and decay; in a span of about 150 years, Illinois lost 80% of our natural forest ecosystems, 90% of our natural wetland ecosystems, and over 99% of our natural prairie ecosystems (INHS). The Roadless Rule is a wall holding together some of the few intact ecosystems in my state. Without it, these are vulnerable to a systematic breakdown: splinter roads, invasive species, and anthropogenic fires will whittle away at the little we have left. I hope that I will never see an Illinois without the Shawnee, nor a New Mexico without Gila, nor Kentucky without Daniel Boone; revoking the Roadless Rule inches us closer and closer to the precipice such a reality.

Dear Secretary Rollins, I am writing in opposition to rescinding the Roadless Area Conservation Rule. For 25 years, the rule has limited permanent road construction and logging in these areas; protecting clean water, connected wildlife habitat, old-growth forests, and places that provide refuge as development consumes more of the landscape. The protections have been particularly vital in the Midwest, where less than 200,000 acres of roadless, untrammeled forest lands survived the widespread logging of the past two centuries. As a lifelong Wisconsin resident, my family and I thoroughly enjoy annual trips to Michigan’s Ottawa Forest as well as countless trips to Wisconsin's Chequamegon-Nicolet Forest, the Shawnee National Forest in Illinois, and many other national forests, national parks and public lands throughout the U.S. The Midwest’s national forests have important roadless areas that provide critical habitat for wildlife, clean our drinking water, store carbon, and offer refuge for people seeking quiet and beauty. For decades my family has harvested and enjoyed eating Wisconsin’s manoomin, a.k.a. wild rice. Clean, fresh water that flows through Wisconsin’s national forests support manoomin. Manoomin is an Indigenous cultural touchstone, food resource, and keystone wetland plant species found primarily in the Great Lakes region. Wild rice significantly influences wetland productivity, pollutant fate, and intricate relationships with various other plant and animal species. However, manoomin is rapidly disappearing across the heartland’s waters. Climate change, land development, and stripped protections threaten “the food that grows on water.” Poor water quality also contributes to manoomin declines. Water clarity is critical for early stages to access sunlight and oxygen. More roads leads to more runoff and more pollution. This will impact manoomin. I am asking the Agency to address my concerns. Wildfire reduction and active forest management The Agency has stated more roads within the roadless areas are necessary to reduce wildfire – a reversal of the agency’s own environmental analysis finding that human-caused ignition density is several times higher on roaded land than in the affected roadless areas. The DEIS shows that the repeal will significantly increase in fire risk. As illustrated in Table 18 in the DEIS, ignition density is nearly four times higher in NFS lands that are not subject to Roadless Rule protections, and the area burned (as a percent of total land area) is also substantially higher on unprotected NFS lands. After nearly 20 years of monitoring data, a 2020 Forest Service Study concluded that more roads do not lead to better forest health through increased fire-management activity. Please explain this reversal. Provide detailed evidence that repealing the Roadless Rule will deliver tangible benefits related to forest health or wildfire risk. Also, provide evidence how repealing these protections may affect other resources, including drinking water and biodiversity, and how climate change may interact and exacerbate the environmental impacts of the proposal. Economic impact The Agency cites the proposal’s own multi-billion-dollar road-maintenance backlog. Repealing the Roadless Rule will ultimately exacerbate this problem because the anticipated revenue from extractive activities “would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project.” Please address how building more roads will address this funding-deprived backlog. Climate changes We have seen increases in extreme temperature, wildfire risk, drought, and insect disease and outbreaks, which the Agency deems as key rationale for the proposed repeal of the Roadless Rule. However, the DEIS does not address the fact that these trends are human-caused. What actions will the Agency take to address human-caused climate change and its effects in future analysis? Outdoor recreation community and outdoor recreation economy The Roadless Rule is extremely important to the outdoor recreation community and the outdoor recreation economy. The rescission would remove important protections for approximately 45 million acres of back-country national forests, including more than 25,000 miles of trails, 10,000 climbing routes, nearly 1,000 miles of whitewater, and more than 10,000 miles of mountain biking. Please include data outlining the impact rescinding the Roadless Rule will have on outdoor recreation activities and outdoor recreation economy. Rescinding the Roadless Rule is unpopular and unnecessary. 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. Thank you for considering these comments. Sincerely, Mary

I strongly oppose this proposed regulation. Putting roads in forests opens them to development that will destroy the ecosystems these forests provide for flora and fauna. Our forest ecosystems have diminished over the years, and they need to be preserved for future generations. I live in Illinois and particularly love the Shawnee National Forest.