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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The places I am describing are real to me. I hike, backpack, and ride my gravel bike in the Sierra National Forest, and I have covered ground across California and west through Colorado, Arizona, New Mexico, Oregon, Washington, Idaho, Montana, Utah, Wyoming, and Nevada. I oppose the rescission of the 2001 Roadless Area Conservation Rule. The wildfire argument the agency makes for rescission collapses against its own findings. Oat Mountain needs protection from fire, and I believe people are a hazard to that area. The agency's record states this plainly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ride gravel bikes and I am familiar with the damage that motorized vehicles cause. They race around on roads and are not respectful of nature. The Woodchuck area is now burnt up, and I believe it should be protected from vehicles, not opened further to them. The Shuteye area draws the same concern. I ask that the agency explain why this proposal departs from its own prior findings, 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 does not hold together either. 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." Against that, 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, with a net present value spanning negative $92 million to positive $199 million. The Forest Service is already carrying a $6.9 billion maintenance backlog on its road system. California alone 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. I have hiked and ridden my bike along the Kings River, where the water is collected in reservoirs and released as needed and the river serves both recreation and farming. Opening these watersheds to roads for economic returns the agency's own numbers cannot confirm is not a trade I accept. The agency must reconcile this proposal with a Cost Benefit Analysis that cannot establish a net benefit, and explain how expanding a road system already billions of dollars in arrears serves the public interest. I have backpacked in Dinkey Lakes. It is stunningly beautiful. We need to protect it for future generations. I watch for eagles, mountain sheep, mountain goats, bighorn sheep, birds, fish, frogs, whatever we can see. The record shows that Alternative 3 exists precisely because commenters asked the agency to protect big game habitat, fisheries, and wildlife connectivity. The agency built that alternative and then chose the one that protects none of it. On birds, the DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency must say plainly why it rejected the alternative its own record built for the protection of these species, and what it proposes to substitute. The agency tried replacing the national rule with state-by-state approaches before. The record acknowledges that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected that approach. The agency has not explained how this proposal avoids the same deficiencies that caused it to lose in court the last time it tried this, and that explanation is owed. Finally, the agency has certified no significant impact on small entities while its own DEIS identifies outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books a minimum recreation benefit loss of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than examining the specific outfitters and guides holding permits in these areas. The agency should withdraw that certification and assess the small entities actually operating in the affected roadless areas. Sincerely, Laura Fresno, CA

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.

I strongly oppose the proposal to rescinding the 2001 Roadless Area Conservation Rule, commonly referred to as the 2001 Roadless Rule. Both my husband and I have spent many vacations in areas of the U.S. that are either adjacent to or within National Forest areas. As a child, I spent time in Michigan’s Upper Peninsula, including the Hiawatha National Forest, as well as along the western side of the Lower Peninsula near the Huron Manistee National Forest. In the 1980’s we lived in Rhode Island, and spent winter vacations cross-country skiing in the back country near Jackson, New Hampshire in the White Mountain National Forest. After relocating to California, we have spent the last 40 years vacationing in or near many of the National Forests located in the state. We have hiked and skied the back country near Mammoth Mountain and Lake Tahoe. My husband has been trout fishing for the last 20 years in the lakes and streams around Bridgeport in the Eastern Sierra. The common thread that runs through all of these forests is areas that are protected by the Roadless Rule. The roadless areas that we access by hiking or skiing provide peace and quiet that help us decompress from our busy urban lives, and our tourism helps support those local economies so that we can continue to enjoy them. Even more important, roadless areas help protect watersheds from silt and runoff contamination, since roads are a significant source of sediment in forested watersheds. By preventing sedimentation of the watershed, the Roadless Rule protects both the natural areas themselves and the drinking water sources for many downstream residents. Since I have spent most of my adult life in California, I would like to point out just a few of the important ways the Roadless Rule greatly benefits me and my family. The Roadless Rule is what helps protect the water clarity of Lake Tahoe, a major recreation asset for my family as well as the State. The Roadless Rule supports wonderful fishing areas in the Stanislaus and Humboldt Toiyabe National Forests around Bridgeport, since it prevents the sedimentation that kills trout. The Roadless Rule protects thousands of acres of the Sierra National Forest that contribute to the “Sierra Snowpack” that provides clean water for millions in California. Repeal of the Roadless Rule would endanger these all of these benefits. Most importantly, the Roadless Rule helps, rather than hinders, wildfire resilience in the forest. The US Forest Service own analysis shows that repealing the Roadless Rule would increase the risk of wildfire due to the increased human activity(1). In California, about 86% of wildfires are caused by human activity, and the ignition risk if four times higher near roads (2,3). In contrast, the Forest Service has been successfully increasing wildfire resilience in roadless areas for many years without building new roads. The Wildfire Crisis Strategy selected 10 initial forests for additional funding for work already underway within the Social and Ecological Resilience Across the Landscape Project (SERAL). One of the of the forests selected was the Stanislaus National Forest. This allowed the Forest Service to work in partnership with state and private land owners to perform proactive treatments to reduce fire risk. These treatments included hazard tree removal, prescribed fires, fuel break construction, and hand thinning to remove smaller trees and brush. Thinning is very important, since it reduces the vegetation that fires can use to climb from the ground to the forest canopy. Rather than the removal of mature trees by industrial logging that would harm the watershed, removal of small trees and brush leaves the larger older trees better able to withstand drought, insects, and new fires. Examples like the current work in the Stanislaus National Forest show that the Roadless Rule does NOT block wildfire prevention. Instead, it is a national standard that ensures a strong baseline of protection for these areas. It strikes the right balance with cooperation between the Forest Service, private land owners, and the State encouraged through local land management plans. By preventing unnecessary new roads and logging, the Roadless Rule just provides guardrails that prevent short-sighted political or industry pressure from damaging irreplaceable resources. Please reject the broad repeal of the Roadless Rule. Preserve what has worked well for more than 20 years. 1.Draft Environmental Impact Statement – 2001 Roadless Rule Rescission Volume 1. Project #68605 Updated August 19, 2026 by Patrick C.Yamnik. 2. 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 3. Morrison, P.H. 2007. Roads and Wildfires. Pacific Biodiversity Institute, Winthrop, Washington. 40p.

I live in Colorado and recreating in the Western United States is the great joy of my life. Running, climbing and fishing are the most meaningful experiences for me and seeing the areas that would be impacted by the proposed change is nothing short of devastating. I would very much encourage those proposing the change to listen to the voices of those who enjoy this land and live in the United States because of our amazing access. We need to preserve the land that makes this country special, not listen to the greedy extractive demands of those who have hardly stepped foot on the places they will destroy. Places impacted by this change that I frequently use would include Bears Ears, Grand Staircase Escalante, Los Padres National Forest, Sierra National Forest, Cuyamaca Mountains, the La Sals, and many other places over the years.

I am opposed to changes to the roadless rule. It is a significant measure that has been effective in preserving and managing natural resources, hiking, fishing and hunting opportunities that the public enjoys and support. I have been a visitor to national forest lands in Colorado (Uncompahgre NF, Rio Grande NF, White River NF), Utah (Dixie NF, Fishlake NF), California (Sierra NF, San Gabriel NF, others), Arizona (Coconino NF, Kaibab NF), others. I support the roadless rule and I don’t support eliminating it. Yes, the President’s donors may be trying to benefit from removing the rule, but a majority of the public supports preserving it. Utah politicians like Lee may claim no one supports measures like the roadless rule, but he is undoubtedly pandering to outside interests.

Please keep our public lands wild. Rescinding the roadless rule would tarnish the small amount of wild land our country has left. I live near Sierra National Forest, and I enjoy using the public lands for hiking. If the government rescinds the roadless rule, the scenery of my hikes would suffer, but that is nothing compared to the harm it would do to the habitats of the animals that live there. “A society grows great when old men plant trees in whose shade they shall never sit.” Rescinding the roadless rule is in direct conflict with this proverb. More roads and more logging isn’t the right answer here.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking into the Sierra Nevada is for me as it was for John Muir. There is no substitute for immersion in wilderness to refresh the human spirit, and when I travel to places like the Tuolumne River roadless area in the Stanislaus National Forest or Devil Gulch in the Sierra National Forest and capture that beauty on my phone, the people back home are delighted beyond measure by the glimpse into the natural world. That experience is what I am defending here. I oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that this letter be entered into the record in full. The agency's own language on wildfire risk undercuts the case for rescission before that case can be made. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency now proposes to open the Sierra Nevada roadless areas and others like Bear Canyon in the Los Padres National Forest to new road construction on fuels-management grounds, it must explain how that action is consistent with those words. I ask that the agency reconcile this proposal with the ignition data in its own DEIS Table 21 and explain why it departs from its prior findings on fire occurrence and fuel treatment inside roadless areas. The economic rationale offered for rescission is, by the agency's own numbers, unconvincing. The record holds: "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." Americans like me expect the Forest Service to spend its budget, which originates with taxes we pay, in a transparent and responsible manner. We want those funds used to better maintain existing infrastructure and to enhance our recreational opportunities, not to build new roads into areas the rule now protects. That expectation only sharpens when the agency's own Cost Benefit Analysis cannot establish a net benefit and when the agency is already carrying a road maintenance backlog of $6.9 billion against a road budget of roughly $73 million a year. I ask that the agency reconcile this proposal with its own economic analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, and explain how expanding a road system carrying that backlog is a responsible use of public funds. The rule the agency proposes to rescind already contains the flexibility it now cites as justification for rescission. The record acknowledges that the rule "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)." If those exceptions already address public health emergencies, existing mineral leases, and community wildfire protection, then full rescission is not the narrowly tailored response the agency owes the public. The agency must identify, with specificity, which burdens the existing exceptions do not already resolve, and it must quantify them. The water that originates in the Tuolumne River roadless area and in the other Sierra Nevada inventoried roadless areas reaches communities downstream. Americans like me want those water supplies to remain healthy, without the watershed degradation that follows road construction and heavy equipment operations. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of watersheds fed by roadless areas have impaired streams today. Opening these areas to roads risks that record. Finally, the process the agency used to justify rescission is itself defective. 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 cannot simultaneously declare foreseeable consequences out of scope and invite comment on them. There were more than 600 public meetings to make the rule, but none to undo it. Americans like me want our kids to inherit the same wild places we did. The agency must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as a full part of this action before any final decision is made. Sincerely, Kimberly S San Jose, CA

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I have spent my adult life hiking and exploring the Sierra National Forest, watching for Stellar's Jay, black bear tracks, identifying endemic plant life, and enjoying the greatest example of pristine nature our public lands have to offer. The agency's proposal to rescind the 2001 Roadless Area Conservation Rule threatens all of that, and it does so on grounds the agency's own record cannot support. The wildfire rationale the agency offers is the most striking example. The agency's own draft environmental impact statement 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 Sierra National Forest has seen what fire can do. If the agency's position is that opening roadless areas serves fire management, I ask that it explain, in direct response to this comment, why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case fares no better. The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those figures, the agency's own cost-benefit analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, set against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The road system the agency would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile those numbers and explain, plainly and on the record, how an action whose own analysis cannot establish a net benefit justifies this course. The agency's preference for a state-by-state approach over a national rule is not new, and its failure in that approach is not either. The record quotes the agency's own prior position: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit has already reviewed what happens when the national rule is replaced with local decision-making. The agency has made no showing that this proposal avoids those deficiencies. It should be required to address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values. On the question of authority, the agency argues that the 2001 rule exceeded what Congress granted. Courts that reviewed that question reached a different conclusion. The Tenth Circuit held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency should address that holding directly, including the court's conclusions regarding the Organic Act and the Multiple-Use Sustained-Yield Act, and state explicitly the basis for any position to the contrary. Wildlife depends on roadless habitat remaining genuinely roadless. The agency's own record, drawing on the federal grizzly recovery plan, documents that open roads increase shooting, habituation, and food reward, and that even secondary unpaved roads raise the contact and conflict that can ultimately end in bear mortality. The endemic plants and the wildlife of the Sierra are not abstractions. They exist in a landscape the 2001 rule was designed to protect, and that the agency has not come close to showing should be left unprotected. I oppose this rescission. Sincerely, Qixin Lang Fresno, CA

I grew up recreating in the Sierra National Forest. As a child my parents would take my brothers and I into Wilderness areas to backpack and fish. I continue to backpack and hike in my 60's in these special places preserved by forward thinking people. I urge you to not rescind the Roadless Rule. As an American, I cherish our country's public lands and waters, including the millions of acres of wild and roadless forests. There are plenty of roads already in our National Forests. Rescinding the Roadless Rule threatens landscapes that include some beautiful and well-loved places for climbing, fishing, hiking, backcountry skiing, mountain biking and paddling, as well as the economic value of recreation in many rural communities. Beyond these outdoor experiences, these protections are critically important in the face of a changing climate and changing demands on our public lands. These ecosystems help support all life on Earth, from clean drinking water to habitat for endangered wildlife. Keep the Roadless Rule in place. Millions of Americans have supported the Roadless Rule since its creation, and I join them in urging you to protect our legacy of public lands. Generations of future Americans will have to live with the damage rescinding the Roadless Rule would create. You don't know what you have until it's gone.

I am a field biologist who regularly works on national forests containing inventoried roadless areas in California that would be impacted from the rescission of the 2001 Roadless Rule including: Stanislaus NF, Sierra NF, Plumas NF, and Mendocino NF. I also regularly visit Coronado NF lands containing inventoried roadless areas in Arizona, including the Chiricahua Mountains, Dragoon Mountains, Santa Rita Mountains, and Catalina Mountains. These lands and the communities that inhabit and rely on them, some of which are threatened and endangered species, are sensitive to further fragmentation and degradation from development. Their watersheds (which humans also rely on) are sensitive to the erosion and sedimentation caused by construction and maintenance of new roads and/or other development. I strongly oppose the recission of the Rule and list objections to the rationale for the Proposal and to the draft EIS below. One of the main stated rationales for rescission of the Rule presented in the Proposal is the need to return control of inventoried roadless areas to local FS authorities because the national 2001 Roadless Rule was too restrictive and burdensome to locally adapt, specifically regarding active management for fire and fuels. Yet, on page 14 of the draft EIS, Table 1., 2001 Roadless Rule exceptions (alternative 1) (36 CFR 294.12(b) and 294.13(b) (2001)), states: “Road construction, reconstruction, including temporary road construction, is prohibited in inventoried roadless areas, except when: 1) A road is needed to protect public health and safety in cases of an imminent threat of flood, fire, or other catastrophic event that, without intervention, would cause the loss of life or property” Fuel reduction projects on FS lands in California have been actively taking place since the Roadless Rule went into effect. I know this because I have worked on these projects. I also know this because there is published research documenting these activities: “The findings in our analysis are consistent with other studies, including research supported by the Forest Service’s Rocky Mountain Research Station, which evaluated nearly twenty years of monitoring data, concluding that “a lack of roads in IRAs [Inventoried Roadless Areas] has neither prevented fuel treatment nor led to substantially more fire” (Trout Unlimited 2026). On page 24 of the draft EIS, Table 3., which shows comparison of effects under alternatives 1-3 divided by resource/topic, under Fire and Fuels Management, it states “Currently, the number, frequency, and density of wildfire ignitions are lower in designated wilderness and potentially affected IRAs compared to other NFS lands. Under alternatives 2 and 3, if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads.” This statement, along with statistics from other published, peer-reviewed, and agency-accepted studies regarding the topic (see below), refute the argument that adding additional roads would reduce fire risk by any meaningful amount. “Analysis of information about ignition source and location from the Forest Service fire occurrence dataset (USA.FireOccurrence) shows the occurrence of human-caused wildfire ignitions is strongly correlated with roads. Seventy-eight percent of human-caused fires on NFS lands nationwide start within ½ mile of a road” (Trout Unlimited 2026). References: Trout Unlimited, 2026. Roadless: Active Management and Fire A GIS data analysis and research review. September 2, 2026. Accessed October 5, 2026, online at https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa.

I’m an aspiring wildlife biologist, and, as someone who has worked, camped and explored in the lands protected by the Roadless Rule, I urge you not to rescind the Roadless Rule. It is the fact that those lands have been untouched by roads that is one of the reasons they are so beautiful. It’s the expanse of this beauty—the network of creeks and streams, the forests, grasslands, bogs where millions of things are alive, thriving, dying, and cycling—that is one of the things we as Americans can collectively be proud of. We share this land together as a country to protect, steward, and we have people from all walks of life who enjoy camping, fishing, and hunting in these protected lands. I am young and I still have so much left of American land to see and explore. I want to see the enormous trees of the Sierra National Forest. I want to see the sun set over the rock formations of Shawnee National Forest. What I don’t want to see is more rapid and easy to spread wildfires because the roads cutting through become places for wildfires to easily infiltrate into deep parts of a forest. What I don’t want to see is more and more wildlife getting hit by cars and crushed by wheels only because they want to get to areas of their home range. What I don’t want to see is more pollutants seeping into our soils and waterways. Or more floods when timber-harvested lands fail to retain water. What I don’t want to see is forests taking up less CO2 because they’re fragmented and less efficient. But these are what we may see if this rule gets rescinded. Our forests are already shrinking and burning due to wildfires and we would be putting these lands that we treasure at even more risk. Please support Alternative 1 (No Action). Thank you, Selena Cao

I am impressed with the speed and effort in the recent of repair Garnet Dike Road in the Sierra National Forest. I also understand that there is a large backlog Great work to repair Garnet Dike Road, but I do know that there is a lot of forest road maintenance that the USFS is not able to keep up with. As for the Roadless Area Conservation Rule of 2001, I support alternative #1. Please leave existing areas roadless. The argument that these new roads will help reduce wildfires overall is just plain bogus. We need wild places now more than extractive resources.

I am a mom and a 3rd generation Californian. I oppose the elimination of the Roadless Rule. I support Alternative 1: No Action Inventoried Roadless Areas protect watersheds to keep streams and the lakes they feed clean. In California these areas supply 50% of our drinking water. Inventoried Roadless Areas protect our forests from fire as data on fire ecology has shown. From a meta study published 29 January 2026, "Inventoried Roadless Areas had (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha).” That is 4 X the fires near roads! This study reviewed dozens of previously published and peer-reviewed studies from 1992 to 2024. 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 Inventoried Roadless Areas protect our wilderness and national forests because they are adjacent and surround these protected forests. Another 2007 study by Peter Morrison found 90% of wildfires in the US happen with half mile of a road. Morrison, P.H. 2007. Roads and Wildfires. Pacific Biodiversity Institute, Winthrop, Washington. 40 p. I have a personal connection to many of these areas. Specifically I have hiked and horsepacked the Dinkey Creek Lakes backcountry in the Sierra National Forest. I have hiked sections at risk on the Tahoe Rim trail near Loon Lake in the El Dorado National Forest. My husband and two children spent a lot of time in the surrounds of the Desolation Wilderness area. My brother lives near the Glass Mountains and hikes and telemark skis the backcountry there. I have wonderful memories of these clean, untouched forests and meadows and it would break my heart to see them disturbed. I value the diversity of the Jeffrey, Lodgepole, Sugar pines, and the fir trees and the fauna they support. These wild areas are a national treasure. Please also note that the current rule already allows for forest management, clearing fuel loads and removing vegetation and putting in emergency roads if necessary. We do not need more roads through our forests. Please do NOT rescind the Roadless Rule. Thank you.

Over the course of many decades, my love for the outdoors has taken me to many national forests here in California and has allowed me to form close personal connections with these remarkable places. In particular, I have backpacked, hiked, and camped in the Sierra and Sequoia National Forests extensively, those being the two national forests that I lived the closest to before moving to the Central Coast and finding myself in close proximity to the Los Padres National Forest. During the course of my lifetime, I also worked for the Sierra National Forest as a forest technician. My intimate connections to national forests have also been fueled by two of my passions: birdwatching and wildflower viewing. Because of my background recreating and working in national forests, I know firsthand what both roads and roadless areas represent. Based on my personal experiences and because of what research has shown, I can unequivocally say let the Roadless Rule stand! Hands off the Roadless Rule! 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 strongly oppose the proposal to rescind in part or in full the Roadless Area Conservation Rule. I am a landscape photographer and adventurer who visits public lands any chance I get. I see the impacts of human activity with the roads we already have across lands in Inyo National Forest, Los Podres National Forest, Sierra National Forest, Sequoia National Forest, Fishlake National Forest and many others throughout California, Nevada, Utah and beyond. These places are special. I oppose to changing this because more roads will lead to more fires as fires are way more likely to start from human activity near roads than in the wilderness alone. Existing rules already allow for roads in service of fire prevention. The ground disturbance would allow for more invasive species which are a greater fire risk as described in the draft EIS. I’m opposed to allowing commercial logging deeper into wilderness areas when there is plenty of other land already available. It’s unnecessary. The logging activity will disrupt drinking water sources and scar the landscape for short term gains that cause bigger long term losses. The roadless areas can remain roadless and areas can still be logged in a responsible manner. For these and many more reasons, I am opposed to any rescinding of the Roadless Rule in full or in part. Please adopt Alternative 1 (No Action)

As someone who hikes in the Sierra National Forest, I am writing to request that the agency maintain the Roadless Rule without exceptions. The outdoor recreation economy relies heavily on the pristine, wild character of roadless areas. Millions of Americans visit these lands every year for hiking, camping, backcountry hunting, and fishing. These activities not only increase the health and well being of individuals, they also inject billions of dollars into local rural economies. Building roads for commercial logging or resource extraction permanently degrades the quiet, backcountry experiences that draw visitors to these regions. Please protect our outdoor recreation economy and the wilderness experiences of everyday Americans by preserving the Roadless Rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The redwoods brought me here. Any old growth forest is something I would call sacred. I feel human there, and that feeling is the reason I am filing this comment opposing the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres, among them Boundary Peak in the Inyo National Forest, the Rincon area in the Sequoia National Forest, the Siskiyou area in the Klamath National Forest, and Orleans Mountain in the Klamath National Forest, along with many others across the state. These are the places I go to remember that we are just humans. I am asking the agency to keep the national rule that protects them. The agency has pursued this exact path before. The record shows that the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach." 70 Fed.Reg. at 25,656. That rejection led to state-by-state rulemaking, and the Ninth Circuit struck it down. The agency's own prior record acknowledged that local decision-making can incrementally reduce nationally significant roadless values. The forests I care about in California, including the Sespe-Frazier area in the Los Padres National Forest and the Kings River area in the Sierra National Forest, would be governed by whatever replacement approach this proposal produces. I ask that the agency explain, in this proceeding, how the current proposal avoids every deficiency the Ninth Circuit identified when the agency last tried to substitute state-by-state approaches for the national rule. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The courts reviewed that question and held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit found the 2001 rule was within the authority Congress granted and did not create de facto wilderness. The Paiute, Carson-Iceberg, Coyote Southeast, Glass Mountain, Fox Mountain, and Sawmill-Badlands roadless areas are real places, held by a real rule, upheld by a real court. The agency must state on the record what legal basis it has for a contrary position, and explain why this action survives the statutory authority analysis the Tenth Circuit already completed. The economic analysis accompanying this proposal cannot be squared with its own findings. 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. Across the Pacific Southwest region, which includes California, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. People who make their living guiding others into these forests, and communities whose water supply depends on intact roadless watersheds, are not statistical abstractions spread across a national average. The agency must withdraw the small-business certification and conduct a genuine assessment of the outfitters, guides, and operators actually permitted to work in the specific roadless areas this proposal would open to new road construction. Finally, the agency opened a door it has not looked through. 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 such a reliance interest. I go to old growth forests because the Roadless Rule has kept them that way. The rule is the basis for expecting they will remain intact. An agency that changes course must account for what people and communities have built around its prior commitments. The agency must identify and weigh the reliance interests that commenters describe, including this one, before it proceeds any further. Sincerely, Zoe Pakledinaz An American citizen who I hope you remember

To the U.S. Forest Service, I am writing to express my strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user and advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless areas. I frequently visit the Sierra National Forest near my home in California as well as many other forests I visit across the country throughout the year. Protecting these unfragmented landscapes is deeply personal to me because I not only enjoy spending time in the natural world for my well-being, I depend on these watersheds for clean drinking water, and I value the pristine wildlife habitats more than anything. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment. Sincerely, Samuel Asher Bearman

Good day, My name is Jenesis Jimenez and I am a born and raised Florida resident. Today I write to you on the matter of rescinding the 2001 Roadless Rule. I greatly appreciate the opportunity to comment and advocate for the vital need to continue preserving the 58 million acres of National Forest. Given the chance for the citizens of America to share their comments, and your required advanced identification and disclosure of harm per the National Environmental Policy Act of 1969, I am of the belief that the Roadless Rule act could not possibly be rescinded. The honor of being amongst trees that have stood proudly over the centuries is beyond words, nevertheless I will attempt to convey their invaluable role to our magnificent planet and all of the species that reside in it. The National Forests gracefully serve our country by storing clean water that downstream communities depend on and they bring in economic value of recreation in rural communities. As for the imperative function the National Forests have on the planet, the older the forest gets, the more time it has to home a fully-fledged, interconnected ecosystem. Within this ecosystem, the National Forest takes charge of supporting the native and endangered wildlife. The undisturbed effect that the Roadless Rule allows for the National Forests have must be thoroughly reviewed in the environmental impact statement. Habitat connectivity is understood as one of the most important functions of intact, roadless forests, providing migration corridors for species such as elk, deer, fishers, and salmon. Rescinding the Roadless Rule would fragment these landscapes, cutting off wildlife from breeding grounds, food sources, and seasonal ranges, and diminishing the ability of older forests to sustain resilient ecosystems and buffer against climate change. My personal experiences immersed in the old growth forests at Sequoia National Forest and Sierra National Forest, have given me a greater understanding of the meaning of life that could not have been taught without the history of their trees. Allowing for the construction of roads and harvesting of timber, would not only be a great dishonor to the land but would ultimately be detrimental to the sensitive ecosystems, and cause more damage to the environment at an expedited rate.A Pacific Biodiversity Institute study found that over 90% of all wildfires occurred within a half-mile of a road. This is largely because humans, who start the vast majority of fires, are most active near roads. Although the rationale for rescinding the Roadless Rule to permit road building in IRAs is given as reducing wildfire risk, a wide body of research shows that the opposite is true (Aplet et al., 2026; Balch et al., 2017; DellaSala and Frost, 2001; Yang et al., 2006). Shifting fire regimes are the main driver of increased structure loss (Higuera et al., 2023) and have profound implications for species distribution by modifying ecosystem composition and transforming threatened species habitat (Doherty et al., 2024; Hantson et al., 2024). Logging within IRAs runs counter to the urgent need to prevent forest degradation of intact forest ecosystems (Moomaw et al., 2019; Pan et al., 2024; Watson et al., 2016). The protection of Earth's remaining intact forests, including IRAs, is necessary to help humanity adapt to some of its greatest challenges – water security, climate change, and biodiversity loss. The proposed rescission of the Roadless Area Conservation Rule endangers irreplaceable intact forest landscapes in the US. These areas are part of a global network of intact forests vital to regional and planetary health (Dinerstein et al., 2020; Ibisch et al., 2016; Selva et al., 2015; Watson et al., 2018b). The justifications for rescinding the Roadless Rule are fiscally misguided and ecologically flawed. Please keep the Roadless Rule entirely intact. Sincerely, Jenesis

Subject: Public Comment in Strong Opposition to Rescinding the Roadless Area Conservation Rule (Docket ID: FS-2025-0001) I am writing to express my strong opposition to the proposal to rescind the 2001 Roadless Area Conservation Rule, which currently protects roughly 4 million acres of pristine public lands across California. Stripping these protections will directly threaten vital, undeveloped backcountry areas in places like the Los Padres National Forest, the Inyo National Forest, and the Sierra National Forest. Allowing commercial logging and industrial road construction into these intact ecosystems will permanently degrade critical wildlife habitats, increase roadside wildfire risks, and jeopardize clean drinking water supplies for millions of Californians. I urge the U.S. Forest Service and the Department of Agriculture to abandon this proposal and keep the 2001 Roadless Rule fully intact to safeguard California's wild forests for future generations.