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Please, do not rescind or alter the roadless area conservation rule in any way. I recently had the opportunity to visit three amazing roadless areas in Oregon. They were not the first I had visited, as I love exploring outside and have been doing so as often as possible — usually with my kids — for more than 20 years. In fact, I moved to Oregon to explore the outdoors that I had heard so much about having grown up in the midwest. The places I visited and so many more like them within Oregon’s more than 2 million acres of roadless forests — and the nation's more than 45 million acres — are absolutely amazing. I cannot believe that you would even consider building roads into some of these areas, or opening them to logging, mining or other industrial activity. These are a legacy that should be left for future generations to enjoy and for the benefit of all the other species we share this world with. Tamawanas Falls, Mt. Hood Additions Roadless Area, Mt. National Forest Part of a 7,000 acre roadless area, this amazing, short hike to an epic waterfall was breathtaking. It was not remote or tranquil, but amazing to be able to share this experience with so many other people out there enjoying the natural world on a beautiful Sunday afternoon. Mt. June, Hardesty Mountain Roadless Area, Willamette and Umpqua National Forests A spectacular climb through this 6,300 acre roadless area spanning two of Oregon’s national forests. Spending a morning in this area to catch post-sunrise at the summit. To spot a deer on my way up through the lush woods. To feel like I had the mountain to myself, not seeing another hiker that morning — but hearing the echo of owls and birds ring through the understory. Niagara Falls, Hebo 1a Roadless Area, Siuslaw National Forest A nearly 14,000 acre area in the coast range. An easy hike through a lush forest to a waterfall, which I am sure is much more prominent in the spring (I can't wait to return). Full of a variety of mosses, lichen, fungi, slugs, frogs, birds and one of my favorite things to see on a hike — nurse logs. I have attached a photo from each of the places I visited most recently, so that you can —and indeed have to — see just a few examples of what you would be spoiling just here in Oregon. To make sure that you open your eyes to the natural world that is not just here for exploitation and profit. Upon leaving these places recently, I was also confronted by spray paint on numerous trees marked to be cut and also an active logging operation before I exited those national forests. I just can’t imagine seeing either of those sights in the areas I spent the day hiking in. When will enough be enough? There are so few of these places left. Please do not rescind or alter the roadless area conservation rule. Thank you for considering my voice. Justin Boyles Portland, OR

I am a resident living near the Siuslaw National Forest in the Pacific Northwest where I regularly enjoy hiking the trails in Siuslaw. I’ve enjoyed hiking and camping in other roadless national forest areas, including the Olympic, and the Willowa Whitman National Forests. I am urging the USFS to retain the 2001 Roadless Area Conservation Rule and I select the No Action Alternative because the USFS did not provide any documented justification or evidence of any direct economic benefit for rescinding this rule. It sites no studies or reports to strengthen its position. Most documented studies point to an economic detriment that would result from rescinding this rule. This proposal to rescind a Rule that emerged from a thoroughly inclusive and collaborative bipartisan process is so poorly presented that its only result will be the immediate launch of multiple nationwide lawsuits. One of the best aspects of the National Forest system is that its lands belong to all Americans; lands that all people pay for with their tax money, and that the use these protected areas are cost free. The roadless areas must stay that way for generations because the total roadless areas amount to only about 24% of the Forest Service lands. The USFS has not provided a credible rationale for why the 2001 Roadless Rule should be rescinded. For example, the Forest Service makes the vague rationale that “as resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from the timely, place-based discretion needed to meet the Forest Service's multiple-use mission. The USFS states that 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. This statement is false. The 2001 Roadless Area Conservation Rule does allow for emergency wildfires measures and other approved projects. In addition, the USFS has not made a credible argument for why the Roadless Rules law is a problem for preventing wildfires and vegetative diseases. Regarding wildfire threats, the USFS has not cited any evidence of where its efforts at fighting wildfires were hampered by the lack of roads in areas designated within the Roadless Conservation areas. Conversely roads are proven to play a measurable role in wildfires. NPS studies have already shown that 85% of wildfires are caused by human activities, and 78% of them occur within one half mile of a road. The USFS has not cited any economic studies that show how extracting timber from these areas will create a significant ongoing economic benefit to surrounding communities. Over the decades of timber extraction, those jobs have proven to be temporary for surrounding communities. However, it is proven many times over that surrounding communities benefit from wildlife and recreational tourism where the scenic beauty is protected.. To be clear, adding more roads only adds millions more dollars in road maintenance costs when it’s reported that the Forest Service is already $7 to 9 billion behind in deferred maintenance on its 375,000 existing roads, culverts and bridges. The agency is not estimating economic or environmental impacts correctly or consistently, and the unintended consequences of rescinding this rule will further drain needed resources and have long term negative economic and environmental costs. Again, the 2001 Roadless Rule already allows limited exceptions for road construction and timber harvesting in certain circumstances, such as responses to wildfires and other emergencies, just not industrial level timber extraction and road construction. In summary I urge the USFS to retain the 2001 Roadless Area Conservation Rule and I select the No Action Alternative .

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to eliminate or weaken the Roadless Rule. I'm an Oregonian and frequently spend time hiking, backpacking, hunting, and exploring many of the Roadless areas in Oregon, Washington and throughout the West. Repealing or weakening the Roadless Rule is reckless and unnecessary. It will waste taxpayer resources, devastate public lands, and degrade watersheds (and our clean drinking water), disrupt wildlife areas, and destroy fragile and intact ecosystems. Just last month I went on an annual backpacking trip with my two sons and my sister to Bobby Lake in the Maiden Peak roadless area in the Deschutes National Forest. This was one of the few areas in Oregon last summer (2026) not impacted by wildfires. There were so many folks out enjoying many of the backcountry campsites - adventuring into the wilderness to experience a weekend without the noise and pollution of vehicles, to fish in the lake, to enjoy being "out in nature". This is not the same experience with a road running through it. The Deschutes National Forest, and the Willamette National Forest it borders, are unique and special recreation areas that folks from all over the US come to enjoy. We should be doing more to protect these areas, not stripping them of the few protections they currently have. A few days ago, I took friends visiting the coast to explore the Oregon Sand Dunes near Tahkenitch Creek in the Siuslaw National Forest-- another area currently protected by the Roadless Rule. We love this area because of the miles of contiguous sand dunes-specifically because there are not roads running through the Dunes. This fall, I will go elk hunting with neighbors in another Roadless Area in the Siuslaw, near Drift Creek. This area is great for hunting in part because there are not roads cutting through it, which limits traffic, vehicle noise, and human access. Wildlife, Elk included, avoid roads, vehicle noise, and human noise. Wildlife rely on these contiguous wilderness/forested regions--these are places they can live and thrive without constant threat of human impact. These are also areas that hunters in our region rely on to be able to fill tags each year. Again, this is a place we should be doing more, not less to protect our forests. We should keep the roadless rule intact Roadless forests include some of the most resilient ecosystems in our country. They filter and store clean drinking water, provide refuge for vulnerable species, and serve as carbon sinks mitigating the worst impacts of climate change. Americans love these forests: we hike, hunt, forage,fish, camp, ski, climb, and find solace in these remote places. Roads spread invasive species, fragment wildlife habitat, and destroy ecosystems. More roads in the backcountry also lead to more fires: research shows wildfires are more likely to ignite near roads--most fires are caused by humans. More access leads to more fires started. Once roads and clearcuts fragment these landscapes, the damage is permanent. Weakening or repealing the Roadless Rule is a mistake. I strongly oppose any actions that weaken the Roadless Rule. Please abandon this misguided effort and instead strengthen America's commitment to protecting our forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule in place. References: 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 Mildrexler, D.J., Berner, L.T., Law, B.E. & Both, M.S. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation 321, 111950 (2026) https://doi.org/10.1016/j.biocon.2026.111950

I am submitting my comment to vehemently oppose partially or fully rescinding the Roadless Rule. To reverse this rule would throw decades of peer-reviewed research in the trash, to favor short term financial gain for very few and without benefit to the American public. To allow such a change would be a dereliction of the Agriculture Department's duties to protect public health, conserve natural resources, and responsibly manage agricultural production. In 2025, approximately 99% of public comments opposed changing the Roadless Rule. Despite this, the federal administration is once again attempting to force this through without appropriately addressing the public's substantial opposition to partially or fully rescinding this rule. Roadless areas are some of the last intact landscapes in America, providing clean water, critical wildlife habitat, and world-class recreation opportunities. As a resident of Oregon, my health, safety, and enjoyment of public lands include Roadless areas like Larch Mountain, Lost Lake, and the Salmon River Trail (Mount Hood National Forest), Iron Mountain and Hardesty Mountain (Willamette National Forest), Oregon Dunes (Siuslaw National Forest), Lookout Mountain (Ochoco National Forest), Joseph Canyon (Wallowa-Whitman National Forest), and Tumalo Mountain (Deschutes National Forest). In the summer of 2026, Oregon saw some of the worst wildfires in our country's history, and unsustainable forestry, deforestation, fragmented habitat, and irresponsible recreation were largely to blame. Not a lack of roads. The proposed changes to the Roadless Rule fail to consider the overwhelming body of scientific evidence that habitat fragmentation increases wildfire risk and negatively impacts protected species. Alternatives 2 and 3 of the Draft EIS are wholly unacceptable. Therefore, I support Alternative 1 - No Action.

I oppose the proposal to rescind or alter the Roadless Rule, and I support Alternative 1, the No Action alternative. I write this comment as an Oregonian. My home state has 211 roadless areas encompassing 1.9 million acres. I regularly recreate in and near roadless areas on the Deschutes National Forest. My spouse and I paddle our kayaks on lakes that are bounded by or sit within roadless areas, including Elk Lake, Hosmer Lake, Sparks Lake, and Little Lava Lake. We also enjoy visiting roadless areas across the state. Wildflower hikes near Iron Mountain on the Willamette National Forest and visits to Drift Creek roadless area on the Siuslaw National Forest are cherished experiences. Rescinding the Roadless Rule may well destroy the unparalleled plant diversity of Iron Mountain and Cone Peak. It would certainly affect the bird watching on the Cascade Lakes. In addition to affecting my personal enjoyment of my local forest, this would decimate the tourism economy in Central Oregon. As many Oregonians will tell anyone who will listen, we greatly value our quiet outdoor experiences. Many of us, myself included, have a need to recreate without having to listen to noisy vehicles or the sort of loud and inconsiderate people who only go where they can drive. People need places they can go, under their own power, that are quiet and remote—areas that promote solitary enjoyment of nature. I’m very concerned that the proposal to rescind the Roadless Rule has been made without due consideration of the impact of climate change as well as the repercussions on the climate. So much of Oregon has burned in the last 10 years, in part because of changes in the climate, that more people (i.e. Oregonians who need their solitude in untrammeled natural surroundings) are recreating in a decreased area. Opening up roadless areas would further degrade the remaining back-country areas by making them vulnerable to potential development. In addition, destruction of old-growth temperate rainforests and sub-alpine forests would release massive amounts of currently sequestered carbon, thus accelerating global temperature rises and increasing drought. This in turn would lead to more intense wildfires. The result is a destructive cycle that worsens the climate catastrophe worldwide, with negative impacts on recreation and natural splendor, degradation of water quality for humans and habitat for many protected species. This also means that communities like mine in Central Oregon will be increasingly threatened with total destruction by wildfire. Not everyone living on or near the urban/wildland divide can afford to fire-harden their residences. In fact, many can only afford to rent, and landlords are not investing in hardening rental properties against wildfires. That leaves belongings at risk when evacuations happen. The average American cannot pay for private fire protection services in the case of threat by wildfire. The increasing frequency of evacuations in these communities greatly impacts work availability and ranchers’ ability to care for livestock. Evacuations are becoming much more frequent, and they use up vast amounts of financial resources and time that working Americans do not have to spare. Proponents of rescinding the Roadless Rule have argued that they are motivated to improve wildfire management. They argue that roadless areas hinder firefighting efforts. This argument is specious and disingenuous. Roadless areas are much less likely to start burning in the first place. Analysis shows that areas with roads have increased instances of fire starts compared to roadless areas. The vast majority of fires are human-caused. Furthermore, if they were serious about limiting wildfires, they would realize that the increased timber harvests that would undoubtedly follow the opening of roadless areas will release currently sequestered carbon, which in turn would worsen climate change and promote more frequent and more intense fires. My drinking water comes from a watershed in an inventoried Roadless Area. Opening the area to roads would threaten the quality and safety of my drinking water. Please do what is right for Americans and do not fully or partially rescind the Roadless Rule under Alternatives 2 and 3 of the draft EIS. I oppose the proposal to rescind or alter the Roadless Rule, and I support Alternative 1, the No Action alternative.

I am writing in opposition to altering or repealing the Roadless Area Conservation Rule. I am a former forest service natural resources employee and an active recreational user of my local national forests and inventoried roadless areas are a critical component of the US forest service's land management strategy of balancing ecosystem maintenance with recreational and resource extraction. Many inventoried roadless areas preserve ecologically sensitive areas of our national forests from the habitat fragmentation, increased wildfire risk, and water quality degradation that roads bring to an area. Limpy Rock in the Umpqua National Forest is an inventoried roadless area that I have visited several times to birdwatch and observe the rare Kalmiopsis plants that grow there and only a few other places in the world. This roadless area and the rare endemic plant that it protects are a tourism draw for the area. Removing this area's roadless protections to allow for timber sales would potentially drive the local Kalmiopsis population to extinction. Other inventoried roadless areas such as Shasta Costa on the Rogue River-Siskiyou National Forest and Tahkenitch on the Siuslaw National Forest are similarly a recreational draw because of the lack of roads and their associated industrial use. I made an effort to visit these areas despite the lower level of access because of the relatively intact nature of the ecosystems in these areas and the fragments of late seral ecosystems that remain within them. The Roadless Area Conservation Rule already provides the ability to conduct ecological forest management activities within roadless areas, and the construction of roads if needed for wildfire response, so there is no need to modify the roadless rule in order to respond to wildfires on our national forests. Please protect these areas from the degradation that roads bring by not altering or repealing the Roadless Area Conservation Rule.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. We need to protect our wild, public, and National Forest lands. I live in Oregon and this would affect 2 million acres here including the Mount Hold National Forest that has seen devastating wild fires this fire season. Rescinding the Roadless Rule would put already strained areas under more pressure and risk that would affect our beautiful state lands, our resources, and our people. We have seen enough unprecedented wildfire seasons and the trauma they cause in the last few years, and the chances would increase 4 times over as studies show due to roads and logging. We need to be mitigating these risks as our climate changes, not increasing them. Not to mention increasing funding to keep up these roads. The National Forest road system maintenance is backlogged in deferments close to $7 billion, with a B. And we would only be increasing that burden on taxpayers and the Forest Service workers who have been targeted by cuts. This administration ran on saving the people money and would only be putting more pressure on taxpayers that are already seeing tension build as prices for everyday necessities rise. This will create financial anxiety on top of the anxiety of increased fire risk, resource safety with changes to watershed protection for over 2 million Oregonians (that's one Oregonian at risk for every acre, just in case you weren't counting), and the fear of losing or changing recreational areas that many Oregonians enjoy and many tourists come here to enjoy, boosting our local economies. This is also threatening Indigenous cultural values. Many of the proposed areas affected are next to reservation land like the Grande Ronde, Warm Springs, Siletz, and Umatilla reservations. Much of this land is culturally important for traditional ways, for food sovereignty, and native plant restoration (which has been crucial for habitat repair after big fire seasons like the one this year). And majority sentiment among tribal governments is opposed to the Roadless Rule change. And these are just the human considerations, this is not considering the loss of habitat and the destruction of ecosystems among our most intact forests that are home to many important species of flora and fauna native to our area, many that are threatened including the marbled murrelet that require old growth coastal forests, such as the Siuslaw National Forest lands that would be targeted. And this is just for Oregon, each state has its own lands and resources that this would devastate and it would cause repercussions for all of us as a whole, both environmentally and economically. For all of these reasons, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a detrimental mistake for all of us. I wholeheartedly oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1 which is the no action rule. We must protect what makes America great and that is our people and our wild, public, and National Forest lands.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Dark Divide felt like nothing else I've seen in the Cascades. I ran a 100 mile race there in September, moving through country where you could go mile after mile without seeing a car or a road. That is what roadless areas make possible, and it is what this rescission would end. I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001). I am an ultra trail runner. The acreage to run without seeing cars or roads in roadless areas is my favorite way to experience the National Forests. The Dark Divide, at 52,483 acres in the Gifford Pinchot National Forest, gave me that. So does Drift Creek, 6,333 acres in the Siuslaw National Forest, which sits surrounded by private clearcut logging and stands as an echo of the majesty of what the Oregon Coast Range temperate forest used to be before extractive colonialism stripped it. Hebo 1a, another 13,930 acres in the Siuslaw, is another small remnant of what remains of that rainforest. These places are also where old growth forest still stands, and old growth is where I go to photograph, where biodiversity is greatest, and where, even as summers grow hotter and drier, the forest still feels cool and damp. What remains of that old growth is rare. Roadless areas help balance the conservation mission of the Forest Service by protecting some of the 4% of remaining old growth in this country. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. The agency should say plainly, on the record, what share of remaining old growth in Oregon would be exposed to road construction and timber extraction if those areas lose their protection. The agency's own analysis undermines the wildfire rationale it offers for this rescission. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." 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. I ask that the agency quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard, and that it explain how the proposal departs from its own prior findings as recorded in DEIS Table 21. Intact forests protect and clean water for communities and wildlife. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. My tax dollars should go toward protecting those ecosystem services, not toward building new roads into country that has none, especially when the agency already carries a $6.9 billion maintenance backlog against a road budget of roughly $73 million a year. The record the agency itself assembled states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. How does an action whose own analysis cannot establish a net benefit justify expanding a road system the agency cannot afford to maintain? The rule as written already accommodates the concerns the agency invokes. 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)." I ask that the agency identify specifically which burdens are not already addressed by those existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and that it quantify each claimed burden with evidence in the record. I commented on this rescission in 2025. By the agency's own count, 99.5% of comments were against it. That the administration proceeds regardless raises a direct question about its obligations under the Administrative Procedure Act and the notice-and-comment process. The agency must address in the record how a response rate of that character is consistent with its duty to consider public input rather than to discard it. Sincerely, Brian Dugovich Corvallis, Oregon

As a resident of Yachats, Oregon, I am deeply troubled by the proposed changes to the Roadless Act and urge you to reverse course and leave it as is. We need a permanent roadless rule. Increased logging and the accompanying roads will only increase the potential for fires that could devastate our nearby forests and potential endanger our homes. New roads will make our forests more vulnerable--not less--to wildfires. The University of Oregon and Oregon State University scientists have researched this vital issue and they have concluded that fires are four times more likely to be started near roads due to increased vehicle traffic. Yachats relies on surface water from Reedy Creek and Salmon Creek, tributaries of the Yachats River. This flows directly out of the Siuslaw National Forest. Your own DEIS acknowledges the likelihood that removing roadless protections will risk soil erosion. Sediment will flow into those very creeks that supply our water. The Yachats treatment plant will struggle to filter our water and we might end up without fresh water flowing out of our faucets. Our community, like so many others in our beautiful state of Oregon, will see degradation of our forests, increased potential for landslides that can cut us off entirely (like the area near Siletz on Highway 229 that will take years to address), and loss of habitat for many species. I strongly oppose these changes.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My name is Olivia Clements and I am a lifelong Pacific Northwesterner. As an artist, photography taught me to look closely, and what I keep finding along the Pacific Coast is irreplaceable. From the Mt. Baker-Snoqualmie National Forest to the Siuslaw National Forest to the Humboldt Redwoods, the colors, landscapes, trees, climate, and wildlife of this region are unlike anything that can be reconstructed once lost. I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because the agency's own record does not support it. As it currently stands, the argument to repeal the Roadless Rule is based on faulty logic and false claims. The wildfire rationale the agency offers for rescission is flatly contradicted by its prior findings. The agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The Siuslaw and the forests I travel to photograph already face pressure. Adding roads does not reduce ignition risk; the agency's own data says the opposite. I ask the agency to explain why this proposal departs from those prior findings and to 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. Additionally, arguments for the repeal of the Roadless Rule strongly imply that roadless forests as they currently stand are unmanaged. This could not be further from the truth. Forests and spaces protected in the Roadless Rule are managed forests, meaning they undergo steps to reduce fire risk-including minimal but responsible logging to mitigate wildfire risk. To imply that a roaded forest is a safer forest is not only false, but detrimental to the health and safety of all-environment, wildlife, and recreational participants. The fiscal reasoning is no stronger. 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." These are not numbers that describe a national economic emergency. The agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. Meanwhile, the agency already carries a $6.9 billion maintenance backlog on its existing road system. My own view is simple: steward our resources toward maintaining what we have, rather than spending money on destructive infrastructure that exacerbates environmental and wildlife health. You can lay cement anywhere, but you can't replace our one, precious earth. The agency must explain on the record how an action whose own analysis cannot establish a net benefit justifies expanding a road system already in deficit. The agency also claims permitting burdens as a reason for rescission, but the rule as written already contemplates the situations it cites. The rule, by the agency's own description, "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)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection are already embedded in the rule. The agency should identify, specifically and quantitatively, which burdens are not already addressed by those exceptions, and place that accounting on the record. Finally, the regulatory flexibility analysis underlying this proposal does not hold together. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides, and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by averaging an estimated loss across every small firm in the sector nationally, rather than examining the outfitters and guides who actually hold permits in the affected areas. The photographers, guides, and small operators who work in forests like the Siuslaw are not a national average; they are specific businesses facing specific losses. The agency should withdraw the certification and conduct the analysis on the entities actually operating in the potentially affected roadless areas. Sincerely, Olivia Clements Seattle, WA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hunting in the woods with friends, breathing clean air in the campgrounds of Oregon and Washington, watching the recovery continue on the slopes of Mount St. Helens. These are the things I am asking you to protect when I oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. Being out in the woods is good for the soul. The beauty of wild places and the animals in them is unmatched. I also spend time in state and national campgrounds in Oregon and Washington for the clean air, the quiet, and the enjoyment of nature away from the noise of city life. It is affordable vacation for many people. I want my children and grandchildren to have wild places with old-growth trees to revere and experience. I do not think they should inherit fewer of these places than I did. The Siuslaw National Forest holds the Oregon coast range, the dunes, fresh water, and salmon. Salmon depend on cold water, and the agency's own record states that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and that warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, with the affected area including Essential Fish Habitat and critical habitats managed by NMFS. The Siuslaw's roadless areas amount to 52,000 acres of coast range forest that the agency would open to new road construction. I ask the agency to address what specific protections replace those lost for cold-water fish habitat in the Siuslaw if this rule is rescinded. The Deschutes National Forest is a high desert place of calderas and ancient formations, fantastic and unlike anywhere else. Bend and the surrounding area get their water from this forest, and this should not be threatened. Bridge Creek, running through old-growth forest on the Deschutes, supplies roughly 60 percent of Bend's municipal drinking water. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The Deschutes holds 136,000 acres of inventoried roadless area, and the lower Deschutes holds one of only two national strongholds for federally threatened bull trout. I ask the agency to explain how rescinding federal roadless protections over these watersheds is consistent with its obligations to communities and to listed species whose strongholds sit inside them. The Olympic National Forest is magical. Having no roads through the middle of the peninsula is a true treasure. The 86,000 acres of roadless area there, with their old growth and pure water, must be maintained. The agency argues that new roads serve wildfire management, yet its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." I ask that the agency reconcile this proposal with that finding and explain what ignition data now overrides it. The agency also argues that opening these areas generates economic benefit. Its own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency 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 agency already carries a $6.9 billion road maintenance backlog on a road budget of about $73 million a year. No new roads. The Gifford Pinchot National Forest, with Mount St. Helens and its continuing recovery, holds 213,000 acres of roadless area I have visited since childhood. The agency now argues that state-specific management can replace the national rule, yet its own record shows: "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 already rejected the last attempt to substitute local approaches for a national rule, finding that piecemeal local decisions can erode nationally significant roadless values. Leave the little remaining old growth alone. Leave the natural water sources alone. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. That process failure alone demands a full answer before this rescission moves any further. Sincerely, Kristina Rheaume Portland, Oregon

My name is Kaitlyn Hanley, I am a scientist and avid hiker of National Forests, in my backyard (the Rogue-River Siskiyou National Forest, Siuslaw National Forest and Umpqua National Forest) and beyond. I oppose the propose rule to fully or partially rescind the Roadless Area Conservation Rule (Roadless Rule). While I can understand why folks may think increasing management flexibility sounds like a good idea, the rescission of this rule would not result in management flexibility but would result in an expansion of the system of roads that already are challenging to manage with limited budgets, increase the risk to critical water supplies local communities rely on and are likely to increase wildfire risk, not reduce it. First, rescinding the Roadless Rule is likely to result in an expansion of road systems into roadless areas which would require construction and routine maintenance that would result in an increase financial burden on taxpayers and Forest Service Staff. Recent reductions in force have reduced the agency by 20%, reducing their capacity to tackle existing deferred maintenance. In fact, the DIES estimates new roads across 18.2 million acres (44.5% of current IRAs) in the short term would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion. This particularly holds true for Forests in coastal Oregon where steep unstable slopes routinely result in road failure. It is also inconsiderate to the municipal towns and cities that rely on roadless areas for their drinking water to expose those watersheds to sedimentation risk and reduced water quality. The agency's own analysis indicates that roads and their associated facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of the relevant watersheds have impaired streams today, and opening these areas to new road construction would put these water resources directly at risk. The agency has not accounted for what that means to the communities downstream, and it should be required to answer for that gap before any final action is taken. Additionally, the agency describes wildfire management, particularly in the WUI as a need to rescind this rule which a false cause and oversimplification of a complex issue. First, fire reduction in the WUI is essential to protecting human life and property, but the WUI is not often proximal to roadless areas. In fact, research has shown reserve lands like roadless areas have limited interaction or ignition risk for wildfire in WUI (Ager et al. 2016). Second, increased road density is linked to human-caused wildfires with recent research finding that fires are 4 times more likely to start near a road than in a roadless area (Applet et al. 2026). Thus new road access could increase the number and frequency of wildfires. The claimed wildfire hazard reduction cannot be evaluated honestly without quantifying what road access adds to ignition risk, and the agency has not done that. It should. Finally, national forests near me and throughout the West are where I spend much of my personal time. The gas, food, and lodging I pay for in small towns along the way is part of how those communities sustain themselves. Recreation supports those local economies, and the protections that make those forests worth visiting are what make that economic relationship possible. Rescinding the 2001 Roadless Area Conservation Rule would unravel those protections and I oppose it. Thank you for considering my comment. Sincerely, Kaitlyn Hanley Coos Bay, Oregon

Re: Docket No. FS-2025-0001, RIN 0596-AD66 — Proposed rescission of the 2001 Roadless Area Conservation Rule My name is Kari Hansen. I live in rural Washington County, Oregon, five miles down a gravel road from the nearest pavement. The woods are not scenery to me. They are where I live. I live in the Tualatin Mountains on the edge of Oregon's Coast Range, so the Siuslaw National Forest is my neighboring national forest. Places like the roadless ridges around Mount Hebo are the kind of country I live beside. The Mt. Hood National Forest's roadless acres matter to me too. And across the river in Washington, the Dark Divide in the Gifford Pinchot National Forest is the largest unprotected roadless area in the Cascades, and it deserves to stay that way. I oppose rescinding the 2001 Roadless Rule. It has protected some of the last large undeveloped forests in this country for 25 years. Once the roads go in, the quiet goes, the clean water goes, and the habitat goes, and none of that comes back. Please keep the 2001 Roadless Rule in place. Kari Hansen North Plains, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Siuslaw National Forest is where I hike one to two times a week, drawn by big trees that dominate the landscape in a beauty you need to experience. I kayak three to four times a month on Woahink, Tahkenitch, and Tenmile Lakes and on the Siuslaw, Umpqua, and Alsea Rivers. The land around these waters is magnificent. People come here to recreate and to connect with nature, but these forests also capture carbon, sustain essential habitat for animals including humans, and provide the watershed for thousands of people. I am submitting this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule because the places I depend on, including the Tahkenitch, Tenmile, Woahink, and Smith Umpqua roadless areas within the Siuslaw National Forest, sit inside the 1,937,741 acres of inventoried roadless land Oregon holds, and the proposal threatens all of it without adequate legal or factual support. The agency justifies rescission partly on wildfire and fuels management grounds, yet its own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." Opening roadless areas to new road construction in forests like the Siuslaw, where I hike weekly beneath those big trees, does not reduce fire risk; the agency's own data says it compounds it. I ask that the agency explain why the proposal departs from these prior findings, and that it reconcile the rescission with the ignition data reported in DEIS Table 21, which the record shows reflects far higher fire density on roaded land than inside the affected roadless areas. The economic justification is no stronger. 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 marginal extraction figures, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of only $5.2 to $11.4 million a year, while projecting recreation losses of at least $6.1 million a year and a net present value ranging from negative $92 million to positive $199 million. A range that wide cannot establish a net benefit, yet the agency proposes to expand a road system already carrying a $6.9 billion maintenance backlog. The rivers and lakes where I kayak draw visitors and support local economies in ways the proposal does not seriously account for. The agency must explain on the record how this arithmetic supports rescission. The proposal also certifies no significant impact on small entities, yet the DEIS identifies outfitters, guides, and tour operators as affected parties, and the Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The regulatory flexibility analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually permitted to operate in the affected areas. The Pacific Northwest, which includes Oregon, has 1,522 municipal water intakes sitting in watersheds containing affected roadless areas, meaning the communities those small businesses serve are directly at stake. The certification should be withdrawn and replaced with an assessment of the specific small entities operating within and around these roadless areas. 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 one such interest. I have organized my weekly hikes in the Siuslaw and my regular paddling of Tahkenitch, Tenmile, Woahink, and the surrounding rivers around the protections the 2001 rule provides. Under controlling administrative law, an agency reversing course must genuinely identify and weigh the reliance interests its prior policy created. The agency should treat the comments it receives, including this one, as the reliance record it invited, and give that record real weight before proceeding. Sincerely, A concerned citizen Yachats, Oregon

I am appalled at the Trump administration's attack on our forests and I am writing to oppose the rescission of the Roadless Area Conservation Rule. I live in Oregon and the forests around Smith Umpqua, Hardesty Mountain, and Fairview are the places I visit on a regular basis to camp, hike, and bird watch. Rescinding the 2001 Roadless Area Conservation Rule would open them, and the 211 inventoried roadless areas totaling 1,937,741 acres across Oregon, to road construction and the harms that follow. Opening up this land would cut down and destroy more of our forests and habitat for wildlife. Not only that, building roads into our forests will increase the risk of human-caused wildfires. The agency's own record undermines the wildfire rationale offered for rescission. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding is the agency's, not mine. If roads into areas like Smith Umpqua on the Siuslaw NF and Fairview on the Umpqua NF increase the likelihood of human-caused ignitions, the agency must explain why it now treats road access as a wildfire remedy. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and reconcile the rescission with the ignition data in its own DEIS. That data is specific. The DEIS reports: "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." Hardesty Mountain at 2,597 acres sits alongside Fairview at 7,417 acres and Smith Umpqua at 7,622 acres. These are not abstract numbers. Opening such areas to roads would, by the agency's own data, sharply increase ignition risk within them. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this proposal can proceed. The recreation and small-business analysis is internally inconsistent. The agency's own materials state: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification is reached by spreading the $9 million annual expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The Pacific Northwest, which includes Oregon, has 1,522 municipal water intakes in watersheds containing affected roadless areas, meaning the downstream consequences extend well beyond recreation. The agency should withdraw the small-business certification and assess the impact on the specific firms operating in the potentially affected roadless areas, not the national average firm. Finally, the agency has solicited comment on reliance while declining to weigh any of it. The proposal requests "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 precisely such an interest. The forests at Smith Umpqua, Hardesty Mountain, and Fairview on the Umpqua NF are places whose protection under the current rule I have counted on. Under the legal standards governing agency change of course, that kind of reliance must be identified and weighed, not solicited and then set aside. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Leave our forests alone! Sincerely, Stephanie Wolpers Eugene, OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Siuslaw National Forest is where this proposal lands for me. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and the Siuslaw and its nearest areas account for 58,236 of them. Every one of those acres stands to lose its only federal protection under the current proposal. I vacation in Oregon and Washington and depend on many of these areas for fishing and camping. Don't ruin them for future generations. The agency's turn toward state-by-state decision-making is not new, and the courts have already reviewed it. When the USDA previously moved away from a national rule, 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. The Ninth Circuit found that approach legally deficient. This proposal revives the same logic without explaining what is different now. I ask that the agency address its own prior finding that local decision-making can incrementally reduce nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time the agency replaced the national rule with a state-by-state approach. People like me who fish and camp in Oregon's roadless areas have organized our recreation around the protections the 2001 rule provides. Those protections matter to the water as much as to the experience. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency has invited public comment on exactly this kind of stake: 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. An agency changing course is required to assess the reliance interests its prior policy created. This comment is one of them. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The environmental review in this proposal did not seriously consider keeping or strengthening protections for places like the Siuslaw. Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose defined purely as deregulation cannot produce the honest comparison among alternatives that NEPA requires. Foreclosing protective options at the outset is not analysis. The agency must restate the purpose and need in terms of actual forest conditions and analyse at least one protective alternative in full. Finally, the agency has reversed a factual finding it made in 2001 without accounting for that reversal. The proposal asserts that local land management planning now adequately protects roadless values; in adopting the 2001 rule (66 FR 3244) the agency found the opposite, that local planning had allowed those values to be reduced piece by piece and that their national significance required a national rule. The 58,236 acres of roadless land associated with the Siuslaw are nationally significant for the same reasons they were in 2001. Nothing in this proposal identifies what changed. The agency owes a reasoned explanation: what evidence supports the reversal, and what is the agency's response to its own prior finding that local planning was insufficient to protect these values? Sincerely, Mr and Mrs Harold Richter Minneapolis, MN

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Siuslaw National Forest (52,000 acres), Siuslaw National Forest, Oregon - Deschutes National Forest (136,000 acres), Deschutes National Forest, Oregon - Hardesty Mountain (2,597 acres), Umpqua NF, Oregon As a resident and taxpayer in Oregon I benefit from the ecosystem support of roadless areas. The flora and fauna that exist across my own property does so because these areas are unharmed and interacting with the ecosystem as a whole. Opening more of these spaces to roads, logging, and other exploitation is against national interest to the benefit of corporations. Personally, I take several vacations a year which involve hiking, camping, fishing (including salmon fishing) and other outdoor activities along the Oregon coast and mountainous regions of Oregon. My personal enjoyment of the vistas and recreation areas would be vastly diminished if roads and logging were allowed in currently protected areas, but that feels like a small complaint next to the horror I feel at the idea of damaging old growth rainforests and key watersheds for monetary gain. Shame on all of you. 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. Sincerely, Amber Willett Eugene, Oregon

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule of 2001. I am a lifelong Oregonian and currently live in Oregon's southern Willamette Valley. I regularly recreate on public lands, including currently inventoried roadless areas that are protected from roadbuilding and timber harvest under the Roadless Area Conservation Rule. Threemile Lake located in the Tahkenitch Roadless Area of the Siuslaw National Forest is one of my favorite places to hike and bring kids to play on dunes. This area consists of coastal rainforest with ancient sitka spruce trees that have ferns growing way up high in the tree canopy. The forest supports wildlife and is a prime area for finding edible wild mushrooms. Tahkenitch Roadless Area also contains a rare coastal dune ecosystem that supports plant species uniquely adapted to shifting sands and the wet deflation zone. The Western Snowy Plover, federally recognized as threatened, nests on the beach in the area. I am also concerned in addition to potential roadbuilding and logging, rescinding the Roadless Rule would expand motorized corridors in the general area for recreational use impacting wildlife. Tenmile Creek is another roadless area further south which is less accessible to hiking and therefore even more valuable to wildlife. Another vitally important IRA is Iron Mountain in the Willamette National Forest in Lane County. A hiking trail takes you through forest and wildflower meadows that support over 300 native wildflower species. The views to the east are phenomenal and if roads were built and surrounding areas were logged the recreational value would be irreparably harmed. To get there, people travel through the small towns and support small businesses along the way. I also frequent Three Creeks Lake and surrounding areas in Deschutes National Forest adjacent to the Three Sisters Wilderness. Roadbuilding and logging in these areas would harm wildlife, recreational value and water resources. Many of the areas currently protected by the Roadless Area Conservation Rule are near the headwaters of watersheds that supply drinking water to our cities. Protecting clean water is vital to our future. According to the DEIS "inventoried roadless areas typically have good water quality due to limited disturbance,” and “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” My drinking water comes from watersheds partially within Inventoried Roadless Areas. I am also concerned that rescinding the Roadless Area Conservation Rule in whole or in part could increase fire risk. As the Administration itself states, “Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. The increasing number of wildfires, size of wildfires and intensity of wildfires is a serious concern in the West and doing anything that increases the probability of human caused fires is unwise. Enough fires start due to lightening during our increasingly long fire season, that adding risk that the hot underbelly of a vehicle or a careless toss of a cigarette butt will ignite new fires is unacceptable. The DEIS states that a key purpose of proposing a rescission of the roadless rule is to have greater local decision-making and reduce regulatory burden. A return to decision-making at the individual national forest level means that concerned citizens like myself would have to track proposed roadbuilding and timber harvest across the state and comment on each project. This would limit the public’s ability to meaningfully weigh in. Entirely local planning and decision-making will not adequately account for public opinion. The result would be an erosion of protections needed to support clean drinking water, wildlife habitat, and recreational opportunities. Consistent nationwide protection measures are critical to protecting these values. For all of the above reasons, I believe that alternatives 2 and 3 of the draft EIS would be a serious mistake. I oppose the proposal to rescind or alter the Roadless Rule and I support “Alternative 1, the No Action alternative." I want the Forest Service to protect forests for the multitude of services they provide to people, wildlife, plants, and water resources. I do not want decisions about our public national forestland to favor the private construction industry and timber industry which would inevitably have a bigger voice at the table. The inventoried roadless areas are national treasurers. We cannot afford to serve private industry interests at the expense of the public interest. I urge the Forest Service to retain the current Roadless Rule under Alternative 1.

I am opposed to rescinding or altering the Roadless Area Conservation Rule. Roadless areas, like the Siuslaw National Forest, are important natural areas for recreation, education, and ecological benefit. I urge you to keep the Roadless Rule in place as it is.

My name is William Glassmire. I live in Oregon 97330. I am completely against the proposed repeal of the Roadless Area Conservation Rule. Oregon benefits from the current rule for several reasons, such as: A.much of Oregon’s drinking water comes from rivers in the Roadless area; B.much irreplaceable wildlife habitat is within the Roadless Area; C.the Roadless Area includes many well-used recreation areas. All in all, roadless areas serve the American people and our country’s geography, including in Oregon the Siuslaw National Forest, the Willamette National Forest, the Umpqua National Forest, and the Siskiyou National Forest. I visit our National Forests regularly, and I have seen with dismay “so-called “development”, including steep clear-cuts, once-healthy rivers and streams which have almost disappeared, and abandoned machinery by “developed” roads. Please retain the Roadless Area Conservation Rule and the public goods which it provides the American people.