Every public comment on the proposed rescission of the Roadless Rule, sorted by what it talks about. Pick a topic, then narrow by position, by how hard the comment is for the agency to set aside, or by how substantive it is. Each comment is shown in full, as filed. How comments are classified and scored is explained in the Comment Analysis.
24 unique comments25 submissions
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Opposes rescission 100.0%
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A1 strong 1
A2 moderate 6
A3 weak 1
A0 none 9
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24 unique comments naming Six Rivers National Forest· showing 1–20Clear all filters
As a Park Ranger, I have experienced many of these concerns while exploring the Maine woods and during the mundane routines of life. Roads serve as dispersal corridors where invasive plant species are spread by humans, vehicles and animals. The roads that have cut through forested land have led to an increase in invasive plant species in both terrestrial and aquatic ecosystems. One such plant is known by the common name bittersweet (Celastrus scandens). It is considered extremely invasive in the state of Maine. It is common to find it alongside roads and power lines. Bittersweet prefers loose disturbed soil. Research indicates that invasive plant species tend to decrease with the distance from roads, whereas native species show variable distribution patterns near roads (Dai et al., 2025 (https://doi.org/10.1111/ddi.70002)). Repealing the Roadless Rule would undoubtedly increase the spread of this invasive plant. Over the past two years I watched Maine DOT rebuild a section of Rt. 1 going through midcoast Maine. Many acres of habitat was destroyed to rebuild a culvert and install a new bridge. It was once a relatively easy area for wildlife movement and now it is a steep incline on both sides of the road. Road construction should keep wildlife in mind but instead it is creating more barriers for them to navigate. Wildlife across the country takes part in seasonal migration. Roadless areas allow these species to move freely without hindrance whereas wildlife in other regions face habitat loss, fragmentation, or the threat of wildlife-vehicle collisions. Wildlife-vehicle collisions are far too common. My heart breaks every time I see roadkill. I have seen hundreds of roadkill over the past few years in the region where I work. As someone who loves birds, I am deeply saddened when I see that an owl or another raptor has been struck. Usually, those predators were struck while hunting and didn’t see the vehicle until it was too late. Like most species, road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations (Beebee, 2013 (https://doi.org/10.1111/cobi.12063)). On warm rainy spring nights I would witness hundreds of frogs, salamanders, and other critters migrating to mating grounds. Unfortunately, most of them were hit by cars and did not arrive at their destination. One of the main negative effects of roads on various species is wildlife-vehicle collisions (Grilo et al., 2024 (https://doi.org/10.1038/s41597-024-04207-x)). Wildlife-vehicle collisions are already too common and repealing the Roadless Rule would create more of these unfortunate occurrences.
As an avid outdoor enthusiast, I find great joy in solitary hikes where you cannot hear anything but the sounds of nature. The rescission of the Roadless Rule would put that type of recreation in jeopardy. National forests provide many types of recreation and the regions with roadless areas account for 76% of annual visits to the National Forest System. Repealing the Roadless Rule would cause hiking, fishing, hunting, and backcountry camping to decline as these types of recreation are considered more quiet and dispersed (https://www.pew.org/en/research-and-analysis/articles/2026/10/05/us-department-of-agriculture-proposes-eliminating-the-roadless-rule). Opportunities for solitude and primitive non-motorized experiences would be negatively impacted by the noise and disturbance of vehicles. Noise pollution from logging operations or road construction and visual impacts to landscapes are a concern for many Americans who value quiet recreation. (USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)). The Roadless Rule protects many cherished backcountry recreation areas. These forests provide us with clean air and water, sequester carbon, and are the backbone of a $1.3 trillion outdoor recreation economy that supports 5.2 million jobs. This rescission puts 45 million acres of national forest at risk (Alliance, 2026 (https://www.outdooralliance.org/roadless)). Nearly 80,000 miles, about 59%, of National Forest System Trails valued by outdoor enthusiasts across the country are at risk right now (Woodard et al., 2025 (https://www.nrdc.org/media/what-usdas-emergency-logging-map-gets-dangerously-wrong)).
In conclusion, the Roadless Rule was brilliantly created 25 years ago and has proven to be effective at prioritizing conservation efforts while also providing a recreational outlet for the nation as well as aided in wildfire mitigation efforts. The Roadless Rule is not the enemy. Allowing the Roadless Rule to be rescinded would have catastrophic consequences and irreparable damage. Millions of Americans are in favor of the Roadless Rule. Please reject full repeal and reject the removal of any acreage from roadless protections.
Opposes rescissionA2 moderateSubstance 16/24Owed an answerOct 7, 2026FS-2025-0001-611361
PLACESTANDDOCGAPEVIDASKALTLAW
Exact copy — Byte-identical to another submission. This comment stands for all 2 submissions in its group.
Dear USDA Leadership:
I am submitting this comment regarding the proposed rescission of the 2001 Roadless Area Conservation Rule, with particular concern for roadless areas in North Carolina’s Pisgah National Forest, including Bearwallow and Bald Knob.
I regularly hike and explore Bearwallow and have come to value its forests, wildlife, and ecological diversity. Bald Knob is another remarkably beautiful area. These places represent something increasingly difficult to find: relatively undisturbed public lands where people can experience forests and wildlife without the impacts associated with roads and development.
My time outdoors has taught me that the character of a roadless area cannot simply be restored once a road is constructed. Trees can be replanted, but a road permanently alters the landscape, fragments habitat, and introduces continuing human disturbance. Access to relatively untouched wilderness matters not only in North Carolina, but throughout the country.
Roadless areas can also provide disproportionately important habitat for federally listed threatened and endangered species. Road construction and associated disturbance can fragment habitat, restrict wildlife movement, and affect the ability of species to find food, reproduce, and survive.
### Concern Regarding ESA-Listed Species and Land Management Plans
The DEIS reports 327 “may affect, likely to adversely affect” determinations and 71 adverse critical habitat determinations for ESA-listed resources. At page 170, however, it states that activities on National Forest System lands must be consistent with applicable land management plans and that “future project designs in these areas would avoid and minimize adverse effects to ESA-listed resources.”
The Forest Service’s Draft Biological Assessment indicates that this assurance does not apply equally to all listed species because some applicable land management plans predate the species’ federal listing and contain no species-specific protections.
For example, the Assessment states:
• Page 352: The 1995 Six Rivers National Forest Land Management Plan “does not contain species-specific protections” for Lassics lupine because the plant was not federally listed until October 2023.
• Page 307: The applicable land management plans for the Mark Twain and George Washington and Jefferson National Forests predate the listings of several crayfish species and therefore “do not include plan-level analysis or plan components specific to these species.”
These species appear in the DEIS’s own adverse-effect determinations: big sandy crayfish and Big Creek crayfish at page 325, Lassics lupine at page 328, and Sonora chub at page 332.
The DEIS should clearly disclose when the land management plan on which its analysis relies predates the listing of the species at issue and therefore contains no species-specific plan components.
This is significant because the Draft Biological Assessment itself recognizes that administrative protections within a forest plan can affect the outcome of the analysis. At page 243, regarding Sonora chub, it states that removal of existing administrative protection could result in a future project reaching the level of “may affect, likely to adversely affect.”
This issue cannot simply be deferred to future project-level review. Whether an operative land management plan contains species-specific direction is a plan-level fact. A project-level biological evaluation cannot create plan components that do not exist.
I therefore request that the final environmental review:
1. Correct or clarify the statement at page 170 so it does not imply that land management plan consistency provides species-specific protections where the applicable plan predates the species’ listing and contains no species-specific components.
2. Identify each ESA-listed species whose listing postdates the applicable land management plan.
3. For each such species, disclose that the applicable plan contains no species-specific components and identify the protections or analytical measures on which the effects analysis instead relies.
4. Clearly identify where these issues have been addressed in the final environmental review.
The information needed for this disclosure appears to already be contained in the Forest Service’s Draft Biological Assessment, including its “Existing Protections” tables.
Bearwallow, Bald Knob, and other roadless areas are valuable public resources that provide recreation, wildlife habitat, and places where natural ecological processes can continue with comparatively little disturbance. I respectfully request that the USDA fully consider these ecological and species-protection implications and fully disclose the limitations of relying on existing land management plans.
Sincerely,
Megan Johnston
Asheville, nc
I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Southwestern Colorado, and have spent years exploring much of the west. I work, recreate and live within areas that are currently protected by this measure, and cannot imagine the impact this would have on places I hold close. I worked for years in the Frank Chruch River of No Return Wilderness area, a place that truly cannot be described in words. The most amazing part of that place is that is it has no roads. I have also worked in the Six Rivers National Forest in Northern California, who’s endangered chinook salmon population would be at risk. Outside of work, I have spent countless hours in the Fishlake National Forest, Ashley National Forest, and Dixie National Forest in Utah. All of these places deserve to be protected in their current state. Rescinding the “2001 Roadless Rule” puts countless resources, ecosystems and recreation areas at risk. These places I’ve listed (along with all others affected by this potential measure) protect drinking water resources, preserve old growth habitats, store carbon and support wildlife that we all enjoy. These areas are crucial to local people, for water, food and shelter. Please do nott rescind this preservation measure.
Dear Chief Schultz,
Roadless forests in national and state parklands are inherently valuable resources that we have a duty to preserve. Spending time in forested areas like those near where I grew up in Virginia and West Virginia has been hugely influential in fostering my love for science and my appreciation for the complexity and importance of conservation. Protected forests harbor precious biodiversity and in turn provide essential ecosystem services for our future.
I have spent countless summer days in Monongahela National Forest in WV, learning about nature, forming friendships, and fostering the confidence and environmental awareness of my peers and younger mentees.
The lack of roads or interference from the outside world while experiencing these forests made the lessons learned, adventures had, and bonds formed infinitely more meaningful.
I want my kids and the next generation of outdoor educators and workers to have the same access to protected, healthy, biodiverse roadless forests as I had.
Regarding the Marlin Mountain in the Monongahela National Forest, West Virginia:
Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing.
Recreation disturbance has measurable effects on wildlife. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)
Rescinding the Roadless Rule would open the Marlin Mountain, Monongahela National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary.
National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species... — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205). Estimates and figures used by the forest service in their proposed recission of the roadless rule require correction and more detailed, correct explanation. The thousands if not millions of Americans who support upholding the roadless rule deserve to have their voices heard.
The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress.
“Unclosed Derivation of the 44.7-Million-Acre Baseline (58.2 less 9 less 4 equals 45.2)
The Draft EIS derives the acreage baseline for its entire analysis in a single passage, and the derivation does not close.”
“Superseded 58.5-Million-Acre Baseline Stated as Current in the Cost Benefit Analysis; Components Reconcile to Neither Total.”
“Identifies the most "natural" (least human-modified) corridors between large protected areas in the U.S. Many of the highest-priority corridors fall within or overlap inventoried roadless areas, providing direct evidence that maintaining roadless protections is critical to climate-adaptation connectivity strategies for wide-ranging species. — Belote et al., 2016 (https://doi.org/10.1371/journal.pone.0154223)”
Most respectfully,
A Virginian
I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule (66 FR 3244).
My name is Patricia Ann Johnson, of Blue Lake, California. In addition to seeking solitude in remote locations as a national forest recreator, I live in the lower watersheds of approximately 150,000 acres of Inventoried Roadless Area (IRA) of the Six Rivers National Forest. As a community adjacent this IRA we depend on the rivers whose headwaters lie in the conservation landscapes, for our drinking water. It is essential for the health of our community these rivers remain flowing, clear and clean; and for the salmon who return home to spawn in these rivers. Building new roads, opening access to closed forest landscapes, and allowing more motorized access across roads, jeopardizes our clean water. It is proven fact that existing forest roads contribute a staggering amount of sediment into surrounding watersheds. More roads, equals more use – of all kinds. Increased human use has been proven to negatively impact natural areas, exposing and drying soil, causing erosion, and increasing wildfire ignition; all from roads. Rescinding the Roadless Conservation Rule is a dis-service to my community and all the communities of Northwestern California for this reason. The mission of the U.S. Forest Service in part is “to sustain the health of the nations forests” … to meet the needs of present and future generations; roads are not healthy, for any reason. These forest are more valuable left alone!
I support the No Action Alternative.
The risks of rescinding the 2001 Roadless Rule do not meet the agency mission, will jeopardize clean water with sediment and erosion in waterways and increase a decline in watershed health, and will increase human use, which is synonymous with wildfire ignition.
I favor reduced government regulations with regard to businesses, but I am strongly opposed to this proposal to rescind the 2001 Roadless Rule. I am a resident of Sacramento California, where I retired 5 years ago to enjoy the outdoors including national forest lands. Those National Forest lands are especially important to me because we can take our dog with us when hiking or camping. That's not allowed in the vast majority of National or State Parks. I chose to live near the Sierra Nevada and multiple national forests from El Dorado National Forest in the south through Tahoe NF to Plumas NF north of Lake Tahoe. But I am within fairly easy driving distance of Inyo NF to the southeast, and Klamath, Shasta Trinity and Six Rivers NF's in the northern part of the state. In the former 3 NF's I see this rescission fragmenting beautiful forest lands that will devalue the forests for biking, fishing, hiking and hunting alike. At the same time easier access for people from an expanded road system (not necessarily loggers and others) will increase the likelihood of increased fire danger. But in the latter four forests the even higher percentage of areas being proposed to allow new roads goes beyond devaluing the forest and approaches fragmenting them into a small number of microforests that destroy the existing wilderness. This does not seem well thought out and has no new budget for supporting an even larger road system (neither construction or maintenance). It is also likely to shift current control from a single government unit to conflicting state and local jurisdictions. Therefore, I am strongly opposed to the proposal to rescind the 2001 Roadless Rule.
I am writing to support Alternative 1: the “No Action” alternative because we should keep the roadless rule intact.
I live in Northern California and visit roadless areas in the Six Rivers National forest and the Shasta Trinity National forest frequently for recreation and nature study. New roads and logging will inevitably damage plants, animals and the natural environment. As part of various environmental restoration teams in California and New York, I have seen how long and expensive it is to restore biodiversity in areas that have damaged by erosion and pollution caused by road building and logging.
I urge you to protect the ecological health of our national forests by moving forward with No Action Alternative 1 and keep the Roadless Rule intact.
Thank you,
Felicity Wasser CPA
I strongly oppose rescinding the 2001 Roadless Area Conservation Ruel. As a resident of a remote community surrounded by National Forest System lands, including Shasta-Trinity National Forest, Six Rivers National Forest, and Klamath National Forest, I am deeply concerned about the severe, localized impacts such a sweeping policy change would bring to my local economy and our natural heritage. I urge the USDA and the Forest Service to maintain the 2001 Roadless Rule protections based on the following three points of impact:
1) The Severe Economic Impact on Ecotourism: My rural community depends directly on a thriving outdoor recreation and ecotourism economy. Visitors travel here precisely because these roadless areas offer pristine, unfragmented natural landscapes for hiking, wildlife viewing, and backcountry recreation. Stripping these protections to allow industrial timber harvesting and road building will permanently degrade the visual and environmental integrity of these lands, directly harming local small businesses, guiding services, hospitality, and our municipal tax base.
2) Irreversible Habitat and Wildlife Fragmentation: The preservation of intact, roadless ecosystems is vital for local wildlife conservation. Constructing new roads and introducing commercial logging operations will fragment critical migration corridors, further disrupt fragile habitats, and degrade water quality in local watersheds. Once these pristine areas are developed, the ecological damage to biodiversity cannot simply be reversed.
3) Aggravated Wildfire Risks Near Infrastructure: While the administration cites wildfire defense as a rationale for local thinning, peer-reviewed data consistently shows that roads frequently serve as a primary vector for human-caused wildfire ignitions. Introducing miles of new road infrastructure deeper into our national forests increases, rather than decreases, the long-term wildfire threat to nearby wildland-urban interface (WUI) communities like mine.
National forests should be managed to protect local community stability, biological diversity, and sustainable outdoor recreation. Rescinding the 2001 rule contradicts these values and directly threatens my community's livelihood. Please withdraw this proposed rescission and uphold national roadless area protections.
Thank you for considering my comments.
Opposes rescissionA2 moderateSubstance 9/24Owed an answerOct 5, 2026FS-2025-0001-556465
PLACESTANDDOCGAPEVIDASKALTLAW
I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in San Jose, California. Public lands matter to me because they allow spaces that people, me included can connect to nature. In these public lands you can see what is left of these ecosystems in action and get a better understanding of how the world around us is supposed to work. Some areas near me that will be affected are the Klamath National Forest, the Siskiyou National Forest, the Six Rivers National Forest and the El Dorado National Forest. These areas hold headwaters for major rivers that sustain wildlife, snowpact and maintain scarce wildlife habitat for threatened and endangered species. I enjoy hiking in these areas as well. In these areas, there are 21,808 miles of trails inside the affected areas, including 1,127 miles of national scenic and historic trails, and most of those miles are non-motorized. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation, and that under rescission the settings could shift toward more developed conditions. You do not have to camp inside a roadless area to be affected: the water in your drainage starts up there, and the wildlife you hope to see moves through (DEIS recreation analysis). As I am also a fisherman, an unfragmented forest or any endangered habitat for that matter is really important for rivers and their water quality. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and its own words on wide-ranging mammals like the grizzly: they “have suffered habitat loss and the extirpation or fragmentation of their populations.” (DEIS wildlife analysis; Haddad et al. 2015). Another thing is that I want the forests managed responsibly, only around 6% of the untouched old growth forest remains in the US. The purpose and need is to reduce regulatory burden and return decisionmaking to local officials, not forest health and not fire. Every conservation alternative was eliminated for failing that purpose: more acreage “would not be responsive to the deregulatory executive orders,” and one option was cut partly because analysing roadless values is “an administrative and legal burden for the agency.” The agency even monetized what roadlessness itself is worth to people who never visit: $5.3 to $11.5 million a year forgone, landing in the same range as the timber gain, which is why its own accounting cannot clear zero. And in its own words, “This proposed rescission does not mandate timber cutting or road construction”: nothing about management is promised, only the removal of the protection (DEIS purpose and need; alternatives analysis). Roads also cause fires. The agency’s own new analysis, 2014 to 2024: human-caused ignitions run 22.4 per million acres per year on roaded national forest land, against 3.0 inside the affected roadless areas. Seven and a half times. Its own conclusion: “human caused ignitions increase in abundance with proximity to roads,” and its effects analysis concedes road access could increase the number and frequency of wildfires (DEIS Table 21). Roads are also more expensive to maintain than we can afford, as this is taxpayer money. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase (DEIS economics and infrastructure analysis; USDA Cost Benefit Analysis, p. 29). Sediment and vegitation removal near or within proximity of these headwaters due to these roads in these areas harm threatened fish populations by killing eggs and raising water temperatures. The DEIS: sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale (DEIS; USFWS 2024; Patric 1976; Swift 1988). The DEIS: removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS (DEIS; Carter 2005). For the reasons stated above and many more, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would cause irreversible harm and permanently negatively effect all peoples in the US.
Opposes rescissionA2 moderateSubstance 12/24Owed an answerOct 5, 2026FS-2025-0001-563527
PLACESTANDDOCGAPEVIDASKALTLAW
Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001
Creatures that need protection: bison, wolves, elk, moose, hummingbirds, and even spiders are all part of our natural world and deserve a clean, safe home. I have ridden my bicycle on trails in nearly every state in the country. Our natural places are one of the greatest things we have going for us. They need protecting. Rescinding the 2001 Roadless Area Conservation Rule would threaten both, and I oppose it.
The roadless areas I am most concerned about are the South Fork area of 16,786 acres and the Underwood area of 3,046 acres in the Shasta-Trinity National Forest, and the Cow Creek area of 1,271 acres in the Six Rivers National Forest, all in California. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. These are not abstractions.
On wildlife: the DEIS itself documents that habitat fragmentation reduces biodiversity by 13 to 75 percent, that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter. The agency's own words acknowledge that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations." The elk I hope to see in places like South Fork depend on exactly the kind of habitat this rule protects. The agency's own sources found that elk survival rates rose during a road closure and fell again when the gates were removed, and that ideal summer elk habitat is unroaded land with cover and forage. For moose, the DEIS notes they are drawn to road corridors for road salt, increasing human-moose conflict, and the agency's own Tribal record credits the rule's protection with the recovery of deer and moose populations by preserving old-growth winter shelter. Building roads into these areas would directly harm the animals I care about. I ask the agency to explain specifically how it reconciles these findings with the proposal to lift protections.
The agency's small-business analysis cannot be reconciled with its own cost figures. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting analysis reaches its no-impact conclusion by spreading losses across every small firm in the sector nationally, not the outfitters and guides actually holding permits in the affected areas. People who lead bicycle tours and wildlife trips through these forests are exactly the small businesses that would feel this loss first. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm.
The agency invited reliance interests and then declined to weigh them. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My own riding and my own wildlife watching in these forests are reliance interests. An agency changing course must account for what its prior policy encouraged people to count on. The agency must identify and weigh the reliance interests described in the comments it receives, including this one.
The agency's treatment of future plan amendments is internally contradictory. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). Inviting comment on a scenario the agency refuses to analyze is not a substitute for analysis. The foreseeable plan-amendment scenario, including expanded timber harvest area, must be analyzed as part of this action, not deferred to a later process that commenters cannot yet reach.
Finally, the agency's own fire data undermines the proposal's safety rationale. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The trails I ride and the animals I look for do not survive catastrophic fire any better than they survive bulldozers. The agency has not quantified the expected increase in human-caused ignitions that would follow new road access, nor weighed that increase against any claimed reduction in wildfire hazard. That calculation belongs in this record before any final decision is made.
Sincerely,
Molly Martin
Eureka, California
Dear Ms. Rollins,
Being a resident near roadless national forest has given me a particular view of what intact land provides — not just ecological, but economic and social — and the 2001 Rule is what's kept it intact.
The Roadless Rule is important because it protects some of our nation’s most valuable and undeveloped public lands. The ecological health of our waters and forests is directly connected to our own health and well-being. Opening our wildest forest lands to development threatens clean water, fragments habitats and takes away our access to quiet recreation.
Though I live in the Adirondack Park, our protected state lands provide safe habitat and migratory corridors for many birds and animals that rely on national forest and protected national lands in Vermont and on to New Hampshire and Maine. Without these connections, it is questionable if I would have grown up with the return of the moose in our forests, the Bald Eagle nesting on the lakes in the St. Regis Canoe Area, or seen Coywolves walk across frozen lakes in pursuit of deer.
When roads and development begin in our public lands and protected forests, we stand to lose access to quiet foot paths under canopies of leaves. We stand to lose broad swaths of undeveloped landscapes. We stand to lose quiet visits to lakes and rivers where the only sound is the lapping of water on the shore. We stand to lose our understanding and connection to the outdoors.
Recreation disturbance has measurable effects on wildlife. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)
The Roadless Area Conservation Rule has protected our public forests and spaces for 25 years. Keep our wild spaces wild. Let our landscapes remain unfragmented and our wildlife corridors open. Now is not the time to unravel decades of conservation work. We all share the responsibility for keeping protected national and state public lands intact so the legacy of access and enjoyment of our iconic landscapes can endure for generations.
Rescission of the Roadless Area Conservation Rule is opposed; its retention is respectfully requested.
All the best,
CommentID: RLC-20261004-S289FA
Opposes rescissionA2 moderateSubstance 14/24Owed an answerOct 4, 2026FS-2025-0001-544595
PLACESTANDDOCGAPEVIDASKALTLAW
October 2, 2026
Dear Secretary Rollins,
I strongly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule.
I am a biologist who has spent more than 20 years working in and on topics affecting forests and public lands throughout the country and especially in California where I currently live. I have been recreating – backpacking, hiking, camping, bird watching, etc. - in National Forests even longer.
Backpacking in California in remote roadless areas in the Stanislaus Forest and Six Rivers National Forest when I was younger were formative experiences that guided my career. Now I am exploring the incredible diversity of California and I am thrilled by the roadless areas here including the Rubicon and the American River Roadless areas.
Eliminating the roadless rule would remove protections for 45 million acres of the wildest and most intact public lands across our National Forests. There is nothing like these irreplaceable and unique places. Alternative 3 would still open the majority – 31.7 million acres – to road building, logging and other development. This would imperil drinking water, habitat, Tribal values, recreation, fire risk, and it would be economically very costly. And the draft EIS acknowledges many of these known issues (e.g. increased road construction and timber harvest are likely to “introduce and spread invasive plant species due to ground disturbance.”).
Intact Roadless areas provide critical habitat for a multitude of species including California and Northern Spotted Owls, fisher, salmon, and hundreds more. However, the DEIS acknowledges that eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. These Roadless areas also overlap with high demand hunting and fishing areas and provide important habitat for native trout, salmon, and elk, favored by anglers and hunters and are crucial areas for wide-ranging carnivores like wolverines. (https://www.sciencedirect.com/science/article/pii/S0006320726002624). How does the Forest Service plan to prevent further degradation of these habitats and populations and mitigate harm if the Roadless Rule protections are eliminated?
Communities depend on our National Forests for clean, fresh drinking water and Roadless areas are a key to maintaining this quality, providing 25 million Americans with affordable, clean water. Inventoried Roadless Areas (IRA) protect over 130,000 km of streams and rivers, representing 2.5% of total river length, and serve as the primary protection mechanism for more than 100,000 km of rivers (1.9%) (https://journals.plos.org/water/article?id=10.1371/journal.pwat.0000538). According to the DEIS,“Potentially affected 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.” for providing clean water and flood protection. The the Agency protect critical watersheds and ensure that communities continue to have clean safe drinking water and aquatic species are protected?
Rescinding the Roadless Rule will increase the risk of wildfire. 78% of human-caused fires on National Forests start within ½ mile of a road (https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=National+USFS+Fire+Occurrence+Point). Fires are four times more likely to start near a road than in a roadless forest, and logging also increases fire hazard (https://link.springer.com/article/10.1186/s42408-026-00450-2). The DEIS even admits “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.” It would be disingenuous to claim that rescission will allow for fire related management since the 2001 Roadless Rule allows for forest management activities, including timber harvest, to reduce the risk of uncharacteristic wildfire, as well as to restore habitat for sensitive fish and wildlife species. In fact, nearly 2 million acres of Inventoried Roadless Areas have had hazardous fuels treatments to reduce fire risk. Why does the Agency think it is a good idea to deliberately increase fire risk in the midst of a wildfire crisis and how would it propose mitigating the increased risk?
Finally, it is remarkable to me that the Forest Service is proposing to build new roads when – as anyone who has been on a Forest Service road knows – it is barely (and often, not) maintaining the more than 386,000 miles of current roads to a safe standard. In fact there is already over $6.9 billion in deferred road maintenance. Poorly maintained roads threaten public safety .
I am a voter in Anderson, California. I frequently hike, camp, picnic and recreate in the Shasta-Trinity National Forest, the Lassen National Forest, the Six Rivers National Forest, and the Klamath National Forest. I raised my children in these forests, and now as young adults they also frequently recreate there.
I am writing to express my strong opposition to the proposal to rescind the nation's landmark roadless rule. This action would open nearly 45 million acres of pristine national forests to road construction, logging, and other development. The consequences of this decision would be far-reaching and devastating for our environment, wildlife, and communities.
* Biodiversity: The roadless rule has been instrumental in preserving biodiversity and habitat. These untouched forests provide critical habitat for over 500 imperiled species.
* Water Quality: The roadless rule protects millions of acres that serve as the headwaters for major rivers that supply drinking water to more than 60 million people across 33 states. By allowing road construction, we risk introducing significant water pollution to these vital water sources.
* Fire Protection: Contrary to the administration's claims, rescinding the roadless rule would actually increase wildfire risk. Scientific studies have shown that wildfires are four times more likely in areas with roads compared to roadless forest tracts. This fact directly contradicts the justification being used to push this harmful proposal forward. My Northern California home area is acutely aware of fire danger: we've lived through massive, devastating wildfires the last several years. Any action that increases fire danger is a direct attack on citizens' lives and property.
Top findings from the fire study cited below (Aplet, Hartger, & Dietz):
1. From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1,000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1,000 ha).
2. The highest wildfire-ignition density was in lands within 50 meters of roads (7.99 fires/1,000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1,000 ha).
3. The results show that ignition density is much higher near roads than away from them. Across the National Forest System and in every region examined, the density of wildfire ignitions within 50 meters of a road is higher than in wilderness, Inventoried Roadless Areas, or other national forest lands, often by quite a bit.
I implore you to stand against the rescission of the roadless rule. Protect our national forests, endangered species, clean water, and the interests of the millions of Americans who benefit from these pristine wilderness areas. The legacy of our public lands and the health of our environment depend on your action to preserve the roadless rule.
Sources/references:
U.S. Fish and Wildlife Service, “USFWS Threatened & Endangered Species Active Critical Habitat Report,” Environmental
Conservation Online System (ECOS), updated August 7, 2025, accessed April 29, 2026, https://ecos.fws.gov/ecp/report/
table/critical-habitat.html.
NOAA Fisheries, “National ESA Critical Habitat Mapper,” updated February 18, 2025, accessed
December 8, 2025, https://www.fisheries.noaa.gov/resource/map/national-esa-critical-habitat-mapper
U.S. Forest Service, “Water Facts,” https://www.fs.usda.gov/managing-land/national-forestsgrasslands/water-facts.
Southern Environmental Law Center, “For Virginians, Roadless Areas Mean Clean Drinking Water,” December 18, 2025,
https://www.selc.org/news/for-virginians-roadless-areas-mean-clean-drinking-water;
Friends of Shenandoah Mountain, “Water Quality,” accessed March 31, 2026, https://www.friendsofshenandoahmountain.org/water-quality.html
U.S. Department of Agriculture Forest Service, “Summary of Public Water Systems and Populations Receiving Surface
Drinking Water Supply From National Forest System Land,” GTR WO-100 (September 2022), https://www.fs.usda.gov/
research/publications/gtr/gtr_wo100/GTR-WO-100-Sup1.pdf
Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2
Dear Mr. Schultz:
I am a life long adventurer in exploring our nations lands and waterways. I've been exploring all over the USA and there are still many places I have yet to explore. I'm very concerned that the direction of climate change will prevent me from exploring some new places where I currently live.
“Of the 537 wildlife species of conservation concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA lands. If all IRAs were added to the protected-area system, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas. — UNKNOWN, 2021 · Global Ecology and Conservation (https://doi.org/10.1016/j.gecco.2021.e01943)”
“Of the nation's species currently listed as threatened, endangered, or proposed for listing under the ESA, approximately 25% of animal species and 15% of plant species are likely to have habitat within inventoried roadless areas (IRAs) on National Forest System lands. Inventoried roadless areas function as biological strongholds and refuges for many species. — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)”
“Opportunities for solitude and primitive non-motorized experiences would be negatively impacted by the noise and disturbance of vehicles. Motorized trails change the character of these otherwise undisturbed landscapes. Noise pollution and visual impacts to landscapes are a concern for those who value quiet recreation, solitude, and viewing undisturbed landscapes. The creation of any additional motorized recreation is believed to be a threat to the recreational experiences and aesthetic values observed by visitors who enjoy quiet recreation. — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)”
“wildfires are almost twice as likely to occur in roaded areas as in roadless areas, because roadless areas are generally located further away from communities and are harder to access — U.S. Senate, 2025 (https://www.congress.gov/bill/119th-congress/senate-bill/2042/text)”
Craggy Gardens is an incredible place that challenges all my senses and physical abilities. Part of the Pisghah Forest it is an area that I would love to explore further. But the constant change in the climate makes it difficult to go there. Hurricane Helene did so much damage to our forest there, that it still is not cleared.
I remember the first time I explore Craggy Gardens and did this incredible hike through the woods that challenged my ability to hike over these big bolders. The water flowing through added to the mystic of the forest. Listening to birds I have never heard before. Trying to see if I could spot any salamanders or other reptiles in the area.
Do not remove the protections of the forest and the wildlife by removing the roadless rule. It would be a disservice to any and all who have not experienced this area.
I'm a member of the public with a stake in these lands, and my stake is in keeping them roadless.
With gratitude,
CommentID: RLC-20260912-UXKYBK
Opposes rescissionA2 moderateSubstance 15/24Owed an answerSep 13, 2026FS-2025-0001-375554
PLACESTANDDOCGAPEVIDASKALTLAW
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 Linville Gorge near my home
- Protecting these unfragmented
landscapes is deeply personal to me because I value the pristine wildlife habitats and we all benefit from the natural resources and tourism that these beautiful protected spaces allow. 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,
Teresa Fisher
The DEIS Relies on Land Management Plan Consistency for Species Whose Listings Postdate the Plans
The DEIS's conclusion on ESA-listed species rests on a premise the agency's own Biological Assessment records as false for an identified set of those species.
At page 170, under "Conclusion," the DEIS states: "Under all alternatives, activities on NFS lands must comply with laws, regulations, and policies. All projects on NFS lands must be consistent with land management plans," and that "future project designs in these areas would avoid and minimize adverse effects to ESA-listed resources." Consistency with land management plans is the only effects-limiting assurance the DEIS offers against the 327 "may affect, likely to adversely affect" species determinations and 71 adverse critical habitat determinations it reports on that same page.
The Forest Service's Draft Biological Assessment for USFWS-listed species establishes that plan direction is load-bearing in those determinations. At page 243, for the Sonora chub, the agency reasons directly from the loss of an administrative protection to a worse outcome: "Removal of the high degree of administrative protection within the Coronado National Forest Plan; any future project could reach the level of not being discountable and may affect, likely to adversely affect Sonora chub." Where plan-level protection exists, the Assessment treats its removal as changing the determination.
For several listed species there is no such protection to begin with, because the operative plan was adopted before the species was listed. Draft Biological Assessment, page 352: "The 1995 Six Rivers NF LMP does not contain species-specific protections for Lupinus constancei (Lassics lupine), because the plant was listed as federally endangered in October 2023." Page 307: "Big Creek crayfish and St. Francis River crayfish were federally listed in 2023 and the big sandy crayfish was listed in 2016. The current land management plans for the Mark Twain National Forest and George Washington and Jefferson National Forests (where these species potentially occur based on IPAC) pre-date the listing of these three crayfish species and therefore do not include plan-level analysis or plan components specific to these species." All of these species appear in the DEIS's own Table 58 as likely to be adversely affected — big sandy crayfish and Big Creek crayfish at page 325, Lassics lupine at page 328, Sonora chub at page 332.
The DEIS does not disclose this. The phrases "predate the listing" and "plan components specific to these species" appear nowhere in it; its only discussion of anything that pre-dates a plan concerns roads and mineral leases pre-dating the 2001 Rule (pages 185 and 218). A reader of the DEIS is told that plan consistency and project design will avoid and minimize adverse effects to listed species, and is not told that for an identified subset of those species the plans contain no species-specific direction at all. The statement at page 170 is therefore incomplete as to those species, and it is the agency's own Assessment that establishes it.
This cannot be deferred to project-level analysis. The absence of a species-specific plan component is a plan-level fact. No project-level biological evaluation creates a plan component that the plan does not contain, and a project cannot be made consistent with direction that has never been written. The assurance the DEIS gives at page 170 cannot be made accurate at the project stage, and the disclosure therefore has to occur in this document.
Nor is it addressed elsewhere in the analysis. The ESA discussion at pages 168 through 170 states the determinations and the plan-consistency assurance; it says nothing about whether the plans it relies on cover the species it lists.
Dear Ms. Rollins:
In my years as an outdoor enthusiast accessing the interior portions of national forests, I have observed that roadless areas function as a qualitatively distinct public resource, and it is from this vantage that I oppose the Department's proposed rescission of the 2001 Rule.
Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina:
Quiet, undeveloped recreation on roadless lands supports local economies through tourism, outfitting, hunting, and fishing.
Recreation disturbance has measurable effects on wildlife. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)
Rescinding the Roadless Rule would open the Craggy Mountain, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary.
We lose some of the most beautiful areas for hiking and wildlife in the US.
These are irreplaceable lands for wildlife and our enjoyment and for generations that come after us.
The forests don't need fewer protections. The Roadless Rule should stay.
Gratefully,
Simon Neuwahl
I am a graduate of Stony Brook University with a B.S. in Coastal Environmental Studies. I know many relatives and friends, myself included, who seek refuge away from the noise and chaos of modern life every year. The White Mountain National Forest is not only an important habitat for the wildlife that breathes there, but also for people for all seasons of the year. New road construction, reconstruction, and associated developments fragment this beautiful habitat, introduce disturbances, and eliminate roadless character. We visit this forest to get away from modern developments and the constant hum of cars whizzing by. However, noise from roads reaches deep into protected areas. Anthropogenic noise doubles background sound levels in 63 percent of U.S. protected area units and produces a tenfold increase in 21 percent of them. Elevated noise was found in habitats of endangered species, with 14 percent of critical habitats experiencing a tenfold sound increase. Noise pollution in protected areas is closely linked with transportation, development, and extractive land use (Buxton et al. 2017). — Buxton et al., 2017 (https://doi.org/10.1126/science.aah4783). Without the Roadless Rule, finding serenity within the nearby natural, beautiful landscapes will only prove more and more difficult.
One of my family’s first hikes was Mount Lafayette in New Hampshire, where we took the Franconia Ridge Trail loop. That day marked itself as having the most amazing natural view of the Northeast I had ever seen, and it is the reason I am an environmentalist today! Without these amazing natural landmarks, I, my family and friends, and hikers from around the country could lose our most beloved trails and fragment the natural views that come with them - our reason for coming back and staying in the Northeast. Many people who value these wildernesses will be negatively affected. Roadless areas anchor the primitive end of the Forest Service recreation spectrum. Inventoried roadless areas are classified by the agency as supporting primitive and semi-primitive recreation — landscapes characterized by quiet, dispersed access, minimal infrastructure, and apparent naturalness. These conditions are what distinguish backcountry recreation from developed recreation and are not present in roaded areas (USDA Forest Service 2016; USDA Forest Service 2024). — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf); U.S. Fish and Wildlife Service, 2024 (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf).
With the fragmentation and noise pollution associated with new roads and development, wildlife will lose their homes and the paths they take to get to and from them if the Roadless Rule cannot protect them. A systematic review of 274 studies found that more than 93 percent documented at least one effect of non-consumptive recreation on animals, with 59 percent of those effects classified as negative. Motorized use covers larger spatial extents than non-motorized activities and brings additional disturbance through dust, soil compaction, and vegetation damage. Forest Service leadership has named unmanaged recreation as one of four key threats to national forests (Larson et al. 2016; USDA Forest Service 2016). — Larson et al., 2016 (https://doi.org/10.1371/journal.pone.0167259); USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf). Also, population declines are widespread among North American migratory birds. The Connecticut Warbler has declined 62 percent since 1966; the Cerulean Warbler is declining at roughly 4.4 percent per year; the Golden-winged Warbler has lost an estimated 22 percent of its Great Lakes habitat and 43 percent of its Appalachian habitat since the 1960s. Habitat fragmentation on breeding grounds is documented as a major contributor (Hallworth et al. 2021; NRCS 2016). — Hallworth et al., 2021 (https://doi.org/10.1098/rspb.2020.3164); USDA Natural Resources Conservation Service, 2016 (https://www.nrcs.usda.gov/sites/default/files/2022-12/Golden_Winged_Warbler_Strategy_8-7-16.pdf). This will only worsen if the Roadless Rule cannot protect their habitat.
The Roadless Rule protects countless species - including us. In an age where environmental regulation and outreach is more important than ever, where the global climate crisis is evermore looming above our heads, and where those in power would seek to steal as much land and money as possible, there absolutely must be protections in place to keep us humans and wildlife safe from unabated industrialization! We cannot allow more development on the few natural landscapes that would destroy natural habitats and continue to remind us environmentalists what we live and fight for!
Opposes rescissionA1 strongSubstance 16/24Owed an answerSep 7, 2026FS-2025-0001-316505
PLACESTANDDOCGAPEVIDASKALTLAW
Dear Secretary Rollins,
It is as an outdoor enthusiast with direct experience of roadless national forest that I address these comments to the Department, urging that the administrative record be carefully evaluated before rescission of a rule whose protective reach was established through one of the most extensive public comment processes in Forest Service history.
I do not just use this land for recreation. I am from here. My father still lives near this land and you can see Kinsman Mountain from his backyard.
The amount of wildlife I have seen in this area is incredible. From yearling American Black Bears, to Moose, to Monarch Butterflies, it is an incredibly important area to wildlife that call these lands home.
I’m concerned for the numerous hiking/backpacking trails and specifically, how repealing this rule would effect Bridalveil Falls.
Regarding the Kinsman Mountain in the White Mountain National Forest, New Hampshire:
Headwater Protection for the Pemigewasset River Drainage — Kinsman Mountain contains the headwaters of the Pemigewasset River and multiple tributary streams (Coppermine Brook, Eliza Brook, Slide Brook, Reel Brook, Judd Brook, Kendall Brook, and Whitehouse Brook) that form the foundation of this major watershed. The high-elevation spruce-fir forest and montane heath woodland on the peaks and upper slopes intercept precipitation and snowmelt, regulating water flow and temperature across the entire drainage network. Removing forest canopy through road construction would expose these headwater channels to direct solar radiation, raising water temperatures and reducing the cold-water conditions that native fish and aquatic invertebrates depend on throughout the downstream system.
Roadless areas anchor the primitive end of the Forest Service recreation spectrum. Inventoried roadless areas are classified by the agency as supporting primitive and semi-primitive recreation — landscapes characterized by quiet, dispersed access, minimal infrastructure, and apparent naturalness. These conditions are what distinguish backcountry recreation from developed recreation and are not present in roaded areas (USDA Forest Service 2016; USDA Forest Service 2024). — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf); U.S. Fish and Wildlife Service, 2024 (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf)
Rescinding the Roadless Rule would open the Kinsman Mountain, White Mountain National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary.
Rescinding the Roadless Rule would cause serious harm to these lands.
Stale-Source Citation for FY2024 Recreation Visitation Statistic
The Draft EIS states that "the 193 million acres administered by the Forest Service received approximately 164 million recreation visits in FY2024" in its discussion of Economic Activity from Recreation in Roadless Areas, but this figure is cited to White et al. 2016 — a publication issued eight years before the reported data year. By definition, a 2016 report cannot be the source of FY2024 visitation data, and independent review confirms that White et al. 2016 is silent on this specific statistic. This is a foundational number underlying the entire recreation-economics discussion used to justify the rescission's benefits, yet it rests on no traceable source. Under Motor Vehicle Manufacturers Association v. State Farm, 463 U.S. 29 (1983), an agency must examine relevant data and articulate a rational basis for its conclusions, and agency NEPA procedures on scientific integrity and reasonably available materials require accurate sourcing. I request that the agency replace this citation with the actual current source, such as the National Visitor Use Monitoring program report, and audit related recreation statistics for the same error.
Keep the Rule. That's the whole comment.
Regards,
Sarah Floyd
I strongly oppose the proposed rescission of the Roadless Rule. As a Humboldt County resident, I consider the wild character of Six Rivers National Forest part of our community’s identity and quality of life.
Places such as the North Fork Smith Roadless Area provide quiet hiking on the Elk Camp Ridge, High Dome, and Stony Creek trails. Their value comes precisely from what is absent: industrial roads, heavy equipment, fragmented forest, and constant motorized disturbance.
Repealing nationwide protection would leave these lands vulnerable to decisions that permanently diminish their recreational value. A newly built road is not a temporary administrative choice. It changes water movement, spreads invasive species, fragments habitat, and destroys the solitude people seek in a roadless forest.
Please fight this proposal with every legislative and oversight tool available. Demand its withdrawal and work to make the protections of the Roadless Rule permanent. These public lands should never be treated as expendable inventory for private industry.I am submitting this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, docket FS-2025-0001.
Sincerely
I am submitting this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation
Rule, docket FS-2025-0001. I am a Humboldt County constituent writing in unequivocal opposition to USDA’s proposed repeal of the 2001 Roadless Rule. The North Fork Smith Roadless Area protects nearly 38,000 acres of Six Rivers National Forest. Its cold, undammed watershed supports salmon, steelhead, and cutthroat trout while providing the kind of fishing and backcountry recreation that makes the North Coast exceptional.
Opening these lands to additional road construction and commercial development would sacrifice clean water, intact habitat, and public recreation for short-term industrial access. Once roads fragment a watershed and sediment reaches spawning streams, the damage cannot simply be reversed.
The Roadless Rule must remain fully intact. I urge the Forest Service to select the No Action Alternative, withdraw the proposed rescission, and retain the Roadless Rule in full.
I am also concerned with maintaining the Roadless status of
Black Butte
Chanchelulla
Chinquapin
English Ridge
Mad River Buttes
Mount Lassic
North Fork Eel
Pattison
Redwood NP
Sanhedrin
Siskiyou
South Fork Eel River
South Fork Trinity River
Trinity Alps additions
Underwood Mountain
Yolly Bolly addition
Yuki
It’s what maintains the last connection we have to wild places away from roads.
Exact copy — Byte-identical to another submission. This comment stands for all 2 submissions in its group.