Read the comments.

To the Department of Agriculture and the Forest Service: As someone whose work depends on knowing the difference between revision and erasure, I want to be direct: this isn't a reform, it's a rollback. I grew up going to this area, seeing the redbuds in bloom in the spring, swimming in the river in the summer. Nature is our shared heritage, and it supports clean, bountiful water, clean air, and life. I will lose clean and abundant water, breathable air, home for animals who help to maintain vegetation and the water cycle, recreation space for myself, and knowledge that nature is out there, regulating conditions for life on Earth. Regarding the Tuolumne River in the Stanislaus National Forest, California: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Freshwater extinction risk. Aquatic species face disproportionate extinction risk globally. A multi-taxon assessment of 23,496 freshwater species found that 24% are threatened with extinction, driven primarily by pollution, habitat fragmentation, and sediment loading from upstream disturbance (Sayer et al. 2025). — Sayer et al., 2025 (https://doi.org/10.1038/s41586-024-08375-z) Rescinding the Roadless Rule would open the Tuolumne River, Stanislaus 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. Roads degrade watersheds. They cause erosion; silt up streams, harming fish; and they enable widespread logging that actually makes fires worse because it dries out the land. Trees and land are responsible for nearly half of rain over continents. The more we cut trees, the more we exacerbate never-ending drought. A rule that has survived multiple administrations and multiple rounds of circuit-court review should not be rescinded on the present record. Very truly yours, Erica Gies CommentID: RLC-20261007-D7HXTD

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

I strongly oppose the proposal to rescinding the 2001 Roadless Area Conservation Rule, commonly referred to as the 2001 Roadless Rule. Both my husband and I have spent many vacations in areas of the U.S. that are either adjacent to or within National Forest areas. As a child, I spent time in Michigan’s Upper Peninsula, including the Hiawatha National Forest, as well as along the western side of the Lower Peninsula near the Huron Manistee National Forest. In the 1980’s we lived in Rhode Island, and spent winter vacations cross-country skiing in the back country near Jackson, New Hampshire in the White Mountain National Forest. After relocating to California, we have spent the last 40 years vacationing in or near many of the National Forests located in the state. We have hiked and skied the back country near Mammoth Mountain and Lake Tahoe. My husband has been trout fishing for the last 20 years in the lakes and streams around Bridgeport in the Eastern Sierra. The common thread that runs through all of these forests is areas that are protected by the Roadless Rule. The roadless areas that we access by hiking or skiing provide peace and quiet that help us decompress from our busy urban lives, and our tourism helps support those local economies so that we can continue to enjoy them. Even more important, roadless areas help protect watersheds from silt and runoff contamination, since roads are a significant source of sediment in forested watersheds. By preventing sedimentation of the watershed, the Roadless Rule protects both the natural areas themselves and the drinking water sources for many downstream residents. Since I have spent most of my adult life in California, I would like to point out just a few of the important ways the Roadless Rule greatly benefits me and my family. The Roadless Rule is what helps protect the water clarity of Lake Tahoe, a major recreation asset for my family as well as the State. The Roadless Rule supports wonderful fishing areas in the Stanislaus and Humboldt Toiyabe National Forests around Bridgeport, since it prevents the sedimentation that kills trout. The Roadless Rule protects thousands of acres of the Sierra National Forest that contribute to the “Sierra Snowpack” that provides clean water for millions in California. Repeal of the Roadless Rule would endanger these all of these benefits. Most importantly, the Roadless Rule helps, rather than hinders, wildfire resilience in the forest. The US Forest Service own analysis shows that repealing the Roadless Rule would increase the risk of wildfire due to the increased human activity(1). In California, about 86% of wildfires are caused by human activity, and the ignition risk if four times higher near roads (2,3). In contrast, the Forest Service has been successfully increasing wildfire resilience in roadless areas for many years without building new roads. The Wildfire Crisis Strategy selected 10 initial forests for additional funding for work already underway within the Social and Ecological Resilience Across the Landscape Project (SERAL). One of the of the forests selected was the Stanislaus National Forest. This allowed the Forest Service to work in partnership with state and private land owners to perform proactive treatments to reduce fire risk. These treatments included hazard tree removal, prescribed fires, fuel break construction, and hand thinning to remove smaller trees and brush. Thinning is very important, since it reduces the vegetation that fires can use to climb from the ground to the forest canopy. Rather than the removal of mature trees by industrial logging that would harm the watershed, removal of small trees and brush leaves the larger older trees better able to withstand drought, insects, and new fires. Examples like the current work in the Stanislaus National Forest show that the Roadless Rule does NOT block wildfire prevention. Instead, it is a national standard that ensures a strong baseline of protection for these areas. It strikes the right balance with cooperation between the Forest Service, private land owners, and the State encouraged through local land management plans. By preventing unnecessary new roads and logging, the Roadless Rule just provides guardrails that prevent short-sighted political or industry pressure from damaging irreplaceable resources. Please reject the broad repeal of the Roadless Rule. Preserve what has worked well for more than 20 years. 1.Draft Environmental Impact Statement – 2001 Roadless Rule Rescission Volume 1. Project #68605 Updated August 19, 2026 by Patrick C.Yamnik. 2. Aplet, G.H., Hartger P. & Dietz, M.S. Three-decade record of contiguous U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8(2026). https://doi.org/10.1186/s42408-026-00450-2 3. Morrison, P.H. 2007. Roads and Wildfires. Pacific Biodiversity Institute, Winthrop, Washington. 40p.

U.S. Forest Service: I’m writing in strong opposition to the proposal to change the National Forest Roadless Area Conservation Rule. I have direct experience of the impact of the Roadless Area Conservation Rule. I lived and worked in and adjacent to the Stanislaus National Forest for more than two decades - spanning the introduction of the roadless rule. During that time my family, friends, and co-workers traveled many old and new logging roads. And we hiked many forested miles without logging roads. The differences between roads and roadless areas is stark and not trivial. Roads through our national forests lead to: •heavily eroded hillsides and river banks in fragile ecosystems; •downstream pollution fouling fishing and drinking waters; •significantly more illegal poaching and logging; •greater incidence of life-threatening wildfires; and •wasteful use of taxpayer dollars to subsidize, build, repair, and maintain destructive infrastructure The Roadless Rule: •prevents or significantly reduces each of these destructive outcomes; •protects recreational, ecological, and economically sustainable uses of the nation’s forest lands; •is a proven, fiscally responsible way to manage the nation’s natural resources; and •has been validated as an effective, successful public policy by numerous studies. The Forest Service is mandated by Congress to manage our national forests for “multiple use” and “sustained yield.” The roadless rule is an irreplaceable tool in that management toolbox. Rescinding or weakening the rule would open almost a third of our national forests – our national heritage – to certain destruction. I’ve seen what our forests looked like before there was a roadless rule. It would be the height of irresponsibility to return to that kind of unsustainable, destructive policy. Retain the Roadless Area Conservation Rule! Nikki Mandell Former resident, and current property owner bordering the Stanislaus National Forest

Regarding Docket No. FS-2025-0001 and RIN 0596-AD66: I STRONGLY OPPOSE repealing the Roadless Rule. I own a home near the Stanislaus National Forest. Its fragile ecosystems need the safeguards against industrial logging, road building, and commercial development that the Roadless Rule provides.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking into the Sierra Nevada is for me as it was for John Muir. There is no substitute for immersion in wilderness to refresh the human spirit, and when I travel to places like the Tuolumne River roadless area in the Stanislaus National Forest or Devil Gulch in the Sierra National Forest and capture that beauty on my phone, the people back home are delighted beyond measure by the glimpse into the natural world. That experience is what I am defending here. I oppose rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that this letter be entered into the record in full. The agency's own language on wildfire risk undercuts the case for rescission before that case can be made. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency now proposes to open the Sierra Nevada roadless areas and others like Bear Canyon in the Los Padres National Forest to new road construction on fuels-management grounds, it must explain how that action is consistent with those words. I ask that the agency reconcile this proposal with the ignition data in its own DEIS Table 21 and explain why it departs from its prior findings on fire occurrence and fuel treatment inside roadless areas. The economic rationale offered for rescission is, by the agency's own numbers, unconvincing. The record holds: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Americans like me expect the Forest Service to spend its budget, which originates with taxes we pay, in a transparent and responsible manner. We want those funds used to better maintain existing infrastructure and to enhance our recreational opportunities, not to build new roads into areas the rule now protects. That expectation only sharpens when the agency's own Cost Benefit Analysis cannot establish a net benefit and when the agency is already carrying a road maintenance backlog of $6.9 billion against a road budget of roughly $73 million a year. I ask that the agency reconcile this proposal with its own economic analysis, which projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million, and explain how expanding a road system carrying that backlog is a responsible use of public funds. The rule the agency proposes to rescind already contains the flexibility it now cites as justification for rescission. The record acknowledges that the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If those exceptions already address public health emergencies, existing mineral leases, and community wildfire protection, then full rescission is not the narrowly tailored response the agency owes the public. The agency must identify, with specificity, which burdens the existing exceptions do not already resolve, and it must quantify them. The water that originates in the Tuolumne River roadless area and in the other Sierra Nevada inventoried roadless areas reaches communities downstream. Americans like me want those water supplies to remain healthy, without the watershed degradation that follows road construction and heavy equipment operations. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Fewer than 12 percent of watersheds fed by roadless areas have impaired streams today. Opening these areas to roads risks that record. Finally, the process the agency used to justify rescission is itself defective. The proposed rule concedes that subsequent land management plan amendments and revisions "could increase the area where timber harvest and road construction would be allowed," declares changes to plans beyond the scope of the proposal, and then requests public comment on them (91 FR 53830). The agency cannot simultaneously declare foreseeable consequences out of scope and invite comment on them. There were more than 600 public meetings to make the rule, but none to undo it. Americans like me want our kids to inherit the same wild places we did. The agency must analyze the foreseeable plan-amendment scenario, including expanded timber harvest area, as a full part of this action before any final decision is made. Sincerely, Kimberly S San Jose, CA

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My husband and I hike and camp in the Waterhouse, Carson-Iceberg, and Eagle roadless areas of Stanislaus National Forest. We go for the quiet solitude and the wildlife. This summer our children swam in a lake in the Waterhouse area for the first time, and they look forward to coming back year after year. They appreciate the remoteness and the quietness. This land should be preserved as is for future generations. I am filing this comment to oppose Docket FS-2025-0001, the proposed rescission of the 2001 Roadless Area Conservation Rule. Carson-Iceberg, 56,430 acres of volcanic rock and stunning views, and Eagle, 16,116 acres, are exactly the kinds of places the rule was written to protect. We have spent time hiking in areas close to Waterhouse and Eagle that have roads, and nothing is worse than hiking and coming across part of the forest that has been clear-cut. We have been cut out from so many surrounding forest lands because private timber interests mark them to keep the public from seeing the clear cuts. It is absolutely tragic. Waterhouse, at 4,394 acres, is small enough that a single new road corridor would change its character entirely. California holds 381 inventoried roadless areas totaling 4,389,760 acres. These are not replaceable. A logged stand grows back. A road does not, at least not on any timescale that matters to the children swimming in Waterhouse lakes today. The agency frames part of its justification for rescission around wildfire and fuels management. Its own record cuts the other way. 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." The same record reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. I ask that the agency explain why the proposal departs from these findings and how it reconciles the rescission with the ignition data its own DEIS presents. The agency should also quantify the expected increase in human-caused ignitions that would follow from new road access into areas like Eagle, Carson-Iceberg, and Waterhouse, and weigh that increase against whatever reduction in wildfire hazard it claims to achieve. That calculation belongs in the record before any final action is taken. The regulatory flexibility analysis certifies no significant impact on small entities. That conclusion cannot be squared with what sits beside it. 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 certification is reached by spreading an estimated loss across the national universe of small firms in the sector rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw that certification and assess the actual small businesses operating in these roadless areas, not a national average firm that bears none of the specific loss. The agency has also invited comment on reliance interests and then built no mechanism for weighing 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 family's use of Waterhouse, Carson-Iceberg, and Eagle, our children's attachment to these places, and the expectation we formed under a rule that has been in place for over two decades are exactly the kind of interests that binding administrative law requires an agency to identify and assess when it changes course. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Across the Pacific Southwest region, 1,034 municipal water intakes sit in watersheds containing affected roadless areas. The people downstream from Stanislaus National Forest depend on the filtering and stabilizing function that unroaded slopes provide. Road construction disturbs those slopes. The agency has not demonstrated that its proposal accounts for this downstream exposure in any concrete way, and I expect a substantive response on that point in the final record. The 2001 rule followed more than 600 public meetings and 1.6 million comments. This proposal has held none. The agency should answer, in writing, how a rescission of that magnitude satisfies the notice and participation standards that produced the original rule. Sincerely, Krista Picone Ripon, CA

I oppose the proposed rescission of the Roadless Area Conservation Rule and support Alternative 1 (No Action). I live in Piedmont, California, and have a deep background in finance, including evaluating the costs, risks and returns of major investments. Measured that way, this proposal fails on its own record. Page citations are to the Draft EIS (DEIS). 1.Drinking water. About 90 percent of my tap water comes from EBMUD's Mokelumne River watershed, which EBMUD describes as "largely protected from human activity" and consisting "mostly of national forests and undeveloped lands" (EBMUD 2023 Annual Water Quality Report). That watershed includes inventoried roadless land on the Stanislaus National Forest along the North Fork Mokelumne River canyon. The DEIS finds that nearly 5 million people in the Pacific Southwest Region draw water from intakes in watersheds containing affected IRAs, more than any other region, and calls the region "particularly vulnerable" (Table 35, pp. 121-123). It acknowledges that these areas "typically have good water quality due to limited disturbance," that road construction is "the largest source of sediment related to timber harvest operations," and that Alternative 1 "provides the greatest protection of water quality" (p. 122). Post-fire and post-harvest reforestation in California increasingly relies on herbicides, including glyphosate; the Caldor Fire Reforestation Project, for example, lists glyphosate among five herbicides it may use (Lake Tahoe Basin). The DEIS mentions herbicides only for invasive-plant control, conceding they can have "unintended adverse effects" on terrestrial and aquatic species (p. 142), and never analyzes post-harvest herbicide use or its effects on source water. Fuel reduction near communities is already permitted under the 2001 Rule (36 CFR 294.13(b); DEIS Table 1, p. 14); commercial timber harvest and new road construction in source watersheds are not necessary to achieve it. At minimum, protections should be retained in municipal source watersheds. 2.Wildfire. The DEIS's own data undercut its fire rationale. Ignition density on other NFS lands is about four times that of affected IRAs (41.8 vs. 12.0 fires per million acres per year, Table 18, p. 87), and human-caused ignitions are over seven times higher (22.4 vs. 3.0, Table 21, p. 90). The DEIS concedes that "human caused ignitions increase in abundance with proximity to roads" (p. 90) and that IRAs burned a smaller share of their area (8.7% vs. 13.8%, Table 18). It also admits "a lack of roads has not prevented fire prevention or protection measures" (p. 105). Its answer to added ignitions, restricting public access to new roads (p. 105), depends on gates, closures and enforcement the agency cannot fund (see 3). 3.Fiscal responsibility. The DEIS reports a $6.9 billion deferred maintenance backlog for roads and bridges, counting passenger-car roads only, and a drop in annual road appropriations from $234 million (2004) to $73 million (2024); supplemental GAOA funding expired in 2025 and IIJA funding was set to expire September 30, 2026 (p. 43). It assumes timber revenue "would not be sufficient to cover the costs of constructing and maintaining all new roads related to a project" (p. 45). No prudent fiscal strategy adds new liabilities to a portfolio that cannot maintain the assets it already has. The agency should address the existing backlog and disclose the life-cycle cost of new roads, and how it would be paid, before removing protections. 4.Old growth and intact habitat. Roadless areas protect some of the last undisturbed forest, cold headwater streams and wildlife corridors. The DEIS finds the proposal "may affect, and is likely to adversely affect" 327 ESA-listed species and 71 critical habitats (pp. 25, 161), and that 11-16% of the operable area where plans allow harvest is old growth and 54-63% is mature forest (p. 78). It projects 253,000-557,000 ccf of added harvest per year (p. 77), yet defers site-specific analysis because future activities are "uncertain" (p. 32). The agency cannot model where the timber is while declining to analyze the harm in those same places. I urge the Forest Service to withdraw the proposed rescission and retain the 2001 Roadless Rule (Alternative 1). If any change proceeds, it should occur through state-specific rulemaking with full analysis of water supply, wildfire, fiscal and habitat impacts. Other sources: EBMUD 2023 Annual Water Quality Report (ebmud.com); CSERC, Stanislaus NF roadless areas (cserc.org); South Tahoe Now, Caldor Fire Reforestation Project (May 4, 2026); KUNR, Tahoe herbicide concerns (May 27, 2026); Mother Jones/Reveal investigation on Forest Service glyphosate use in California (Apr. 2026). Jeff East Bay, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Biodiversity is crucial to the health of natural forests, and Cherry Lake has shown me that truth for more than 30 years. Eagles, hawks, chipmunks, river otters, bears, mountain lions: the country around that 1,106-acre roadless area in the Stanislaus National Forest holds all of them, and I have spent years there as a professional fine artist painting the vistas and the hidden spots where wildlife live without human interference. It’s that world, and this rule, I’m writing to defend against the proposed rescission under Docket FS-2025-0001. The agency's own record on wildfire should stop this proposal before anything else is considered. 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 5 times more likely to occur on essentially roaded lands than on essentially unroaded lands." The agency now proposes rescission partly on fuels and fire management grounds while its own draft environmental impact statement records far higher fire density on roaded land than inside the affected roadless areas. I ask the agency to explain why this proposal departs from those prior findings and reconcile its reasoning with the ignition data in DEIS Table 21. Bears are among the animals I watch at Cherry Lake, and the stakes around roads and wildlife contact aren’t abstract. The DEIS, drawing on the federal grizzly bear recovery plan, documents that increased contact and conflict that come with open roads in bear habitat can ultimately end in mortality, and that shooting, habituation, and food reward all increase with the use of secondary unpaved roads. That consequence weighs directly on the unroaded character I depend on when I go looking for wildlife. I ask the agency address this conflict between its own cited recovery science and the effect of expanding road access into areas that now carry that protection. Water is where the proposal's costs become impossible to dismiss. California alone holds 1,034 municipal water intakes in watersheds containing affected roadless areas. We don’t have enough clean water today. Between selling off our water supply to huge foreign corporations and now this, I have to ask: when will you finally recognize the true value of the natural world instead of exploiting it? Once these resources are gone, they're gone. The agency's own analysis says roads and their facilities can produce up to 90% of the sediment from a timber sale, and fewer than 12% of the watersheds fed by these areas have impaired streams today. That’s a record worth protecting, not trading. The agency must explain on the record what it proposes to do when increased sedimentation degrades the water supply for communities downstream. The economics don’t justify the trade either. The agency's record states: "the total timber volume affected by this rule is less than .5% of total United States production, and the total oil and gas production from all National Forest System lands is currently about .4% of the current national production." My tax dollars already support a road system carrying a $6.9 billion maintenance backlog against a road budget of about $73 million a year. Building new roads into country that currently has none, in exchange for a share of national production measured in fractions of a %, isn’t stewardship. The agency must reconcile this proposal with a cost-benefit analysis that can’t establish a reliable net benefit before asking the public to absorb that risk. The agency also argues that state-by-state approaches can do the work of the national rule, but its own record reflects the outcome of that experiment. The DEIS notes 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 rule-making approach.' 70 Fed.Reg. at 25,656." The 9th Circuit has already reviewed what happened when the agency replaced the national rule with local decision-making. The agency should explain how this proposal avoids repeating those deficiencies. On authority, the 10th Circuit was clear: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the 2001 rule was within the authority Congress granted and didn’t create de facto wilderness. The agency's contrary position, if it maintains one, requires a legal explanation this record doesn’t yet contain. Humans are supposed to be the stewards of the natural world, not the destroyers. I oppose this rescission without reservation and expect the agency to answer each of these points before it proceeds further.

Several years ago, I had the opportunity to spend multiple days rafting the Tuolumne River in California. It remains one of the most extraordinary experiences I have ever had on public lands. What I did not fully understand at the time was that the wild landscape I was experiencing was not there by accident. The Tuolumne flows through and alongside inventoried roadless lands in the Stanislaus National Forest, including the Tuolumne River and North Mountain Roadless Areas. The Clavey River, which joins the Tuolumne in this remarkable canyon, is also surrounded in part by the Tuolumne River Roadless Area. For days, we traveled through a landscape that felt enormous, remote, and genuinely wild. There were stretches where the canyon and river seemed completely removed from the developed world. That experience changed the way I think about public lands. The Tuolumne itself has protections under the Wild and Scenic Rivers Act, and I am grateful for those protections. But a river does not exist separately from the landscape surrounding it. The forests, canyon slopes, tributaries, wildlife habitat, and undeveloped lands surrounding a river are part of what makes that ecosystem—and that experience—whole. That is why the Roadless Rule matters to me personally. I live in Colorado, more than a thousand miles from the Tuolumne River. But I have stood in these roadless lands. I have traveled through that canyon. I know what it feels like to experience a place that has remained largely wild. I want someone twenty, fifty, or one hundred years from now to be able to float that river and feel what I felt. Once we build roads into landscapes like these, we cannot truly make them roadless again. We should be extraordinarily cautious about giving up protections that have helped keep them intact. Please retain the 2001 Roadless Rule and the protections it provides to places like the Tuolumne River Roadless Area and roadless lands across our National Forest System.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forests around Yosemite and the Stanislaus, including the Tuolumne River roadless area, are where I go to escape the constant pull in all directions that defines everyday life. I hike and camp there to experience untouched land, and the Tuolumne River area, all 17,217 acres of it in the Stanislaus National Forest, is precisely the kind of place the 2001 Roadless Area Conservation Rule was built to protect. I believe it should stay that way, with the Roadless Rule intact. I am filing this comment in opposition to the proposed rescission under Docket FS-2025-0001. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and the Pacific Southwest region, which includes those areas, has 1,034 municipal water intakes sitting in watersheds that contain affected roadless land. Opening that country to roads and the extractive activity roads invite is not a minor administrative adjustment. It changes the character of places that, as I have experienced in the Tuolumne corridor, remain nearly untouched yet accessible in ways that make them genuinely available to the everyday, average American. Our extensive public lands make this country unique and special, and I do not think that value is being given serious weight in this proceeding. On the fire question, the agency's own data makes a case against the proposal it appears to be ignoring. The DEIS states that "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." Rescission means new roads; new roads mean more ignitions; the numbers in the agency's own table show the scale of that increase. I ask that the agency quantify the expected increase in human-caused ignitions that would follow from new road access and weigh that figure openly against whatever wildfire hazard reduction it believes the proposal achieves. The fiscal argument against rescission is equally direct. The agency is already $6.9 billion behind on road maintenance against a budget of roughly $73 million a year. It does not make sense to build something we will not be able to maintain, especially given that we already cannot maintain existing roads appropriately. We should be fiscally responsible and not add to a growing backlog. The regulatory flexibility analysis does not engage this reality honestly. "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 losses across every small firm in the sector nationally rather than looking at the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw the certification and assess the impact on those specific firms, not the national average. The agency also invited comment on reliance and then performed no analysis of what it received. "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." I have spent time in these areas because the rule existed and the land remained open in the way it did. That is a reliance interest. The agency should identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds. Finally, the alternatives analysis forecloses the comparison NEPA requires. "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 as deregulation eliminates protective options by definition. The Black Butte roadless area in Los Padres National Forest and the Tuolumne River area in the Stanislaus deserve analysis under at least one alternative that takes their conservation values seriously. The agency should restate the purpose and need in terms of actual forest conditions and carry at least one fully protective alternative through to analysis.

The foolhardy, destructive and illegal assault by the current administration on the environment and American people make the 19th century robber barons look like raging democratic socialists. I strongly OPPOSE rescinding the Roadless Area Conservation Rule that has helped protect roadless areas, and adjacent Wilderness areas, on our national forests for the past 25 years. You obviously know that roadless areas provide critically important habitat and migration corridors for endangered species and other at-risk wildlife and plant species. Undoubtedly, you realize these areas have extremely high value as healthy, undisturbed watersheds to provide clean water to streams that supply rivers benefiting downstream water users. Allowing additional roads will create additional run off – sending dirt and sediment downstream which will damage habitat for fish and aquatic wildlife. And, of course, adding roads in steep, rugged country increases the risk of landslides. As an avid outdoors person, I value roadless areas for recreational use hiking, camping and backpacking. Others value these areas for horseback riding, hunting and fishing. Of critical concern to me are my nearby PUBLIC lands: Carson Iceberg Wilderness, Emigrant Wilderness, the Stanislaus National Forest and Yosemite National Park. I have had the pleasure of outdoor recreation in numerous other wilderness areas, national forests, as well as state and national parks in California, Oregon, Washington, Alaska, Hawaii, Arizona, New Mexico, Colorado, Idaho, Utah, Montana, Pennsylvania, New York, and Florida. Wilderness areas and national forests provide buffer zones for wildlife around our precious national parks. These lands were set aside by Congress “for the benefit and enjoyment of the people”—NOT corporations looking for lumber, oil, gas and minerals. Additional roads in our wild areas will cost taxpayers millions – just to subsidize corporations’ greed. The Forest Service can’t even maintain the 380,000 miles (longer than our highway system!) of existing national forests roads, how will they maintain more? According to some, there is an estimated $8.6 billion maintenance backlog already. Why build more if you cannot maintain what you have? As a native Californian, I understand the risk of fire all too well. Adding more roads to the wilderness will undoubtedly result in more human-caused fire. Research shows that more than 60 percent of human-caused fires on national forests in the Lower 48 states are ignited within 1/8-mile of the nearest road, and 95 percent are ignited within 1/2-mile. And contrary to the disinformation being spread by the current administration, the Roadless Rule act ALREADY allows prescribed burns and fuel reduction projects. We do NOT need more roads in our forests. If you want to do something useful for the American public regarding the Roadless Area Conservation Rule, strengthen it! Eliminate logging and road-building loopholes and provide better protection to roadless areas and adjacent Wilderness areas. Preserve our wild roadless areas! They are a priceless heritage to be passed down to future generations.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Sierra Nevada range, from Lake Tahoe down through the Stanislaus and on to Bishop, is where I climb. The country I move through includes the Tuolumne River roadless area, 17,217 acres inside the Stanislaus National Forest. I am filing this comment to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. My view of what public land should be managed for is straightforward: environmental restoration and preservation. This proposal moves in the opposite direction, and the agency's own record explains why. The fire justification for rescission does not survive a reading of the DEIS. The agency's own text 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 Tuolumne River area and the broader Tahoe region are exactly the kind of high-elevation, fire-prone landscapes this finding describes. I ask that the agency explain why the proposal departs from these prior findings and reconcile the rescission with DEIS Table 21, which reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas across the decade 2014 to 2024. The DEIS itself states that human-caused ignitions increase in abundance with proximity to roads. The agency should quantify the expected increase in ignitions from new road access and weigh it against any claimed reduction in wildfire hazard before this rule proceeds. 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. Road construction in areas like the Tuolumne River watershed carries direct consequences for water quality downstream. The agency has not adequately addressed what opening these watersheds to road building means for the communities and intakes that depend on them. That question deserves a direct answer in the record. The regulatory flexibility analysis is not credible. 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 losses across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. Spreading a known loss across a national average firm does not assess whether the firms in these specific places are harmed. The agency should withdraw the certification and conduct an analysis focused on the small entities actually operating in the potentially affected roadless areas. Finally, the agency invites comment on reliance while never weighing it. 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. I have planned my use of these lands around the protections the 2001 rule provides. Under the legal standards that govern agency reversals, that kind of reliance interest must be identified and weighed, not solicited and ignored. This comment is such an interest. The agency must account for the reliance interests described in the record it is building, including this one. Sincerely, Joshua Thomas Daly City CA

Throughout my life the public lands have been an integral part of my close familial bond. My father would take my family hike in White Mountains National Park as his father took him. I grew up on the outskirts of Big Cypress Forest in South West Florida and conservation and time in nature where pillars of my up bringing. As a young adult hiking the Appalachian Trail from Boiling Spring PA to Leigh High opened up a deep love for backcountry camping. Later during the pandemic my husband and I would backpack from Harrisburg PA through to Liberty Mountain in NH. Now that we live California, we spend every free moment in Emigrants and Stanislaus National Forest. Every summer my close friends and I hike in Eagles Nest Nation Forest in Vail CO. Our public lands are what make America unique and special. Being able to connect with nature and experience these wild places they way they were when the country was founded in a privilege that we cannot afford loose. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. I care deeply about our national forests. I have hiked and fished extensively in Plumas National forest, Stanislaus National Forest, Tahoe National Forest, El Dorado National Forest, Inyo National Forest, Los Padres National Forest and Sequoia National Forests over the past 50 years. In addition to recreating in these forests, I have lived significant parts of my life in areas where the clean drinking water flowing from our taps originated in national forests. The Roadless Rule has protected important areas of our national forests and their ecosystems for 25 years. The Forest Service, in the text of the Roadless Rule, states that conserving roadless areas was critical because road construction and logging were the activities most likely to harm the values and characteristics the Forest Service is tasked by statute with protecting. The science is clear; road building fragments habitat, disrupts wildlife and watersheds; increases siltation and other pollution and worsens the spread of invasive species. The science is also clear that, contrary to USDA's claim in its Notice, more roads will not reduce the risk of fire, it will increase that risk. Over 80% of wildland fires are human caused, and more roads means more people. Most fires ignite within a few hundred feet of roads. New research shows wildfires are four times more likely to start in roaded areas than in unroaded areas. Both the Rim Fire in 2013 and the Donnell Fire in 2018 in Stanislaus National Forest were caused by unattended campfires near roads. The current administration has significantly reduced the number of forest service personnel including those providing wildfire prevention, suppression and management. These policies make it clear that this rule is not genuinely about mitigating fire risk. Indeed the reduction in forest service personnel will make it impossible for the forest service to manage either additional roadbuilding activities or the added persons coming on to the newly opened areas in our national forests. The forest service has not been able to adequately maintain its existing road network to safety or environmental standards. For all of the above stated reasons, I strongly oppose the arbitrary and capricious action of the USDA in proposing rescinding the 2001 Roadless Rule. USDA, before moving forward, should undertake a thorough environmental analysis of roadless areas to assess the impact of additional road building, guarantee that no watersheds will be negatively impacted by rescission, and develop and share a detailed plan for addressing its current backlog of road maintenance and repairs. USDA should also commit to providing a transparent and complete accounting of how public comments were considered and concerns addressed in any revised rule. Ken Strong

We need to continue our current Roadless Rule, protecting our wilderness. Roadless areas are of great recreational value, providing a wild, quiet environment for visitors. I frequently visit the Stanislaus National Forest. The Forest Service already has many dirt roads throughout the forest, and they cannot adequately maintain them. It makes no sense to add more.

I am asking this agency to withdraw Docket FS-2025-0001. Watching what roads and logging do to forests and upper watersheds, has given me a particular way of assess proposed changes to public land protections. I have seen severe degradation of streams due to logging such that fishing was not possible, or simply very unappealing because of the damage caused by heavy machinery, slash piles, and sediment buildup from runoff. I have led backpacking groups into the Eagle, Dome, and Carson-Iceberg roadless areas of the Stanislaus National Forest, and into Castle Peak in the Tahoe National Forest, because I believe these places are provide unique value. I organize trail crews, collaborate with local foresters, and last year our team reopened three miles of trail in the Carson-Iceberg area that had been lost to undergrowth and downed trees. I bring volunteers to a backcountry hut at the base of Castle Peak to prepare it for winter, and those volunteers come largely because there are no roads and no industrial operations there. The appeal would be gone if roads were built into this area. The streams I have watched over decades carry the clearest argument against this rescission. The DEIS itself states that skid roads, trails, and log landings are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That figure appears in the document and yet nothing follows it: no projection of how much sediment would reach waterways. The agency's own data further states that sedimentation from harvest can negatively impact fish by causing egg and juvenile mortality and reduced suitable habitat. The Eagle roadless area, 16,116 acres in the Stanislaus, holds springs and seasonal creeks already trampled by cattle, with sediment already clouding waters downstream. Adding road-based timber harvest to a watershed already under that stress is a compounding harm the analysis does not attempt to quantify. I ask that the agency project the expected sediment delivery to the municipal intakes downstream of these areas before it finalizes any rule. Bear range through the Stanislaus and Humboldt-Toiyabe forests I have traveled for more than thirty years. The DEIS cites the likelihood of increased contact and conflict that come with open roads in bear habitat can ultimately end in bear mortality, and habituation and food reward all increase with the use of even secondary unpaved roads. The agency entered that finding into the record and then did not carry it forward into a projection of mortality under the proposed action. What does the agency expect to happen to bears in roadless areas that become roaded? The record needs an answer. After fire, these places team with new life. You can see the resilience of the forest first hand. After industrial logging, these places are silent and feel much less alive. The agency's own fire data records human-caused ignition density at 22.4 fires per million acres per year on roaded National Forest 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 analysis itself concedes that road access could increase the number and frequency of wildfires. No quantification of that expected increase appears alongside the claimed wildfire-hazard justification for the rescission. I ask that the agency reconcile those two positions by projecting the net change in ignition risk before it proceeds. 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. I have paid millions in federal taxes over a long career, largely without reservation, because I saw value in what agencies like the Forest Service do. The trail work, the backpacking groups, the volunteer hut preparation at Castle Peak: all of it rests on a reasonable expectation that these roadless areas and their neighbors will not be handed to extractive industry. I am expressing a reliance interest. The agency must weigh it. 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 Stanislaus, Tahoe, Eldorado, and Humboldt-Toiyabe forests I visit support permit holders whose entire operation is tied to specific roadless terrain, not to the national average across which the flexibility analysis spreads its numbers. The agency should withdraw the certification and assess the impact on the individuals and small entities actually holding permits in these areas. These forests are central to what public land means. Americans own them and want them protected. I still believe government can work for its citizens, if it would just listen to them. Sincerely, Scott Mattoon Stockton, California

Secretary Brooke Rollins U.S. Department of Agriculture 201 14th Street SW Washington, DC 20250 Thomas Schultz Chief, U.S. Forest Service 1400 Independence Ave., SW Washington, D.C. 20250-0003 Re: Docket No. FS-2025-0001 - Comments on the 2001 Roadless Area Conservation Rule Rescission Draft Environmental Impact Statement (DEIS) Dear Secretary Rollins and Chief Schultz: I strongly urge USDA to keep the 2001 Roadless Area Conservation Rule (Rule) intact, select the No Action Alternative, and revise the DEIS as stated below. I spend time in Rubicon in the El Dorado National Forest and the Tuolomne River in Stanislaus National forest and deeply value Inventoried Roadless Areas there]. I enjoy hiking tand fishing here. This place matters to me because I enjoy getting out in remote areas away from cars and traffic]. They provide clean water, wildlife habitat, recreation, solitude, and increasingly rare intact forests. The current Rule already allows substantial forest management, including prescribed fire and other hazardous-fuels reduction. While USDA claims rescission would reduce wildfire risks, the DEIS cites research that 1) the lack of roads has not prevented fire prevention or protection measures, and 2) acknowledges that almost 90% of wildfires are human caused and more than four times likely to ignite near a road. If specific constraints exist, USDA should identify and address those narrow constraints rather than remove the Rule’s nationwide protections. USDA has not adequately assessed the reasonably foreseeable national and regional environmental effects of its decision to eliminate the Rule’s protections across 44.7 million acres of public lands. Deferring NEPA review to future site-specific individual projects will not address the regional and national consequences of rescission. While later reviews may evaluate individual projects, they would not address foreseeable programmatic impacts at scale from landscape fragmentation, habitat connectivity, native plants and invasive species. interstate or inter-forest migration corridors, or regional watersheds. USDA should assess now where national rescission would put intact habitat, wildlife movement, and native plant communities at greatest risk, and where added roads and timber harvest could most threaten watersheds and drinking-water sources. Rescission would also remove protections from 9.3 million acres in the Tongass National Forest, relying on the 2020 Alaska Roadless Rule Final EIS, but it has not demonstrated the earlier environmental analysis adequately evaluates rescission. Tribal consultation remains incomplete. USDA should fully consider Tribal concerns about subsistence, cultural resources, fish and wildlife, and intact landscapes before making a final decision. I urge you to keep the national protections of the Rule in place and reassess the reasonably foreseeable effects now. attached file(s)

I live in Tuolumne County surrounded by the Stanislaus National Forest. In 2013 the Rim Fire burned directly through our land, destroying 95% of the timber and habitat; happily, our home survived. I know what fire does here, and I do not accept the claim that repealing the Roadless Rule will make us safer. The rule already allows fuel-reduction work near communities, and fires ignite far more often near roads than away from them. Repeal would bring new roads the Forest Service cannot maintain, more ignition points, and logging and mining pressure on the intact watersheds that hold our snowpack and supply our water. Please choose Alternative 1 and keep the 2001 Roadless Area Conservation Rule fully in place (Docket FS-2025-0001). More than 600,000 people said so last year. Listen to them, and to those of us living at the forest's edge. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.