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Hello, To those who will read this comment, I share the following: In 2023 I thru-hiked the entirety of the Pacific Crest National Scenic Trail. In 2011 I canoed miles of the Boundary Waters and surrounding Superior National Forest. Between 2018-2020 I spent countless times hiking, backpacking, and camping in the Manistee National Forest of Michigan. Today my family enjoys spending our weekends and vacation time in the numerous national forests in Washington and Oregon, before that it was Nevada, California, and Utah. All of these areas share commonality of federal public lands that hold roadless areas. All of which will be negatively impacted if the roadless rule is repealed. In a world that is constantly focused on development and progress, I believe we must protect these spaces. We are on a current path that closely parallels the terrifying plunder and waste our forefathers carried out in the late 19th and early 20th centuries. We need our elected officials to pause and recognize the natural treasures our country holds and seek not to plundered but preserve. The American people stand, bipartisan, firmly against this proposed change, and we demand you listen. I want to be able to return to these spaces in with future generations and share and pass on the same experiences that I had when first visiting them. If we open these places to roadways which will inevitably lead to vast logging and mining operations, and perhaps even data center developments; it will forever alter these incredible spaces that define the wild and unique American spirit. We won’t be able to get them back in our lifetime or many lifetimes after ours. We have ample land currently under federal management that can be looked to for development without encompassing the current lands that have protection through the roadless rule. The USFS currently manages over 265000 miles of roads, 8 times the length of the interstate system. They are dilapidated and backlogged for repairs or replacement. The US Forest Service estimates it between 7-10 billion dollars in deferred maintenance! Much of this due to chronic underfunding, and yet the funding was cut even more ($438 billion, 24%) earlier this calendar year. Adding more roadways defies sensibility. The forestry service doesn’t have the ability to maintain what it oversees now, it will only amplify the problem. Lastly, this brings me to roadways and wildfires. Because where there are more roads there are more fires. Something none of the country needs or wants. According to research done by the Sierra Club, 90% of forest fires start within .5 mile of a roadway. The USFS cited that 66% of human cause forest fires start near roadways. We don’t need to extend and/or introduce more locations to spark flames and burn our public lands to the ground. Considering wildfires are 4 times more likely to start near a roadway, we will make the West, Midwest, and even Eastern wildfire problems a certainty if the roadless rule is repealed. I appreciate the time to read my comments. I pray the elected officials, who were put into their positions by the people, will remember to whom they answer and what duty means. Be bold, be honorable, protect our beautiful natural spaces and leave the roadless rule

I have been visiting the Indian Peaks and the Indian Peaks Adjacent Area since I moved to Boulder, CO, in 2005. The fishing and hiking are excellent, and some of my most blessed moments have come while watching the evening light over Blue Lake. The baby moose I discovered in 2013 changed my relationship with my partner. I will be hiking and camping in the Indian Peaks adjacent area for the rest of my life. I ask that the agency explicitly describe its plan for how to preserve the pristine cleanliness of the watershed in Colorado. Superior National Forest is one of the most magical places in the upper Midwest of the United States. So much of the land in neighboring North Dakota has already been privatized and developed. It will be a tragedy to put roads in such proximity to the watershed of the Boundary Waters. I have canoed and backpacked in the forest with my best friend, where I observed loons and a bald eagle. When we hiked in 2008, we encountered a great deal of blown-down timber from a past tornado in the area. This resulted in carpets of fresh raspberries that fed birds and rodents in the wilderness. I will be returning in the summer of 2028 for a canoe trip with my friend and my goddaughter. Please keep protections in place for all parts of wilderness preserved by the Roadless Rule. Losing the wild nature of this area will condemn us to consumerist doom. I ask the agency to explicitly describe what steps it will take to maintain the wilderness, the pure watershed, and the bird habitat in the Superior National Forest. "The visitor industry is the largest private sector contributor to regional employment after government. The visitor industry provides over 8,000 jobs, 18 percent of regional employment, and over $249 million in earnings, 11 percent of regional earnings, each year." (Complaint para. 51, same filing, pp. 22-23 of 50) "Given the urgency of keeping additional carbon out of the atmosphere and continuing carbon accumulation from the atmosphere to protect the climate system, it would be prudent to continue protecting ecosystems with large trees for their carbon stores, and also for their co-benefits of habitat for biodiversity, resilience to drought and fire, and microclimate buffering under future climate extremes." (Mildrexler, Berner, Law, Birdsey and Moomaw 2020, Front. For. Glob. Change 3:594274, abstract) I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Michael Edward Christoph Denver, Colorado

My family has hiked and camped in Superior National Forest in MN for over a decade. This rule is the reason this national forest is wild enough to camp in and the trails worth hiking because they're free from noise pollution. Destruction to this national wilderness is not reversible once it's gone. Roadless areas see fewer human-caused wildfires than roaded ones. Wildfires are 4 times more likely to start near roads. Roads don't reduce fire risks, it increases it. Roadless areas are carbon vaults, keeping our air clean. Many of these areas are the foundation of a pristine watershed, and the Superior National Forest ensures that Lake Superior stays clean. Road maintenance is significantly more costly than no roads. Please keep the 2001 Roadless Rule intact.

I'm an avid outdoor enthusiast, and treasure all of the National Forest areas that are currently protected by the 2001 Roadless Rule, but especially those in my home state of Minnesota. Preserving the 62,000 acres of Superior National Forest that fall under this rule is extremely important, not just for environmental reasons, but economic ones. Outdoor recreation in northern Minnesota has and will continue to be a thriving sector of the economy for generations, but only if the integrity of these wilderness areas remains intact. Rescinding the Roadless Rule would directly contradict this, and I strongly urge the USDA to choose Alternative 1 "No Action".

I am opposed to repeal of the roadless rule because I frequently recreate in National Forests that will be effected and recreation with the current amount of roads is completely sufficient to fulfill more than a lifetime of recreation in these places. It is worth noting that I often recreate in my overlanding vehicle, which is a 2021 Chevrolet Silverado 2500 with an AT Overland Atlas camping topper that is specifically designed for overloading, which is exploring backcountry roads (primarily in national forests) and camping. I often string together trips of 2-5 days overloading in various national forests. (I will provide my experience doing so at the end of this comment.) Due to the plethora of road options already available in National Forestland, which is enough to satisfy a lifetime of use, the addition or more roads is not a compelling rationale for this proposal. Specifically, these are the reasons I am opposed to repeal of the roadless rule. 1. Impact on nearby National Parks: National Forests play a critical role in the National Park System by often surrounding National Parks and thus serving as a buffer between pristine parkland and wilderness areas and human activity. This is the case for nearly all the major parks in the park system, including the Crown Jewels of the National Parks Service, which will be directly impacted by the recession of the roadless rule—Yellowstone, Grand Teton, Glacier, Mount Ranier, Yosemite, North Cascades, Olympic, Everglades, Grand Canyon, Rocky Mountain, Sequoia and Kings Canyon, Redwood, Crater Lake, Shenandoah, Wrangell St. Elias, and Great Smokey Mountains. It is additionally the case for lesser known, but still important, national parks such as Theodore Roosevelt, Badlands, Guadalupe Mountains, Lassen, Pinnacles, Voyaguers, Mesa Verde, Black Canyon of the Gunnison, New River Gorge, as well as other national park units such as Pictured Rocks National Lakeshore and Sleeping Bear Dunes National Lakeshore. The impact on the Greater Yellowstone Ecosystem looks particularly acute. The GYE, which includes Yellowstone National Park, Grand Teton National Park, and several impacted National Forests — Custer-Gallatin NF, Shoshone NF, Bridger-Teton NF, Caribou-Targhee NF. Like the other National Parks mentioned above, Yellowstone greatly benefits by being completely surrounded by National Forest land. In fact, also like many of these other National Parks, it is impossible to enter Yellowstone without passing through a National Forest. Simply put — increasing roads and industrial motor vehicle traffic in national forestland will adversely impact the ability of people to get into the parks and will have an adverse effect on nearby wildlife and wilderness areas. 2. Impact on last remaining intact ecosystems Personally, when I camp and backpack, I do it in an intact ecosystem. Whether in/around Yellowstone, Tongass NF, Chugach NF, Superior NF / Boundary Waters, or other roadless wilderness areas, these areas are few and far between and provide solitude that is simply unavailable in forestland that permit roads. The personal benefits to me, my family, and my friends are significant. These areas provide time and space and silence for personal reflection and personal growth. Adding additional roads into roadless areas threatens this recreation. It is also worth noting that these areas are some of the last areas WITHOUT ROADS in the world, so the only areas that permit space for reflection away from modern society. These areas need to be preserved as is for this unique and limited experience. The estimated loss of $6.1M annually is a ridiculous underestimate that completely lacks support. The real total is far greater. 3. No definition of the “regulatory burden” that will allegedly be relieved. There is no real definition of what the exact “regulatory burden” that USFS claims is present. If this is just another way of stating that this current government just doesn’t like the rule, then that is not a persuasive reason to repeal it. Moreover, the rationale is full of vague, undefined justifications that do not hold up to scrutiny: - “Constrains responsible officials from exercising the timely, place-based discretion…” - “Evolving national priorities and changed conditions…” - “Removed important management tools for key areas…” - “Unique ecological, economic, and social needs of their communities…” These are vague, boilerplate terminologies for which no concrete examples are given in the rationale. Indeed, there are no examples given of any local forest service officials expressing desire for more “flexibility to address conservation and resource issues” by repealing the roadless rule. Absent any examples, the rationale for this repeal cannot stand. (To be continued - 1 of 2)

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.

My family has hiked and camped in the Superior National Forest in Minnesota for more than a decade, and the character of that landscape—its quiet, its intact ecosystems, its sense of true remoteness—exists today because of the protections established under the 2001 Roadless Area Conservation Rule. These areas are not theoretical policy abstractions; they are real places that Americans rely on for recreation, clean water, wildlife habitat, and climate stability. Removing national-level protections would jeopardize all of these values. Roadless areas are among the last remaining large, unfragmented tracts of public land in the country. Once roads are built, the ecological impacts are immediate and irreversible. Roads introduce noise pollution, fragment wildlife habitat, increase erosion, and open previously remote areas to human-caused disturbances. Research consistently shows that human-caused wildfires are far more likely to start near roads—up to four times more likely—meaning that roads do not reduce fire risk; they increase it. The claim that rescinding the rule will improve local flexibility ignores the fact that roadless areas are already functioning as natural buffers against wildfire ignition. These landscapes also serve as critical carbon vaults. Intact forests store carbon far more effectively than fragmented ones, making roadless areas an essential tool in mitigating climate change. In the Superior National Forest, these protections help safeguard one of the most important freshwater systems in the world. The forest is a foundational part of the Lake Superior watershed, and maintaining its roadless character helps ensure that Lake Superior—an irreplaceable resource for millions—remains clean. Economically, road construction and maintenance impose significant long-term costs on taxpayers. The Roadless Rule prevents the creation of new financial liabilities for the federal government while preserving the ecological and recreational benefits that already exist. The idea that rescinding the rule will “reduce regulatory burden” overlooks the fact that the rule has provided clarity and consistency for 25 years. Removing it will create a patchwork of forest-by-forest decisions, increasing administrative complexity and inviting conflict. The 2001 Roadless Rule is one of the most successful and broadly supported conservation policies in modern U.S. history. It protects values that cannot be replaced once lost. I strongly urge the USDA to keep the Roadless Rule intact and maintain national-level protections for these irreplaceable landscapes.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about Kawishiwi Lake To Sawbill (15,305 acres), Superior National Forest, Minnesota. I ask that the agency disclose and analyze the site-specific environmental consequences of the proposed rescission for each covered areas, including the effects of the road construction and timber harvest it would newly allow. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: Elk survival, in the agency's own citation The agency's own record shows road access hurts elk. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. No population-level effect on big game is projected anywhere in the document. I ask that the agency project the effects on big game populations and hunter opportunity. Issue 2: Land fragmentation is quantified and not applied The agency put a number on fragmentation and then never applied it: The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. In this particular area, deer, moose, and wolves are all vulnerable to land fragmentation The number appears; no projection across the 40.1 million affected acres follows. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. Issue 3: Reliance interests are invited and never assessed I and many others have built years of outdoor recreation (canoeing, camping, hiking, hunting) around the protection this rule provides. That is a reliance interest, and it is exactly what the agency invited comment on. 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. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. Issue 4: The small-business certification contradicts the analysis beside it Small business outfitters and guides are part of many of my trips. They deserve a real assessment, not a national average. 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 regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. Issue 5: Foreseeable plan amendments are placed beyond scope I have paddled/hiked through the interior of these areas, and what future plan changes would open is not an abstraction to me. I raise this because the agency put that future beyond its own analysis. 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 is asking commenters to perform the analysis it declared out of scope. I ask that the agency analyse the foreseeable plan-amendment scenario, including expanded timber harvest area, as part of this action. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for all covered areas. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

I live in New Hampshire and am very concerned about the repeal of the Roadless Rule. The White Mountains and the Lakes Region serve as the two primary anchors for New Hampshire's tourism economy, drawing the vast majority of the state’s 14.6 million annual visitors (6M to the White Mountains) from all 50 U.S. states and roughly 72 different countries. These visitors generate approximately $7.5 billion in total spending and support ~70,000 jobs. folks visit and live here for the wild. The Whites are also the crown jewel of the AMT which spans 14 states with 16.9M visitors. You may be aware that the logging industry's mismanagement and destruction in the Whites was the impetus for establishing the USFS. It took over 100 years to restore these mountains and we don't want to go back. The White House defends the repeal with the truly laudable goals of reducing wildfire risks, improving forest health and enhancing local control and flexibility however the brief and the accompanying Draft Environmental Impact Statement (DEIS) provide little evidence that the repeal promotes those goals and often show the opposite. Other actions by the Executive Branch also demonstrate the opposite. • The evidence in the DEIS is often contrary or missing. For instance, the DEIS shows that wildfires are 4x more likely in roaded areas than roadless. Further, the DEIS analysis shows that ~2x as much land is burned in roaded forest fires than roadless ones. There is no commitment in the DEIS to improve vegetation or fuel treatment management. •The DEIS shows that the new revenue from industry is insufficient to build the new roads or even offset the impacts from this administration's forest service cuts. Cuts have exacerbated fire risks, already deficient road/bridge repairs and insufficient forest management. ~6,000 USFS personnel have been eliminated. Due to support staff shortages, active wildland firefighters are being diverted to non-fire tasks like facility maintenance, cleaning, and grounds keeping instead of the fire line. Fire risks are further exacerbated by cuts to climate change research and resiliency, the leading contributor to the severity of wildfires according to the overwhelming majority of scientists around the world. • the sole logging project approval thus far does not demonstrate intent to improve forest health. The Lost River Project approved in 2025 with a threadbare environmental impact review is for 1,093 acres of commercial logging in the Western White Mountains with over 200 acres of clearcuts. • the "national emergency" justification for eliminating protections and the due process overrides in the 3/1/25 Timber Production Expansion executive order (14225), the 4/24/25 "American Mineral Production Expansion (14241), and the 1/20/25 Energy Expansion (14154) appear exaggerated and insincere. The president justifies the drilling regulation overrides in 14154 saying that regulations limit supply and weaken national security while allowing 55% of our country's domestic crude oil and natural gas (NGPL) products to be exported (EIA) and actively eliminating alternative energy sources. The lumber and mining emergencies were created with the trade wars we initiated, such as the trade war we started with Canada, currently our leading lumber supplier. Our lumber supplies would remain sufficient if we backed off our trade war and repaired our relationship with Canada. • Executive actions are contrary to providing more local control as they remove state, local and public input and decision from the permit process and give the president total control of those decisions. Little to no input to these incredibly consequential decisions is required and the decisions will raise questions of self-benefit and conflict of interest. a case in point was the executive branch's advocacy of Antofagasta PLC to build an a mineral mine in the headwaters to the pristine Superior National Forest despite the overwhelming objections of state and local authorities, indigenous tribes, and the citizens of Minnesota. In summary, the National Forests are a treasured legacy that we must protect and pass down to future generations as previous generations did for us. I think we all share the goals of reducing wildfire risks, improving forest health and enhanced local control and flexibility but repeal of roadless protections sets us back rather than advancing those goals. Executive orders for accelerated drilling, mining, and tree harvesting should be rescinded to de-escalate the emergency and allow for more thoughtful solutioning to meet these goals. Given the permanent impacts to current and future generations, more public consideration of the pros and cons of alternatives is needed, not less., not less. further reading: https://blogs.law.columbia.edu/climatechange/2026/09/03/several-key-problems-with-the-forest-services-proposed-repeal-of-the-roadless-area-conservation-rule/

I am deeply concerned about the proposed rescission of the Roadless Rule. As someone who lives within Superior National Forest, I spend significant amounts of time hiking, camping, hunting, and fishing in Roadless Areas, both locally and on my journeys through western states. I am deeply concerned that rescinding the Roadless Rule will greatly impact my ability to hunt, fish, gather, travel by non-mechanical means, and recreate on my own public lands. If more of my Forests have roads through them, it greatly reduces the opportunities and access to the land- if there are more and more roads, I have to travel further and further to get away from them. I am additionally concerned about the issues that arise when people in vehicles have increased access to our Forests- significant increases in unintentional wildfires, significant increases in invasive species and aquatic invasive species, and degradation of soil and water quality. I hope the agency will do the right thing and not rescind the Roadless Rule. We have plenty of roads and plenty of access to our public lands as things are currently. The agency’s time and my tax payer dollars would be much better spent improving the hundreds of miles of National Forest roads and hundreds of NF buildings that are currently in disrepair. Additionally, I must point out: Unsourced National Wilderness Preservation System Acreage Figures (DEIS p. 195) The Draft EIS states, at page 195, in the Wilderness discussion under "Recreation Opportunities and Setting — Effects of Alternative 3 – Modified Rule": "The National Wilderness Preservation System includes approximately 111.9 million acres; of these, approximately 36.7 million acres are on National Forest System lands." Neither figure is sourced. The sentence names no inventory, no dataset, and no date, and no source is supplied anywhere else in the document — each figure appears exactly once in the Draft EIS, in this one sentence. The only reference in the passage, Landres et al. 2015, appears three sentences later and is attached to a different proposition: the qualities the Forest Service and other wilderness-administering agencies read into "wilderness character." Nothing in the Draft EIS supports the acreages themselves. This is not a formality, because the quantity is not fixed. The Draft EIS states two sentences later that "Congress has the sole authority for designating additions to the National Wilderness Preservation System," and Congress has continued to exercise it. Without a named inventory and an effective date, a reader cannot tell whether 111.9 million and 36.7 million describe the system as it stands, the system as of some earlier compilation, or an internal calculation — nor whether the two figures were drawn from the same source as one another. The National Forest System subtotal is the one that carries weight here. The Draft EIS reports that the 2001 Roadless Rule applies to approximately 44.7 million acres of National Forest System lands (pp. 9, 11, 21). The 36.7-million-acre figure is the only quantity in this document that lets a reader set the designated wilderness estate on National Forest System lands against that roadless estate — and this section invites exactly that comparison when it states that inventoried roadless areas "provide popular, appropriate alternatives to wilderness areas because, although they contain many attributes similar to wilderness, a wider range of recreation opportunities with fewer restrictions is available." A comparison offered to the public in the effects chapter cannot rest on a denominator the document declines to source. I request a factual correction under 7 CFR 1b.7(f)(2)(v): that the Final EIS identify the source and effective date of both figures, and conform them to a current, identified national wilderness inventory as of the date of the Final EIS, giving the current figures wherever they differ from 111.9 million and 36.7 million acres. Under 7 CFR 1b.7(f)(3), the Final EIS should cite where that correction is accounted for. I raise this as a discrete correction and join no other request to it. If the agency's position is that no source can be identified for either figure, it should say so expressly and state the basis on which the figures were derived, so that the record shows what the Final EIS's description of the wilderness estate rests on. The accuracy and provenance of a baseline quantity presented in the effects chapter is information that meaningfully informs the consideration of reasonably foreseeable impacts and compliance with applicable law within the meaning of 7 CFR 1b.11(a)(53), and the disclosure at issue is required by 42 U.S.C. § 4332(2)(C). An agency may not present as established fact a figure its own record does not support. Motor Vehicle Mfrs. Ass'n v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983); 5 U.S.C. § 706(2)(A).

I strongly oppose the U.S. Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule. I am a hiker, lover of the outdoors. Having spent time in Superior National Forest in MN, in the White mountains near Joubildunk region in New Hampshire and most recently living near Balsam Cove in the Black Mountains in North Carolina, I value protected roadless spaces. I go to the forests to recharge and to ground. It is where I feel most connected to the divine and to spirit. As someone who regularly spends time in these protected areas, these are not abstract areas. I know first hand that the roadless run e matters. I'd like to see it left alone. The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. I am concerned that the building of roads in these protected areas will lead to the destruction of the forests that I love so much. Road networks bring a number of secondary impacts -- opening previously inaccessible areas to extraction via logging and wood harvesting. These activities would bring machinery, chemical inputs and intrusion into the pristine habitats that I love. The roads themselves would compact the soil, reroute surface and subsurface water flow, create impervious surfaces....disturbing wildlife.. I am particularly concerned about the increased risk of forest fires as areas along the roads, with human activity . A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Logging and wood harvesting results in the cutting down of the largest trees that are most resilient to fires, and which are most beneficial in terms of carbon storage, which is essential in the face of climate change. Road construction and logging also adversely impact on water quality, biodiversity and habitat integrity. Runoff from roads add contaminants and sediment to streams, degrading water quality and impacting aquatic wildlife. I urge the U.S. Forest Service to withdraw this proposal and maintain the protections provided by the 2001 Roadless Area Conservation Rule.

Dear US Forest Service: As a hunter and taxpayer who regularly recreates in the Superior National Forest, I urge you to reject the proposed recission of the Roadless Rule. After another summer of wildfires that destroyed homes and ranches across the US, wildfire protection is what we need. Contrary to claims made by the USDA, statistics show that the roadless rule has reduced wildfire likelihood as forest fires most often are human-caused and therefore more likely to be started where roads are present. Rescinding the roadless rule will only result in a greater quantity and more powerful forest fires. Also, as a taxpayer, I'm concerned about the cost to maintain new roads that would be built should the rule be rescinded. It's my understanding that the USFS is already facing extensive maintenance costs that are hard to keep up with and allowing more roads will result in additional deferred maintenance and potentially increased costs. Lastly, as a hunter, these swaths of remote habitat are important to the biodiversity of our great country and the adventure we all are invited to be a part of. Thank you for your time and consideration.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Dear U.S. Forest Service Officials, I respectfully urge the Forest Service to retain the 2001 Roadless Rule and reject the proposed rescission. Roadless lands are not idle land. They supply clean water, wildlife habitat, and recreation to communities nationwide, and rescission would do far more harm than good. WHAT IS AT STAKE (Forest Service roadless inventory) - Deschutes NF, central Oregon: about 137,000 acres protecting the headwaters of the Deschutes and Metolius rivers. Oregon's roadless lands protect drinking water for about 800,000 people, including Bend. - Wallowa-Whitman NF, northeast Oregon: about 515,000 acres. Its mountain streams supply Baker City, one of only two Oregon cities whose water is clean enough to go unfiltered. - Gifford Pinchot NF, southwest Washington: about 213,000 acres. Its streams supply drinking water to communities and support threatened Chinook and coho salmon, steelhead, bull trout, and the northern spotted owl. - Superior NF, northeast Minnesota: about 62,000 acres bordering the Boundary Waters, home to moose and threatened Canada lynx. - White Mountain NF, New Hampshire and Maine: about 235,000 acres, including headwaters of the Pemigewasset River, which forms the Merrimack, a drinking water source for Manchester, Nashua, and Massachusetts towns. - Bridger-Teton NF, western Wyoming: about 1.4 million acres at the headwaters of the Snake and Green rivers, feeding the Columbia and Colorado systems, with grizzly bears, wolverines, lynx, and native cutthroat trout. Nationally, roadless watersheds supply drinking water to about 25 million Americans. THE FOREST SERVICE'S OWN SCIENCE The agency's report Forest Roads: A Synthesis of Scientific Information (PNW-GTR-509) found that roads contribute more sediment to streams than any other land management activity, and that most sediment from timber harvest is tied to roads. Forest Service research on Washington's Clearwater River found fine sediment making up 15 to 25 percent of spawning gravels in heavily roaded basins, smothering salmon eggs. That matters: the Columbia Basin once produced 10 to 16 million salmon a year, and logging and road building were among the causes of its decline, alongside dams. The current DEIS itself acknowledges that new roads and logging could bring more human-caused fires, sedimentation, harm to threatened and endangered species, and recreation losses. WILDLIFE Roadless areas cover about 2 percent of U.S. land but support roughly 25 percent of threatened and endangered species. In Idaho, 75 percent of Chinook salmon and steelhead habitat is in roadless areas. The U.S. Fish and Wildlife Service has called roads probably the most imminent threat to grizzly habitat. Roads also fragment migration routes and push elk out of secure cover: in Wyoming, hunters in mostly roadless country harvest about one bull elk per 2.4 square miles, versus one per 25 square miles in heavily developed areas. THE COST OF ROADS The proposed rule anticipates permanent roads could be built across 18.2 million acres now protected. Yet the Forest Service already manages over 370,000 miles of roads with a maintenance backlog the agency puts at about $6.9 billion, and fewer than one in five roads is fully maintained. Neglected roads wash out, plug culverts, and send sediment into streams, and deferred repairs grow costly. Former Chief Mike Dombeck noted that reconstructing five miles of one road cost $1.4 million when $100,000 in earlier upkeep would have preserved it. The DEIS projects just $5 to $11 million a year in new timber revenue and admits this would not cover the cost of building and maintaining new roads. Adding roads the agency cannot maintain shifts the bill to taxpayers and downstream communities. WILDFIRE The rule already allows thinning and road access to reduce fire risk, and areas near roads have recorded nearly four times as many human-caused ignitions as roadless areas. I ask the Forest Service to keep the Roadless Rule in place and pursue any needed changes through targeted reform with full public input. Thank you for considering my comments. Sincerely, Marguerite Nico Allen, Texas

I would like to express my disagreement and disappointment with the U.S. Forest Service proposed rule to rescind in its entirety the National 2001 Roadless Area Conservation Rule. My family and I are avid nature lovers. We would rather be outside than inside. We prefer to experience the wonders of our nation's outdoors in their natural surroundings. We walk, hike, backpack and camp using Leave No Trace ethics. We admire the changes in nature during the 4 seasons: the new life of Spring, the active growth of Summer, the preparations of Fall, the resting time of Winter. I remember seeing more than 2 dozen varieties of wildflowers blooming during the last week of March on a Spring Break camping trip in Hoosier National Forest, IN. During a Summer backpacking trip in Superior National Forest, MN, I watched the emergence of a dragonfly crawling out from its final stage and making its way to a rock, where it rested and dried itself in the sunshine, gaining strength to fly away. Having grown up in the Chicago Metro area, my first trip to Shawnee National Forest in downstate IL was a wonderful awakening to the fact that Illinois is not made up of just farmland and cities...Downstate IL is Forest! My family has traveled throughout all 50 United States. From White Mountain National Forest, NH, across to Sequoia National Forest, CA, up to Chugach National Forest, AK, over to the Forest Reserves of Hawaii, and many forests in between, our National Forests provide us with un-surpassing beauty, solitude, diversity, and peace. The busy National Parks are crowded with tourists visiting the wonders of our country. Many National Forests border these Parks, providing undisturbed habitat and access to the land. Our children, grandchildren, and future generations deserve the opportunity to seek out the amazing wonders of our unique natural spaces in solitude and peace. My husband and I recently spent time camping and hiking in our nation's first National Forest, Gila NF, NM. The strip mining area outside Silver City, NM, is an ugly example of what happens when the forest and land are destroyed. Opening up NF land to the possibility of new roads being built and private business taking over is not in our nation's best interest. We have an unknown number of species that have not yet been discovered and cataloged. Their survival depends on unique characteristics and habitats found only in the small amount of pristine, untouched, old growth forests we have left. When their habitats are destroyed, species we have never observed will be gone from Earth forever. We can't get them back. Please do not rescind the National 2001 Roadless Area Conservation Rule. Thank you

I am writing to express my strong opposition to the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the agency to take Alternative 1, the No Action alternative, and retain full Roadless Rule protections. My husband and I live in the Twin Cities, and we depend on public lands for upland bird hunting, bird watching, and fishing. The large expanse of unfragmented land in the roadless areas of the Superior National Forest provides habitat not found elsewhere in the state. We plan trips around locations where we can birdwatch for species we cannot find in the suburbs of Minneapolis, and the cold-water fishery in these headwaters, brook trout among them, draws us back because the experience is genuinely irreplaceable. Rescinding the 2001 Roadless Rule would degrade that habitat, fragment that forest, and reduce hunting, fishing, and birdwatching opportunities in a beautiful area. The loss of unfragmented forest land cannot be replaced, and I see no evidence of any significant, long-term economic gain from doing this. The agency's primary forest-health rationale does not hold up against its own document. The agency states, in the Rationale for the Proposed Rule, that "The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which has contributed to challenges in addressing forest health concerns." Yet the same document cites research finding the rule did not meaningfully constrain fuel treatments as a share of forested land, and it acknowledges that insect and disease risk in western roadless areas is similar to or lower than on managed forest land. Those findings directly undercut the claim that roadless protection caused the forest health problems the agency now invokes to justify rescission. The agency must reconcile its forest-health rationale with these internal findings before finalizing any rule. The economic accounting is equally incomplete. The agency estimates, in the section on Economic Benefits from Recreation in Roadless Area Forests, that "Assuming an upper limit of a 1 percent annual loss of economic benefit within the likely operable and likely operable but complex areas translates into potential annual losses for trail and dispersed area recreation of $4.8 million and $1.3 million for wildlife-related recreation, nationally." That single-year, 1-percent ceiling is set against roadless recreation benefits of upwards of $1.5 billion, and the same section concedes that the magnitude of losses is unknown. Roads and degraded recreation settings accumulate and persist; a one-year snapshot tells us nothing about what my husband and I, and people like us, stand to lose over decades. We fish these headwaters partly because they are cold, clear, and unsilted. Sedimentation and solar warming from the loss of canopy cover are not one-time events. The agency should estimate cumulative recreation losses over a meaningful time horizon and compare them honestly with projected timber revenue, and it should explain why that comparison does not appear here. The wildlife and listed species analysis is also unfinished, which should stop this rulemaking. The agency's preliminary findings resulted in a “may affect, likely to adversely affect” determination for 327 species and 71 designated critical habitats, as stated at the section on ESA-Listed Species and Regional Forester Sensitive Species, yet formal Section 7 consultation with the Fish and Wildlife Service and NOAA Fisheries has not been completed. I care about protecting habitat for federally listed species, and seeing wildlife in undisturbed habitat within the Superior National Forest's protected areas matters to me in a way that is hard to quantify but easy to lose. Basing a nationwide rulemaking on a preliminary biological assessment covering hundreds of species, before a Biological Opinion exists, means the public cannot evaluate whether the final consultation will require different alternatives, mitigation measures, or a jeopardy finding. The Forest Service should complete ESA consultation and make the resulting Biological Opinion available before this rule goes any further. There are very few opportunities for a genuine wilderness experience left in this country. Unfragmented forest makes that experience possible. The agency has not shown that rescission produces economic gains large enough, or forest-health benefits certain enough, to justify what would be permanently lost. For these reasons, I strongly urge the U.S. Forest Service and the U.S. Department of Agriculture to abandon the proposed rescission and instead support Alternative 1, the No Action alternative. Thank you for the opportunity to provide public comment.

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule and urge the Forest Service to adopt the no-action alternative. I hike and paddle in the Superior National Forest in northern Minnesota. The Superior National Forest is one of the most heavily used and ecologically important forests in the Midwest. Its remaining roadless areas protect clean headwaters, intact boreal forest, and habitat for wolves, moose, lynx, and other species that depend on large unfragmented tracts. Many of these areas border or sit within the same watershed as the Boundary Waters, where water flows between lakes and protection of one part of the landscape affects the rest. Removing roadless protections would make new road construction, logging, and mineral-related development easier in the Superior, and roads are what open up fragile country to damage. Roads fragment habitat, bring in invasive species, add sediment to streams, and create maintenance costs the Forest Service already can’t cover for its existing network. The rule already allows thinning and fuel reduction near communities, so it isn’t the barrier to wildfire management that the proposal claims. Northern Minnesota’s outdoor economy, from outfitters to resorts to hunting and fishing, depends on wild, quiet, intact places. Once roads are built, that character can’t be restored.

To whom it may concern, I am deeply concerned about the potential removal of the roadless rule. With a biology degree and environmental science degree, the health of ecosystems is very important to me. Additionally, I recently read Ben Goldfarb’s book “Crossings” and learned even more ways roads impact the habitats around them. Please, PLEASE, do not start fragmenting our wilderness areas with roads. The effects will be detrimental. I am particularly concerned about my home, the Superior National Forest. Heidi Stromberg

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing the Boundary Waters Canoe Area each summer, my husband and I have watched the lakes there stay clear while fish advisories multiply elsewhere across Minnesota. We are told we can eat only a certain number of fish per week from other lakes in the state because of pollution. The BWCA remains what it is precisely because of the protections around it, including the roadless areas of the Superior National Forest feeding it. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask the agency to answer the specific questions below. The Superior holds 13 inventoried roadless areas totaling 62,004 acres that form the hydrological engine of the Boundary Waters system. Rain falling on unlogged ridges filters through intact forest soils and enters the lake system as some of the cleanest freshwater in the lower 48. My husband and I paddle and camp there for its beauty, its serenity, and the connection we feel to nature. That water quality is not incidental to the experience. It is the experience. The common loon, the bald eagle, the lake sturgeon, the gray wolf, the moose, the Canada lynx: these are the species that travel with that intact landscape. Rescission threatens all of it, and the agency has not explained why the rule's existing flexibility is insufficient to address whatever burdens it claims justify that step. The rule as written already accommodates the concerns the agency gestures at. It generally banned road building subject to limited exceptions including the preservation of "reserved or outstanding rights" or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). If specific administrative burdens remain after accounting for those exceptions, the agency has not said what they are or put a number to them. I ask the agency to identify which specific burdens are not already addressed by the rule's existing exceptions, including those for public health and safety, existing mineral leases, and community wildfire protection, and to quantify those burdens in the record. The water quality concern is not speculative. The DEIS itself states that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number appears in the document. What does not appear is any projection of how much of that sediment reaches waterways, or what it means for the lakes my husband and I fish. The agency also acknowledges that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." Having said that, the DEIS claims forest plans will address drinking water sources without pointing to a single enforceable provision in any of them. I ask the agency to identify, forest by forest, which plan provisions are equivalent to 36 C.F.R. Section 294.12 and 294.13 for municipal watersheds, so that the public can evaluate whether the assertion holds. The biological consequences are similarly stated and then dropped. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears and then nothing follows from it. No projection is made across the 40.1 million acres of potentially affected environment. The Superior's roadless areas carry verified populations of the northern long-eared bat alongside the species listed above. Fragmentation is not a theoretical concern in this landscape. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and put that analysis in the record before any final decision is made. The BWCA stays pristine because something has protected it. That something is not luck. I ask the agency to answer each of these questions in the record and to explain, with specifics and numbers, why rescission of the rule serves the public better than retaining it. Sincerely, Carolyn Ritter Minneapolis, MN

Hello, My name is Paige Penningroth and I am writing to submit a public comment on the Notice of Intent to rescind the 2001 Roadless Rule. This issue is deeply personal to me as someone who spends extensive time in the incredible beauty of our National Forests; with much of my time spent in the Superior National Forest and Chequamegon National Forest of the Northwoods. I strongly oppose rescinding the 2001 Roadless Rule, because it is a threat to the complex and unique ecosystems, as well as the economy built by those who love to visit it. As a water scientist and avid forager, I oppose the removal of the Roadless rule as it strips protections for 1,600 at-risk species, and threatens the clean drinking water that Minnesota and the Northwoods are known for. I have been fortunate enough to experience seeing at-risk species such as moose, the Gray Wolf, and the Showy Lady Slipper during my time in these National Forests. It has been proven that the addition of roads in these areas increases habitat fragmentation, disrupting populations and further threatening these at-risk species (Wattles et. al 2018, https://doi.org/10.1002/jwmg.21459). At a time when water quality and accessibility are top of mind for many Americans, the Roadless Rule is more important than ever. Forested watersheds, those that have not been impacted by human development like roads, provide the vital ecosystem services of water filtration and storage; reducing sediment and pollutants. The importance of clean water is evident by the millions of visitors coming to recreate in pristine Northwoods lakes, often coming from places where water is contaminated with harmful algae, e.coli, and agricultural runoff. Runoff from roadways can quickly change small lakes that are already at risk from invasive species and a warming climate (Gillis et. al 2022, https://pmc.ncbi.nlm.nih.gov/articles/PMC8817996/). These opinions are echoed across the nation - over 95% of comments on the issue support keeping roadless protections in our National Forests. It is for these reasons - the opportunity to encounter rare species, the value that healthy lakes provide our communities, and the will of the people - that I strongly oppose rescinding the 2001 Roadless Rule. Moving forward, I ask that the agency do the following: Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; Guarantee that no watersheds will be negatively affected by rescission; Develop and share a detailed plan for addressing its existing backlog in road maintenance and repairs; And commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Please protect America’s remaining roadless areas for current and future generations. Paige Penningroth

I oppose rescinding the 2001 Roadless Area Conservation Rule (RIN 0596-AD66, docket FS-2025-0001) and urge the Forest Service to retain 36 CFR part 294, subpart B. I lived in Minnesota for years and the roadless areas of Superior National Forest — in the same watershed as the Boundary Waters Canoe Area Wilderness — are places I know and return to. Their protection is not abstract: intact, roadless forest is what keeps that water clean. New roads fragment wildlife habitat, carry sediment and runoff into lakes and streams, and open corridors for invasive species, and those effects do not stay at the road's edge. The wildfire rationale for rescission cuts the other way. Most ignitions are human-caused and cluster near roads; building more roads into currently roadless areas is more likely to increase fire starts than to reduce risk. The 2001 rule also already leaves room for active management, including prescribed fire and limited vegetation treatment where it is genuinely needed — rescinding it wholesale is not necessary to do that work. Roadless areas also underpin the quiet-recreation economy that gateway communities depend on. I ask the Department to keep these protections in place. — Emily Anderson, Playa del Rey, CA (formerly Minnesota)