Read the comments.

I oppose the proposal to fully and partially rescind the Roadless Area Conservation Rule. As someone who lives in the Tongass National Forest rescinding the Roadless Rule will greatly negatively impact thousands and that’s just here in Alaska! Rescinding the Roadless Rule will not meaningfully reduce wildfire risk. In fact, it's likely to increase it. - "The proportion of human-caused fires in Roadless areas is less than half. on other NFS lands, which may be due in part to public access limitations. The incidence of human-caused fires generally increases with proximity to roads." (pg 86; see Aplet et al. 2026) USFS doesn't have the budget to maintain their existing road infrastructure, much less new ones. - Costs for maintaining roads = $5,000-$50,000 / mile. Costs for building new roads = $80,000 - $2 million / mile, depending on if the road is dirt, gravel, or asphault. (pg 42) - The Forest Service has a $7 billion deferred maintenance backlog, and an estimated $1.6 billion is needed annually to maintain existing roadways. In 2023, the USFS received <20% of this amount for road maintenance. (pg 42) - Less than 30% of NFS roads are in 'good condition' (pg 40) - The DEIS states "...revenue generated by timber sales or other resource extraction activities would be used for some road-related system management but not be sufficient to cover the costs of constructing and maintaining all new roads related to a project." (pg 45) These are just a couple examples of the many why rescinding the Roadless Rule is shortsighted and reckless. The decisions of what happens to our public lands are most often made by those who will never be impacted by their actions and the communities who rely on our public lands. Destroying our forests and public lands for short term gains will be irreversible. Please stop this madness. Concerned Juneau and Tongass National Forest resident.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The humpback whales we watched around Baranof Island brought me to this fight. I want those waters protected, and I want to know exactly how logging the Port Alexander and North Baranof roadless areas, covering 120,681 acres and 314,089 acres respectively in the Tongass National Forest, will affect the humpback whales who frequent those waters. The Tongass is the largest intact temperate rainforest left on Earth, holding over 12,930 miles of salmon-producing streams. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. I oppose that outcome completely. I also paddle parts of the Teanaway River, which flows through the Teanaway roadless area in Wenatchee National Forest. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Washington State is currently in the fourth consecutive year of drought and in a drought emergency. Our rivers have remained free flowing. How will rescission affect the volume of water and sediment load in the Naches, Tieton, and Yakima rivers and all their tributaries on the east side of the Cascades? Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, in habitat the DEIS identifies as Essential Fish Habitat and critical habitat managed by NMFS. I want to know what the effect on local salmon runs will be, and I ask the agency to answer that question squarely in the final record. We have visited Hyder, Alaska the last two summers and enjoyed watching the bears fishing at the USFS Fish Creek Wildlife Observation Site. The DEIS quotes the federal grizzly recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. How will rescission affect the number of bears and salmon that come to that observation site? The agency must address this. The national forests of Washington state already show scars from previous National Forest roads that remain in place, many of those roads receiving no maintenance. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. What will happen to the service level on current National Forest roads if the roadless rule is repealed and additional roads are built? How much will that cost taxpayers? The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." 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 how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. The agency's own record also 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 proposal justifies rescission partly on wildfire and fuels management grounds. Those two positions cannot both be right. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. Sincerely, Margaret Van Cleve Selah, WA

Dear Joshua White, Hi my name is Greta Healy and I live in Southeast Alaska. My favorite places in Southeast are the old growth forests. Old, massive trees, mossy forest floors, quiet serene places. The 2001 Roadless Rule has safeguarded the world's largest intact temperate rainforest for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economy, and ecosystems of Southeast Alaska. I live in a town where logging roads have totally changed the forests. The woods that have been logged are dense and the undergrowth is impossible to walk through. Small trees that were undesirable for selling still were cut down but instead of being hauled out they were left in place. Walking through a second growth forest is not conducive to recreating and diminishes habitat for wild animals. I fear more roads and logging will further impact ecosystems that our wildlife depend on. Lets use roads we already have. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity. The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience. Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed 13 of Southeast's 16 hydroelectric projects are located in Roadless areas. A strong future for Alaska would involve investing in ecotourism. Getting people into these wild places with the goal being to appreciate nature. Not extraction. Extraction is unsustainable and eventually will end. Once the trees are gone the logging *money* will go away- yet the roads and the people who love this wild place will still exist and will once again need to figure out how to survive. Why not figure that out now. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Greta Healy

Dear Joshua White, I am a person of faith who cares about protecting the Pacific Northwest fishery, clean water and old-growth and legacy forests. The 2001 Roadless Rule has safeguarded the world's largest intact temperate rainforest for nearly twenty-five years, and removing it would be a costly, shortsighted decision that fails the people, economy, and ecosystems of Southeast Alaska. Increased road building may increase human incursion into areas prone to wildfire. Mining will pollute pristine waters that support the Alaskan fishery. This is what is at stake. The Tongass is the backbone of life and livelihood in Southeast Alaska. It produces the salmon that our subsistence, sport and commercial fisheries depend on. It provides recreation and tourism opportunities that anchor the regions largest private sector industry. It produces our hydropower from abundant rainfall. Roadless forests are critical for our subsistence foods, and subsistence harvesters have repeatedly testified through ANILCA 810 hearings that removing the Roadless Rule will result in reduced subsistence opportunity and productivity. The Tongass is a temperate rainforest that is not subject to the wildfires and the wildland-urban interface issues of national forests down South, and it should not be managed for these issues. Roadbuilding and timber harvest will not reduce insects and disease; it will exacerbate these issues by reducing climate resilience. Removing the 2001 Roadless Rule would also be fiscally irresponsible. In the proposed rule, the agency itself recognizes that there is a $6.9 billion backlog in road maintenance. Taxpayers have subsidized the Tongass timber program at a rate of over $25 million per year, with individual timber sales like Big Thorne losing roughly ten dollars for every dollar of revenue generated. Why should we pay to subsidize a failing timber industry, at the expense of our tourism and outdoor recreation industries? Flexibility and exceptions are important - and the 2001 Roadless Rule already includes them. Roads for hydroelectric projects, mining, telecommunications, and other community needs are allowed 13 of Southeast's 16 hydroelectric projects are located in Roadless areas. I would like the Forest Service to protect watershed integrity and intact ecosystems in the vast and beautiful northern forest. Removing the 2001 Roadless Rule is a distraction from the work that needs to be done to support our communities. The USDA is wasting time, money, and staff capacity to remove a popular land management rule, while acknowledging themselves that market conditions, operability, and staff time to do actual work on the ground are limited. This is wasteful spending at its worst. The Forest Service should conduct a cost-benefit analysis for the economic impact of removing Roadless protections versus investing in restoration, road and trail maintenance, and recreation infrastructure. If the USDA is actually interested in prioritizing the needs and interests of local forest users, I urge them to listen to what Southeast Alaskans have been saying all along: abandon the proposed repeal and keep the 2001 Roadless Rule in place on the Tongass National Forest. I support Alternative 1. Kathleen D Delbecq

I am an Alaska resident with a strong interest in the long-term stewardship of our public lands and natural resources. The Tongass National Forest is an important part of Alaska's environmental, cultural, and economic landscape. I believe it is essential to protect Alaska’s old growth forests, fish and wildlife habitat, and watershed health for the benefit of future generations. These resources are part of what makes Alaska unique, supporting our communities, economy, and way of life while providing opportunities for residents and visitors alike. By safeguarding these landscapes today, we can ensure that healthy forests, productive fisheries, abundant wildlife, and clean water remain available for the next hundred years and beyond. The Tongass contains some of the most extensive old-growth forests remaining in the United States and is widely recognized for its ability to store large amounts of carbon in its trees, soils, and forest ecosystems. These forests developed over centuries and provide ecological functions that are difficult to replace once disturbed. In addition to carbon storage, old-growth forests support biodiversity, watershed health, and habitat for a wide range of fish and wildlife species. Because the Tongass is one of the largest remaining temperate rainforests in the world and is often described as the nation's largest forest carbon sink, management decisions affecting these forests can have implications for both regional ecosystems and long-term carbon storage. The Tongass also provides critical habitat for salmon, bears, Sitka black-tailed deer, bald eagles, and numerous other species. Its extensive network of undeveloped streams and rivers supports some of the most productive salmon runs in the world, which in turn sustain commercial, recreational, and subsistence fisheries throughout Southeast Alaska. Healthy salmon populations are a cornerstone of the broader ecosystem, providing a food source for bears, eagles, and other wildlife. Large, intact landscapes help maintain these ecosystems by minimizing habitat fragmentation and preserving the stream conditions that fish and wildlife depend upon. Beyond their ecological value, these resources support industries and traditions that are central to life in Southeast Alaska. Commercial fishing, tourism, hunting, wildlife viewing, and subsistence activities all benefit from healthy fish and wildlife populations, making the long-term health of the Tongass important to both local communities and the regional economy. Additionally, the U.S. Forest Service already faces a multibillion dollar road maintenance backlog, and constructing additional roads would create new long-term maintenance, repair, and replacement obligations. Fiscal concerns over expanding an already extensive road network were a key factor in the development of the 2001 Roadless Rule, which recognized that the agency was struggling to adequately maintain existing infrastructure. In Alaska, where road construction and maintenance is particularly costly due to remote locations and challenging environmental conditions, expanding the road system raises important questions about the long-term financial sustainability of additional road development. Protecting these lands today is an investment in Alaska’s future. By maintaining healthy old growth forests, clean watersheds, and thriving fish and wildlife habitat, we can ensure that the natural resources and landscapes that define Alaska continue to support our communities and enrich the lives of residents and visitors for generations to come.

Dear Secretary Rollins and Chief Schultz, As a resident of Southeast Alaska, Roadless areas on the Tongass National Forest are essential to my family's way of life and our regional economy. The fishing and visitor industries collectively deliver $2 billion in economic impact and represent 26% of jobs in our region. Roadless areas are home to some of Alaska's most productive salmon and deer habitat, and are particularly important to rural communities that rely on abundant fish and wildlife for our livelihoods and food security. I live on Prince of Wales Island, where most of the economically-feasible timber has already been harvested by an industry that today represents less than one percent of our regional jobs. Meanwhile, our local salmon and deer populations are declining, and habitat loss is a concerning factor in these trends. That's why our best remaining fish and wildlife habitat should be managed to produce more salmon and deer. These are our most valuable forest products that will sustain our economy and culture in the long run, in addition to supporting the administration's goal of increasing domestic fisheries production. I urge USDA to maintain the Roadless Rule, which has broad public support. At a minimum, the Department should direct the Forest Service to ensure durable conservation measures are maintained for the most productive fish and wildlife habitat on our national forest lands, including in Alaska. Our rural communities depend on it. Thank you for your consideration.

Hello, My name is Levi Showalter and I am writing to express my strong opposition to the repeal of the Roadless Rule. I spent several years as an employee of the Forest Service in Idaho and Alaska, doing hands-on forest management in several of the areas this rule protects. America's roadless areas protect many of our most valuable, long-term public resources: clean water, fish and game, sensitive plant species, and many others. Specifically, I worked on a botany crew; roadless areas are the only suitable habitat for several species of rare plants we surveyed for. The activities currently prohibited by the Roadless Rule are those which would severely degrade the suitability of these habitats for sensitive species. Once these areas are developed for road construction, mining, or logging, their resources are not replaceable, and neither are their intangible cultural value. As an employee of the Tongass National Forest, I had the opportunity to live in the remote Alaskan community of Thorne Bay, on Prince of Wales Island. There, I experienced firsthand how proper forest management affects people’s lives. The locals depend heavily on wild game, fish, and plants as major parts of their diet, as imported groceries were extremely costly. Our work at the Forest Service to properly steward forest resources helped support not only an ecosystem that would be sustainable long-term in and of itself, but also support a human community that could trust the resources it provided. The Roadless Rule, which governs large areas of the Tongass near Thorne Bay, is critical for preserving the habitats that can support these natural resources and the people who depend on them. We saw this contrasted with other parts of the island that had been mismanaged by clearcutting, poorly managed uranium mining by foreign companies, and haphazard road construction. The former areas were able to support communities where people were proud of their way of life. The latter were expensive remediation sites, and served little useful purpose to either nature or society, in contrast to the USFS mission of “Caring for the land and serving people”. These areas greatly impact offsite resources as well; they protect stream headwaters and clean air that find their way into populated places. The Roadless Rule exists not to cordon off these resources and make them “unusable”; it exists because they are performing essential ecosystem functions that will keep the land productive for many generations to come. As such, I strongly urge the Forest Service to retain this rule. I hope my children and grandchildren will one day be able to enjoy the same great American outdoors that I do, and that they may be able to take an active role in properly stewarding its natural resources. I have contacted my congressmen already to express my sentiment, and I earnestly hope that Secretary Rollins will trust the experience of her agency’s employees such as myself, along with the many other concerned citizens who recognize the irreplaceable value of the lands protected by the Roadless Rule. Thank you, Levi Showalter

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Leaving this rule in place is the best way to preserve the unique economic & ecological benefits of the resources in protected areas. Since the Roadless Rule was issued in 2001, public support for the Roadless Rule remains strong; a Pew Charitable Trust survey in 2019 found that 75% of Americans support the rule, with agreement among rural & urban respondents & across the political spectrum. As reported in this rule’s docket, the consensus opinion of the Tribal governments consulted is similarly opposed to the rescission of the Roadless Rule. This rule has bipartisan support for good reason: the lands it protects benefit all Americans, even those who do not live in their immediate vicinity. National Forests System lands are vital sources of clean drinking water & carbon sinks for Americans across the country, & rescinding the Roadless Rules puts those resources at risk. According to the Forest Services water fact sheet, some 180 million people depend on National Forests & Grasslands to capture & filter their drinking water. Over 68,000 communities source their water from Forest Service lands, including major cities that are not immediately near the forests, such as Los Angeles, Portland, & Denver. These cities lie in the areas affected by the Roadless Rule, but the drinking water that these national forests hold is in danger of contamination should the Roadless Rule be rescinded. Construction of new roads & infrastructure, introduction of logging, new mining operations, & other industrial disruptions opens the door to contamination of critical drinking water by fuel emissions & spills; chemical runoff; & increased sediments in rivers & streams due to soil erosion. Additionally, forests that have been protected from development are critical carbon sinks that store carbon dioxide emissions & protect against climate change. Old-growth forests are particularly effective at storing CO2 in trees & soils. Alaska's Tongass National Forest—9 million acres of which is covered by the Roadless Rule—stores 8% of the total carbon stored in all U.S. forests, which is hundreds of millions of emissions. Logging even a portion of this forest poses massive risks for carbon emissions & worsened climate change: in 2016, proposals to log 300,000 acres of this forest was estimated to result in the emissions of 4 million vehicles on American roads added for a century (DellaSala, 2016). With 30 times as much land available for logging in that forest alone, the risks for more extreme temperatures & severe weather events skyrockets. While this rescission has been publicized as an economic benefit, it poses real risks for economic loss. Much recreational activity in national forests is based on the opportunity for peace and quiet, isolation from industry and urban life, and self-reliance. However, as is noted in the impact statement, adding roads & industrial activity removes the opportunity for this form of recreation, resulting in more conflicts between people using these lands & an estimated $6.1 million loss of annual revenue from recreation. Additionally, the presence of undeveloped forests protects recreational & commercial fishing populations. Trees naturally filter sediments out of our water as it enters natural waterways, preventing these particles from clogging gills, suffocating aquatic eggs, & blocking the photosynthesis of native plants. This also reduces the likelihood of algae blooms, which, when they occur, kill plants, invertebrates, & shellfish at high rates. Without trees to filter this water, fish populations face suffocation & loss of food sources, threatening the populations that commercial fishers depend on & that attract recreational fishers. Finally, I am especially concerned about the impact this rescission will have in my area. The Sam Houston National Forest neighbors my community, & 4,000 acres of the forest could be opened to commercial logging, mining, & drilling. This area is home to the red-cockaded woodpecker, a species that only recently after 5 decades of conservation efforts, was downlisted from endangered to threatened. Commercial logging will destroy parts of this bird's habitat, resulting in population loss & endangered status again, while new roads may enable the spread of invasive species like Chinese tallow. Roads fragment forests by dividing animal populations & causing a reduction in biodiversity by 13 or up to 75%. Losing animals in these forests means losing natural predators of disease-bearing insects & animals like ticks, increasing the risk of Lyme disease in my community. East Texas also frequently experiences flooding due to hurricanes or severe weather, & Sam Houston National Forest absorbs stormwater runoff, thereby decreasing flood risk in my community. The Roadless Rule is critical to keeping my community safe, as well as communities across the country, which is why we must maintain it.

Hello, My name is Levi Showalter and I am writing to express my strong opposition to the repeal of the Roadless Rule. I spent several years as an employee of the Forest Service in Idaho and Alaska, doing hands-on forest management in several of the areas this rule protects. America's roadless areas protect many of our most valuable, long-term public resources: clean water, fish and game, sensitive plant species, and many others. Specifically, I worked on a botany crew; roadless areas are the only suitable habitat for several species of rare plants we surveyed for. The activities currently prohibited by the Roadless Rule are those which would severely degrade the suitability of these habitats for sensitive species. Once these areas are developed for road construction, mining, or logging, their resources are not replaceable, and neither are their intangible cultural value. As an employee of the Tongass National Forest, I had the opportunity to live in the remote Alaskan community of Thorne Bay, on Prince of Wales Island. There, I experienced firsthand how proper forest management affects people’s lives. The locals depend heavily on wild game, fish, and plants as major parts of their diet, as imported groceries were extremely costly. Our work at the Forest Service to properly steward forest resources helped support not only an ecosystem that would be sustainable long-term in and of itself, but also support a human community that could trust the resources it provided. The Roadless Rule, which governs large areas of the Tongass near Thorne Bay, is critical for preserving the habitats that can support these natural resources and the people who depend on them. We saw this contrasted with other parts of the island that had been mismanaged by clearcutting, poorly managed uranium mining by foreign companies, and haphazard road construction. The former areas were able to support communities where people were proud of their way of life. The latter were expensive remediation sites, and served little useful purpose to either nature or society, in contrast to the USFS mission of “Caring for the land and serving people”. These areas greatly impact offsite resources as well; they protect stream headwaters and clean air that find their way into populated places. The Roadless Rule exists not to cordon off these resources and make them “unusable”; it exists because they are performing essential ecosystem functions that will keep the land productive for many generations to come. As such, I strongly urge the Forest Service to retain this rule. I hope my children and grandchildren will one day be able to enjoy the same great American outdoors that I do, and that they may be able to take an active role in properly stewarding its natural resources. I have contacted my congressmen already to express my sentiment, and I earnestly hope that Secretary Rollins will trust the experience of her agency’s employees such as myself, along with the many other concerned citizens who recognize the irreplaceable value of the lands protected by the Roadless Rule. Thank you, Levi Showalter

I live a mile or two from the tongass NF in Haines Ak and regularly hunt, fish and recreate on the tongass in my back yard and elsewhere in SEAK. As a local assembly member I am made aware of the massive positive contribution an intact and roadless tongass has on our local economy. Haines has little to nothing to gain by relaxing this management policy but further road development on the tongass will seriously affect the local and regional economies we depend on. Similarly our food subsistence is reliant on contiguous ecosystems throughout the archipelago. The benefit derived from such a policy change is focused on a small number of extraction interests, most or all of whom are not significant contributors to our regional economies. Please evaluate this change based on the needs of today and tomorrow not a failed model from the past

Bill Clinton's 60 million acre Roadless Rule was perhaps one of the most important Executive Orders of that time!! Back then, I personally made the issue one of my activist obligations, getting signatures and going to Forest Service meetings. It was bad enough when later, President Bush omitted the Tongass National Forest from the "Rule" opening up those old growth forests to commercial logging, mining, etc., so now with the Trump administration adding an additional 45 million acres to the chopping block, I am here again to protest this idea with all my heart and intelligence. I'm sure every letter you have received up until now, this last day for public comment, regarding this ludicrous idea to rescind the entirety of the Roadless Rule is full of all the reasons why this is a bad idea!! And then some!!! So, I see no need to make such a list. Rather I wish to be noted as one who is against any policy that will lessen protections for the roadless areas of our nation. Looking at a map of the current roadless areas remaining in the United States, it would seem that to save these lands for wildlife populations, clean water & air, safe from human destruction, now and forever is the most sensible choice!!! Leave the remaining nature alone. Do not rescind the Roadless Rule!!!

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the USDA to keep it in place. I'm a documentary filmmaker in Port Townsend, Washington, currently making a film about the Tongass National Forest. Roadless forests and standing old growth are irreplaceable. As conditions shift across the country, longer, hotter fire seasons, warmer winters, and more extreme weather, we need more intact forest, not less. The proposal is framed around wildfire management, but the evidence points the other way. A 2026 study in Fire Ecology, covering national forest fires from 1992 to 2024, found that wildfires were four times more likely to ignite within 50 meters of a road than in roadless forest, and the result held in every Forest Service region. Even lightning fires were more common near roads, because openings in the canopy dry out the forest floor. Congressional Research Service data show about 89% of U.S. wildfires are human-caused. Roads bring people, and people bring fire. Building roads into roadless areas to reduce wildfire makes no sense. I am not anti-logging. We need wood but there is a good way to do it, and a bad way to do it. One aspect of the forest that needs to be carefully considered is that of old growth. Old growth forests hold some of the densest carbon stores on the planet. In their trunks, roots, and deep soils. Big old growth also keeps adding carbon as they age. Logging releases that stored carbon and replanting forests takes centuries. Many of the trees in the Tongass are 300-800+ years old. Once it is cut, no one alive will see it come back, in fact the next 7 generations will not. Old trees are more fire resistant. Old growth stabilizes steep slows, filters water and shades streams to improve the lives of Salmon which annually feed millions of species and people. Old growth shows what healthy forests look like without human disturbance, which makes it a reference for managing everything else. The Tongass is the only national forest where raw, unprocessed logs can be exported, and much of its timber has historically been shipped to Asia. Meanwhile the U.S. imports about 30% of the wood it uses. Opening the last intact old growth rainforest in the country to send raw logs overseas is not a good use of a public resource. Repeal would open nearly 45 million acres nationwide to road building and logging. Roads and clearcuts degrade salmon streams with sediment and warmer water, fragment habitat for brown bears, deer, and other wildlife, and raise landslide risk on steep, wet slopes like those in Southeast Alaska. These effects ripple through entire ecosystems and the fishing and tourism economies that depend on them. Finally, in the Tongass, the Tlingit, Haida, and Tsimshian peoples depend on this land for food, cedar, and cultural sites. Any change must fully account for Tribal and subsistence use, with meaningful consultation. For these reasons, I ask the USDA to withdraw the proposed rescission and keep the Roadless Rule in place.

My wife and I enjoy hiking, rafting, and the simple joys of bird and wildlife watching in the Chattahoochee-Oconee National Forest. We also make frequent visits to California and Oregon to explore the Redwood and Sequoia Forests. We oppose the rescinding of the Roadless Rule permitting road construction that would result in severe damage to these pristine ecological areas and threaten fish and wildlife species. Allowing roads to be built for logging or mining equipment will have numerous devastating impacts: 1- Roads are the primary cause of the introduction of invasive, non-native species that can overwhelm native wildlife. 2- Roads increase sedimentation that seriously pollutes water quality, affecting not only fish, amphibian, and reptile life in the streams but ultimately groundwater that can impact the natural aquifers from which humans draw their drinking water. 3- Road stream crossings create a barrier to fish movement in national forests and restrict spawning and propagation of trout and other aquatic life. 4- Road construction introduces potential landslides and erosion that destroy established forest roots and slope stability resulting in potential floods and stream sedimentation. 5- The introduction of livestock can cause overgrazing which adversely affects species dependent on grasses for feeding or ground nesting, increasing runoff and soil compaction. 6- Roads can interrupt fires necessary for fire-dependent ecosystems while increasing the possibility of uncontrolled wildfires due to campsites or cigarettes thrown from vehicles. Road construction in roadless areas is the primary cause of ecosystem destruction and endangering wildlife. For these reasons, in addition to the aesthetic loss of our national treasures, we vehemently oppose rescinding the Roadless Rule. Facilitating energy, mineral, and timber production “to the maximum possible extent” on public lands will cost our nation far more in ecological desecration than will be compensated by short-term revenues they generate. We urge you to support H.R. 3930, the Roadless Area Conservation Act, to provide lasting protection for inventoried roadless areas within our treasured National Forest System. The Draft EIS states the purpose of the proposed rescission in terms of "changing and localized conditions, such as increasing wildfire risk, the spread of insect and disease infestations, and the need for community protection in the wildland-urban interface" (DEIS Vol. I, p. 18), and asserts that the 2001 Roadless Rule "has contributed to the lack of active management of the national forests" (p. 19). The rescission would lift the 2001 Rule's prohibitions from approximately 44.7 million acres of National Forest System lands, with a potentially affected environment of 40.1 million acres under alternative 2 and 27.2 million acres under alternative 3 (p. 29). The DEIS does not translate that purpose into a quantified projection of the road construction, sedimentation, or landscape fragmentation the rescission would enable, and it says so itself: "Across the resources evaluated in the DEIS, the potential effects of increases in road construction and timber harvest activities are described in a general, programmatic, and qualitative way" (p. 30). For timber it goes as far as a nationwide range — "a 4 to 10 percent increase in total sawtimber harvest" (p. 30) — and then only "it is expected that some portion of that increase may occur within the potentially affected environment" (p. 79). For road miles, sedimentation, and fragmentation it supplies no projection at all. Table 3 reports the existing condition (about 9,500 miles of road within the potentially affected IRAs) and the acreage on which land management plans would allow road construction (18 million acres under alternative 2; 14 million under alternative 3), but no estimate of miles that would be constructed, no sediment delivery estimate, and no change in patch or core-area metrics. I request that the Forest Service supplement the analysis under 7 CFR 1b.7(f)(2)(iii) with a quantified, regionally stratified projection of road-mile construction and of the resulting sedimentation and fragmentation across the potentially affected environment under each action alternative, at the level of specificity the DEIS applied to the Tongass National Forest at pp. 238-239, and cite in the final EIS where that supplemented analysis is accounted for, as 7 CFR 1b.7(f)(3) provides.

To the USDA Forest Service Chief Schultz and rulemaking team, I am asking the USDA Forest Service to maintain the 2001 Roadless Rule, both nationally, and within my home region of the Tongass National Forest. Beginning in 2002, I worked as a research assistant, then wildlife biologist and graduate student on the Tongass National Forest, often working within designated roadless areas across the Tongass. I also served as a professor at the University of Montana for eight years, where my students, and staff, participated in wilderness stewardship efforts across roadless areas (and wilderness study areas) on USFS lands and BLM lands (WSAs). Not only do I know roadless areas personally, as a recreation enthusiast and for subsistence hunting, fishing and harvesting, but my professional positions often rely on intact federal public lands, or advocating for these lands. My students benefit from learning about these lands while traveling across roadless areas to understand the different kinds of land management. These lands, first identified in part by the Wilderness Institute in the 1970s, where I served as director, are lands destined for protection from fragmentation, and therefore, they have become important, default habitat areas for wildlife in some cases. On the Tongass, roadless areas also represent places where mining access is not currently allowed, and roadless areas have prevented some of the worst, half-baked state of Alaska projects (e.g. Road to Juneau) from moving forward because of roadless designations on the Tongass. I realize this, in part, is why the Trump administration would like to remove these protections. However, I would like the administration to know that myself, and many other Alaskans who stand to lose the most in this rulemaking, overwhelmingly do not support rescinding the roadless rule. There are many legal inaccuracies and hasty decisions that create a faulty rulemaking process. I have attached supplemental letters that illustrate both the legal issues and inaccuracies with the roadless rule decision-making process, and its implications for the near-term Tongass Land Management Plan revision process. Again - I continue to live and work on the Tongass National Forest. Though these are national public lands, important for everyone, I think it is very important to also listen to those of us who live, work, and reside adjacent to these roadless areas, as your decisions from Washington, DC will very immediately impact our lives in local, rural and remote communities across Alaska. All the best, Dr. Natalie Dawson Haines, Alaska

I live within boating or walking distance of several magnificent Inventoried Roadless Areas in the Tongass National Forest in Southeast Alaska. Rescission of the Roadless Area Conservation Rule is a terrible idea. Within your summary alone are two gaping flaws. Ostensibly, this "will reduce regulatory burden and return decisionmaking for the management of inventoried roadless areas to the land management planning process at the individual national forest level. Rescission of the national-level prohibitions provides responsible officials with flexibility to better guide management of National Forest System lands and respond to changing local resource conditions." The first flaw with this is that, in reality, you have also been cutting professional employees from the forest service who are necessary for decision-making (biologists, geologists, timber and soil specialist and so many more with the experience and knowledge to inform decision making). You are opening the gates to logging, mining,etc.,while purposefully cutting the skilled forest service employees who could help made this work without devastating these biologically significant areas. Also, our National Forests belong to everyone in our country, and so far, the nation has recognized this in helping maintain some protections for Inventoried Roadless Areas in our National Forests. My nearby roadless areas include the South Revilla Inventoried Roadless Area, which is easily accessible to me by boat (kayak, canoe, skiff, etc.) via Carroll Inlet, George Inlet, etc.) and by short hikes from my home. We have camped, hiked, berry-picked, fished, and generally enjoyed these unlogged areas. Other IRAs our family has been able to spend time in include Revilla, North Revilla, Gravina, Quartz, and several on Prince of Wales Island. Southern Southeast Alaska has been heavily and unsustainably logged (mostly with our old growth being shipped overseas), with lots of roads going in for that purpose. Currently, the forest service is unable to maintain existing roads nationwide due to funding. This is not a good time to place additional burdens on an already underfunded system. For the past 46 years, our forest's roadless areas have been a joyful part of my daily life, sometimes within the roadless areas and sometimes enjoying seeing them across the water from my home. They give visual beauty, solitude, wildlife homes galore, native plant diversity, undisturbed creeks, wetlands, and our amazing cedar, spruce, and hemlock old growth. I also value the roadless areas in the lower 48 states, even if I don't get there often. Quiet, unroaded areas are a gift to future generations. . . a public good held in trust. Thank you, Inventoried Roadless

I submit this comment in opposition to rescinding the 2001 Roadless Area Conservation Rule, also known as the Roadless Rule. The idea of facilitating large-scale timber, mineral and oil extraction with associated road building projects on 58.5 million acres of inventoried roadless areas across the National Forest System by the single action of rescinding the Roadless Rule is unconscionable. In the section of the Proposed Rule titled "Purpose and Need for Action", it is stated: "Today, the Department believes increased management flexibility in the administration of these lands is needed to better meet the multiple-use mission and provide benefits to the American people." Among the multiple uses supported by lands currently protected by the Roadless Rule are clean water, recreation, tourism, wildlife, commercial fisheries, subsistence harvesting and mental health. Protecting these uses provides greater benefits to the American people than the two uses most likely to benefit from rescinding the Roadless Rule, timber and mineral extraction. Those two extractive industries already have more than their share of the multiple-use equation. In the case of the timber industry, I encourage a return to their previously logged and managed areas for "sustainable" timber harvests. One justification presented for rescinding the Roadless Rule is concern about wildfire risk and increasing access for fire suppression in roadless areas. Wildfire risk is almost nonexistent in Alaska's Tongass National Forest, the largest intact coastal temperate rainforest on Earth, and the fire risk is low in most coastal forests of the Pacific Northwest. Just as the argument against the Roadless Rule states that one size doesn't fit all, so, too, do proposed justifications for rescinding the Roadless Rule not apply to all the National Forests containing presently designated Roadless Area Conservation lands. In the "Rationale for the Proposal" section, there are repeated references to "changed conditions" and also evolving "national policy" and "national priorities" on National Forest System lands. I am heartened to see some acknowledgement of the effects of global climate change on our environment. While the environmental "changed conditions" are huge and broad, the result of political changes manifested by the evolving "national policy" and "national priorities" may be more significant in the near term. The resulting push for accelerated resource extraction from the 58.5 million acres of Forest Service lands presently protected by the Roadless Rule will have profound environmental impact. Political priorities and mandates are ephemeral, while consequences of physical actions taken due to those priorities and mandates are longer lasting, and they may have significant negative environmental consequences which are difficult, expensive and perhaps impossible to repair. In the "Summary" section, and in other sections throughout this Proposed Rule, it is stated that the intent of this proposed action is to "reduce regulatory burden". That is a ubiquitous refrain of the Trump administration, across the board. Given the amount of acreage presently managed under the Roadless Rule and the environmental complexity and variety represented by those lands, I submit that the "regulatory burden" is exactly what IS needed. While moving fast and breaking things may spur innovation in the tech industry, it is bad environmental policy. There is value in moving slowly and thoughtfully. Do not rescind the Roadless Rule. Rather, modify the process to thoroughly consider possible exceptions on a case-by-case basis, soliciting input, truly weighing pros and cons and then justifying decisions with facts and rational statements. Thank you for considering my comment.

Dear USDA Forest Service Planning Team, I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I urge the Forest Service to select Alternative 1 (the No Action alternative) and keep the 2001 Roadless Rule fully intact. As someone who lives in Anchorage and values Alaska's public lands, I rely on these intact landscapes for clean water, outdoor recreation, and wildlife habitat. The Roadless Rule protects roughly 58 million acres of national forests—including vital regions like the Tongass National Forest and the Kenai National Forest—without preventing legitimate, targeted local fuel treatments or recreation. Repealing these safeguards increases erosion, fragments critical habitat, and adds to the Forest Service's multi-billion-dollar road maintenance backlog. Please keep the Roadless Rule in place. Sincerely, Laura Grossman Anchorage, AK

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I am someone who has hiked and camped in the National Forest System and understands what could be lost by implementing the proposal. As is, the rule protects about 44 million acres of the last undeveloped land in the National Forest System, which provide fish and wildlife habitat, supply drinking water, and offer backcountry recreation. Rescinding it would remove the only national protection these areas have, opening them to logging, and mining and energy development. The wildfire rationale does not justify full rescission. To begin with, new roads can often raise fire risk, since most wildfires are started by people. And the 2001 rule already allows cutting of small-diameter trees to reduce wildfire risk and permits road construction when needed to protect public safety from an imminent threat of fire. The agency's own figures show that 11.3 million acres of roadless land are already near existing roads. Lack of access therefore cannot explain why only 5% of high-hazard roadless acreage has been treated since 2014. Limited funding and staff appear more likely. The proposal's purpose and changes extend beyond wildfire policy. The USDA announcement ties the proposal to executive orders directing expanded timber production, energy development, and resource extraction in Alaska. This suggests the rule would mainly open roadless areas, such as Alaska's Tongass National Forest, to commercial extraction. Commercial logging often removes the large, fire-resistant trees that fuel treatments are meant to preserve and protect. The Forest Service also has a multibillion-dollar backlog of deferred road maintenance. Adding roads it cannot maintain would increase erosion and sediment in the streams that supply drinking water to downstream communities. I urge the Forest Service to withdraw the proposed rule, keep the 2001 Roadless Rule in place nationwide, and address wildfire risk through the underused fuel treatments that are already permitted. Thank you for the opportunity to comment.

Re: Special Areas; Roadless Area Conservation, Proposed Rule (91 FR 53827), Docket FS-2025-0001, RIN 0596-AD66 As an avid naturalist, camper, hiker and supporter of our Natural Forests, I submit this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the Forest Service to select the No Action alternative and keep the rule in place. 1. The rule works and has broad public support. For 25 years, the Roadless Rule has protected tens of millions of acres of National Forest from new road construction and industrial logging while still allowing recreation, hunting, fishing, and fire management. It was adopted after one of the largest public comment efforts in the history of federal rulemaking, and the public response to this rescission has been just as large. Nothing in the record shows that the public has changed its mind. 2. Roadless areas protect clean water. Intact forests filter and regulate the flow of drinking water for millions of Americans. Roads are a leading source of sediment, landslides, and stream damage. Rescinding the rule would put these watersheds at risk and shift costs to downstream communities and water utilities. 3. Roads are not a wildfire solution. The Department says rescission would reduce wildfire risk, but the rule already allows thinning and hazardous fuel treatment near communities, and the great majority of such work happens outside roadless areas. New roads open backcountry to human ignitions, the leading cause of wildfires, and they carry long-term maintenance costs. The Forest Service already has a multibillion-dollar road maintenance backlog. Adding more miles of road makes that problem worse. 4. Habitat and climate. Roadless areas are some of the last large, connected blocks of habitat for species such as grizzly bears, salmon, and elk. They also store large amounts of carbon. Fragmenting them is difficult or impossible to reverse. 5. Forest-by-forest planning is not an adequate substitute. The Department says forest plans would govern roadless areas after rescission. Plans can be amended, are subject to local political pressure, and vary widely in strength. A national rule gives consistent, durable protection and certainty for communities, businesses, and visitors who depend on these lands. Rescission also invites years of costly, piecemeal conflict and litigation. 6. The process has been rushed. Complex rules affecting tens of millions of acres warrant longer comment periods and more thorough environmental review. The Department should fully analyze the cumulative impacts of rescission, including effects on water, wildlife, climate, Tribal interests, and rural economies built on recreation and tourism, and it should respond to the substance of public comments. Conclusion. The Department has not shown that the benefits of rescission outweigh the loss of protection for these lands. I urge the Forest Service to retain the 2001 Roadless Rule in full, including for the Tongass National Forest. Respectfully, Laverne Simoneaux Baton Rouge, Louisiana

I spent my twenties and early thirties working as a wilderness fishing guide in the Tongass National Forest. The place was Yes Bay Lodge in the Behm Canal. It was the most powerfully formative time of my life, because it was wilderness. The land and water taught me lessons that are unteachable in mainstream American culture. Like patience. And that nature has the answer, every time. Salmon that return from a thousands-mile journey feed the forest and the forest protects their spawning beds, cooling the streams. It is a symbiotic relationship that is of ancient wisdom that cannot be recreated by fish hatcheries or farms. And it was my great privilege to teach people this every time I guided them. And it was the most satisfying work I’ve ever done. It inspired my life so much, I’ve made two feature films about protecting them and their habitat, with a thrird on the way. You can watch them at www.augustisland.com – and click on the films tab. In Southeast Alaska, the combined visitor, tourism, and commercial/sport fishing industries support nearly 30,000 to 45,000 jobs (or roughly 1 in 10 to nearly a quarter of regional private employment), to the tune of $2 billion dollars to the region. Opening this completely intact bioregion again to aggressive commercial logging will only ship this resource away for pennies on the dollar and harm the people of Alaska, as well as devastate the salmon runs that bind everything in this region together, including its economy. Please keep the Roadless Rule intact.