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

I wrote environmental analysis effects for scores of timber sales on the Umpqua National Forest. There are more than 8 designated roadless areas on that Forest that feed the North and South Umpqua Rivers. The Umpqua National Forest has as many miles of roads as streams, and segments of those roads all channel water to the rivers and habitat for aquatic life downstream. When more water volume and velocity reaches streams than it did before those roads were built, the channels adjust by eroding their banks and filling pools. The result is simpler channels with fewer niches and pockets for insects and other invertebrates, and fewer refuges for the fish and aquatic amphibians that live on them. Caddis, mayfly, rough-skinned newt, Pacific giant salamander, chub, dace, steelhead and salmon are harmed. I took advice writing my analyses from colleagues in the Bureau of Land Management, U.S. Geological Survey, National Weather Service, Oregon and Portland State Universities, non-governmental organizations like Umpqua Watersheds and Oregon Natural Resources Coalition and others. I have 30 years experience as a hydrologist for the University of Arizona, Forest Service Forest and Range Research, U.S. Peace Corps and Shawnee and Umpqua National Forests. I have a bachelor's degree in forestry and masters degree in snow hydrology from the University of Arizona in Tucson. The environmental effects of very timber sale I worked on depended on the sum of rainfall and runoff from roaded and roadless areas combined. The proposed elimination of the roadless rule and construction of roads in those area makes the decisions in all those activities invalid, with unplanned and unevaluated increases or changes in floods, droughts, sediment, channel scour and deposition. Finally, road "decommissioning", or attempt to remove roads and their impacts, doesn't work. Once a road is built, the root strength of cut trees disappears, portions of the closed roads still feed directly into streams, and water diverted from road ditches makes road fills into debris flows that scour channels for miles downstream. The elimination of the Roadless Rule will cause physical and ecological changes which guarantee poorer water quality and quantity for people and aquatic life that are already degraded. I oppose the decision to do that.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless means quiet. That is not a small thing. In places like Hardesty Mountain, in the Umpqua National Forest in Oregon, that quiet is the point. It is what makes it possible to actually hear the birds and other wildlife. I love all waters, rivers and mountain lakes included, and I believe our public lands should be managed for true multi-purpose: certain areas for sustainable tree harvest, certain areas for ecologically safe extraction, but large areas left for recreation, for clean water and air, and for all the non-human inhabitants. The 2001 Roadless Area Conservation Rule is one of the few tools we have that holds that line. I oppose its rescission. The agency's own draft environmental impact statement acknowledges what anyone who goes looking for birds already knows. The DEIS cites the finding that "road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely." Bird richness declines with road presence in forested habitat. These are the agency's own cited findings, from Kroeger et al. 2022, McClure et al. 2013, and Ware et al. If the agency rescinds this rule and roads follow, the habitat that makes quiet possible at Hardesty Mountain and across Oregon's 211 inventoried roadless areas totaling 1,937,741 acres is not recoverable on any human timescale. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and yet no projection of that range across the 40.1 million acres of potentially affected environment appears in the record. I ask the agency to apply that cited fragmentation range to the full 40.1 million acres before it takes any final action. The proposal invokes wildfire as a justification for rescission. But the agency's own record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is the agency's language, not mine. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain why the proposal departs from its own prior findings and reconcile the rescission with that ignition data. The economic case for rescission is not made. The agency's own analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. A cost-benefit analysis that cannot establish a net benefit does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. Moreover, the record states that "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." How does an action with those projected stakes, and that degree of economic uncertainty, justify permanent loss across millions of acres? The agency has not answered that question, and it must do so in this proceeding. The permitting burden argument fares no better. The rule as written states that 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)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection already exist inside the rule. The agency has not identified which specific burdens fall outside those existing exceptions, nor has it quantified them. It should do both before the record closes. Oregon has 1,522 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Northwest region. Clean water is one of the necessities of life I named, and it is not separable from the lands that filter and protect it. Rescission puts those watersheds at risk. The record must reflect that cost. Sincerely, John Mullen Dexter, Oregon

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

Leave the Roadless Rule intact. As an avid recreational hiker and paddeler, mental health clinician, advocate for wildlife and earth, and former Forest Service employee, I implore you to listen to the 100's of thousands of citizens of this country from a variety of perspectives and backgrounds who have, once again, submitted comments because we were ignored previously and the Roadless Rule is on the chopping block again. Large, contiguous, wild spaces are necessary for the health of every species on this earth. Clean water, protected watersheds, wildlife corridors, old growth forests, biodiversity, escape from the bombardment of technology, news, and noise. Relief from anxiety, depression, bullying, through connection with the natural world. I have hiked in beautiful roadless areas in the Pacific NW and Desert SW and I have also collected load tickets from asphalt trucks after a timber sale on the Umpqua National Forest. I'll take the majesty of the Olympic Peninsula forests and coastline over decimation of roadless areas for extraction for as long as I live. Once these areas are parceled out, we can never go back. We also know that undisturbed forests are more resilient to wildfire and that human caused wildfires are more prevalent near roads, so using wildfire prevention as justification for opening 58 million acres to roads flies in the face of logic. Leave the Roadless Rule intact, for our future, the future of our children, to honor indigenous cultures, and maintain diversity and health of flora and fauna, to keep our earth in balance.

I am appalled at the Trump administration's attack on our forests and I am writing to oppose the rescission of the Roadless Area Conservation Rule. I live in Oregon and the forests around Smith Umpqua, Hardesty Mountain, and Fairview are the places I visit on a regular basis to camp, hike, and bird watch. Rescinding the 2001 Roadless Area Conservation Rule would open them, and the 211 inventoried roadless areas totaling 1,937,741 acres across Oregon, to road construction and the harms that follow. Opening up this land would cut down and destroy more of our forests and habitat for wildlife. Not only that, building roads into our forests will increase the risk of human-caused wildfires. The agency's own record undermines the wildfire rationale offered for rescission. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding is the agency's, not mine. If roads into areas like Smith Umpqua on the Siuslaw NF and Fairview on the Umpqua NF increase the likelihood of human-caused ignitions, the agency must explain why it now treats road access as a wildfire remedy. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and reconcile the rescission with the ignition data in its own DEIS. That data is specific. The DEIS reports: "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." Hardesty Mountain at 2,597 acres sits alongside Fairview at 7,417 acres and Smith Umpqua at 7,622 acres. These are not abstract numbers. Opening such areas to roads would, by the agency's own data, sharply increase ignition risk within them. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before this proposal can proceed. The recreation and small-business analysis is internally inconsistent. The agency's own materials state: "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." That certification is reached by spreading the $9 million annual expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The Pacific Northwest, which includes Oregon, has 1,522 municipal water intakes in watersheds containing affected roadless areas, meaning the downstream consequences extend well beyond recreation. The agency should withdraw the small-business certification and assess the impact on the specific firms operating in the potentially affected roadless areas, not the national average firm. Finally, the agency has solicited comment on reliance while declining to weigh any of it. The proposal requests "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is precisely such an interest. The forests at Smith Umpqua, Hardesty Mountain, and Fairview on the Umpqua NF are places whose protection under the current rule I have counted on. Under the legal standards governing agency change of course, that kind of reliance must be identified and weighed, not solicited and then set aside. The agency should identify and weigh the reliance interests described in the comments it receives, including this one. Leave our forests alone! Sincerely, Stephanie Wolpers Eugene, OR

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

The true value of our natural resources in the United States of America cannot be fully understood and appreciated unless one has experienced these personally. Land, clean air, healthy trees, adequate and clean water, and wildlife that survive and thrive in our national forests deserve to be protected. Over past decades I have hiked in, boated in, skied, and camped in a number of our spectacular national forests: the Olympic National Forest, Mount Baker Snoqualmie NF, Okanagon-Wenatchee NF, the Cherokee NF in my native state, the Deschutes NF, the Finger Lakes NF, the Gifford Pinchot NF, the Huron-Manistee NF, the Idaho Panhandle NF, the Malheur NF, Mount Hood NF, the Pisgah NF, the Santa Fe NF, the Tongass NF, the Tonto NF, the Umatilla NF, the Umpqua NF, the Wallowa-Whitman NF, and the Willamette NF. In 2001 when the Roadless Rule was enacted, it allowed the NFS get somewhat caught up on maintenance of the 44.7 million acres of Inventoried Roadless Areas (IRAs). The 9.3 million acres of IRAs in the Tongass National Forest have also been better protected than prior to the RR. The claims being made in the Proposed Rule do not « hold water. » It was local control (one of the purported justifications for rescinding the 2001 RR) that led to enormous harm in the Wolverine Fire of 2015 in Washington state. Local pressure by regional fire departments persuaded the Director of the Firefighting Operations, a staffer brought up from the Tonto NF, ordered a CPL (Community Protection Line) that ended up a 50-mile long, 300-foot wide CPL and cut 40% of the critical habitat for the endangered Northern Spotted Owl. Over 930 log trucks hauled out logs, with one tree being so large that it was the only tree on one of the trucks. In my view, it was criminal to do that much damage. The scientist on the Oka-Wen NF tried to persuade the fire director that the fire was not heading in the direction of the CPL cuts. « Managers continued logging even after weather conditions turned rainy and cool, and objections were raised by their own staff, who saw no emergency, internal records and emails to The Seattle Times by US Forest Service showed. The fire never came anywhere near. » (Lawsuit over firelines to curb forest firefighting tactics, August 22, 2016) Another purported reason given for the Proposed RR Rescission is to reduce wildfire. This is not logical or rational. By allowing access to more roads in the roadless areas, there would be a greatly increased likelihood of experiencing human and vehicle-related forest fires. Strong scientific studies support this and argue strongly against opening up our roadless areas to more traffic for logging or other forest treatments. In fact, fires are four times more likely to occur near roads than in roadless (DEIS, p. 87) Good water quality is also more available in IRAs because of limited disturbance. « Retaining the RR ‘provides the greatest protection of water quality’ for municipal water supplies. » (DEIS, p. 122) For these reasons, and in the hope that science and good evidence about the superb values of Roadless Areas in our USFS will prevail, I strongly oppose the Proposed Rescission of the 2001 Roadless Rule. I would appreciate your serious consideration of my comments. Another

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

I was a USFS Timber Sale planner I worked as a Timber Sale Planner for the USFS on the Umpqua NF for 20 years starting in 1980. The Umpqua NF is in western Oregon where timber sale production was the highest in the country. Timber harvesting started in the 1950s. As a timber sale planner I witnessed the steady harvesting of the old growth forest and saw that the reason that most areas were not roaded and had timber sales is because the timber in these areas was of lower quality and quantity and the cost of road building was much higher and made the sales uneconomical. The agency should take Alternative 1, the No Action alternative, and leave current roadless protections in place. I think it is a waste of taxpayers money to propose that these areas are now economically feasibility for road building and logging Sincerely, Steve Gadd Sisters, OR

Please do not revoke the Roadless Area conservation. I love to hike and camp here in Oregon. I love the Umpqua national forest trails like the Susan Creek Falls. I also love to hike the Dorena dam trail and Spencer Butte trail in Eugene. We know that roadless areas have less chance of Forest fires which is a huge concern here in Oregon. Please uphold the 2001 ruling on this regulation.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wildlife in the Hardesty Mountain wilderness area currently has room to live as it should. That is not a small thing to me, and it is exactly what rescinding the 2001 Roadless Area Conservation Rule would put at risk. I hike in Hardesty Mountain, a 2,597-acre roadless area in the Umpqua National Forest in Oregon, and I am filing this comment in opposition to the proposed rescission under Docket FS-2025-0001. The agency's own numbers undercut the economic rationale for this action before the argument is even made. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that backdrop, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a range so wide it cannot establish whether this action produces any net benefit at all. This is before accounting for a road maintenance backlog already standing at $6.9 billion. I ask that the agency reconcile the proposal with those figures and explain how an action whose own economic analysis cannot demonstrate a net benefit justifies expanding a road system already carrying that debt. The water I drink every day begins in these affected watersheds. I do not want water treatment costs to rise, and I do not want to drink unclean water. The wildlife that depend on these watersheds for their lives matter too, and roads are precisely the threat the rule was designed to hold back. Across the Pacific Northwest region, which includes Oregon and encompasses the Siuslaw and Umpqua national forests where the Smith Umpqua, Hardesty Mountain, and Williams Creek roadless areas sit, 1,522 municipal water intakes lie in watersheds containing affected roadless areas. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres. The agency's own analysis found that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Opening these areas to road construction is not an abstraction; it is a direct threat to the watershed quality that municipal intakes and aquatic species depend on. The agency must explain, with specificity, how it proposes to protect those intakes and that wildlife if the national rule is removed. The proposal argues that state-by-state approaches can substitute for a uniform national rule. The agency has tried that before and the record reflects what followed: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit found that prior state-by-state substitution inadequate. The agency should explain how this proposal avoids the same deficiencies, and address its own prior finding that local decision-making can incrementally erode roadless values that are nationally significant. On the question of statutory authority, the Tenth Circuit has already spoken: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." That court held the 2001 rule fell within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency must state on the record what legal basis it believes supports a contrary reading after that holding. Finally, the administrative burden argument does not survive contact with the rule's own text. The rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions already exist for public health and safety, existing mineral leases, and community wildfire protection. The agency should identify by name which specific burdens fall outside those existing exceptions and quantify them, because a vague appeal to permitting friction is not a record basis for eliminating protections that took years to establish and that serve the 1,937,741 acres of Oregon roadless land and the communities downstream from them. Our public lands must be managed with environmental integrity and with future generations in mind. The agency has not met that standard here. Sincerely, Lila Moore Eugene, Oregon

I am writing in opposition to the proposed rescission of the 2001 Roadless Rule. Unfragmented tracts of land are becoming more and more important as increased development and population pushes up against our public lands. Roadless areas provide pristine lands to hunt and recreate. Its hard for me to believe that alternative 2 and 3 are nothing more than a way to dramatically increase the harvesting of mature old groth Fir trees in the Pacific Northwest and Alaska given the executive orders that have been issued expressly calling for a dramatic expansion of timber production. Once these Old Growth timber tracts are roaded and trees cut and turned into a tree farms its a changed landscapes forever. I am fortunate to live near Twin Lakes in the Umpqua National Forest in Oregon. These lakes and surrounding area are squarely in inventoried roadless area. This place is a gem loved and visited by many. Its home to mature Fir trees hundreds of years old that cant be replaced. Opening up this area and others like it to harvesting is a terrible notion. Sincerely Kenneth Zamba.

I have lived in Oregon for over 70 years. Most of that time has been spent in Roseburg, a small timber town near the Umpqua National Forest. Roseburg once billed itself as the timber capital of the world. Perhaps it still does. Roseburg Forest Products, a giant logging industry has moved its headquarters elsewhere, and has now spread its operation to other, mostly southern states. Although not as dominant as it once was, the timber industry still has much influence over the business and politics of this area. It is not surprising then that these groups might overwhelmingly support the Trump administration’s plan to rescind the Roadless Rule of 2001. The administration plans to build more roads. This is a time when the Forest Service cannot maintain the existing roads due to erosion and landslides and possibly lack of funding. When driving to a trailhead or simply driving the forest roads for pleasure it is wise, especially in the rainy season to call ahead for road closures. The administration said the roads are necessary to control wildfires. This concern is strange. They have already substantially reduced Forest Service personnel. Due to climate change the weather is far different than it once was. Due to dry, hot winds and lack of rain and snow, fires that once left a patchwork of burned and green forest now leave complete devastation. Most scientists agree these changes are due to greenhouse gases being introduced into the atmosphere, carbon dioxide being one of the main culprits. Each year the fires are more devastating than the year before and that trend is predicted to continue. Live standing trees store vast amounts of carbon. At a time when so many of these trees are being destroyed by devastating wildfires the administration proposes to cut even more of the trees in the roadless areas. The administration maintains that unroaded areas are more prone to wildfires than roaded areas. This may be so but I have my doubts. Some of my concerns with hazards are as follows: building of the roads, logging (which is sure to follow the road building), sparks from vehicles, careless tossing of cigarette butts, large campfires. I believe the administration’s plan to rescind the Roadless Rule is not only untimely but ill advised. The president’s plan to build roads in roadless areas is a fraud and should be condemned by the American people. The proposal is not to protect forest from wildfire but simply to cut more timber. I could not object more to that plan.

I am writing to strongly oppose the rescinding of the Roadless Act. I am a 69 year old woman who understands the value of conserving and protecting large tracts of wild lands for many reasons: clean water and air, recreation in unique and beautiful areas, & the economic benefit of attracting people of all ages from across the globe. Once destroyed, our children and grandchildren will suffer the consequences of destroying these wilderness areas. Nature is essential to the human spirit. Regarding the Hardesty Mountain in the Umpqua National Forest, Oregon. I joined a small group hike through the old growth forest and it was unlike any other hike. The trees were enormous compared to any other area I’d hiked - and solely because they were not clear-cut as the majority of trees in this area have been. I believe it is essential to protect these areas for the enjoyment of future generations. Rescinding the Roadless Rule would open the Hardesty Mountain, Umpqua National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Once gone, these wilderness areas will not regenerate to the size, health and diversity of ecosystems for centuries if ever. This loss is crushing to me and to most Americans. Nothing is worth their destruction. The forest service works for the people and a future generations of this country. The opinions and comments being submitted in favor of the continuation of the Roadless Rule must be the determining factor in any decision to rescind or minimize the Roadless Rule Act. Let the Roadless Rule stand. With gratitude.

I am writing to express my strong, unequivocal opposition to the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule. I urge the agency to adopt the No Action Alternative and maintain these crucial protections in their entirety. Eliminating this foundational conservation rule threatens roughly 2 million acres of pristine backcountry across Oregon. As a resident invested in the future of the Pacific Northwest, I am deeply alarmed by the severe, disproportionate impacts this repeal will inflict on the fragile ecosystems, local economies, and communities of Southern Oregon.Southern Oregon possesses a globally unique concentration of biodiversity, shaped by the convergence of the Cascade, Siskiyou, and Coast ranges. Our Inventoried Roadless Areas (IRAs)—including critical expanses neighboring the Sky Lakes Wilderness, the Rogue River-Siskiyou National Forest, and the Umpqua National Forest—serve as the last remaining sanctuaries for vulnerable wildlife. Rescinding the Roadless Rule will open these remote, intact backcountry forests to destructive road building and commercial logging.The Forest Service’s own environmental analysis acknowledges that dropping these protections will harm wildlife, degrade water quality, and increase wildfire risks. In Southern Oregon, the fragmentation of IRAs will permanently disrupt critical migration corridors and destroy old-growth nesting habitats for threatened species like the Northern Spotted Owl, the coastal marten, and the Pacific fisher. Furthermore, road construction causing soil erosion will choke local waterways with sediment. This threatens the high-quality spawning gravels essential for wild Coho and Chinook salmon, devastating regional aquatic ecosystems and Tribal cultural resources.Crucially, the justification that removing the Roadless Rule will mitigate wildfire risks is completely contradicted by historical data and modern fire science. Southern Oregon is already on the frontlines of catastrophic wildfire seasons. Agency data shows that over 85% of wildfires are human-caused, and over 90% ignite within a half-mile of a road. Conversely, fewer than 1% of wildfires in Western national forests originate in protected roadless areas.Building a new web of taxpayer-subsidized timber and temporary roads into Southern Oregon’s remote backcountry will inevitably introduce more human ignitions deeper into the woods, putting rural communities at an even higher risk. Furthermore, opening these areas to commercial logging often replaces older, fire-resilient trees with dense, highly flammable commercial plantations. This exacerbates the exact threat the agency claims it wants to solve.The proposal also threatens Southern Oregon's vital municipal water supplies. Forests in our regional IRAs act as natural filtration systems. They secure clean, cheap drinking water for tens of thousands of residents from Medford and Ashland to Grants Pass. Forcing local municipalities to construct expensive filtration infrastructure to counteract the sediment and runoff from logging roads places an unfair financial burden on local taxpayers.Finally, Southern Oregon's economy relies heavily on our outdoor recreation sector. Millions of visitors travel here annually to hike the Pacific Crest Trail, fish the Rogue and Umpqua rivers, raft wild rapids, and hunt in pristine backcountry. This multi-million-dollar recreation economy depends entirely on the intact wild character, quiet soundscapes, and scenic beauty that the Roadless Rule preserves. Allowing industrial timber infrastructure into these spaces will fundamentally destroy the recreation asset that sustains our local businesses.The public has consistently and overwhelmingly rejected the repeal of these protections. I urge the U.S. Forest Service to reject this short-sighted rollback, stand by sound climate science, and protect Southern Oregon's wild heritage by keeping the 2001 Roadless Rule fully intact.

Dear Secretary Rollins, I support the removal of the 2001 Roadless Area Conservation Rule. In general, I think that forest management decisions should be made at the local (District and Forest) levels because it is the local people that know their landscape best. I will therefore speak to the local area I know best – the North Umpqua Ranger District on the Umpqua National Forest in Oregon. The roadless areas that I am familiar with are Williams Creek, Cougar Bluff, Limpy Rock, Calf-Copeland and Medicine Creek. All of these areas are characterized by steep slopes of varying aspects. There are numerous exposed columnar basalt formations and until the early 2000’s they were primarily large old growth and second growth Douglas-fir stands intermixed with other species such as Western hemlock, mountain hemlock, true firs, Western white pine, sugar pine and some ponderosa pine. There were also open meadows, high lakes and areas of oak scrub. The prevailing reason that these areas are unroaded, is because of the steep rocky slopes. It is impractical and costly to build roads into these areas and there was no reason to do so. That has not changed. A roadless area designation does not change the conditions of the ground and has not protected them. What has happened to these areas is that they are catastrophically burnt. I do not use the term catastrophic, lightly or to overstate the situation. Employees on the North Umpqua Ranger District used to affectionately call it the asbestos forest because it didn’t burn. If there were lightening busts, and there were, the fires remained small and manageable. 1987 was a particularly bad year for lightening and it seem like the entire forest was on fire, but that was nothing compared to fires in the 2000’s. 1987 was characterized by many small fires. Some got large because there wasn’t man-power available to staff them. But “large” then is not was “large” is now. Currently, each of these roadless areas has a watershed-sized, catastrophic burn scar in it. And all of those fires have happened in the 2000’s. Whole forests have been wiped out, soil has been sterilized, water quality has been reduced, protective root structures are gone and highly flammable brush has taken over these landscapes and the brush is currently 10’ or more tall. This is a recipe for yet another wildfire disaster. Many of these sites have burned multiple times in the last 25 years. That is dramatically different from the “asbestos forest” that it should be. Additionally, there are other resources that have been impacted. Recreation facilities like historic shelters and outhouses have burned and have not been rebuilt. Once highly trafficked trails are lost in the jumble of downed trees, some historic trails are likely lost to the public at this point. There are only a few old-timers that could possibly find them and certainly not in their entirety. Landslides resulting from lost root structure have wiped out many sections of trail. Roads accessing other parts of the forest have not been maintained because of the landscape sized fires and sheer numbers of downed trees. If the 2001 Roadless Area Conservation Rule is reversed, I’m hopeful that local land managers will have more tools at their disposal to manage these lands to prevent catastrophic fires, manage the fires when they come and manage the disaster that comes in the aftermath.

As a regular user of National forest lands in the Umpqua National Forest in Oregon, and a holder of multiple Federal Mining Claims impacted by the Fairview Roadless area, I regularly deal with the impacts of the 2001 Roadless rule. It impacts the ability to to fully develop and enjoy the rights afforded for exploration and development of mineral resources through unnecessary and burdensome compliance regulations. The roadless area also significantly impacted firefighting operations during the 2024 Lane 1 fire and the 2023 Chaos fire in this part of the forest. The timber and vegetation is very overgrown and not managed currently, the removal of this national roadblock will allow the local forest management to conduct timber sales and wildfire fuels reduction work in the forest to make it healthier and sustainable for generations to come, instead of being a large charcoal burn scar. I fully support the repeal of the 2001 Roadless Area Conservation rule placing control of the forest back to the local forest supervisor. This will aid in efforts to suppress wildfire, return the forest to active management with timber sales, and remove unnecessary roadblocks for mineral development by mining claim owners.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Umpqua National Forest is where we go to photograph fungi, insects, native plants, and birds, and where I have been honored to see corvids and woodpeckers moving through a landscape that has not yet been carved apart. What the agency is now proposing would put exactly that kind of place at risk, and the agency's own record makes a stronger case against the rescission than for it. The wildfire rationale the agency offers for rescinding the 2001 Roadless Area Conservation Rule does not survive contact with the agency's own draft environmental impact statement. The DEIS states plainly: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That finding appears in the same document that is supposed to support this proposal. The birds I watch along the Umpqua depend on intact forest structure, and the DEIS's own cited research confirms that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The agency must explain, with specificity, why the proposal departs from its own ignition data and its own findings on what roads do to the ecological communities those roads would penetrate. The economic case fares no better. The DEIS states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against those figures, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service, offset by recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. That range does not establish a net benefit. The Forest Service is also carrying a $6.9 billion maintenance backlog on its existing road system. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency must reconcile its proposal with a cost-benefit analysis that cannot demonstrate the action pays, and must explain how expanding a road system already billions of dollars behind on maintenance serves the public interest. The regulatory flexibility analysis reaches its no-significant-impact conclusion by spreading estimated losses across every small firm in the relevant sector nationally, rather than assessing the outfitters, guides, and tour operators who actually hold permits in the affected areas and who the DEIS itself identifies as affected parties. 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 agency should withdraw the certification and conduct an analysis of the specific small businesses operating in the roadless areas at issue, not the national average firm. 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. The people who plan their recreation, their photography, their time watching corvids and woodpeckers in places like the Umpqua around the expectation that roadless areas will remain roadless have built that expectation on a rule that has been in place for decades. This comment is one such reliance interest. The agency must identify and weigh the interests described in the comments it receives, including this one, before it proceeds. I believe we should be good stewards. The land is not simply a resource to extract from. The agency's own record supports keeping these areas intact, and the agency has not explained why it is choosing otherwise. I oppose the rescission. Sincerely, Candy Mitchell Myrtle Creek, Oregon

As a concerned citizen who loves the Umpqua National Forest I submit the following: Comment in Opposition to Rescission of the 2001 Roadless Area Conservation Rule I formally oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to request that the agency adopt the No Action Alternative, thereby retaining the existing rule in its current form. Basis for Opposition The Roadless Rule provides critical protections for inventoried roadless areas within the National Forest System, including: Water quality: Undeveloped watersheds within roadless areas serve as sources of clean drinking water for downstream communities. Wildlife habitat: Roadless areas provide contiguous, undisturbed habitat essential to the persistence of numerous species, including those of conservation concern. Ecological integrity: These areas maintain intact ecosystems that support broader landscape-level resilience. Recreational and economic value: Roadless areas support dispersed recreation, tourism, and associated local economic activity. Sufficiency of Existing Regulatory Provisions I note that the current rule already contains provisions permitting road construction and reconstruction where necessary for public safety, wildfire management, and ecological restoration. The rule as written provides the agency adequate flexibility to address these legitimate management needs without wholesale rescission. Anticipated Adverse Impacts of Rescission Rescinding the rule would likely result in: Increased road construction in previously protected areas Habitat fragmentation and associated ecological degradation Elevated erosion and sedimentation affecting water quality Long-term increases in road maintenance liabilities and associated costs to the agency Requested Action For the reasons stated above, I respectfully request that the agency select the No Action Alternative and retain the 2001 Roadless Area Conservation Rule without modification. Thank you for your consideration of this comment.