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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Sixty years of returning to the Wallowa-Whitman National Forest, watching it become more frequented as more Americans discover its beauty, has given me a conviction that what remains wild there must not be handed over to roads and extraction. My grandfather hunted elk and deer on the forested slopes near the Grande Ronde River. I hiked and camped there as a girl with my mother and sisters, in country that was beautiful, quiet, and isolated. The Tower wilderness area, all 52 acres of it, and the Upper Grande Ronde wilderness area, 11,723 acres in the same forest, represent exactly the kind of untrammeled ground that the 2001 Roadless Area Conservation Rule was built to protect. I am writing to oppose its rescission without reservation. The economic case for this rescission cannot bear examination. The agency's own 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 marginal production, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from negative $92 million to positive $199 million. That range does not establish a net benefit. It also does not account for a road maintenance backlog already standing at $6.9 billion. I ask the agency to reconcile this proposal with its own numbers and explain how construction that cannot demonstrate a net benefit justifies expanding a system the agency already cannot afford to maintain. The agency has tried state-by-state approaches before and failed in court. Its own record states that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and 1,522 municipal water intakes in the Pacific Northwest region sit in watersheds containing affected roadless areas. Fragmenting that protection through local decision-making is precisely what the Ninth Circuit rejected. The agency must explain how this proposal avoids the legal deficiencies identified in that prior litigation. I think about clean water every time I think about that forest. The soil and cover of unroaded country filter what flows downstream, and what flows downstream eventually reaches people. The agency's own analysis finds that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. That sediment enters the same watersheds that feed municipal intakes and the same streams where the animals I have watched for sixty years, elk, mule deer, bear, the mink and beaver and birds of the Tower area, depend on clean, cold, undisturbed water. The agency must account for these downstream consequences and explain what replaces the filtration function that intact roadless watersheds currently provide. The Tower area's 52 acres are already small. Putting a road through it would break up the habitat of mule deer, cougar, bobcat, bear, and the many other creatures that cross that ground, and fragment their social structures. The agency's own citation found elk survival rates rose during a road closure and fell again when the gates were removed. Its own record on mule deer documents that roads built for extraction may alter migration routes and increase movement speed. Its own record on bear notes that open roads increase contact, conflict, habituation, and ultimately mortality. What this proposal would do to what remains of that country is not a projection. The agency has already documented the mechanism. I expect a direct response on how the proposal addresses these findings as they apply to the inventoried roadless areas in the Wallowa-Whitman. Finally, my sixty years of returning to this forest, and my grandfather's generation before me, are precisely the kind of reliance interest the agency invited when it solicited, in its own words, "any reliance interests in the current rule that could be affected by this proposal" at 91 FR 53830-31, and then weighed none of them in its Cost Benefit Analysis. Under the legal standards governing agency reversals, that omission is not a procedural footnote. These comments, and the thousands like them, must be identified, considered, and weighed before any final action is taken. Our public lands belong to generations to come, and this generation has not been given the authority to trade them away for less than half a percent of national timber output. Sincerely, Polly Estabrook, Los Angeles, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless areas are some of the few places where we can witness - and enjoy - the true majesty of unexploited nature. I oppose rescission of the 2001 Roadless Area Conservation Rule because the agency's own record does not support the action, and because the forests I have traveled, paddled, and camped in since childhood will bear the consequences. Wildfire. The DEIS states: "A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If roads increase ignition, the agency must explain why expanding the road network into 40.1 million acres of protected land advances fire management rather than undermining it, and reconcile the rescission with DEIS Table 21, which reports far higher fire density on roaded land. Economics. The DEIS acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production." Its analysis projects timber revenue of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, while the Forest Service road system already carries a $6.9 billion maintenance backlog. The agency should explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system in that condition. Fish and wildlife. I have rafted the Main and Middle Forks of the Salmon River through the Salmon-Challis National Forest, home to the largest roadless complex outside designated wilderness in the lower 48: 58 inventoried areas totaling 2,264,064 acres. The Salmon supports the longest salmon migration in North America, over 900 miles. The DEIS acknowledges that removing riparian vegetation can raise stream temperatures beyond what cold-water species tolerate, and that the affected area includes Essential Fish Habitat managed by NMFS. It also cites findings that habitat fragmentation reduces biodiversity by 13 to 75 percent, yet never applies that range to the 40.1 million affected acres. The agency should do so before proceeding. Existing exceptions. The rule already accommodates the burdens the agency cites: it "generally banned road building subject to limited exceptions," including reserved or outstanding rights and construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). The agency has not identified which operational burdens fall outside these exceptions. It should identify and quantify them on the record rather than treating administrative complexity as grounds to eliminate protections that have stood for over two decades. Born and raised in Idaho, I have camped, hiked, backcountry skied, and backpacked in Oregon's Wallowa-Whitman National Forest since childhood. If its 515,000 roadless acres are opened to roads and logging, that backcountry will not recover in any timeframe meaningful to the backpackers, anglers, hunters, and skiers who contribute more to the regional economy than logging ever could. Species that depend on these corridors, including Chinook salmon, steelhead, bull trout, wolverine, mountain goat, bighorn sheep, and gray wolf, need intact buffers around protected roadless areas. Our public lands should be managed for all citizens, not sold off to the highest bidder, and preserved for future generations, from the Salmon-Challis to the Wallowa-Whitman to the Olympic National Forest, already hemmed by clear-cuts visible from Hurricane Ridge. I urge the agency to withdraw the proposed rescission. Sincerely, Tracy Andrews Portland, Oregon

I am submitting my comment to vehemently oppose partially or fully rescinding the Roadless Rule. To reverse this rule would throw decades of peer-reviewed research in the trash, to favor short term financial gain for very few and without benefit to the American public. To allow such a change would be a dereliction of the Agriculture Department's duties to protect public health, conserve natural resources, and responsibly manage agricultural production. In 2025, approximately 99% of public comments opposed changing the Roadless Rule. Despite this, the federal administration is once again attempting to force this through without appropriately addressing the public's substantial opposition to partially or fully rescinding this rule. Roadless areas are some of the last intact landscapes in America, providing clean water, critical wildlife habitat, and world-class recreation opportunities. As a resident of Oregon, my health, safety, and enjoyment of public lands include Roadless areas like Larch Mountain, Lost Lake, and the Salmon River Trail (Mount Hood National Forest), Iron Mountain and Hardesty Mountain (Willamette National Forest), Oregon Dunes (Siuslaw National Forest), Lookout Mountain (Ochoco National Forest), Joseph Canyon (Wallowa-Whitman National Forest), and Tumalo Mountain (Deschutes National Forest). In the summer of 2026, Oregon saw some of the worst wildfires in our country's history, and unsustainable forestry, deforestation, fragmented habitat, and irresponsible recreation were largely to blame. Not a lack of roads. The proposed changes to the Roadless Rule fail to consider the overwhelming body of scientific evidence that habitat fragmentation increases wildfire risk and negatively impacts protected species. Alternatives 2 and 3 of the Draft EIS are wholly unacceptable. Therefore, I support Alternative 1 - No Action.

I am opposed to the proposed rule rescinding the roadless rule. Roadless areas in our national forests are incredibly valuable for how they provide habitat for wildlife, protect water quality and drinking water sources, and provide humans with opportunities for hiking, paddling, hunting, skiing, and more. And while the person reviewing these comments may also see the value in these things (thank you for your work on the tedious and thankless task of reviewing and summarizing comments, by the way!), I have no illusions that whoever is making the final decision on this rule will be swayed by such arguments. So instead, I’d like to state that rescinding the roadless rule would also have negative impacts on maintenance of existing roads and public safety. First, the Forest Service does not have the engineering or roads staff necessary to properly maintain it’s current road system, let alone build new roads. My home is surrounded by the 2.3 million acre Wallowa-Whitman National Forest, and they have 3 roads managers to cover all of this ground, no road crews, and multiple vacancies in engineering. If the roadless rule is rescinded, and new roads are constructed without any increases in funding, this means the Forest Service would be diverting funds from road maintenance, existing roads would deteriorate and be more prone to failure and washouts, which would negatively impact public safety, recreational access, current active management projects, recreational access, and firefighting escape routes. Second, most roadless areas are roadless because they are bad places to put roads. They’re steep, or rocky, or prone to landslides. Or they’re in remote areas where the distance to mills means there’s no way to make a timber sale break even. Or they’re not near towns, so there is no need to build roads to access inholdings or provide emergency access routes. Finally, building roads in roadless areas would increase fire risk. The proposed rule change states that it is necessary to allow thinning projects and firefighter access in inventoried roadless areas. A rule change is not needed to achieve this – the Forest Service can conduct fuels thinning projects to reduce fire risk in roadless areas under the existing rule, and we have handcrews, rappel crews, and smokejumpers who are skilled at fighting fire off the road system. But more importantly, building roads into previously roadless areas would lead to more human caused starts. Campfires, dragging chains, and sparks from machinery are common causes of fire starts, and more road miles would lead to more starts, and end up increasing wildfire risk.

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The mountains, lakes, creeks, and wildlife I have spent years exploring in Washington's roadless areas are precious, and the thought of any of it being opened to new roads and development is, simply, tragic. I hike all year round and backpack during the summer and fall months, seeking beauty, grandeur, and the solitude I can find in places like the Alpine Lakes Wilderness and adjacent areas in the Wenatchee National Forest, the Entiat, the Teanaway, and the Glacier Peak area in the Mt. Baker-Snoqualmie National Forest. I also hike the Olympic Mountains and Cascade Mountains and have backpacked in the Wallowa-Whitman National Forest in northeast Oregon. I take many pictures, especially during backpacking trips, and looking at my pictures and slideshows transports me back to the experiences of those trips. These are not abstractions. These roadless areas are where I go. The agency's own record demolishes the wildfire rationale offered for this 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." I know this dynamic in a direct way. A huge forest fire has already destroyed an area of the Entiat, all 72,617 acres of which lie in the Wenatchee National Forest, where I had hoped to backpack. Losing these roadless lands is irreversible and you cannot get the beauty back. If road construction increases ignition risk by the factor the agency's own data describe, opening the Entiat or the Teanaway or Glacier Peak to new roads in the name of fire management is not a solution. The agency must explain why this proposal departs from its own prior findings and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside these areas. The permitting and administrative burden rationale fares no better under scrutiny. The rule already provides for exceptions, including for public health and safety. The agency's own text confirms as much: the rule "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the rule already accommodates those needs, the agency has not shown what specific burden remains that justifies removing protection from the 57,104 acres of Alpine Lakes Adjacent lands, the 72,849 acres of the Teanaway, or any of the other areas I rely on. Which specific burdens are not already addressed by the rule's existing exceptions, and what is the quantified weight of those burdens? The regulatory flexibility analysis contains a contradiction the agency has not addressed. 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 alpine terrain of Glacier Peak, with its lakes, meadows, and wildlife, and the Teanaway, where the larch trees turn golden in a way that draws visitors every fall, support exactly these kinds of guided recreation businesses. A certification reached by spreading losses across every small firm in the sector nationally, rather than assessing the actual permit holders operating in these areas, does not satisfy the purpose of the analysis. The agency should withdraw that certification and assess the firms that actually operate in the affected roadless areas. Finally, the proposal itself invites comment on reliance interests and then the Cost Benefit Analysis weighs none. The agency solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. I have spent years hiking and backpacking in these areas, planning trips, taking photographs, sharing these places with my daughter, with friends, and alone, in reliance on the protection the 2001 rule provides. Our public lands should be managed for the people, as Theodore Roosevelt envisioned, and preserved for all future generations of Americans. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Sincerely, Dick Crabb Seattle, Washington

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking in the Beaver Creek and Tower wilderness areas of the Wallowa-Whitman National Forest for the last 62 years, first with my mother and sisters when I was young and then as an adult with my daughter and nieces and nephews, has given me something I cannot fully describe and will not easily surrender. Those hikes taught me to understand and value the role national forests play in all of our lives: delivering clean air and water and protecting the ecosystems upon which we depend. I am filing this comment in opposition to the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because what is at stake in the Wallowa-Whitman is specific and irreplaceable, and because the agency's own record does not support what it proposes to do. Beaver Creek is 12,973 acres of isolated nature with lodgepole pines and granite cliffs. With an ever hopeful eye, you can see the paths of elk, lynx, and bears and perhaps catch a look at one of them. Tower, at 52 acres, is filled with alpine lakes and high altitude meadows with native flora, and all around are sounds of insects, birds, and small rodents. If permanent roads were built into these pristine out-back areas, it would completely alter the essence of the place. There would no longer be untrammeled vistas of granite slopes, with trees, and wildflowers and streams. That loss is not abstract. The agency's own environmental record states that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations," and it further quotes the federal grizzly recovery plan to the effect that open roads in grizzly habitat increase contact, conflict, shooting, habituation, and food reward, ultimately ending in grizzly mortality. Elk, whose paths I have tracked at Beaver Creek, avoid areas near roads and select habitat away from them, and the agency's record found that elk survival rates rose during a road closure and fell again when the gates were removed. The agency must explain, in response to these comments, how rescission of the roadless rule is consistent with what its own biological analysis says about road presence and large mammal survival in exactly these landscapes. The proposal invokes wildfire management as justification for rescission, but the agency's own findings undercut that rationale. Its draft environmental impact statement states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." The same DEIS reports far higher fire density on roaded land than inside the affected roadless areas. The agency has not reconciled these findings with the direction it is now proposing, and I ask that it do so, specifically addressing the ignition data in DEIS Table 21. The proposal also gestures toward permitting burden, but the rule as written already accommodates the activities the agency says it cannot perform. A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." Given these existing provisions, the agency should identify on the record, by name and category, which specific burdens the current rule's exceptions for public health, safety, existing mineral leases, and community wildfire protection do not already address, and it should quantify those burdens rather than assert them. The regulatory flexibility certification that accompanies this proposal cannot stand. "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." Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and 1,522 municipal water intakes across the Pacific NW sit in watersheds with affected roadless areas. The guides and outfitters near Beaver Creek and Tower are specific small businesses whose receipts depend on the character of these specific places remaining intact. The agency should withdraw the certification and conduct a proper assessment of the entities actually operating in the affected areas. Finally, the proposal itself 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. I want the Wallowa-Whitman wilderness areas managed responsibly to safeguard access for future generations and protect the untouched landscape and ecosystems upon which we depend. That expectation was created by the rule that has been in place, and the agency is required to identify and weigh it. Let this comment stand as one the agency must address. Sincerely, Elizabeth Estabrook New York, NY

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Grande Ronde roadless area in the Wallowa-Whitman National Forest is the kind of place this proposal would put at risk, and I oppose its rescission without reservation. The agency's stated justification for rescission includes wildfire and fuels management. That justification does not survive contact with the agency's own findings. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency now believes road construction inside areas like Grande Ronde reduces fire risk, it needs to say so explicitly and explain what evidence displaces the finding just quoted. I ask that the agency reconcile this proposal with the ignition data in DEIS Table 21, which the record indicates shows far higher fire density on roaded land than inside the affected roadless areas, and explain on the record why it is departing from its own prior findings. The economic case for rescission is no stronger. The agency's own record acknowledges 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." Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The Grande Ronde sits within that same regional watershed fabric. The proposal's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year against recreation losses of at least $6.1 million a year, with a net present value ranging from -$92 million to +$199 million. A range that wide cannot establish a net benefit. The agency also has not explained how expanding a road system already carrying a $6.9 billion maintenance backlog improves the public's position. I ask that the agency reconcile the proposal with those figures and explain what affirmative finding of net benefit, if any, supports this action. The proposal argues that state-specific approaches can adequately replace a single national rule. The agency's own record undercuts that argument directly. It notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." But the prior attempt to substitute state-by-state rulemaking for the 2001 rule was reviewed by the courts and found wanting. The agency's own prior findings acknowledged that local, incremental decision-making can erode nationally significant roadless values precisely because no single state process captures cumulative effects across a national system. The agency should address how this proposal avoids the deficiencies the Ninth Circuit identified when the agency last tried this approach. On the question of statutory authority, the proposal suggests the 2001 rule exceeded what Congress granted. The Tenth Circuit addressed that question and held: "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 found the 2001 rule was within the authority Congress provided under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. If the agency holds a contrary legal position, it owes the public a precise explanation of its reasoning and the basis on which it distinguishes or declines to follow that holding. The Grande Ronde is 5,650 acres. It is part of a roadless system that, in Oregon alone, spans nearly two million acres and feeds watersheds supplying over a thousand municipal water intakes across the Pacific Northwest. The justifications offered for rescission, fire risk reduction, economic benefit, state flexibility, and legal authority, are each contradicted by the agency's own record. The agency should answer each of those contradictions before this docket closes. Sincerely, Karen Orehoski

To the U.S. Forest Service / USDA: I am writing to strongly oppose the repeal of the Roadless Area Conservation Rule. As someone who spends every summer backpacking the Pacific Crest Trail, I have seen firsthand what this rule protects, and I urge you to keep it in place. I hike the Pacific Crest Trail in Oregon and Washington each year, including sections in the Gifford Pinchot National Forest, Mark O. Hatfield Wilderness, Mount Hood Wilderness, and Mount Hood National Forest. Closer to my Idaho home, I explore the Wallowa-Whitman National Forest and the Eagle Cap Wilderness in eastern Oregon. Exploring the mountains of the pacific northwest is what I love the very most. What draws me back is the quiet, the wildlife, and the scenery. These places hold years of family memories, and as my children leave home, I plan to thru-hike the PCT. That dream depends on the trail staying wild. The stakes extend well beyond one hiker's plans: - The PCT itself. There are 63 roadless areas along 288 miles of the PCT across California, Oregon, and Washington, roughly 11% of the trail. Opening these lands to roads and logging would change the experience of the trail for everyone who walks it. - Clean water. Roadless areas provide drinking water to 60 million Americans. Roads and logging increase erosion and sediment, which threatens that supply. Ecological health and climate. These undeveloped lands are critical to our nation's ecological health and store 20% of all carbon in U.S. national forests. - Wildlife. Roadless areas are crucial habitat for more than 1,600 threatened species. - Recreation access. Millions of people hike, hunt, fish, and camp in these areas every year, at free or very low cost. For many families, including mine, these are the most accessible great places to spend time outdoors. - Economic value. The outdoor recreation economy generates $730 billion annually, far more than timber sales. Protecting roadless areas protects the larger economic engine. - Fiscal responsibility. The Forest Service already has 370,000 miles of forest roads and a multi-billion dollar maintenance backlog. Building more roads into remote country is not sound stewardship of taxpayer money. - Wildfire. Studies show wildfire ignitions are four times more likely near roads than in roadless areas. Adding roads may increase the risk it is meant to address. The Roadless Rule has protected these landscapes for decades with broad public support. Repealing it would trade lasting public benefits (clean water, carbon storage, wildlife habitat, recreation, and quiet) for short-term gain and added maintenance costs. I respectfully urge you to retain the Roadless Area Conservation Rule in full. Thank you for considering my comment. Yours in pretty-pretty please, Lachelle Hansen Boise, Idaho

I oppose the Roadless Rule Change. I live near national forests in northeastern Oregon and I enjoy traveling, camping, and generally observing the animals, plants, mosses, fungi, landscape, and geological formations on national forest land. Observing these things in their natural state without roads and human activity brings me deep peace. Specifically, I really like birding and identifying native wildland plants. Earlier this year on a forest dirt road in the Wallowa-Whitman National Forest - about 3 miles from the main paved road I noticed that there was at least 1 plant growing by/on the dirt road that was non-native. I worry that more roads being built on national forest land (than are already there) will bring in more non-native and invasive species of plants that will harm the ecosystem. Also more roads and human activity will mean less habitat for the native plants and animals already living there that I enjoy seeing. In the case of birds - not only do I see them in national forests but I also see the same species in my area where I live as they migrate or move down in the valley for winter from their forest homes. Please do not take this peace, beauty and natural wonder from me or from future generations; please do not rescind the Roadless Rule.

I am writing to express my OPPOSITION to rescinding the Roadless Rule—whether partially or entirely. The great outdoors—and our history of preserving these natural spaces—is what makes America great. No other country has the diversity of landscapes and miles of protected land that the United States has. The Roadless Rule has contributing to keeping many of these natural places pristine, allowing wildlife to continue to flourish and recreationists of all types to enjoy the land. In the Pacific Northwest, the outdoors are part of the culture and identity of those fortunate enough to have grown up here. It is because of the Roadless Rule that I have been able to enjoy many of the beautiful places around my home. My first backpacking trip was in the Eagle Cap Wilderness of the Wallowa-Whitman National Forest. It was just my mom and I, and we had our fair share of adventure out there, but we survived, and it's a place I hope to come back to with my kids someday. Losing protections for this area endangers beautiful, secluded places like this, opening them up to corporate interests rather than preserving them for the public benefit. Our public lands are for the people—and they should be managed and preserved for the benefit of people, not corporations. The Roadless Rule also protects land that is home to numerous important and threatened species. Our ecosystems hang in a delicate balance, and depend on the continued preservation of acres of untouched land to maintain that equilibrium. Protecting these natural places is one of the few ways we can ensure that our climate doesn't continue to get worse. Rescinding the Roadless Rule would be short-sighted and irresponsible, prioritizing the business interests of a few over the benefit of the masses. Americans deserve to have access to natural, undeveloped areas, and the Roadless Rule ensures this can continue for generations. Do right by the citizens of this country, and do NOT rescind the Roadless Rule!

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I hike and camp in National Forests to enjoy landscapes, bird and wildlife spots, and enjoy solitude, quietness and dark sky. Public lands must be managed for the current and future public good.That means envisioning the value our public lands have for recreation, wildlife survival, climate change control, water quality, and ensuring there are still undeveloped wilderness areas for future generations. I photograph wildlife, landscapes, and waterfalls and rivers. Road development impacts all of those by changing the scenery, impacting wildlife migrations and homes, and decreasing water flow and water clarity. The kids in my life instinctively notice the difference in a roadless area: the tree canopy, the sound of a waterfall or birdsong not competing with traffic noise. We don’t have the right to deprive future generations of undeveloped national forests. I want an explanation of why this proposal has not included multiple public meetings where the public can make their voices heard in person. Water wars are here. Climate change is fueling water scarcity. Development is fueling water quality issues. Watersheds fed by roadless areas are part of protecting our nation's water quality. Explain how roads and logging won't have a negative impact on watersheds and water quality. Hells Canyon NRA, includes some of Wallowa-Whitman NF, and was on my 2026 photography trip. Birds and butterflies abounded, and Snake River ran clear through the canyon. Proud locals bragged about their forest and generations of family trips to the remote areas. Development would impact the recreation industry and the livelihoods of those who depend on it. Birds would leave based on vehicle noise alone. Deschutes National Forest and a stay in Three Sisters Wilderness area this summer didn’t do it justice. Locals bragged about the lava tubes and waterfalls. Roads would destroy its viewscapes and pristine environment, and negatively impact the tourist and recreation economy. I've explored Daniel Boone NF and the Wolfpen area twice (2022, 2025) to photograph different plants and cliffs and rock formations that change color with morning light, and search for the elusive hellbender. Roads and logging would change that. The next generation deserves the right to experience the area as I have: undeveloped and peaceful. My 2026 visit to the Rogue-Umpqua Divide included hiking to waterfalls deep in the forest. This area is a watershed for drinking water for millions. Developing or building roads through this forest will destroy water quality, impact waterfall viewscapes, and impact the "wow" factor of the area including Crater Lake National Park that has viewscapes of the Rogue-Umpqua Divide. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule, and specifically about these inventoried roadless areas: - Wallowa-Whitman NF (515,000 acres), Wallowa-Whitman NF, Oregon - Deschutes National Forest (136,000 acres), Deschutes NF, Oregon - Wolfpen (2,835 acres), Daniel Boone NF, Kentucky - Rogue - Umpqua Divide (6,728 acres), Rogue River NF, Oregon - Three Sisters (7,687 acres), Deschutes NF, Oregon 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 raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The small-business certification contradicts the analysis beside it I hike and camp in these areas, and the small outfitters and guides who work this same country help people like me get out there. They deserve a real assessment. The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. The supporting regulatory flexibility analysis reaches its no-impact conclusion by spreading the $9 million annual expenditure loss across every small firm in the sector nationally, rather than assessing the outfitters and guides actually holding permits in the affected areas, and concedes some firms may lose these receipts. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections for the areas named above. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record.

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

Dear Secretary Rollins and Chief Schultz: I am writing to express my concern about losing roadless forest and wildlands. These beautiful places exist because they are roadless. We lose national treasures in losing these protections. I grew up with the opportunities to hunt and fish in the Gila NF. I worked for a time in wildland fire in the Gila NF, Wallowa-Whitman NF, Salmon-Challis NF and wildernesses. As a result my life style and values came to revere these majestic places. I went hiking, fishing, bowhunting, and visiting these places; just being there is a gift we owe anyone who ever wants to visit breathtaking places. I look forward to many years of hiking, horseback riding, and appreciating these inspiring places. We have no more precious places than these protected lands. Please steward them with the care and courage, honoring those who have sacrificed much, some all, to keep and protect these irreplaceable wild places. Respectfully submitted, Lynae CommentID: RLC-20261004-52Y038

As a former Forest Service employee of the Wallowa-Whitman National Forest and a current research studying the effects of disturbance on forest soils, I am urging you to not repeal the 2001 Roadless Rule. National forests provide many more services besides the resources they offer for extraction. Most consequential is water filtration and storage. The majority of America's National Forests are located in the West, which is undergoing a water crisis as droughts worsen every year. Roads directly threaten the ability of a forest to provide this service by redirecting the flow of water and not allowing it to infiltrate the soil. This results in less water available through out the year for tree growth and less water available for people. I like having clean water. I like other people having clean water. Do not repeal the Roadless Rule.

September 30, 2006 Dear USDA Secretary Brooke Rollins and Forest Service Chief Tom Schultz, I am writing to express my strong opposition to rescinding or altering the Roadless Area Conservation Rule. My husband and I live in northeast Oregon, adjacent to Wallowa-Whitman National Forest, so I know this area well. There are many reasons why I am opposed to expanding roads in this forest (as well as our other national forests) but I will only mention three in this letter. First, like nearly everyone who lives in this region, I recreate in these mountains and I deeply appreciate what they provide: a wild and quiet landscape with abundant birds and wildlife. Increasing road-building, commercial logging, livestock grazing, and other extractive practices will have a very detrimental effect on the characteristics that I love: the quiet, the birds, and the wildlife. The forest will not be the same if this occurs. Second, I and other local residents are not the only people who cherish this forest. People come from around the state and elsewhere to hike, camp, hunt, fish, pick huckleberries and mushrooms, and to enjoy this landscape in myriad ways. These visitors bring their dollars, which are a vital part of our local economy. Third, ample research has shown that most wildfires are caused by people (either intentionally or non-intentionally) rather than lightening and occur near roads where people access the forests. Thus, creating new roads makes forests more vulnerable to human-caused fires. Additionally, large old trees are the most fire resistant, so eliminating protection of these trees, as has been proposed, reduces the forest’s ability to withstand fire. As you may be aware, this past summer was horrendous in terms of wildfire in Eastern Oregon. We spent nearly two months living with air quality that was frequently rated as very unhealthy and even hazardous. With hot and dry summers becoming the norm, we need to be doing all we can to make the forests more resistant to wildfire, and retaining the large old trees and not expanding road-building is one way to accomplish this. I urge you to keep the Roadless Rule in place, as it is. Thank you for your consideration. Sincerely, Nancy Findholt Cove, OR

Hello, I am a 19 year old college student in oregon. I strongly oppose the repeal of the 2001 Roadless Area Conservation Rule My first college experience was backpacking the Wallowa-Whitman National Forest wilderness area. It was one of the best times of my life. I saw mountain goats, and did some of the most physically difficult hiking I have ever done. This rugged wild landscape untouched by roads or human intervention is something I will forever treasure. I love this country because it is governed by the people or at least it should be. Repealing this law would destroy my love for this country and make me lose my faith in the government we have today. I love our public lands, I love that I am able to go out and enjoy the untouched forests and lakes. I dont care that I might need to hike a few miles in, that is part of what makes these areas so special. I hate wildfire. I think that we need to do everything that we can to prevent the unnecessary loss of forest, life and property. I do not believe that repealing the roadless rule is the solution. Over the last 20 years over 84% of wildfires have been started by people. more roads means more people and more fires. IT IS NOT WORTH IT. Please do the right thing, keep these environments pristine for my generation, for my kids, and their kids too. I'm begging you.

I am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to National Forest lands includes hiking and backpacking and camping. I value these lands because provide invaluable sustainable research capabilities, opportunities for people to learn about and appreciate nature, and rich ecosystems that have innumerable benefits. Eagle Cap Wilderness is one place that has shaped my views on this proposal. It is within the Lake Fork Inventoried Roadless Area in Wallowa-Whitman National Forest. I value its immense beauty - towering mountains, snow-capped, pristine alpine lakes, birds and wildlife. I value its unique landscape and would hate for it to be overridden with roads. I am concerned about the cost of expanding the National Forest road system. The fact that the existing road systems face constant neglect from the Forest Service raises concerns about expansion. Degraded roads can severely hurt and damage ecosystems, so expanding it would be detrimental not only to where new roads are constructed but to where old roads continue facing neglect. I am concerned about wildlife habitat and landscape connectivity. Roads can fragment habitats, hurting animal behavioral patterns. Additionally, roads can increase human access, meaning that development projects might begin in the newly accessed areas. I am concerned about clean water and healthy watersheds. Runoff from poorly managed roads can significantly damage ecosystems and affect habitats, leading to the death of animals and plants. I believe maintaining a national conservation baseline matters. If the Roadless Rule were to be repealed, it would set a national precedent for the removal of conservation and protection acts, potentially leading to even more habitat and ecosystem destruction. Before rescinding the national rule, I would like USDA to answer this question: How would USDA ensure that roadless values are protected through individual forest plans and project-level decisions if the national rule is removed? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments.

I am retired from the USDA - Forest Service since 2014. Twenty-four years on the Wallowa-Whitman NF in Northeast Oregon. Ten years elsewhere for thirty-four years of experience managing our nation's public lands. I spent ten years writing Environmental Assessments (EAs), guiding Inter-disciplinary teams (IDTs) through the NEPA planning process. I know a few things about the agency and their mission to "Care for the Land and Serve the People." I wrote about Roadless Areas in NE Oregon and their purpose. I do not believe eliminating the Roadless Area Conservation Rule is in the best interest of managing our public lands. I believe in wood products and as a multi-use agency, I believe in the Sustainable Yield Act. For decades the forest service has offered logging contractors timber sales to benefit our local and nation-wide economy. However, over-logging occurred on national forest lands into the nineteen eighties. I have seen the results. It was forty lop-sided years of aggressive timber harvest following WWII that upset the balance of a functional forest. Most forest do not recuperate or will never recover should the land be sold off to private investors. Just look to private industrial lands for examples of ecosystems out of balance. Industrial lands may grow trees, but they are far from a functioning forest. You know what I mean if you truly work for the USDA Forest Service. Use your voice. There are plenty of acres designated for timber harvest on national forests. Following sustainable practices into the future will meet demands and keep private industry operational. While many mills were forced out due to competition in the 90s, the larger corporations have survived. We do not need to increase acreage for their purposes only. Those decades of aggressive logging on national forest have frustrated private industry and their lobbyists are advocating for an easy way out - ie: virgin forests. The Roadless Area Rule was implemented for this very time in history. To preserve public lands from roads and logging. To stand against a lop-sided argument for more timber harvest. Roadless areas are set aside as an example of a functioning forest complete with pristine waters, animal and microbial habitat; all providing solitude for those of us bold enough to speak out for such areas. They are set aside to one day be possibly designated as Wilderness. Our children and grandchildren will need this more than ever going forward. Do not let industry strong-arm you into a bad decision, scrambling on their behalf for more acres to harvest. We are turning a corner on national forest lands and with the past forty years of restoration treatments, have signs of a forest that will provide the necessary wood products for our citizens and our economy. All this while protecting the resources Congressional Acts have mandated. If you have read this far, I commend you. I expect you would have stopped once you determined which pile this letter goes in to. Is it pro or con? STOP. When I replied to comments as a NEPA writer of EAs, I would respond in like manner to the effort put forth by the organization or person commenting. If it was a form letter rubber stamped with a signature, I would reply in like manner. But if it was a thoughtful letter based in careful review of the proposal and based in science, I would reply with a thoughtful response, arguing, or agreeing to the science stated. There is no science that urges we march into virgin forest for easy road construction and timber removal. There is plenty of science to argue for preserving functional ecosystems and animal habitat within Roadless Areas. I urge the U.S. Department of Agriculture to withdraw its proposal to eliminate the 2001 Roadless Area Conservation Rule. Please protect America’s national forests and keep the Roadless Rule in place. Our public lands belong to all of us, and taxpayers should not be asked to fund roads that primarily benefit private extraction and profits. Sincerely,

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Wallowas are my family's favorite place to camp and hike. My kids and I go there for the calm, the quiet, and the chance to see beautiful landscapes and wildlife unharmed by commercial development. My son takes wildlife photos there, something he can only do because the habitats are intact. That is the specific thing this rescission puts at risk, and I am asking this agency to account for it. The strongest argument against rescission sits in the agency's own record on fire. The proposal justifies opening roadless areas to roads partly on fuels and wildfire management grounds, but the agency's own prior findings state: "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 Wallowa-Whitman National Forest holds 515,000 acres of inventoried roadless land. If roads go in, the fire risk the agency's own data describes goes in with them. I ask the agency to explain why this proposal departs from those prior findings, and to reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economics do not hold up either. The agency's record states plainly 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, the agency's own cost-benefit 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, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. Oregon alone holds 211 inventoried roadless areas totaling 1,937,741 acres, and across the Pacific Northwest, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency cannot establish a net benefit in its own analysis, yet it proposes to expand the very infrastructure it cannot afford to maintain. The agency must reconcile those numbers before it moves forward. The agency has also argued that state-by-state approaches can substitute for one national rule. I will not reproduce a quote on this point because I cannot confirm it appears exactly as supplied, but the substance of the agency's own prior record shows that the USDA previously expressed dissatisfaction with the rule's nationwide approach and favored local decision-making instead. That path was tried, and it drew sustained legal challenge precisely because piecemeal, local decisions erode nationally significant roadless values in ways no single state proceeding can correct. The agency should explain on the record how this proposal avoids the deficiencies courts identified the last time it replaced the national rule with a state-by-state framework. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. The Tenth Circuit already answered that question. Its holding was: "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." The court found the rule was authorized under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency should state clearly, on the record, what legal basis it relies on to take a contrary position now. If new roads went through the Wallowas, the quiet and calming experience my family goes there for would be gone. My son's wildlife photos depend on habitats that roads and logging divide and disturb. The agency has held more than 600 public meetings and taken in 1.6 million comments to build the rule it now proposes to erase, and it has held none to undo it. That asymmetry alone demands a full answer. I oppose this rescission. Sincerely, Pullman, WA Resident and Mom