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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The humpback whales we watched around Baranof Island brought me to this fight. I want those waters protected, and I want to know exactly how logging the Port Alexander and North Baranof roadless areas, covering 120,681 acres and 314,089 acres respectively in the Tongass National Forest, will affect the humpback whales who frequent those waters. The Tongass is the largest intact temperate rainforest left on Earth, holding over 12,930 miles of salmon-producing streams. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. I oppose that outcome completely. I also paddle parts of the Teanaway River, which flows through the Teanaway roadless area in Wenatchee National Forest. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, and across the Pacific Northwest region 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Washington State is currently in the fourth consecutive year of drought and in a drought emergency. Our rivers have remained free flowing. How will rescission affect the volume of water and sediment load in the Naches, Tieton, and Yakima rivers and all their tributaries on the east side of the Cascades? Removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon, in habitat the DEIS identifies as Essential Fish Habitat and critical habitat managed by NMFS. I want to know what the effect on local salmon runs will be, and I ask the agency to answer that question squarely in the final record. We have visited Hyder, Alaska the last two summers and enjoyed watching the bears fishing at the USFS Fish Creek Wildlife Observation Site. The DEIS quotes the federal grizzly recovery plan directly: the increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. How will rescission affect the number of bears and salmon that come to that observation site? The agency must address this. The national forests of Washington state already show scars from previous National Forest roads that remain in place, many of those roads receiving no maintenance. The agency is already $6.9 billion behind on maintaining the roads it has, against a road budget of about $73 million a year. What will happen to the service level on current National Forest roads if the roadless rule is repealed and additional roads are built? How much will that cost taxpayers? The agency's own record states: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." I ask that the agency reconcile the proposal with its own economic analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and that it explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying that backlog. The agency's own record also states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal justifies rescission partly on wildfire and fuels management grounds. Those two positions cannot both be right. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. Finally, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. Sincerely, Margaret Van Cleve Selah, WA

I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I live in Wenatchee, Washington, below the Okanogan-Wenatchee National Forest. I hold a Ph.D. in geoscience from the University of Wisconsin–Madison, I make documentary films about earth science, and I’m an avid outdoorsman on this beautiful country’s public land. The wildfire rationale conflicts with the Department's own analysis. The Department gives rising wildfire risk as the main reason for rescission. Yet the draft EIS for this proposal states that "road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions." A study published in Fire Ecology on January 29 of this year looked at federal wildfire records from 1992 through 2024. It found that areas within 50 meters of a forest road were as much as four times more likely than roadless areas to see ignitions, and the result held in every Forest Service region. Allowing new roads into the areas that now have the fewest roads would add ignition sources to them. The final EIS should explain how rescission reduces wildfire risk given what the draft already concedes about roads and ignitions. The 2001 rule already allows fuel reduction. Under 36 CFR 294.13(b)(1)(ii), generally small-diameter timber may be cut in inventoried roadless areas to reduce the risk of uncharacteristic wildfire effects. The Department has not shown why that exception is inadequate, or why removing the rule entirely is necessary to get the fuel work it describes. The agency cannot maintain the roads it already has. By the Forest Service's own reporting, its system of roughly 380,000 miles of roads carries a deferred maintenance backlog measured in billions of dollars. Adding road mileage to a system the agency already cannot afford to maintain is not sound stewardship. The final rule should explain how new roads would be funded and maintained. Roads are a major source of human-caused sediment in mountain watersheds. The Forest Service's own research on forest roads has documented this for decades. Road cuts, fills and stream crossings deliver fine sediment to channels, and that sediment fills the spawning gravels and cold-water refugia fish depend on. In the Wenatchee and upper Columbia basins those fish include ESA-listed spring Chinook, steelhead and bull trout. Public money is already being spent to recover those populations, and roadless headwaters are among the last places their habitat still works as it should. Opening those headwaters to road building would undercut that investment. The fish downstream are already federally protected. The roadless headwaters of the upper Columbia drain into rivers that hold Upper Columbia spring Chinook, listed as endangered in 1999; Upper Columbia steelhead, listed under the Endangered Species Act; and upper Columbia bull trout, listed as threatened in 1998. Before finalizing any rescission, the Department should analyze, watershed by watershed, how new road construction in these basins would affect listed fish and the recovery efforts already underway. The public process does not match the scale of the action. The 2001 rule followed more than 600 public meetings and drew about 1.6 million public comments, more than any other rule in the nation's history at the time. This proposal would remove those protections from 44.7 million acres. A 30-day comment period with a 15-day extension is not enough for the public to review a draft EIS and cost-benefit analysis of that size. I urge the Department to withdraw the proposed rule and keep the 2001 Roadless Area Conservation Rule in place. Ethan C. Parrish, Ph.D.

To whom it may concern, I write today to express my profound disappointment with and opposition to the proposed legislation to rescind 36 CFR part 294, Subpart B of the Special Areas; Roadless Area Conservation rule (hereafter referred to as the Roadless Rule). As a marine scientist and outdoor recreationist, I understand the immense value in protecting what few inaccessible areas remain on the planet that have not yet been touched by industry. These areas are essential for the conservation, protection, and recovery of countless organisms that provide Americans with priceless ecosystem services. The loss of biodiversity has become a major concern in recent decades, and legislation like the Roadless Rule is one of too few safeguards we have against ecological collapse. Just last weekend, I had the pleasure of hiking within Okanogan–Wenatchee National Forest, Washington. I was happy to share this experience with hundreds of other hikers who journeyed far to enjoy the annual turn of the larches and salmon run. However, my party and I were also met with facilities and garbage disposal sites near capacity as well as litter on the trail. Meanwhile, a hike last year on the north side of Mt. Rainier N.P. yielded 15 rough and occasionally treacherous miles of FR73 that made for a challenging drive in and out. Rather than a sign of mismanagement on the part of our Forestry Service, these experiences speak to a lack of support from the Federal Government to enable proper maintenance. Overall, my sincere recommendation is that this agency be better equipped to do the amazing work it already does at a much higher capacity. Investing in our natural resources, rather than attempting to sell them off, will yield far greater economic, recreational, and ecological returns in the future. I request that this Administration please end its proposal to rescind the Roadless Rule for the benefit of all Americans present and future. With gratitude, Reid Thomson

I strongly oppose the proposal to rescind the 2001 Roadless Rule (the Rule) and wholesale open about 45 million acres of national forest roadless areas to logging, mining, drilling, roadbuilding and other development – without more careful consideration of the great value each area provides to Americans, such as: A)Providing critical watershed and clean water supply to an increasingly drought-stricken West and other parts of the country. B)Offer essential habitat for wildlife, fish and plants that suffer from shrinking, fragmented and climate-shifting habitats. The roadless areas provide refuges them to retreat to, and migrate across, as their habitats shrink or shift. C)Give important recreational opportunities -- and a vital escape from civilization -- for hikers, bikers, campers, horse riders, hunters and fishermen. These contributions, which have enormous economic value to nearby communities and the whole nation, are usually irrevocably lost when the roadless areas are developed. Finally, a main justification for rescinding the Rule is wildfire risk. There are two flaws in that justification: 1) Research cited by the Wilderness Society shows that wildfires are less likely to ignite in roadless forested areas vs. areas with roads; and 2) Wildfire risk does not justify removing protection for some of the most pristine, fish & wildlife rich, and spectacular roadless areas - the approximately 14.7 M acres of roadless areas in the Tongass and Chugach national forests —roughly one-third of area protected under the Rule. With their maritime climates, these forests tend to have a dramatically lower fire risk, e.g., the Tongass recorded only five wildfires totaling approximately 0.6 acres in 2025. Thus, I urge the Administration to reconsider rescinding the Rule. My opinion is based on: 1) my experience as a citizen involved in national forest planning going back to the mid-1980s; 2) my experience as a volunteer wilderness ranger in Wenatchee National Forest; and 3) My visits to scores of national forests around the country and several of the affected roadless areas.

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

Position: Strongly Oppose Rescission of Roadless Rule I am writing to express my strong opposition to the U.S. Department of Agriculture and Forest Service’s proposal to rescind the 2001 Roadless Rule. As a resident of North Central Washington, I am deeply concerned that completely removing these nationwide protections will irreparably damage the wild character of our region. This rollback threatens the biological integrity of our forests, compromises vital watersheds, and directly undermines the robust amenity tourism economy that sustains our rural communities. 1. Severe Economic Threat to Amenity Tourism and Rural Economies In North Central Washington, our economy has successfully transitioned to rely heavily on amenity tourism and outdoor recreation. For example, visitors traveling to the Wenatchee Valley, Leavenworth, and the Methow Valley for outdoor recreation generate hundreds of millions of dollars in local economic impact annually. People travel from around the world to hike, hunt, fish, and backpack along pristine routes like the Maple Pass Loop or the backcountry rivers of the Okanogan-Wenatchee National Forest. The primary driver of this economic sector is the pristine, untouched nature of our public lands. Permitting commercial road construction and industrial timber harvesting in Washington’s 2 million acres of Inventoried Roadless Areas (IRAs) will permanently degrade the scenic backdrops and wilderness experiences that draw tourists to our shops, hotels, and guide services. This proposal actively prioritizes short-term resource extraction at the direct expense of our stable, long-term recreation economy. 2. Severe Threat of Habitat Fragmentation Rescinding the Roadless Rule opens contiguous ecosystems to road construction and timber harvesting, accelerating habitat fragmentation. Roads act as linear barriers that bisect habitats, trap smaller species, create edge effects, and introduce invasive species. In North Central Washington, large, unfragmented habitats are critical for the survival of wide-ranging apex predators and migratory species, such as grizzly bears, wolverines, elk, and gray wolves. Carving roads into these final refuges disrupts migration corridors and drives localized population declines. 3. Destruction of Crucial Watersheds and Aquatic Habitats IRAs encompass the headwaters of some of our nation’s cleanest municipal water supplies and healthiest aquatic ecosystems. In our region, pristine watersheds feed key river systems that support threatened salmonids and trout species. Road building inevitably increases soil erosion, triggers landslides, and sends massive amounts of sediment into streams. This sedimentation chokes spawning gravels used by salmon, increases water turbidity, and alters natural stream hydrology. Preserving the 2001 Roadless Rule is an essential, cost-effective strategy for protecting downstream water quality and maintaining resilient aquatic habitats. 4. Cultural Importance of Wilderness, Solace, and Adventure Beyond their ecological and economic value, roadless areas hold profound cultural significance. These landscapes offer rare opportunities for true backcountry adventure, self-reliance, and solitude. The psychological and societal value of experiencing "untrammeled" nature—where the sights and sounds of mechanized industry are absent—is irreplaceable. Allowing commercial resource extraction and road networks into these spaces permanently destroys the wild character that outdoor enthusiasts, hunters, anglers, and seekers of solace rely upon. Conclusion Managing these millions of acres through a patchwork of localized forest-by-forest plans lacks the cohesive, nationwide standard necessary to safeguard migratory wildlife, broad watersheds, and interconnected regional economies. The 2001 Roadless Rule has successfully balanced conservation with public access for a quarter of a century. I urge the Forest Service to withdraw this rescission proposal and maintain the strong, national protections currently in place.

Roadless Areas contain some of the wild spaces that have shaped my experience with outdoor recreation, and I continue to recreate in these landscapes frequently today. For example, Liberty Bell in the Okanogan-Wenatchee National Forest is where I led my first multi-pitch trad climb, Hidden Creek in the Mount Baker-Snoqualmie National Forest was one of the first canyons I explored and helped inspire my love of public lands, and Mineral Creek in the Okanogan-Wenatchee National Forest is where I take new canyoners to experience the waterfalls and wild landscapes of Washington. These are only three examples of the dozens of ways I recreate in Roadless Areas. I am deeply concerned that rescinding the Roadless Rule could eventually result in the loss of access, or increased costs and barriers to access, as logging, road construction, and other extractive activities expand into currently Roadless Areas. I have already seen some of these impacts in canyons where logging leases have affected access and the surrounding landscape, and I worry that opening roads in Roadless Areas could lead to similar outcomes in other places where I recreate. I am also concerned about the effects of increased roads and human access on the condition of these areas. In canyons that are currently accessible by roads, canyoners already encounter excessive garbage dumping and invasive species. I worry that opening currently Roadless Areas to additional roads and development would expose more of these relatively untouched places to the same problems. Road construction also has the potential to alter the natural processes that make these canyons unique. In my experience, canyons near roads have experienced problems including extreme seasonal flooding, unstable log jams, and destruction of anchors used for technical canyon access. I am concerned that increasing road density could exacerbate these impacts and degrade both the natural character and recreational value of these areas. Wildfire risk is another significant concern for me. Multiple members of my family lost their homes in human-caused fires during the past fire season, making this issue particularly personal. I understand that the existing Roadless Rule allows for wildfire management within Roadless Areas. I would ask the Forest Service to fully explore and utilize those existing wildfire-management options rather than opening additional wild areas to roads and the increased human access and potential for human-caused ignitions that roads can bring. I also have a significant fiscal concern. The Forest Service is already responsible for maintaining approximately 380,000 miles of National Forest System roads, and the agency faces substantial challenges maintaining its existing road network. Many existing roads are aging or inadequately maintained because of limited resources. Given these constraints, I believe it would be fiscally irresponsible to expand the active road network into currently Roadless Areas when there are already so many existing roads that the Forest Service does not have the resources to adequately maintain. I urge the Forest Service to retain protections for Roadless Areas and not rescind the 2001 Roadless Rule. These landscapes provide irreplaceable opportunities for recreation, solitude, and connection with wild places. I fear that rescinding the Roadless Rule will lead to irreversible damage to the places where I recreate, permanently altering the landscapes that I feel incredibly fortunate to enjoy today. I hope future generations will have the same opportunity to experience these wild places as I have.

I hiked the Maple Pass Loop in Washington's North Cascades on October 5 and will be at Cutthroat Lake later this week, trails through roadless country in the Okanogan-Wenatchee National Forest. The larches, the quiet, and the intact watershed exist because no roads were built there. I oppose rescinding the 2001 Roadless Rule. Once roads and timber sales enter these areas, the backcountry character that draws hikers and supports the local recreation economy cannot be restored. Please keep the national protections in place. — Emily Frary

To the U.S. Forest Service Roadless Rule Docket: I regularly hike, forage, ski and appreciate nature in this area. I enjoy viewing nature in this area and feel that this area has an exceptional quantity of biodiveristy. Once biodiversity goes away, it can never be replaced. Due to the unique location of this roadless area between the east and westside of the cascades, it has an incredible amount of biodiversity and a number of endemic species. This area is so understudied and diverse that in 2018 a new species of desert parsley was discovered. Lomatium roneorum is a "critically imperiled" species is a prime example of potential loss of biodiversity from rescinding the roadless rule. Specifically, we could lose biodiversity which hasn't even been identified. I am a recreationist and naturalist who lives very near the Nason Ridge roadless area. I strongly oppose rescinding the roadless rule in order to preserve biodiversity, and due to the value of the ecological value of this area far exceeding monetary value it can provide from resource extraction. Regarding the Nason Ridge in the Wenatchee National Forest, Washington: "Of the 537 wildlife species of conservation concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas (IRAs). The median IRA contains suitable habitat for 10 wildlife species of conservation concern, with a maximum of 62. If all IRAs were added to the protected-area system, there would be a substantial decrease (-38) in the number of wildlife species of conservation concern that are currently considered 'poorly represented' in protected areas." — Global Ecology and Conservation / ScienceDirect, 2021 Without the Roadless Rule, the Nason Ridge IRA in Wenatchee National Forest loses the protection that currently maintains Pacific Northwest Maritime Subalpine Parkland (North Pacific Maritime Mesic Subalpine Parkland) (GNR, 2.8%, ~547 acres) as intact habitat for Whitebark Pine (Pinus albicaulis, G3, T). The species is documented present and ecologically associated with this ecosystem through two independent data sources — rescission puts both at risk simultaneously. Whitebark Pine (Pinus albicaulis, G3) depends on the structural integrity of Pacific Northwest Maritime Subalpine Parkland (North Pacific Maritime Mesic Subalpine Parkland) in Nason Ridge for the specific life-history requirements NatureServe's ecological association identifies. Road construction disrupts canopy closure, soil structure, and moisture regimes — the ecosystem attributes that make this habitat functional for this species. NatureServe identifies Whitebark Pine (Pinus albicaulis, G3) as ecologically associated with Pacific Northwest Maritime Subalpine Parkland (North Pacific Maritime Mesic Subalpine Parkland) (GNR, 2.8%, ~547 acres) in the Nason Ridge IRA. The DEIS must incorporate this documented species-ecosystem association and analyze how road construction in Wenatchee National Forest disrupts it. The Department should recognize that road construction in these areas isn't reversible and act with the caution that irreversibility demands. With appreciation, Patrick Henneghan

I am commenting on the USDA Forest Service's proposed rescission of the 2001 Roadless Area Conservation Rule. I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Gabriel, and I live in Washington State. I am a budding environmental scientist working on restoration projects. I have spent lots of time backpacking in both the Okanagan-Wenatchee National Forest and Deschutes National Forest. If more roads are built, that would greatly detract from the experience. Also, Section 294.13 already permits tree thinning and emergency fire access.

I oppose the repeal of the Roadless Area Conservation Rule. I am 67, and most of my life I have appreciated the opportunities to recreate in the backcountry areas of Colorado and Washington. Accessing areas that are only reached on foot or horseback allow you to experience the solitude and beauty of these undisturbed areas. Allowing new resource extraction, infrastructure development, or other activities that will disturb this natural environment will have a negative impact for the general public that want to preserve these areas for enjoyment of recreational opportunities, preservation of wildlife and water resources, and for future generations. Allowing roads and vehicle access closer to pristine alpine areas will degrade the value of the recreational experiences and the preservation of these wild areas. Over the past 20 years living in Washington State, going to the mountains for backcountry hikes, backpacks and climbs, are my primary recreational activity. I spend nearly every weekend in pursuit of exploring these untouched and protected areas. In reviewing the map of current roadless areas in Washington, many of the areas that I visit frequently on trails and to destinations will be either partially, or completely affected by the repeal of the rule. These include areas in the the Okanogan-Wenatchee National Forest; Chelan area, Boiling Lake, Sawtooth area, Eagle, Martin, Cooney, Crater Lakes. Bigelow, Martin, and Switchback Peaks, Libby Creek trail, East Fork Buttermil trail, West Fork Buttermilk trail, Eagle Creek trail, Willliams Creek trail, Heather Maple Pass trail. Tobinson, Golden Horn, Tower, Hardy, Azuirte, Gardner and N Gardner Peaks, Grasshopper Pass, Cutthroat Pass, Snowy Lakes. Long Swamp area: Thirty Mile trailhead, Chewuch trailhead. Pasayten Rim: Copper Glance trailhead, Big Craggy and W Craggy Peaks. Myrtly Lake; Phelps Creek trailhead, Entiat River trailhead. Twin Lakes area: Dirty Face trailhead. nason Ridge area: Rock Mountain, Merritt Lake trail. Alpine Lakes area: Jim Hill Mountain, Lanham Lake trail. Heather Lake area; Skyline Ridge trail, Lake Minotaur trailhead, Heather Lake trailhead. Also trails, mountains and lakes in the Mount Baker-Snoqualmie NF and Gifford Pinchot NF; Glacier Peak area, Boulder River area, Maount Baker area, Horseshoe area.

I oppose rescinding the 2001 Roadless Area Conservation Rule either fully or partially. The inventoried roadless areas under the jurisdiction of the Forest Service are amazing and irreplaceable places, and we should continue to protect them from roadbuilding and resource extraction. I live in Washington where roadless areas are some of the most spectacular and distinctive locations in the state. In June, the Teanaways, part of Okanogan-Wenatchee National Forest, have usually just melted out and it's possible to scramble gentle red rock peaks such as Bean or Earl and have a view of the stunning Stuart Range. Mount Dickerman in Mount Baker-Snoqualmie National Forest is where my friends scattered the ashes of their beloved golden retriever, and we go up around fourth of July every year to commemorate what a great dog he was. I love the lower Graywolf River in Olympic National Forest, which is accessible all winter and runs blue and clear through a valley lined with ferns and mosses, and I also love ascending Mount Townsend, which on a clear day lets you see five volcanoes at once across the sound. These places make Washington an exceptional place to live and they are also distinctive, important ecological communities that shouldn't be fragmented or disturbed any further. Has the proposed action to rescind the Roadless Area Conservation Rule adequately considered the ecological impact of the change? Has relevant scientific research been considered, particularly with respect to fragmenting and disturbing habitat? I oppose rescinding the Roadless Area Conservation Rule because I do not believe we can undo the fragmentation and loss that will be triggered by lifting these protections, and we should not make this mistake. I support Alternative 1, the No Action alternative.

I live in Snohomish County, WA and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. I have hiked, backpacked, camped, and rode horses all over Washington State, including the Okanagan National Forest and Wenatchee National Forest. I have so many memories of family trips in the wilderness, of roughing it and loving it, of connecting with the generations before me who walked this land. I am concerned about wildlife habitat and landscape connectivity. So much wildlife already has to try to survive around human settlements in fragmented pieces of habitat, hindering ability to migrate and to find sustenance. And what of the cost of expanding the National Forest road system? I would rather we better maintain the roads we already have than spend money on new roads and bridges. And there is the issue of wildfires, which have been increasing in recent years, not only burning the landscape but sending smoke to distant communities and poisoning the air. Since most wildfires are caused by humans, how would increasing access to natural areas lower the chances of wildfire? 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.

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

I am writing to oppose the proposal to partially or fully rescind the Roadless Rule. This rule offers important protections for our National Forests and should be kept in place. The Roadless Area Conservation Rule helps protect our National Forest lands and I have benefited from the recreation opportunities on many of these lands, including trips in Olympic National Forest, the Okanogan-Wenatchee National Forest, and the White Mountain National Forest. As someone who values time outdoors, the recreational opportunities afforded in these preserved forests are extremely meaningful to me. Rescinding the Roadless Rule puts these rare areas at risk and reduces the recreational opportunities, as well as the associated economic benefits provided by these recreational opportunities. This is particularly harmful to small communities who border these areas and benefit from the tourism dollars spent there. In addition to recreation, the Roadless Rule protects our National Forests from development, logging, and potentially negative human impacts. Multiple studies, for example Aplet, Hartger & Dietz, 2026, have shown that wildfires are less prevalent in roadless areas, and the incidence of human caused fires generally increases with proximity to roads. Removing the Roadless Rule protections opens up more areas to road development and heightens the wildfire risk in these areas. Therefore, our forests are safer when there are less roads and less human impacts. Rescinding the Roadless Rule is also likely to negatively impact the environment by increasing the likelihood of landslides and debris in timber harvest areas, contributing to reduced water quality for many reliant communities, and increasing emissions due to trucks and mechanical equipment used for logging. In addition, roadless areas overlap with the range of more than 300 species of threatened, endangered, or proposed species and almost 100 habitats listed under the Endangered Species Act. As a trained wildlife biologist, I recognize the importance of protecting the species, habitats, and biodiversity found in our National Forests. Opening these areas to timber harvest or other development will negatively impact these areas and the animals that rely on the protected habitats. Ultimately, we should be protecting the limited undeveloped areas we have left in our country. Our natural lands offer us clean water, recreational opportunities, and economic benefits. Repealing the Roadless Rule does more potential harm than good. Please keep the Roadless Rule in place. Sincerely, Mackenzie Pearson

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The trails I ride wind through habitat deep in the Okanogan-Wenatchee National Forest. I was born here, I have lived here my whole life, and I am raising my two daughters to appreciate the quiet and wild landscapes that define this place. What I want for these lands is simple: that they be sustained and kept as wild as possible, so that my two daughters and their children can have the same experiences I had as a child, exploring a roadless environment on their own two feet, far from vehicles and noise and the significant impacts of humans. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly that, and I oppose it. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. Building new roads into that country is not a small decision. 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." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. That justification cannot be squared with those findings. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas and that it reconcile the rescission with the ignition data in its own DEIS, which the record indicates reports far higher fire density on roaded land than inside the affected roadless areas. I live in a rural part of eastern Washington where clean rivers and waterways are essential for drinking water, agriculture, and wildlife. Our watershed is a major spawning ground for salmon, which in turn provide a significant economy for so many commercial fishermen and women. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Salmon are already stressed by warming water, and the science the agency has before it shows that removing riparian vegetation can raise stream temperatures beyond what suits cold-water species and can reduce egg survival, rearing densities and growth of coho salmon, in areas that include Essential Fish Habitat and critical habitats managed by NMFS. Opening these drainages to road construction and the sediment loads that follow would put that spawning habitat at direct risk. The agency must explain, with specificity, how this rescission is consistent with its obligations to Essential Fish Habitat and to the communities and commercial fishing economies that depend on cold, clean water coming out of these roadless watersheds. The proposal also argues that the 2001 rule exceeded the agency's statutory authority, but a federal appellate court already resolved that question. That court's disposition reads: "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 agency owes the public a direct answer to what that Tenth Circuit holding means for its current authority argument, including whether it believes the rule created de facto wilderness in a way that court rejected, and what legal basis supports a position contrary to that ruling. The agency also claims permitting and administrative burden as grounds for rescission, but the rule as written already allows exceptions. As the agency's own analysis acknowledges: "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)." The agency has not shown which specific burdens fall outside those existing exceptions. Currently the federal government cannot rally the funds to maintain the trailheads and infrastructure we already have on this forest, so adding more would be impossible. Selling or opening our public lands to private interests without our consent is robbing us of what we have all chosen to steward together. The agency should identify and quantify, on the record, which burdens are genuinely unaddressed by the rule's existing health, safety, and mineral lease exceptions before citing administrative burden as a reason to eliminate protection for millions of acres. The agency should withdraw that certification and conduct a genuine assessment focused on the small businesses actually operating in these roadless areas, not a national average that obscures the localized harm. Sincerely, Samuel Naney Winthrop, Washington

oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66; Docket FS-2025-0001). As a backpacker and frequent visitor to Washington's public lands, I have spent many days in the Okanogan-Wenatchee National Forest, Mount Baker-Snoqualmie National Forest, and the Alpine Lakes Wilderness. These landscapes provide some of the most outstanding backcountry recreation opportunities in the Pacific Northwest. The experience of traveling through largely undeveloped forests, quiet valleys, alpine basins, and roadless terrain is increasingly rare and valuable. I am concerned that removing the national protections of the Roadless Rule could lead to increased road construction and fragmentation of currently undeveloped areas. Roads permanently alter the character of backcountry landscapes, diminish opportunities for solitude, increase impacts to wildlife habitat, and reduce the wilderness qualities that attract hikers, backpackers, hunters, anglers, and other outdoor recreationists. The existing Roadless Rule has successfully protected important watersheds, wildlife habitat, and recreation opportunities for more than two decades. In Washington, roadless areas adjacent to and surrounding treasured destinations contribute significantly to the quality of the outdoor experience and help preserve intact ecosystems for future generations. I support active forest management where appropriate, but I do not believe that rescinding nationwide roadless protections is necessary to achieve those goals. The long-term recreational, ecological, and watershed benefits of maintaining roadless areas outweigh the benefits of expanding road-building opportunities. I urge the U.S. Forest Service to retain the 2001 Roadless Area Conservation Rule and continue protecting inventoried roadless areas across our national forests. Thank you for considering my comment.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My family has hiked the Enchantments many times. A large photograph my son took of Lake Vivian on his graduation celebration hike hangs in our living room. My husband describes that area as a taste of heaven. I grew up in Cashmere, Washington, loving those natural spaces for exactly the reset they gave me. I now live in Spokane, and the older I get, the more I understand that protecting large areas of forest land is one of the most important actions we can take for the health of our entire planet. I oppose the rescission of the 2001 Roadless Area Conservation Rule. I support the no action alternative. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, including more than 1,006,000 acres in the Okanogan-Wenatchee National Forest. These are places my family returns to. We love learning about birds, the American Pipit, the Dark-eyed Junco, and the occasional eagle. The agency's own data give me serious reason to worry what road-building would do to them. The DEIS cites the finding 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.)" The DEIS also cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and is never applied to the 40.1 million acres of potentially affected environment. I ask that the agency apply that fragmentation range to the full extent of the affected acreage before this rule moves forward. Water protection is among my highest priorities. Creating new roads sets off a chain reaction with countless negative consequences from logging. The quality of our lives is directly linked to our access to water free from contamination. Across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I want the agency to explain on the record how it reconciles that figure with opening these watersheds to new road construction. The process behind this rescission troubles me as much as the substance. More than 600 public meetings and 1.6 million comments shaped the original rule. No equivalent process is being conducted to undo it. So many people spoke up to get the roadless rule in place, and we should be working to protect even more wild spaces, not rolling back the protections we currently have. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My family's relationship with these forests is exactly the kind of reliance interest the agency invited and has not evaluated. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire record weakens the case for opening these areas. "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." The agency has not quantified the expected increase in ignitions that new road access would bring or weighed that against the claimed reduction in wildfire hazard. That analysis must be done before any decision is made. Finally, the regulatory flexibility certification does not hold up. "The proposed rule certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year." The certification is reached by spreading losses across every small firm nationally rather than assessing the guides and outfitters actually permitted in the affected areas. The agency should withdraw the certification and assess the operators who actually work in these places. Being in nature and photographing it helps to experience transcendent moments. More and more research shows connections between access to trees and wildlife and increased cognition and mental health. I want my children to grow up and enjoy these same spaces with their own children. Short-term profit is not worth the damage that will be done if we lose these protections. Please protect these sacred places. Sincerely, Tamara Kennedy-Gibbens Spokane, WA

I am writing to ask the US Forest Service to keep the Roadless Rule in place. I value hiking, camping, flyfishing and taking photos in the beautiful, untrammeled, undeveloped country that Roadless Areas consist of. They should not be compromised. We do not need roads, timber harvesting, mining or development in these places that have remained largely untouched for decades. These places represent the closest thing to true wilderness, and most of the Roadless Areas should be considered for wilderness designation. Here, near my current home on Whidbey Island, WA, we have the Dark Divide Roadless Area that stretches between Mount Admas and Mount St. Helens, providing high ridges and dense old-growth forests—a rarity anywhere in the country today. I’ve hiked Sauk Mountain in a Roadless Area in the Mount Baker-Snoqualmie National Forest, and cross-country skied out of Winthrop in a Roadless Area on the Okanagan-Wenatchee National Forest. These places are highly cherished by locals and visitors alike. They protect our watersheds and wildlife. They provide open space and recreation and incredible scenic beauty. There is no going back once roads are built into Roadless Areas. Everyone and everything —people, wildlife, and our planet—stand to lose the valuable treasures that have been protected from development. For these reasons I support keeping Roadless Rule in place. Please.

To the Department of Agriculture: We live off the land. It provides us water food and habitat, it also supports others downstream and provides recreation for the area. My brother wa able to hunt a bear to feed our family. The bear would not be in the area if there were roads. The community near me is orchards. If the area upstream area is disturbed the orchards soils will be affected the water quality will decrease and pests will become higher. Our agricultural producers will take a hit. I am a sister, wife, and soon to be parent. I live off these lands and want them to support my future children. Removing the roadless rule will ruin their future. Regarding the Entiat in the Wenatchee National Forest, Washington: "Mammal and bird population densities declined with their proximity to infrastructure. The effect of infrastructure on bird populations extended over distances up to about 1 km, and for mammal populations up to about 5 km. Data were gathered from 49 studies on 234 mammal and bird species. The main response by mammals and birds in the vicinity of infrastructure was either avoidance or a reduced population density." — Biological Conservation (ScienceDirect), 2010 “Mammal and bird population densities declined with their proximity to infrastructure. The effect of infrastructure on bird populations extended over distances up to about 1 km, and for mammal populations up to about 5 km. Data were gathered from 49 studies on 234 mammal and bird species. The main response by mammals and birds in the vicinity of infrastructure was either avoidance or a reduced population density. — Biological Conservation (ScienceDirect), 2010 (https://doi.org/10.1016/j.biocon.2010.02.009)” Under the standardized IUCN-CMP classification, threat 8.1 — 8.1 - Invasive non-native/alien species/diseases — is recorded against Leavenworth Desert-parsley (Lomatium roneorum, G1) in the Entiat Inventoried Roadless Area, Wenatchee National Forest, at Moderate or 11-30% pop. decline severity with Restricted (11-30%) scope. Roads enable the equipment access, land conversion, and human activity that activate 8.1 - Invasive non-native/alien species/diseases. Without road infrastructure, the extractive and development pressures behind this threat category cannot reach Leavenworth Desert-parsley habitat in Entiat. If the DEIS does not evaluate how rescission affects Leavenworth Desert-parsley (Lomatium roneorum, G1) in Entiat with respect to 8.1 - Invasive non-native/alien species/diseases, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. There's a reason this rule has lasted this long. I'm asking the Department to respect that reason and keep it in place. With appreciation, Cassie Knavel