Read the comments.

Please consider not repealing the roadless rule. The roadless rule has protected 45 million acres of untouched forests for 25 years. While protecting these forests, habitats, endangered species, and the drinking water of 25 million Americans has also been protected. These areas have been protected from industrial logging keeping old growth forests in check which are important in our mitigation of climate change. The choice to repeal this rule isn't a poor environmental decision, but it also takes land out of Americans hands. Public lands should stay public. This would affect families, hunters, anglers, hikers, and backpackers. I frequent the White Mountain National Forest area in New Hampshire. This area would be directly impacted by taking away the roadless rule. Pristine forests and habitats destroyed and hiking trails taken away. This is a bi partisan issue and I truly believe Americans on all sides of the political spectrum support keeping the roadless rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Pemigewasset Wilderness has been part of my family across three generations. I have gone since I was born, and it is meaningful to me, my parents, and my grandparents. Losing its purity would be a loss to family memory and to land I hope to share in an untouched form with my future kids. That is why I oppose the rescission of the 2001 Roadless Area Conservation Rule (Docket FS-2025-0001) and ask the agency to address each of the following points in its final record. The White Mountain National Forest holds 16 inventoried roadless areas totaling 240,669 acres, including the Pemigewasset Wilderness, whose headwaters feed rivers running to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region alone, 286 municipal water intakes sit in watersheds containing affected roadless areas. The New England mountains were clearcut once before, and the damage was so severe that Congress passed the Weeks Act of 1911 specifically to authorize federal purchase and recovery of those lands. These places, home to moose, black bear, brook trout, and Canada lynx, recovered under protection. The economic case for rescission does not hold together. 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 those marginal gains, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, recreation losses of at least $6.1 million a year, and a net present value ranging from -$92 million to +$199 million, a spread so wide it cannot establish a net benefit. Meanwhile the agency already carries a $6.9 billion maintenance backlog on roads it cannot afford to keep, against a road budget of roughly $73 million a year. I think it makes no sense to increase roads that we need to use taxpayer dollars to maintain. This is a terrible and poorly analyzed plan, and reducing long-term spending means doing it pragmatically, not expanding infrastructure the agency cannot sustain. I ask that the agency reconcile the proposal with these figures and explain how an action whose own analysis cannot demonstrate a net benefit justifies adding to a road system already buckling under deferred maintenance. The proposal argues that state-by-state approaches can replace a national rule. The agency's record itself 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." The Ninth Circuit reviewed exactly that state-by-state alternative and found it deficient. I ask that the agency address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies identified the last time a national rule was replaced with a state-by-state approach. The proposal also argues that the 2001 rule exceeded the agency's statutory authority. The court that examined that question reached a different conclusion. The Tenth Circuit 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 within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and held that it did not create de facto wilderness. The agency owes the record a direct explanation of any contrary legal position it intends to rely on. Finally, the proposal cites permitting and administrative burden as justifications for rescission. The rule as written already provides that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Additional exceptions address existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside those existing provisions. It should do so, with quantification, before any further action on this proposal. Public land should be managed for long-term value to the country and its people. The Pemigewasset Wilderness represents exactly that kind of value, accumulated across generations and irreplaceable once a road goes in. I ask the agency to answer each of these points in the record before it proceeds. Sincerely, Calvin Kinghorn San Francisco, CA

Re: Special Area; Roadless Area Conservation Docket No. FS-2025-0001 RIN 0596-AD66 I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule because its claimed wildfire management benefits do not justify the environmental, recreational, and fiscal costs. I am a native New Hampshirite and hike or backpack in the White Mountain National Forest (WMNF) once or twice a month. Some of its wildest areas - like Lincoln Woods, the Sandwich Range and Mount Chocorua, and areas surrounding the Pemigewasset Wilderness - lie within the 235,000 acres of Inventoried Roadless Areas (IRA) in the WMNF [1]. These landscapes help draw roughly six million people annually [2]. The rescission of the Rule places them at risk from commercial timber harvesting. I argue three points against this proposed rescission: 1. Wildfire Management Benefits are not Proportional to Environmental Risks The Rule already allows substantial wildfire risk management, so the Forest Service’s rationale that a full repeal is needed for wildfire mitigation is flawed. Under 36 C.F.R. § 294.13(b)(1), small-diameter timber may be cut or removed to maintain or restore ecosystems, including to “reduce the risk of uncharacteristic wildfire effects.” The Forest Service also stated that “hazardous fuels treatment in inventoried roadless areas is not prohibited by this rule, so long as road construction or reconstruction is not necessary.” 66 Fed. Reg. 3244, 3258 (Jan. 12, 2001). The Rule separately permits road construction when necessary to protect public health and safety from an imminent threat of fire or another catastrophic event. 36 C.F.R. § 294.12(b)(1). I concede that rescission would provide managers more flexibility, but that does not justify eliminating nationwide protections. New roads fragment habitat, increase erosion and sedimentation, and increase human access; the proposed rule itself acknowledges that “greater public access can increase human-caused ignition potential.” 91 Fed. Reg. 53829 (2026). If additional access is needed in particular high-risk forest, “especially in the Western United States,” the Forest Service should adopt targeted exceptions instead of repealing the Rule nationwide. 2. Harm to Scenic Value and Recreation Beyond environmental significance, the WMNF is the crown jewel among NH’s natural assets that support major tourism and outdoor recreation activity. This activity supports 30,000 jobs and contributes $4 billion to the state’s economy annually [2]. The Forest Service acknowledges that rescission could cause “noise, visible infrastructure, and temporary closures” and reduce opportunities for “quiet, remote and self-reliant recreation.” What’s more, the estimated $6.1 million in annual lost recreation is likely an underestimate because the analysis relies heavily on assumptions and admits substantial uncertainty about what and where development would actually occur. In a heavily visited forest like the WMNF, those losses deserve substantial weight. Commercial access that degrades remote landscapes should not be expanded absent a demonstrated public benefit. 3. New Roads are Difficult to Justify Amid a $6.9 Billion Maintenance Backlog The Forest Service already faces a multi-billion dollar backlog of deferred maintenance for its existing roads. 91 Fed. Reg. 53829. It acknowledges that timber harvest and vegetation management would likely create the greatest demand for new roads, and that expected timber-efficiency gains would be “incremental” and constrained by road costs, maintenance funding gaps, and the $6.9 billion backlog. It is fiscally irresponsible to open areas to taxpayer-funded road expansion for the benefit of private timber harvesters when the agency can’t afford to maintain existing infrastructure. Limited Forest Service resources would be better directed toward maintaining existing infrastructure than opening currently roadless lands to additional development. In sum, I request that USDA withdraw the proposed rescission and retain the 2001 Roadless Rule. If the agency concludes that additional management flexibility is necessary for wildfire risk reduction in particular regions or circumstances, it should pursue narrowly tailored amendments that preserve the Rule's nationwide baseline protection while addressing demonstrated management needs. Stripping all protections is an unnecessary excuse to open these delicate ecosystems to extractive industrial activities. [1] https://newhampshirebulletin.com/2026/09/14/repub/unique-stretch-of-new-england-forest-under-threat-after-proposed-rollback-of-roadless-rule/ [2] https://www.unh.edu/news/whos-visiting-new-hampshires-white-mountains

The continental United States is very large, but has very few wilderness areas. Consequently those that do exist, particularly those in the densely populated part of the country that lies to the East of the Mississippi river, have outsized ecological and recreational value. The proposal to rescind the Roadless Area Conservation Rule (66 FR 3244) has the potential to render the United States more domesticated and more European in character. This would dramatically decrease my enjoyment of the few wilderness areas I have access to, including the Pemigewasset wilderness in New Hampshire's White Mountain National Forest. I would encourage the Forest Service to reconsider the proposed rescission of 66 FR 3244 and maintain the Roadless Area Conservation Rule in its current form.

I grew up on a beautiful lake in Maine. I started hiking the 4000 footers in Maine after being introduced to hiking by my 8th grade history teacher, who was an Appalachian Trail thru-hiker. My mom and I hiked all over the state together, creating memories that I will never forget, like hiking Mount Katahdin and meeting other AT thru-hikers along the trail. In 2024, I decided to thru-hike the AT. I walked home from Georgia, meeting some of my now best friends along the way and connecting deeply with the mountain range that has been home my entire life. As a part of my thru-hike, I walked through hundreds of miles of roadless areas, including those in the White Mountain National Forest and just north of the Caribou Mountain Speckled Wilderness area in Maine. New Hampshire and Maine are thru-hikers favorite states because of the wilderness that hikers experience. Now, I work for the Appalachian Trail Conservancy and make my living in part because of the Roadless Rule and the wilderness areas that the rule protects. The recission has bipartisan opposition and would drastically reshape the national forests that so many of us hold dear. I encourage the forest service to listen to the people of the United States and leave the Roadless Rule in place.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Much of my free time goes to exploring wilderness, and a great deal of it falls inside roadless rule areas: the Santa Rita Mountains in Arizona, the Sierra Nevada, across the Siskiyou, and in the east, White Mountain National Forest. I go looking specifically for the bird and plant species that depend on undisturbed ecosystems, the kind of habitat that disappears the moment a road goes in. This proposal would rescind the protections that make those places worth the trip, and I oppose it. The agency's own evidence on wildfire undercuts the rationale for rescission. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." If the agency is justifying this rescission partly on fuels management grounds, it needs to explain why it is departing from that finding. I ask that it reconcile this proposal with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain what in the current record overrides what the agency itself documented. The birds I look for across the Siskiyou, the Sierra, the Santa Ritas, and the White Mountains are not incidental to the roadless rule. They are a direct product of it. The DEIS cites findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The Coronado's verified species list includes the elegant trogon and the Mexican spotted owl, and the White Mountain's includes Bicknell's thrush, each tied to the undisturbed conditions the rule protects. The 23 inventoried roadless areas of the Coronado total 482,687 acres, the Santa Ritas among them, and jaguars have been documented crossing from Mexico through the Santa Ritas into the Rincon Mountains, making those corridors the northernmost viable jaguar range on the continent. Opening any of it to road-building does not merely disturb habitat at the road's edge. It degrades the surrounding area through noise and fragmentation. The agency must address in the record how rescission squares with its own documented findings on road noise and bird abundance, and what specifically it expects to happen to species dependent on those corridors once the rule is gone. The economics do not hold up either. 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." The agency projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. A cost-benefit analysis that cannot establish a net benefit is a thin foundation for expanding a road system already carrying a $6.9 billion maintenance backlog. The agency should reconcile the proposal with those numbers. The state-by-state approach this proposal gestures toward has already been tried and overturned. The record itself acknowledges: "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when the national rule was last replaced with a state-by-state framework. Finally, the rule the agency proposes to rescind already contains the flexibility it claims to need. The DEIS 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 White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. If the agency's concern is genuine administrative burden, it should identify which specific situations are not already addressed by the existing exceptions for health, safety, and existing mineral rights, and it should quantify those burdens with actual data rather than assertion. Sincerely, Timothy Forker Brooklyn, NY

Draft Comment Blueprint Attn: Joshua White, Acting Director, Ecosystem Management Coordination Docket No: FS-2025-0001 | RIN: 0596-AD66 Re: Opposition to Proposed Rescission of the 2001 Roadless Area Conservation Rule I am writing to express my strong opposition to the full rescission of the 2001 Roadless Rule. As a regular visitor to the White Mountain National Forest, the justification provided by USDA Deputy Secretary Stephen Alexander Vaden, claiming that a nationwide rollback is required to grant "access" for active forest management and wildfire reduction, is explicitly contradicted by the agency’s own data. Proceeding with this rule constitutes a textbook case of fiscal waste, administrative abuse, and analytical fraud for the following substantive reasons: 1. A Personal and Generational Stake in Intact Backcountry: Some of my earliest memories from childhood are my mom taking me on a backpacking trip up Mount Lafayette at age six. The deep wilderness experience of standing on Lafayette depends entirely on the pristine, unfragmented backcountry visible below it. Devastatingly, vital access points like the Liberty Springs Trail coming out of Franconia Notch are not off-limits if this rule gets revoked. Please don’t take this opportunity away from other parents and children by disrupting forests in their areas! Furthermore, commercial logging or logging roads near the Appalachia trailhead would completely ruin the gateway to the northern Presidentials like Mount Adams and Mount Madison, creating visual and noise pollution for hikers climbing out of the valley. I just went back to the Whites with my mom 20 years later. We hiked out of Appalachia and shared a similar special moment. Having lived near major metropolitan areas like New York and Boston since graduating college due to my career, traveling to these designated roadless areas is a vital escape that my peers plan for, look forward to, and rely on to maintain their well-being amid urban sprawl. 2. Fiscal Waste (The Road Maintenance Backlog): The U.S. Forest Service currently faces a multi-billion-dollar backlog in maintaining its existing public road network. Rescinding the rule to allow new commercial timber roads will severely exacerbate this deficit. According to the findings of the USDA’s own Draft Environmental Impact Statement (DEIS), repealing the rule will inherently inflate federal road maintenance costs while yielding little to no fiscal return. Spending taxpayer dollars to build new infrastructure when the agency cannot afford to maintain its current assets is a blatant waste of public funds. 3. Analytical Fraud (The Deceptive Wildfire Rationale): Deputy Secretary Vaden’s primary assertion that restrictions "exacerbate rising wildfire risk" is an arbitrary and unsupported narrative. The 2001 Roadless Rule already permits active fuel reduction and thin-burning management without building permanent roads. Furthermore, peer-reviewed fire science consistently demonstrates that roughly 90% of wildfires originate within a half-mile of a road. By introducing new roads into the backcountry, the USDA is actively increasing human-caused wildfire risks to nearby communities—the exact opposite of the rule's stated intent. Presenting a policy as a "wildfire solution" when agency data demonstrates it increases long-term risk and spending is a fraudulent manipulation of the NEPA process. 4. Abuse of Discretion (Disregarding Downstream Economic Damages): The DEIS admits that rescinding the rule will cause widespread environmental and economic harm. Over 25 million Americans rely on intact roadless watersheds for clean municipal drinking water. Commercial logging and subsequent road erosion will drastically increase sedimentation and turbidity. This will shift massive capital costs for advanced water treatment onto downstream local governments and taxpayers. Ignoring these quantified downstream economic liabilities to benefit private commercial extraction constitutes an abuse of the agency's public land mandate. Conclusion: Because the proposal relies on arbitrary claims that fly in the face of the USDA's own cost-benefit analysis and DEIS data, the agency must select the No Action Alternative (Alternative 1) and keep the 2001 Roadless Rule fully intact.

Our summer camp community uses the White Mountain National Forest for recreation and camping. We have often pondered how great this wilderness would be without the Kancamagus Highway and Route 302 dissecting it. Keeping large forest tracks standing is one of the key ways to counter climate change and keep our planet healthy. Allowing roads through our wilderness and further logging is an immense step backwards, both environmentally and economically. Let’s look at the big picture and do the right thing.

I have had the privilege of living very near to several IRA's in the last 6 years. I fundamentally oppose the recission of the roadless rule, and I believe it is not based in logic, science, or the law. The roadless rule should not be repealed and should remain as it has been. I went to college in Southwest Virginia and spent as many weekends as I could hiking, camping, and stargazing at Brush Mountain IRA and Brush Mountain East IRA in the Jefferson National Forest. During deer hunting season I volunteered with the Virginia Department of Wildlife Resources to test deer harvested for chronic wasting disease. A few Saturdays during the season we tested deer from various parking lots throughout Montgomery county. Many of those hunters hunted in the National Forest, and many on Brush Mountain. Kids harvested their first does in this IRA and families bonded hiking to tree stands in the Forest they had been hunting for decades. Brush Mountain and Brush Mountain East is a sacred place to everyone who has spent any time in Craig, Roanoke, and Montgomery county. Whether just passing through on a hike, spending four years of weekends there while in college nearby, or living there for generations, the IRA designation of Brush Mountain protects it as a sacred place. In 2021 I had the opportunity to camp host at a camground at the base of Mount Timpanogos. Growing up in the dense green forests of Appalachia, the wide-open Utah landscape kept me in awe every day. I spent every spare moment exploring the area, spending extra time hiking in the Unita IRAs and Wasatch-Cache Utah IRA. I spent a lot of time off-roading in rock crawlers, hauling my camper around to dispersed camp sites, and mountain biking all over Utah, but the time I spent hiking in the IRA is by far the most memorable. The Forest Service is already incapable of maintaining the roads that it has already built. Opening up acreage to build more roads when the ones that exist are not well maintained is illogical. As a lover of motorized recreation, never once have I thought, I wish there were more roads in the national forest. As a hiker and lover of intact wilderness for their ecological and environmental benefits, I am grateful every day for IRAs and the value they provide to big and small game species, the ecosystem overall, and for the peace and tranquility they offer to everyone who visits. The science shows that intact wilderness, like IRAs, are better for the ecosystem, for more productive environmental services, like water filtration and carbon sequestration, and in more cases than not, more resistant to fire when properly managed under the already existing rules and regulations under the roadless rule. It goes against all valid science to say that repealing the roadless rule will have any scientific, environmental, or ecological benefit. Finally, but maybe most importantly, the proposed recission of the roadless rule is illegal. The draft EIS is deficient in every way, arbitrary and capricious, and lacks any valid alternatives analysis. I am finishing my final semester of law school and have spent the last two years reading nearly every past and present NEPA, NFMA, and APA case. I have been a part of a team that has filed two lawsuits to stop the USFS from continuing on with two logging projects in the White Mountain National Forest. In my time working on these suits I have read some well-done Environmental Assessments and Environmental Impact Statements. I know what a well-done, comprehensive, and legally sound NEPA process looks like, and this roadless rule recission process is the furthest thing from well-done, comprehensive, or legally sound.

I frequent New York States Adirondack Park where I hike and backcountry ski. This is a place where I can get away from the everyday stress of work and suburban living. To be able to recreate in remote areas where there is no sign of human development is special. I look at that park as a treasure that I hope stays for many future generations. Now, this is a state protected park but the same preservation principles applies to federal parks that people,enjoy every day. Parks like New Hampshires White Mountain National Forest which I also occasionally visit. Once developed, it becomes very hard to erase human traces. I feel its extremely important to protect the parks we have established as the world around them continues to get busier. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

I support the Roadless Rule and urge decision makers to keep this safeguard in place to help protect public lands around the country. I live in Maine and I feel lucky to be so close to the the White Mountain National Forest; it is one of my favorite places to visit, recharge, and spend time in nature. Of all the special natural areas that the Roadless Rule protects, the Wild River is one I am most connected to. The Wild River flows seventeen miles through Evans Notch, bringing water from the mountains into to the Androscoggin River. In the spring, the Wild River swells with snowmelt; white water kayakers love to paddle in these strong, cold, and clean waters. My husband and many members of our community drag their boats upriver beyond the gate to kayak downstream. In the summer, the water level of the Wild River drops and round, beautiful stones emerge. Along the river, there are pockets of deeper water that are perfect for swimming on a hot day. Within the river, there are native brook trout that thrive in these waters. I have caught and released one of these special fish when fly fishing. In the fall, the forest around the Wild River bursts with color. I have laced up my hiking boots, packed my tent in my backpack, and hiked along the Wild River to make camp at a backcountry camp site. I have poured the Wild River into my water filter and enjoyed a cool, refreshing drink. In the winter, the world around the Wild River becomes frozen - yet the waters still flow. I have slid beside the Wild River on cross country skis, hearing the water pulse beneath the ice. In every season, I support the Roadless Rule.

I am writing to express my strong opposition to the proposal to fully and partially rescind the Roadless Area Conservation Rule. I urge the U.S. Forest Service to maintain existing protections and select the Alternative 1, No Action. Shifting management to a piecemeal, forest-by-forest process risks fragmenting vital ecosystems and opening irreplaceable backcountry to industrial road construction and commercial logging. My opposition is deeply rooted in a lifetime of recreating in our national parks and public lands. Living near the White Mountain National Forest in New Hampshire, I see firsthand the profound ecological, economic, and recreational value that intact, roadless landscapes provide to local communities and regional watersheds. Just this week our forests are drawing in many tourists during peak foliage season, allowing local businesses to thrive. As a biologist and homeowner, I understand and appreciate how vital these areas are to fire management; soil, air and water quality; and biodiversity. Furthermore, my time spent on our national scenic trails—including life-changing experiences on both the Pacific Crest Trail (PCT) and the Appalachian Trail (AT)—fully shaped my understanding of why large, continuous wild spaces must be preserved. These trails and the roadless areas they traverse are national treasures that offer unmatched opportunities for solitude, personal growth, and outdoor recreation. To me, our remaining roadless national forests and the recreation opportunities within them are among the most precious and defining features of our country. The 2001 Roadless Rule has successfully protected clean drinking water, critical wildlife habitats, and carbon-storing forests for twenty-five years. Dismantling this rule would permanently degrade the wild character of these lands and harm ecosystems and future generations of hikers, backpackers, and outdoor enthusiasts. Please protect the integrity of our public lands, uphold the 2001 Roadless Rule, and select the No Action Alternative. Thank you for considering my comments.

To the US Forest Service and the Department of Agriculture, I strongly object to any and all efforts to rescind the Roadless Rule and/or to remove any national forests from the protection that the Roadless Rule provides. Not only are these efforts spectacularly irresponsible and short-sighted, but they are neither in the public interest nor morally acceptable. I see the trees changing colors in the White Mountain National Forest of New Hampshire and my heart sings. Surely, our nation can afford to leave these remaining wilderness areas as God and Nature created them. Katrin Rouner North Sandwich, New Hampshire

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The protected areas of the White Mountains are my literal home and my spiritual home as well as being tightly tied with my state’s ability to survive economically. I oppose the rescission of the 2001 Roadless Area Conservation Rule and ask that this comment be entered into the record of Docket FS-2025-0001. I live in the White Mountains region of New Hampshire and regularly go out into the woods for a hike or camping trip. The Carr Mountain area, at 17,110 acres in the White Mountain National Forest, is one of the few places beginner backpackers can go to learn outdoor skills, an important American legacy. The Carr Mountain area houses wetland and habitat that would be destroyed by logging, flooding a region's water system with difficult to remove pollutants. The Sandwich Range, at 16,797 acres, is one of the most popular areas for people to visit. It has an intrinsic beauty and sheds water directly into the lakes region of the state, one of the main tourist attractions in New Hampshire. These places have already seen a history of ecological damage that ruined the economy's long-term health. That history is not abstract. The Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut. We are being asked to forget that lesson. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are the headwaters for rivers that flow to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. Across the Eastern region, 286 municipal water intakes sit in watersheds containing affected roadless areas. Logging in Carr Mountain and the Sandwich Range does not stay in those units. It enters the water. I ask the agency to explain how it will protect those 286 intakes and the downstream communities that depend on them if this rule is rescinded. 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." Building new roads that the agency has yet to prove it can maintain, in order to facilitate logging that yields fractions of a percent of national production, makes no sense. It would also decimate the thriving outdoor economy that New Hampshire enjoys, tanking our viability as a state. 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 a $6.9 billion maintenance backlog. The agency also claims the rule imposes permitting and administrative burdens that justify rescission. But the rule as written states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." The rule already accommodates the situations the agency says require relief. The agency must identify which specific burdens are not already addressed by these existing exceptions and quantify those burdens in this proceeding. 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. I have organized my life around these protected areas. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Molly McCahan Plymouth, NH

I am writing in strong opposition to repealing the roadless rule act. This proposal would negatively impact 58.2 million acres of national forest land that is an integral part of our country. I grew up less than 3 miles from the White Mountain National Forest which over 235,000 acres could be affected. Growing up so close to the WMNF I was able to have a childhood filled with positive experiences in the vast wilderness. One of them being a club in high school where I had teachers who brought us reading, writing, and hiking through the White Mountains. Repealing the roadless rule act could be the reason our future generations don’t have that opportunity. Not only would repealing the roadless rule act negatively impact our ability to have access to public land to recreate, but over 60 million people rely on national forest land for drinking water. If we don’t have forests that are intact and managed properly people would lose drinking water. Not only do intact forests give people access to clean drinking water but it also creates crucial habitat for many animals including salmon, trout, elk and many other animals. The national forest service currently also has over 8.5 billion dollars of maintenance backlog, if they repeal and start adding to the roads it could cause even more fiscal stress. The forest service should not take any action on repealing the roadless rule act. Keep our forests protected.

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I grew up living next to the White Mountain National Forest and consider myself so lucky to have had that access to nature and places to explore that are beyond beautiful. I can’t imagine having these places destroyed and not left as is for those that come behind us. This would disrupt and be so harmful to wildlife who need this room to survive and are a vital part of our ecosystem. It would also ruin the economy that these remote places rely on for people recreating. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a mistake. Again I oppose the proposal to rescind or alter the Roadless Rule, and support “Alternative 1, the No Action alternative.”

My home is 2.9 miles from White Mountain National Forest, and an Inventoried Roadless Area in the Sandwich Notch area. My wife, my sons (1 and 4), and our extended family explore this area on a weekly basis - sometimes daily. It is extremely special to us, and maintaining it in its current character is extremely important to us. The repeal of the roadless rule is an action without a need - roads cannot be undone (there are still abandoned roads from 200 years old that run all over our forest lands in New Hampshire). Fire prevention is not needed in our region, and nationwide the data seems to indicate that the overwhelming percentage of fires are caused by people close to roads. Fewer roads, fewer fires. Regardless, the places my family and I are building our memories rely on wild places, and repealing the Roadless Rule directly threatens our enjoyment of this lands. Further, as a licensed outdoor guide, my work and livelihood is directly threatened in New Hampshire and nationwide by any reduction in wild lands. I am submitted photos with my 1 year old son close to our home, overlooking one of the IRAs. Please, strengthen the Roadless Rule, rather than eliminating it.

Dear Chief: I was lucky enough to be introduced to the forests and wild places in this country before I was even a year old. My parents made sure I understood the value of roadless public land, and that value is something that needs to remain for generations to come. I make it a point to travel to the White Mountain National Forest at least once a year. No matter where else I go in the country, or the world, the White Mountains are the place I'm always drawn back to. The abundance in the forest is unparalleled, and there are so many lessons to be learned there. It's where I go to find peace, to get away from the stressors of daily life, to breathe fresh air and drink the cleanest water, to see sights that can't be matched. Last week I was in the White Mountains for my annual camping trip, and there was a day where we spent over ten hours in the woods. We didn't see another person, or hear a single car. The only sounds we heard were from nature - the rushing water of the brook, the Gray Jays chirping in the trees, the wind blowing through the leaves just hitting their peak autumn colors. For someone who lives in a crowded suburb, being able to get away and immerse myself in the woods, away from roads, is essential. If this rule is rescinded, I (and so many others) will lose my favorite place in the world. Seeing roads rip across the forests, the clear waters polluted, the animals killed or pushed out of their homes, the invasive plants taking over the abundant native forests, would be absolutely devastating. I would not be able to go back to the area because it would be ruined. That means no more hiking, no more camping, no more fly fishing, no more photography. Roads would eradicate what makes this place special. Regarding the Presidential - Dry River Ext in the White Mountain National Forest, New Hampshire: Invasive Species Establishment and Spread via Disturbed Road Corridor — Road construction creates a linear disturbance corridor of exposed soil, compacted ground, and altered hydrology—ideal conditions for invasive plants and forest pests to establish and spread into the interior. The documented threats of hemlock woolly adelgid and emerald ash borer, combined with terrestrial invasive species currently limited to hiking trails, would gain a high-speed dispersal pathway along the road. Eastern hemlock (near threatened, IUCN) and white ash (critically endangered, IUCN)—both present in this area—are particularly vulnerable to these pests; a road would accelerate their decline and eliminate the genetic diversity and structural complexity these species currently provide to the forest. Rare alpine plants like New England blazing star and white bog orchid, adapted to specific soil and hydrological conditions, would be outcompeted by invasive species that thrive in disturbed, nutrient-enriched road margins. When road construction degrades fishing quality in the Presidential - Dry River Ext IRA, the economic losses are direct and measurable. Visitors who chose this area for its roadless character take their spending elsewhere. Guide and outfitter operations that depend on backcountry conditions lose clients. Local businesses that serve fishing visitors lose revenue. These losses are a quantifiable cost of road construction that the agency must account for. The DEIS must calculate the dollar value of fishing-related economic activity in and around the Presidential - Dry River Ext IRA, White Mountain National Forest, and project the losses road construction causes. This includes direct visitor spending, supported employment in guide and outfitter services, and multiplier effects in the local economy. These figures are quantifiable, and the agency is obligated to quantify them. "In a systematic review of 274 articles on the effects of non-consumptive recreation on animals, over 93% of reviewed articles documented at least one effect of recreation on animals, the majority of which (59%) were classified as negative effects. Recreation is a leading factor in endangerment of plant and animal species on United States federal lands and is listed as a threat to 188 at-risk bird species globally. Motorized activities often cover larger spatial extents than non-motorized activities, and motorized vehicles can also cause soil loss and vegetation disturbance." — PLOS ONE, 2016 Keep the Rule. Reject the rescission. That's my comment. In earnest, CommentID: RLC-20261007-2I0OUI

To whom it may concern: I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Dr. Amber Rock and I am a biologist who lives in Boston, MA. I am an avid recreator and have enjoyed camping, hiking, backpacking, and fishing on public lands since I was a child in southern California. Locally, I find time to to hike in the the Pemigewasset (32,255 acres) and Sandwich Range (16,797 acres) in White Mountain National Forest, New Hampshire in all four seasons. This summer I also had the privilege of hiking the Pacific Crest Trail, 231 miles of which go through 71 roadless areas across California, Oregon, and Washington. Our pristine wilderness in the crown jewel of America and rescinding the Roadless Area Conservation Rule in any capacity would be a grave mistake ecologically and financially; we owe it to ourselves to keep the wilderness wild for generations to come. While hiking the PCT, I had to miss parts of the trail due to fire and smoke. The proposal justifies rescission in part on the ground that new road access is needed for management. But the agency's own document states that "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 we cannot maintain the roads we already have, and if those roads themselves drive fire ignition at the rate the agency has documented, the case for opening roadless areas to new construction does not hold. I have seen countless unmaintained FS roads, strewn with blown down trees, potholes, and rockfall, barely passable for a walker, let alone vehicles. I ask that the agency explain why this proposal departs from its own prior findings and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. After walking hundreds of miles of burn scars, I know first hand how a single fire can devastate an ecosystem for decades to come. The agency also argues administrative burden and permitting friction as grounds for rescission. The rule's own text, as the agency acknowledges, states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Those exceptions are broad. Which specific burdens are not already addressed by them? I ask that the agency identify those burdens by name and quantify them on the record, rather than asserting that the rule as written forecloses management it does not foreclose. The White Mountain's 16 inventoried roadless areas total 240,669 acres and are headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, drinking water for communities across New Hampshire, Vermont, and Massachusetts. 286 municipal water intakes sit in watersheds containing affected roadless areas. The DEIS states that "skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and 'can contribute up to 90 percent of the sediment generated by timber sale activity.'" That number is documented and then, in the agency's own analysis, set aside without a projection of what it means downstream. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas before any final action is taken. The drinking water question does not stop there. The agency's own record states that "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." The DEIS then asserts that forest plans address sources of public drinking water without identifying a single enforceable provision equivalent to what 36 CFR 294.12 and 294.13 currently provide. Brook trout, moose, Canada lynx, Bicknell's thrush, the northern long-eared bat: species that depend on the clean, cold, undisturbed water these roadless areas produce in New Hampshire and across the system. I ask that the agency identify, forest by forest, which plan provisions would replace those protections for municipal watersheds. The Weeks Act of 1911 was passed specifically because of what happened when New England's mountains were clearcut. We built a federal land protection system from that lesson. Rescinding the Roadless Rule repeats the mistake the Weeks Act was meant to correct. The agency should say plainly why that history does not apply here. I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative. Sincerely, Amber Rock, PhD Boston, MA

My name is Ryan Williams, and I am a conservation biologist from Massachusetts. As a lifelong New Englander, I cherish what little public land we have in the northeast. Our landscape was rapidly deforested in the centuries following European settlement and it has taken generations for our forests to rebound. Inventoried Roadless Areas (IRA) protected by the 2001 Roadless Area Conservation Rule are some of the few remaining wildlands left in the northeast. I vehemently oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. It would be an environmentally and socially irresponsible act to needlessly log some of our few remaining public wildlands. Therefore, I am writing in support of "Alternative 1", the "no action alternative", which would maintain the 2001 Roadless Rule. Roadless Areas are a bastion of biodiversity, providing critical habitat for innumerable wildlife species. A recent study found that 308 of 537 species of conservation concern in the United States have habitat contained within our Inventoried Roadless Areas (Dietz et al., 2021). What measures will the Forest Service take to minimize impacts to biodiversity associated with the proposed action? Wide-ranging species, like the federally threatened Canada lynx, require large core habitat areas connected by corridors throughout the landscape. Many of the existing large forest blocks required by these species are comprised of Inventoried Roadless Areas. A study by Forest Service researchers found that maintaining unfragmented forested corridors from source populations in Canada with lynx habitat in their southern range periphery is critical (Squires et al., 2013). This study was focused on lynx populations in the Northern Rockies. However, in the northeast we have our own population of this threatened species. How does the proposed action by the Forest Service account for any impacts to the Canada lynx specifically in northeastern states? Will the proposed action impact lynx recolonization into previously occupied habitat in northeastern states? Inventoried Roadless Areas provide countless opportunities for passive wildland recreation. In my own “backyard”, the Forest Service recognizes 25,000 acres of IRA’s in the Green Mountain National Forest (Vermont) and 241,000 acres in the White Mountain National Forest (New Hampshire and Maine) that fall under the protection of the Roadless Rule. This is over 20% of the national forest in New England. Many of these areas contain some of the region’s most popular hiking trails and access to iconic mountains and ridgelines. Areas that local hikers hold sacred include Franconia Ridge (Pemigewasset IRA), the Presidential Range (Presidential-Dry River Ext IRA), and the extensive trail network maintained by the Randolph Mountain Club in the northern Presidentials (Great Gulf Ext IRA). How will the proposed action impact trail use in these IRA's? How will potential road building and logging projects in these areas impact their scenic and recreational values? One of the main justifications for the proposed action is the reduction of wildfire risk. However, this proposal would do little to prevent national forests from burning. A recent study found that the density of wildfire ignitions increased as distance from roads decreased. That is, there were more fires started on and near roads than within intact forests. Furthermore, wildfire ignition density was lowest in Wilderness and Roadless Areas (Aplet et al., 2026). How might the proposed action increase the risk of wildfire ignition due to an increase in roads on our national forest lands? Is there any research in northeastern forests showing that more road building and logging would successfully prevent wildfires? For the reasons above, I strongly oppose the proposal to fully or partially rescind the Roadless Rule.