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Dear Secretary Rollins, I am writing to oppose the proposed full or partial rescission of the Roadless Area Conservation Rule. My name is Woody Jackson, President, Friends of the Breitenbush Cascades (FBC). FBC was established in 1988. FBC advocates before the United States Forest Service on behalf of our constituents and operates at the intersection of conservation and recreation. Today, FBC submits public comment objecting to any alteration of the Roadless Rule. I reside in the North Santiam Canyon downstream of our organization’s primary area of interest in the Breitenbush Basin. I, along with over 200,000 Oregonians downstream, rely on the delivery and production of cold, clean water within the North Santiam Basin and Breitenbush Sub-Basin. We are concerned that any modification to the roadless rule would adversely affect the Oregon Department of Fish and Wildlife’s State Wildlife Plan. Our focus area is the Breitenbush Basin within the Detroit Ranger District of the Willamette National Forest. Alterations to the rule would compromise the plan’s objective of maintaining wildlife connectivity among the Mount Jefferson, Opal Creek, and Bull of the Woods Wildernesses. The Breitenbush Basin encompasses approximately 77,000 acres; currently, only 19,000 roadless acres are contiguous with these wilderness areas, leaving roughly 57,000 acres designated as Matrix Lands and Late Successional and Riparian Reserves. Following the 2020 Oregon wildfires, a substantial portion of the remaining wildlife connectivity and refugia were significantly impacted. Preserving the roadless areas within the Breitenbush Basin remains essential to ecological recovery. Nationally, eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. In the Breitenbush basin, rescission would be counterproductive to improving habitat for Spring Coho Salmon. The Breitenbush watershed contains an extensive network of headwaters, seeps, and both thermal and cold springs; additional road construction would jeopardize recovery efforts for spring chinook salmon and accelerate amphibian population declines. The DEIS states, “…inventoried roadless areas typically have good water quality due to limited disturbance,” and “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” There is significant concern that the Detroit Ranger District of the Willamette National Forest lacks the capacity to maintain its current road system and must continue decommissioning roads that frequently contribute to sedimentation and culvert failure. Given the anticipated absence of near- or long-term increases in agency funding and staffing, any revision of the roadless rule would be both risky and ill-advised. What does Friends of the Breitenbush Cascades recommend instead of any alterations in the Roadless Conservation Plan? 1)Continue the conservation efforts to restore anadromous fish runs, such as the upcoming North Breitenbush River Stage 0 Floodplain Restoration, and increase conservation planning for the Beaver Emphasis Area in the Breitenbush Basin as a necessity of climate resilience. 2) Additional decommissioning of roads that have proven to exacerbate sedimentation and culvert failure. 3) Improve federal tribal consultations and leverage Traditional Ecological Knowledge, including cultural burning, replacing today’s proscribed fires. Friends of the Breitenbush Cascades supports Alternative 1, the No Action alternative. Thank you, Woody Jackson President, Friends of the Breitenbush Cascades

Dear Secretary Rollins, I strongly oppose the USDA’s proposal to eliminate or weaken the Roadless Rule. I'm an Oregonian and frequently spend time hiking, backpacking, hunting, and exploring many of the Roadless areas in Oregon, Washington and throughout the West. Repealing or weakening the Roadless Rule is reckless and unnecessary. It will waste taxpayer resources, devastate public lands, and degrade watersheds (and our clean drinking water), disrupt wildlife areas, and destroy fragile and intact ecosystems. Just last month I went on an annual backpacking trip with my two sons and my sister to Bobby Lake in the Maiden Peak roadless area in the Deschutes National Forest. This was one of the few areas in Oregon last summer (2026) not impacted by wildfires. There were so many folks out enjoying many of the backcountry campsites - adventuring into the wilderness to experience a weekend without the noise and pollution of vehicles, to fish in the lake, to enjoy being "out in nature". This is not the same experience with a road running through it. The Deschutes National Forest, and the Willamette National Forest it borders, are unique and special recreation areas that folks from all over the US come to enjoy. We should be doing more to protect these areas, not stripping them of the few protections they currently have. A few days ago, I took friends visiting the coast to explore the Oregon Sand Dunes near Tahkenitch Creek in the Siuslaw National Forest-- another area currently protected by the Roadless Rule. We love this area because of the miles of contiguous sand dunes-specifically because there are not roads running through the Dunes. This fall, I will go elk hunting with neighbors in another Roadless Area in the Siuslaw, near Drift Creek. This area is great for hunting in part because there are not roads cutting through it, which limits traffic, vehicle noise, and human access. Wildlife, Elk included, avoid roads, vehicle noise, and human noise. Wildlife rely on these contiguous wilderness/forested regions--these are places they can live and thrive without constant threat of human impact. These are also areas that hunters in our region rely on to be able to fill tags each year. Again, this is a place we should be doing more, not less to protect our forests. We should keep the roadless rule intact Roadless forests include some of the most resilient ecosystems in our country. They filter and store clean drinking water, provide refuge for vulnerable species, and serve as carbon sinks mitigating the worst impacts of climate change. Americans love these forests: we hike, hunt, forage,fish, camp, ski, climb, and find solace in these remote places. Roads spread invasive species, fragment wildlife habitat, and destroy ecosystems. More roads in the backcountry also lead to more fires: research shows wildfires are more likely to ignite near roads--most fires are caused by humans. More access leads to more fires started. Once roads and clearcuts fragment these landscapes, the damage is permanent. Weakening or repealing the Roadless Rule is a mistake. I strongly oppose any actions that weaken the Roadless Rule. Please abandon this misguided effort and instead strengthen America's commitment to protecting our forests for the clean water, climate resilience, recreation, and biodiversity they provide. Leave the Roadless Rule in place. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026) https://doi.org/10.1186/s42408-026-00450-2 Mildrexler, D.J., Berner, L.T., Law, B.E. & Both, M.S. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation 321, 111950 (2026) https://doi.org/10.1016/j.biocon.2026.111950

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

I oppose the proposal to rescind or alter the Roadless Rule, and I support Alternative 1, the No Action alternative. I write this comment as an Oregonian. My home state has 211 roadless areas encompassing 1.9 million acres. I regularly recreate in and near roadless areas on the Deschutes National Forest. My spouse and I paddle our kayaks on lakes that are bounded by or sit within roadless areas, including Elk Lake, Hosmer Lake, Sparks Lake, and Little Lava Lake. We also enjoy visiting roadless areas across the state. Wildflower hikes near Iron Mountain on the Willamette National Forest and visits to Drift Creek roadless area on the Siuslaw National Forest are cherished experiences. Rescinding the Roadless Rule may well destroy the unparalleled plant diversity of Iron Mountain and Cone Peak. It would certainly affect the bird watching on the Cascade Lakes. In addition to affecting my personal enjoyment of my local forest, this would decimate the tourism economy in Central Oregon. As many Oregonians will tell anyone who will listen, we greatly value our quiet outdoor experiences. Many of us, myself included, have a need to recreate without having to listen to noisy vehicles or the sort of loud and inconsiderate people who only go where they can drive. People need places they can go, under their own power, that are quiet and remote—areas that promote solitary enjoyment of nature. I’m very concerned that the proposal to rescind the Roadless Rule has been made without due consideration of the impact of climate change as well as the repercussions on the climate. So much of Oregon has burned in the last 10 years, in part because of changes in the climate, that more people (i.e. Oregonians who need their solitude in untrammeled natural surroundings) are recreating in a decreased area. Opening up roadless areas would further degrade the remaining back-country areas by making them vulnerable to potential development. In addition, destruction of old-growth temperate rainforests and sub-alpine forests would release massive amounts of currently sequestered carbon, thus accelerating global temperature rises and increasing drought. This in turn would lead to more intense wildfires. The result is a destructive cycle that worsens the climate catastrophe worldwide, with negative impacts on recreation and natural splendor, degradation of water quality for humans and habitat for many protected species. This also means that communities like mine in Central Oregon will be increasingly threatened with total destruction by wildfire. Not everyone living on or near the urban/wildland divide can afford to fire-harden their residences. In fact, many can only afford to rent, and landlords are not investing in hardening rental properties against wildfires. That leaves belongings at risk when evacuations happen. The average American cannot pay for private fire protection services in the case of threat by wildfire. The increasing frequency of evacuations in these communities greatly impacts work availability and ranchers’ ability to care for livestock. Evacuations are becoming much more frequent, and they use up vast amounts of financial resources and time that working Americans do not have to spare. Proponents of rescinding the Roadless Rule have argued that they are motivated to improve wildfire management. They argue that roadless areas hinder firefighting efforts. This argument is specious and disingenuous. Roadless areas are much less likely to start burning in the first place. Analysis shows that areas with roads have increased instances of fire starts compared to roadless areas. The vast majority of fires are human-caused. Furthermore, if they were serious about limiting wildfires, they would realize that the increased timber harvests that would undoubtedly follow the opening of roadless areas will release currently sequestered carbon, which in turn would worsen climate change and promote more frequent and more intense fires. My drinking water comes from a watershed in an inventoried Roadless Area. Opening the area to roads would threaten the quality and safety of my drinking water. Please do what is right for Americans and do not fully or partially rescind the Roadless Rule under Alternatives 2 and 3 of the draft EIS. I oppose the proposal to rescind or alter the Roadless Rule, and I support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Willamette National Forest is where I go to escape, explore, and enjoy the outdoors. That forest, and the roadless areas within it, also feeds the watershed that supplies drinking water directly to Salem, Oregon's capital city, through the Santiam River. Protecting those roadless areas is not an abstract conservation preference. It is imperative that we protect them in order to protect the fresh water they provide our community. I oppose rescission of the 2001 Roadless Area Conservation Rule and ask the agency to respond to the specific points below. The agency's own analysis of fire risk undermines the central rationale offered for this proposal. The record states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The proposal nonetheless justifies rescission partly on wildfire and fuels management grounds. The agency must explain why this proposal departs from those prior findings, and it must reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is equally unsupported by the agency's own numbers. The record acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service while booking recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million. The agency is also proposing to expand a road system that already carries a $6.9 billion maintenance backlog. How does an action whose own Cost Benefit Analysis cannot establish a net benefit justify that expansion? The agency must reconcile those figures before this proposal can move forward. Finally, the agency has invited comment on reliance interests and then built no mechanism to weigh them. 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. Under established administrative law, an agency changing course must identify and assess the reliance interests its prior policy created. My use of the Willamette National Forest, and my community's dependence on the watershed protections the current rule helps secure, represent exactly such an interest. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. Sincerely, Stacey Kline Salem, Oregon

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. My name is Maeve, I am a current graduate student studying natural resource management at Oregon State University in Corvallis Oregon. I work in a research forest in the Willamette National Forest (WNF), which is located near several roadless areas that would be impacted by the rescinding of the Roadless Area Conservation Rule, namely Gordon Meadows in the Willamette NF. I research water quality impacts by fire in the WNF, and travel on old logging roads/USFS roads frequently for my work. I have seen firsthand what road failure does to the hydrology of these forests, and how roads interrupt the hydrology of slopes, bleeding sediment into streams that negatively impacts water quality (Jones & Grant, 1996). I support wilderness areas without road access because they provide true wilderness habitat for the benefit of the American people, as well as habitat for native species. Roads introduce many changes and alterations to wilderness. One is that roads increase ignition points in forests: 90% of fires in the US (1986-1996) of any cause started less than 1/2 of a mile from a road (Roads and Wildfires, Morrison, 2014). In that same report, it was noted that less than 3% of all fires started more than a mile from a road - wilderness areas are buffers for fire ignitions. Increased logging from more roads poses more risk than benefit - the real threat of more logging is losing the services that wilderness areas with old growth forests provide. These areas support the production of clean water to millions of Americans, as well as sequester carbon to keep our atmosphere healthy and reduce the greenhouse effect. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft Environmental Impact Statement would be a grave mistake. I am asking the Forest Service to oppose the proposal to partially or fully rescind the Roadless Area Conservation Rule for the sake and benefit of the American People. I ask that you support Alternative 1, the No Action alternative.

The roadless rule protects public land around the country and conserves the unique habitats of the United States. I personally utilize many inventoried roadless areas in various states. They bring immense value to the citizens of this nation whether camping, hiking, hunting, fishing, or just looking at the natural environments around us. From my mule deer hunts in the Humboldt-Toiyabe National Forest to hiking in the Willamette National Forest, I have experienced places that IRAs protect and they keep America beautiful. Keep our roadless areas wild, productive, and accessible. Take the No Action Alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Please Do Not Rescind the 2001 Roadless Rule, As a native Oregonian, I grew up hiking and backpacking in our National Forests. My parents shared their love of the outdoors with me and my five siblings, and they taught us to leave those places as untouched as possible so that the people after us would enjoy the same benefits we did. Mt. Hood National Forest, our closest, is where my husband and I took our children hiking when they were young. Their first backpacking trip, at ages 8 and 13, was to Mt. Jefferson in the Deschutes National Forest. Now grown up, they also spend their spare weekends hiking and backpacking in national forests. We have hiked and backpacked in many special places: Waldo Lake in the Willamette National Forest, the Snake River in the Wallowas, Mt. Bachelor in the Deschutes, Glacier Mountain in the Malheur, and the Salmon-Huckleberry area near Mt. Hood. In Washington and California, places like Gifford Pinchot, Silver Star Mountain, Eagle in Shasta and the North Cascades near Mt. Baker are part of the same interconnected network. Together, these roadless areas protect our watersheds, wildlife habitat, and old-growth forests, and their value comes from being connected. Once roads are built, there is no going back. Roads fragment wildlife habitat, increase erosion and sediment in streams that salmon depend on, spread invasive species, and raise wildfire risk and long-term maintenance costs for taxpayers. The Forest Service already cannot afford to maintain the roads it has. These are special places that we need to save for our children and our children's children. We owe it to the next generations to keep them safe. The original 2001 Roadless Area Conservation Policy received more than 1.6 million public comments, which was the largest number for any rule in U.S. history at the time. Any changes to it deserves the same consideration and public involvement. Please do not rescind the Roadless Rule. Sincerely, Grace Jeffreys Portland Oregon

We already have plenty lands devoted to timber-production, riddled with roads, many not properly maintained, and continuously leaching sediment and pollutants into vital watersheds and fisheries. Let’s not allow such short-sighted plans to liquidate these remaining wild road-less places in the guise of ‘sustainable’ jobs or wood supplies. Nor buy-into the unsupported claims that more roads will help reduce wildfires. Select the NO Action Alternative: Retain the Roadless Conservation Rule of 2001, with no exceptions. We really shot ourselves in the foot during the rampant unsustainable levels of timber harvest in the past decades- in the 1970s and 1980s -we were shipping every 5th old log overseas. Foreign countries got ‘sweet heart deals’ liquidating the Tongass National Forest, or Olympic, Deschutes, Umpqua, Gifford-Pinchot, Colville or Willamette National Forest, to name a few, just in this region of the U.S. We need to keep this late-landing, sensible conservation measure of the Roadless Conservation Rule 2001, in place now more than ever, with the increasing climate changes. Roads in the Roadless Areas are a long-term cost we simply cannot afford. In terms of destroying what remains of un-carved wildlife habitat, reducing the carbon-storing effect of our forestland, the cost is just too big. Decades of studies have shown that road-building introduces invasive plants and pests, reduces forest resilience, degrades water quality, destroys fisheries habitat, requires ongoing maintenance, and increases fire-risk. Beyond the economic folly, the environmental consequences are severe. Roadless forests represent some of the most intact, resilient ecosystems left in our country. They filter and store clean water, provide refuge for vulnerable species, and are some of the last remaining connectivity of wildlife corridors. Once roads and clearcuts fragment these landscapes, the damage is permanent. More roads in the backcountry also mean more fires: research shows wildfires are four times more likely to ignite near roads. Fighting those fires in remote areas is dangerous, costly, and diverts resources from protecting communities. Roads also spread invasive species, fragment wildlife habitat, and erode the very ecological resilience we need in the face of a warming climate. The Roadless Rule already includes exceptions for emergencies such as wildfire, and rescinding the Roadless Rule for the stated purpose is unnecessary and dangerous. Equally troubling is the USDA’s decision to pursue this rollback through an abridged and inadequate public comment process. The original Roadless Rule was created after the most extensive public engagement process in the history of federal rulemaking, with over 95% of commenters supporting strong protections. During 2025's comment period on the Notice of Intent, over 600,000 Americans submitted public comments, with over 99% of comments opposing the proposed rescission of the rule. Now, the agency is attempting to dismantle these protections through a rushed process that limits and ignores input from citizens, scientists, Tribes, and local communities. This is undemocratic and deeply irresponsible for decisions of such sweeping consequence. For more than two decades, the Roadless Rule has been a cornerstone of sound forest management, balancing ecological, economic, and cultural values. Weakening or repealing it would be a grave mistake. Both Alternatives 2 and 3 will have severe consequences for wildlife, biodiversity, clean water sources, climate resilience, cultural resources, local economies, outdoor recreation, and the health of our nation's wildest forests. I urge the USDA to abandon this misguided effort and instead strengthen its commitment to protecting America’s roadless forests. The agency must choose the No Action alternative and maintain full Roadless Rule protections for America's wild forests. Sincerely, Mrs. A Higinbotham OR

My name is Emily Stevenson and I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. At least some of the land protected by this legislation is very close to me in the Willamette National Forest. Of course like much of the Pacific Northwest, this area is beautiful and offers many options for outdoor recreation but it is also hugely important in terms of biodiversity. Protecting these areas is not just about how us humans will feel about it. It is also about how the entire ecosystems in these area depend on and benefit from their protection. It is our job to be stewards of the land. Removing these protections would be the exact opposite of that. It would lead to the destruction of these lands and the living things that call them home. For the reasons listed above, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a grave mistake and I oppose any changes made to the rule.

As a senior taxpayer and director of Progressive Voices, I state our strong opposition to any removal of roadless areas designation. These are valuable public resources whose forests serve as invaluable "carbon sinks" to counter the climate changes our planet is facing. We have enjoyed hiking in local roadless areas such as McGowan Creek old growth grove near Marcola and Eagles Rest. The latter is a wonderful, unfragmented, old-growth backcountry forest located within the Hardesty Mountain Inventoried Roadless Area of the Willamette National Forest. Located roughly 20 miles southeast of Eugene, its dense Douglas-fir canopies provide municipal watershed protection and excellent outdoor recreation options enjoyed by so many citizens who also pay taxes for the benefits of such roadless areas. Because of these reasons and the fact that they are irreplaceable, such roadless areas should be protected with the current law and their forests allowed to remain uncut so that future generations can also benefit from their existence.

To whom it may concern, I grew up recreating within Oregon's Willamette National Forest, which contains critical headwater, wildlife populations and roadless areas that would be negatively impacted by the rollback of the Roadless Rule. I've now been a Wyoming resident for over a decade, where there is 3.2 million acres under Roadless protection. Nationally, nearly half of all National Forest lands are open to industrial activity. Removing protections from the remaining areas will threaten water quality, spread invasive species, increase wildfire risk, undermine tribal interests and cause significant losses in recreation spending. Data supports these findings. Eliminating the Roadless Rule goes against the public interest. It is critical the Roadless Rule remain in place to safeguard habitat and our remaining undeveloped places. Thank you, Nicole Gautier

Roadless Rule Protects Drinking Water for Up to 2 Million People in Oregon By various counts, up to 2 million people in Oregon get their drinking water from federally inventoried roadless areas in municipal watersheds. Cities like Salem, Eugene, Bend, Ashland, Baker City, Lake Oswego, Oregon City, Pendleton, and Portland all rely on roadless areas of forestland to filter and purify their drinking water before it’s treated for consumption. Most of these cities have found ways to legally shelter their watershed from logging or other extraction. Portland’s Bull Run Creek reservoir is a model in municipal watershed protection, and Bend and Salem watersheds are sheltered by protective covenants, although not to the same extent as Portland. Eugene, population 172,000, is unique among Oregon’s largest cities in that so much of the McKenzie River watershed relies on informal partnerships with private landowners and the various REIT’s and TIMO’s that manage industrial forestlands there. The limits of this model have been made apparent, recently, by the discovery that timber heiress Katherine Jones-McCann had constructed a sizeable compound directly adjacent to the McKenzie River without securing county permits. Luckily, most of the Eugene water supply comes from federally Inventoried Roadless Areas in the Willamette National Forest, notably the Hardesty Mountain Roadless Area some 25 miles southeast of the city. The recission of the Roadless Rule, however, could mean that Eugene’s luck has run out. The experience of a several mall Oregon towns with watershed degradation from private lands logging—Rockaway Beach, Wheeler, Yachats and others--portends an uncertain future for Eugene. The problem with recission is that, contrary to popular belief, there are already tens of thousands of miles of road on National Forest Land already. An estimated 370,000 miles of NF Roads already exist. This massive network of national forest roads is already too expensive for the U.S. Forest Service to maintain. Chris Wood, a former USFS senior policy advisor, recently told Outdoor Life that the service can only maintain about 20% of existing roads, with a current maintenance backlog of $10.8 billion. This was among the original considerations when the Roadless Rule was put into effect 25 years ago; there were just too many roads already. Anyone who hikes, forages for mushrooms or hunts on public land in Oregon has seen how often logging roads can erode and even collapse into creek bottoms, inevitably clouding the rivers they feed. The gated roads I hike and forage in Lane County often require new maintenance annually. Shoulders erode every winter, sometimes dangerously. Culverts can be blocked, causing washouts, just as a matter of course. If USFS opens roadless areas to new roads and logging, municipal watersheds will suffer over the whole state. As I said, my hometown of Eugene is in this exact situation. It is downstream from inventoried roadless areas that naturally filter surface water feeding the McKenzie River, Eugene’s sole water supply. And Eugene is not unique. A 2025 University of Washington study found that some 25,000,000 Americans depend on roadless areas to help filter their drinking water. Absent this natural filtration, many communities will struggle to purify public water. For more than 30 years, Big Timber and Wall Street have hungered for old trees on public land. By feigning concern about wildfire and rural jobs, they’ve not only found a way to get at those trees, but to have the taxpayers pay the price. Please don’t let them get away with it! Uphold the Roadless Rule.

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

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule of 2001. I am a lifelong Oregonian and currently live in Oregon's southern Willamette Valley. I regularly recreate on public lands, including currently inventoried roadless areas that are protected from roadbuilding and timber harvest under the Roadless Area Conservation Rule. Threemile Lake located in the Tahkenitch Roadless Area of the Siuslaw National Forest is one of my favorite places to hike and bring kids to play on dunes. This area consists of coastal rainforest with ancient sitka spruce trees that have ferns growing way up high in the tree canopy. The forest supports wildlife and is a prime area for finding edible wild mushrooms. Tahkenitch Roadless Area also contains a rare coastal dune ecosystem that supports plant species uniquely adapted to shifting sands and the wet deflation zone. The Western Snowy Plover, federally recognized as threatened, nests on the beach in the area. I am also concerned in addition to potential roadbuilding and logging, rescinding the Roadless Rule would expand motorized corridors in the general area for recreational use impacting wildlife. Tenmile Creek is another roadless area further south which is less accessible to hiking and therefore even more valuable to wildlife. Another vitally important IRA is Iron Mountain in the Willamette National Forest in Lane County. A hiking trail takes you through forest and wildflower meadows that support over 300 native wildflower species. The views to the east are phenomenal and if roads were built and surrounding areas were logged the recreational value would be irreparably harmed. To get there, people travel through the small towns and support small businesses along the way. I also frequent Three Creeks Lake and surrounding areas in Deschutes National Forest adjacent to the Three Sisters Wilderness. Roadbuilding and logging in these areas would harm wildlife, recreational value and water resources. Many of the areas currently protected by the Roadless Area Conservation Rule are near the headwaters of watersheds that supply drinking water to our cities. Protecting clean water is vital to our future. According to the DEIS "inventoried roadless areas typically have good water quality due to limited disturbance,” and “Road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation.” My drinking water comes from watersheds partially within Inventoried Roadless Areas. I am also concerned that rescinding the Roadless Area Conservation Rule in whole or in part could increase fire risk. As the Administration itself states, “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.” Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. The increasing number of wildfires, size of wildfires and intensity of wildfires is a serious concern in the West and doing anything that increases the probability of human caused fires is unwise. Enough fires start due to lightening during our increasingly long fire season, that adding risk that the hot underbelly of a vehicle or a careless toss of a cigarette butt will ignite new fires is unacceptable. The DEIS states that a key purpose of proposing a rescission of the roadless rule is to have greater local decision-making and reduce regulatory burden. A return to decision-making at the individual national forest level means that concerned citizens like myself would have to track proposed roadbuilding and timber harvest across the state and comment on each project. This would limit the public’s ability to meaningfully weigh in. Entirely local planning and decision-making will not adequately account for public opinion. The result would be an erosion of protections needed to support clean drinking water, wildlife habitat, and recreational opportunities. Consistent nationwide protection measures are critical to protecting these values. For all of the above reasons, I believe that alternatives 2 and 3 of the draft EIS would be a serious mistake. I oppose the proposal to rescind or alter the Roadless Rule and I support “Alternative 1, the No Action alternative." I want the Forest Service to protect forests for the multitude of services they provide to people, wildlife, plants, and water resources. I do not want decisions about our public national forestland to favor the private construction industry and timber industry which would inevitably have a bigger voice at the table. The inventoried roadless areas are national treasurers. We cannot afford to serve private industry interests at the expense of the public interest. I urge the Forest Service to retain the current Roadless Rule under Alternative 1.

My favorite leisure activity is hiking. I often hike in the designated roadless areas of the Willamette National Forest about 20 miles from my home. The forest already has hundreds of miles of roads. Many are poorly maintained or not maintained at all. Primitive roads attract illegal campers who are often responsible for careless ignition of wildfires and for crimes such as vehicle break ins, illegal dumping and vandalism. For fire suppression it would make more sense to maintain existing roads so you can patrol them instead of making more of them. Non motorized uses of roadless areas are a valuable driver of our economy and non motorized uses do not degrade our water quality the way logging and mining do. Clear cut logging turns fire resistant, multi species old growth forests into single species tree plantations where all the trees are the same age. These immature plantations burn much more readily than old growth. It takes decades for a new plantation to grow into a forest that can support a healthy ground fire without crowning out into a destructive wildfire. Please keep our roadless areas road free!

Dear Secretary Rollins, I am writing to oppose rescinding the Roadless Rule (RR). I live in Lane County, Oregon and 2 of my favorite hiking spots in Willamette National Forest are protected by the RR---Hardesty Mountain and Iron Mountain. I go to these spots for the beauty, the peacefulness and to look for wildflowers and wildlife, especially birds. Once roads are cut into an area, logging, mining and other development will eventually take place. Meanwhile, the roads themselves cause erosion which adds sediments to the streams and rivers that provide drinking water to thousands of Oregon residents. Healthy, clean drinking should be a right, not a privilege. Additionally, building more roads into pristine forest lands would significantly increase human access. Data from several sources indicates that the vast majority of wildfires are caused by human activity. This includes use of equipment; power lines; negligence with campfires and cigarettes; and arson. Nationwide the RR protects nearly 45 million acres of remaining intact forest ecosystems. Once lost these ecosystems are irreplaceable on a human timeline. For the above reasons and in fairness to futures generations, I urge you to retain the RR. Thank you for considering my input on this topic Carolyn Partridge

I am writing to let you know of my extreme opposition to amending the roadless rule. For 25 years, I have been fortunate enough to recreate in parts of Oregon, my home state, that are protected by this rule. Mostly that has been in the Willamette National Forest where I hiked, cross country skied, and later mountain biked in places such as Waldo Lake, Maiden Peak, Indigo Lake, and Sawtooth Mountain. In the past five years, I have moved to Central Oregon where I spend much time on my mountain bike, hiking with my dog, and backcountry skiing in areas similarly protected by this rule. I have come to take for granted the beauty and solitude of these areas, such as Tumalo Mt., Paulina Rim, and Lookout Mt. in the Ochocos. I ride my bike on the Metolius Windigo trail from the Bend area to Sisters and from the Cascade Lakes Highway to Lava Lake. I cannot imagine what opening up those areas to roads would do to wildlife, plant life, and the incredible recreation that drives the economy in Central Oregon. I urge you to reject this short sighted perspective that we need to extract as much from the earth as possible. We have finite resources and we are better served by protecting them in these areas that are still without roads and without vehicles so that may generations can enjoy the gifts of wild areas. Thank you.

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

I am a retired attorney for the United States Department of Interior. I oppose rescinding the 2001 Roadless Rule, and I urge the Forest Service to adopt the no action alternative from its Draft EIS. I have hunted, fished, foraged, biked, hiked and camped in National Forests in Oregon, Colorado, Wyoming, New Mexico, Montana, Idaho, South Dakota and California. Forest management has been a dinner table conversation ever since I can remember. My father taught forestry at Humboldt State, and my son is now a forester in New Zealand. My other son is a fishing guide who relies on the clean waters of the Willamette National Forest for his business. Forest health is a frequest topic of discussion. The full range of services provided by National Forests, especially roadless areas, must be taken into account before deciding which DEIS alternative to choose. Roadless areas protect watersheds and promote water quality. They provide key habitat for all wildlife, including many endangered and threatened species. This is especially true of old growth forests. Road noise and road disruption limit suitable habitat for many species, including the elk and deer I hunt. Roadless areas support local communities by providing recreational opportunities, especially for nearby residents, and by attracting recreation dollars to those communities. Our National Forests provide cultural and communal values for all Americans. For example, my family has enjoyed picking huckleberries in the Rogue River-Siskiyou National Forest in southern Oregon for at least four generations. For over 80 years, we have harvested Christmas trees on National Forests in Oregon and Colorado. These are cherished cultural activities for us and other families. Our National Forests do not need more roads to accommodate these activities. While many of our forests are overloaded with fuel, studies show that new roads do not limit forest fires. In fact, new roads are likely to increase human-caused wildfires. Fires are four times more likely in areas with roads. Also, NOAA reports that this summer of 2026 is now officially the hottest summer since records have been kept. Trees cool the atmosphere and promote healthy air. We need to be planting trees, not falling them. For these reasons, I urge the USDA to adopt the no action alternative.