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I am writing to oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I address this comment as a retired wildlife biologist living in northwest Montana who spent a 32-year career working in the Lassen, Modoc, and Plumas National Forests in California, the Winema National Forest in Oregon, and the Salmon-Challis and Sawtooth National Forests in Idaho. I have hiked, camped, hunted, and conducted wildlife surveys across these forests, including lands protected under the Roadless Rule. I have observed first-hand the importance of Roadless Areas to the conservation of many “Species of Greatest Conservation Need” (SGCN), including the North American Wolverine, Fisher, Mountain Goat, Black Rosy-Finch, Boreal Owl, Flammulated Owl, and several species of amphibians and bats, all of which I have performed survey work to contribute to their conservation status. Roadless Areas retain the forest and watershed habitat integrity at a scale required for the protection and future viability of hundreds of at-risk species (reference state lists of SGCN). The Trump Administration proposal to rescind the Roadless Rule would set up a cascade of deleterious actions that do not have the support of the majority of the American public and public land users. Eliminating the Roadless Rule would: •Remove protections for 45 million acres of high-integrity wild lands across our National Forests; •Increase the risk of wildfire ignitions due to human access into backcountry forests. Highly credible studies show that fires are 4X more likely to start near a road than in a roadless forest; •Increase logging and associated roads/infrastructure that degrades watershed integrity, water quality, and fisheries habitat and facilitates the colonization of noxious weeds. •Increase the taxpayer burden of road maintenance and invasive species control. Our National Forest road system currently carries a $6.9 billion deferred maintenance backlog per the draft EIS. DOGE has slashed Forest Service staff and funding, which will only exacerbate that backlog. I am particularly displeased by this proposed rule in that it ignores the will of the American public, who resoundingly supported the Roadless Rule in 2000. The Trump Administration’s effort to rescind the rule is being pushed by special interest timber and mining corporations and their lobbyists seeking economic benefits that average Americans will never benefit from. Even now, with 600,000+ public comments received as of September 2026, over 99% urge that the Roadless Rule be retained. That level of public opposition to rescinding the Roadless Rule must be respected and weighed appropriately. For the concerns stated above, rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a serious error and affront to the management and integrity of our precious public lands. For the record, I oppose the proposal to rescind or alter the Roadless Rule and support Alternative 1, the No Action alternative.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The N. Boundary roadless area in the Winema National Forest is not a number on a map to me. It is where I go. Rescinding the 2001 Roadless Area Conservation Rule would open it, and the rest of Oregon's 1,937,741 acres across 211 inventoried roadless areas, to roads and the damage roads bring. I oppose Docket FS-2025-0001 and ask the agency to address the specific problems laid out below. The proposal leans on wildfire and fuels management as a rationale for rescission, but the agency's own record cuts against that argument. The rule states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." That is not an environmentalist's talking point. That is the agency's own finding. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. I want the agency to explain, in this rulemaking record, why the proposal departs from those prior findings and how it reconciles the rescission with its own ignition data. The economic case for rescission is not there, and the agency's own analysis says so. Its 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's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year, and a net present value spanning negative $92 million to positive $199 million. That range cannot establish a net benefit. Meanwhile the agency is already carrying a $6.9 billion maintenance backlog on its existing road system. How does expanding that system under these numbers serve the public interest? The agency must reconcile the proposal with its own cost-benefit findings before it can justify proceeding. The agency argues that state-specific approaches can replace the national rule, but it has been down that road before. The record includes the agency's own statement 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." What followed that dissatisfaction was a state-by-state scheme that the Ninth Circuit rejected. The agency has already found, in its own prior proceedings, that local decision-making can incrementally erode roadless values that are nationally significant. The Pacific Northwest alone has 1,522 municipal water intakes sitting in watersheds that contain affected roadless areas, including the watersheds draining into and around the Winema. The agency must explain here how this proposal avoids the legal and practical deficiencies that doomed the last attempt at state-by-state management. The proposal also questions whether the 2001 rule was within the agency's statutory authority. A federal appellate court answered that question directly. 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 was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act, and that it did not create de facto wilderness. The agency must state on the record what legal basis it has for any position contrary to that holding, and it must do so with specificity, not a general reassertion of doubt. I support maintaining the 2001 Roadless Area Conservation Rule without rescission. The N. Boundary area and every other inventoried roadless area in Oregon deserves a response to each of these points before any final action is taken. Sincerely, Matt Volpe Southern Oregon

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. This careless decision would wreak havoc on our communities and public lands. The expensive infrastructure backlog would skyrocket, we would be at an increased risk for wildfires while jeopardizing access to drinking water, wildlife populations would be threatened, and critical sites for recreation that fund local communities through tourist spending would be damaged or irradicated. I live in Portland, Oregon, and I spend just about every weekend going out into public land to spend time in nature. I sincerely urge you to take Alternative 1, the No Action alternative, and retain full Roadless Rule protections. Over Labor Day weekend, I travelled to roadless areas in the Warner Valley, Fremont-Winema National Forest, and Newberry Volcanic National Monument. On this trip, I visited land that still holds indigenous artifacts and petroglyphs thousands of years old, in areas struggling for water and designated as extremely at risk for fire. Some roads were closed due to lack of maintenance and increased chance of causing fires by driving on or near the vegetation. The administration admits that building new roads would significantly inflate the deferred maintenance backlog, which is already over $6.9 billion. Not only that, but recent studies have proven that fires are 4 times more likely to start near a road than in a roadless area. While driving through the Fremont-Winema National Forest in the middle of the day, on our way back home from the roadless area, we had to abruptly slow the car twice to avoid hitting both a coyote and a badger. According to the administration's DEIS, eliminating the Roadless Rule would “adversely affect” 327 threatened and endangered species and 71 designated critical habitats for these species. What that translates to is more wildlife on the additional roads, more risk of collisions for cars, and more loss to critical, already threatened and endangered wildlife populations. Already, our roads put these lands at risk: for the wildlife, the access to safe water, and the increased fire danger. It is crucial to my well-being, and the well-being of many others, that we not only have access to conserved lands where we can be outside and connect to nature, but that our home lives are also safe from natural disasters and shortages. I also fundamentally believe in the rights of non-human life, and their homes must be protected. Even from an anthropocentric perspective, harming native wildlife populations erodes our area's resilience to drought, fire, and food shortages. We are already struggling; we do not need to struggle more. I am truly brought to tears imagining what rescinding the Roadless Rule would do to our beloved lands, the quality of my life, and the quality of the lives of our children. In addition, I am getting married next year in Molalla, a town that gets drinking water from the Molalla River (a drinking watershed in roadless areas). By rescinding the Roadless Rule, Molalla will lose protections in their drinking watersheds. The DEIS states that “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.” I am already worried about wildfires and smoke during my wedding. I cannot handle these threats worsening in addition to the new concern of less secure access to drinking water. Worse, my coworker, her husband, and her kids live in Molalla. They can't just choose to stop visiting a place that becomes less tenable due to harmful development on currently protected areas. Their lives, homes, and livelihoods are at stake. I would be deeply impacted by both Alternatives 2 and 3 of the draft EIS. Under the agency’s proposal, Alternative 2 would eliminate protections for nearly 2 million acres of wild, public lands in Oregon. Under Alternative 3, 1.4 million acres (nearly 75% of IRA acres in Oregon) would lose protections, including the ones I am listing here. For these reasons, and enough more to write a book, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would be a horrific mistake. I oppose the proposal to rescind or alter the Roadless Rule, and support Alternative 1, the No Action alternative.

Hi, my family and I own property in rural Klamath County, on the outskirts of the Fremont-Winema National Forest. The roads in our neighborhood and going into the National Forest are horrible. We would like them better maintained, but not at the expense of the local wildlife or endagering any species living there. We would be ok with some tree clearing and maintenance of the nearby national forests, but nothing excessive or polluting to the water supply or surrounding lands. We bought land on the edge of the national forest for the peace and freedom to live on our own land in a more natural, private setting. We request only that the peace, nature and freedom we are paying for remain undisturbed, and that the roads be maintained. If repealing this rule will not impede our request, and will not cause harm to the surrounding area or residents, then we're ok with it. That is my comment on this proposed change. Thank you for your time and hard work.

Docket No. FS-2025-0001 Special Areas; Roadless Area Conservation; National Forest System Lands I, T Cartwright, strongly oppose the proposed rescission of the 2001 Roadless Area Conservation in this "Special Rule". As a resident, recreationist, and steward of the lands surrounding the Fremont-Winema National Forest and Sky Lakes Wilderness, I view this proposal not as a routine regulatory update, but as a serious threat to the public trust that prioritizes short-term corporate gain over long-term public interests. Technical and Factual Concerns: The 2001 Roadless Rule protects approximately 60 million acres of inventoried roadless areas (IRAs). Rescinding national-level prohibitions would remove protections from approximately 55 million of those acres. The USDA’s justifications are unpersuasive: “Flexibility”: The rule already operates alongside forest plans and site-specific review. Rescission would eliminate consistent national safeguards, leaving roadless lands vulnerable to piecemeal road construction, logging, and commercial development. “Regulatory Burden”: The rule is not an absolute ban. It contains limited exceptions and operates alongside the Clean Water Act, Endangered Species Act, and Wilderness Act. The burden being reduced is not administrative—it is the protection of irreplaceable public lands. Permanent Loss: Once roads, motorized use, or commercial logging are introduced, the wilderness character may be permanently destroyed. No future Congress can restore an ancient forest or replace a thousand-year-old tree after it has been logged. Personal, Community, and Economic Impacts: My family, neighbors, and community rely on these roadless areas for irreplaceable experiences and essential services. We canoe, hike, camp, and sail in this wilderness, and our wells depend on the watershed protections these lands provide. Roadless areas support an outdoor recreation economy contributing approximately $1.2 trillion nationally. Sacrificing these places for short-term extractive profits undermines the long-term, sustainable economic benefits rural communities depend on. These forests are among our last intact systems for storing carbon, mitigating climate change, protecting clean water, and maintaining connected habitat. Treating them as a “renewable commodity” ignores their ecological value and the consequences of industrial disturbance. Supported by over 1.6 million Americans at its inception, the Roadless Rule remains a highly popular conservation policy. Reversing it through omnibus legislation, land swaps, or processes avoiding meaningful professional and public scrutiny violates public trust. Recommendations for Genuine Stewardship: To balance stakeholder interests, the USDA and U.S. Forest Service should pursue reforms that strengthen stewardship rather than expand extraction: Provide full funding to address the ~$22 billion deferred-maintenance backlog and restore staffing for rangers, scientists, and land-management crews. Require fair-market-value payments for grazing, drilling, and timber, with revenues reinvested in restoration and public-land management. End privatization of core services, including campground and visitor operations, to preserve public accountability. Codify National Monument boundaries through Congress to prevent unilateral revocation. Permanently prohibit commercial logging of old-growth and mature forests on public lands. Restore and strengthen NEPA and Endangered Species Act review for development projects. Recognize conservation as a primary, enforceable use of public lands, taking precedence over extraction to protect ecological integrity. Create a permanent, year-round federal wildland firefighting service with full benefits. Establish a new Civilian Conservation Corps dedicated to planting trees, repairing trails, and restoring ecosystems. Conclusion: The agency has provided no adequate scientific justification for reversing decades of established protection. A change of this magnitude, made despite substantial public opposition and without a documented evidentiary basis, is arbitrary and capricious. I respectfully request that the USDA immediately withdraw the proposed rescission of the 2001 Roadless Rule and reject any “Special Rule” changes that weaken protections for wilderness study areas or roadless country. Our wild Public Lands are a finite inheritance and a national trust. They are not for sale. Keep and Expand the 2001 Roadless Rule.