Read the comments.

Dear Director: I am submitting these comments as an individual who has worked in mineral exploration in Southeast Alaska since 2009, and has lived in Ketchikan, Prince of Wales Island and Juneau. I now work as an independent consultant to companies exploring in the region, and these comments are my own. My first work in Southeast was at the Niblack project on Prince of Wales Island, where I was Project Manager from 2009 to 2020. Niblack has tidewater access and roads on patented mining claims, which supported underground development and exploration drilling. The Tongass had been temporarily exempted from the Roadless Rule in 2003, and in 2009 the Forest Service approved exploration drilling at Niblack in a Decision Memo. When a federal court reinstated the 2001 rule on the Tongass in 2011, its judgment allowed the drilling approved in 2009 to continue. However, our drill sites had since been revised based on underground exploration results, so the Forest Service halted our helicopter-supported surface program on National Forest land mid-season. At significant cost to budget and schedule, we moved crews to another project and returned in the fall to drill only from patented claims. A separate 2012 authorization allowed surface drilling to resume, and that was the last field program I managed before the project went into care and maintenance. That is the practical effect of the rule on Tongass projects. Since 2009 I have watched the Tongass move in and out of the 2001 rule with court rulings and changes in administration. The status of the Tongass under the rule has been reversed four times, in 2003, 2011, 2020 and 2023. Approval of exceptions has also changed four times: the Secretary reserved it from 2009 to 2012, it was delegated to regional foresters in 2012 and 2018, and in 2021 pending decisions were elevated to the Department again (DEIS pp. 3 and 6). Each change resets the planning assumptions for projects on the forest. This unpredictability makes it difficult to raise investment for exploration in Southeast and even more difficult to execute programs when the money is raised. Companies and investors generally understand that exploration in Southeast works with helicopters and barges. Most of the programs I've managed in my career, in and outside of Alaska, have been helicopter-supported, because it isn't practical to build a road to a prospect without a proven resource. However, drill pads and landing zones require cutting trees, which in my experience can fall under the same scrutiny as road building in the Tongass. Access for developing and operating a mine comes later, when a project succeeds and needs a road to advance. The companies I work with in Southeast have projects on state, BLM and private land, where access is decided project by project. Southeast is a mineral district, and its mineral belts don't follow political or ownership boundaries. Inside a Tongass roadless area, a mining road also needs a discretionary exception, on top of the environmental review and plan approval it already requires. Whether a successful project can build a road depends on which side of that boundary it sits. I was the Director of the Center for Mine Training at the University of Alaska Southeast in Juneau, which prepares people from the region for well-paying mining careers. In 2025 the average annual mining wage in Southeast was $134,545, more than twice the regional average of $66,796 (Southeast Conference, Southeast Alaska by the Numbers 2026). Jobs like these let people build a life without leaving Southeast. The operating mines, Greens Creek, Kensington and Dawson, provide most of them today. New ones depend on new discoveries advancing, and on the Tongass that relies on access. I support Alternative 2, rescission of the 2001 rule. Not once while working in the Tongass for over 15 years did I encounter someone wanting to build a network of roads throughout the forest. The residents of Southeast Alaska are among some of the most environmentally aware people I have met and care deeply about protecting what they enjoy about living here. Every road would still require site-specific environmental review, consultation with Tribes, the subsistence protections of ANILCA and approval under the Forest Service's minerals regulations. I would rather those decisions be made project by project, by people who know the ground, than set nationally and reversed every few years. Thank you for considering these comments.

I write today in support of the current recission of the 2001 Roadless Rule. I am a lifelong Alaskan who has spent my entire life being molded by the Tongass, and have come to realize just how lucky we are to grow up with something of this magnitude in our backyards. Its with this deep respect, that I believe those who know the land the best should be the shepherds of its future. The Roadless rule is something that works for lower 48 states, with minimal federal forestry land, but when you apply it to the southeast Alaska region, many important Alaskan decisions are made for us. The Tongass was not supposed to be included in the 2001 Roadless Rule in the first place. Congress had already set aside 5.7 million acres of Wilderness and 775,524 acres of Legislative LUD II Areas (Similar to Roadless Areas) in ANILCA and the Tongass Timber Reform Act of 1990 (TTRA). The No More clause of ANILCA (1326(a) was supposed to prevent such additional land set asides that were over 5,000 acres without an Act of Congress. The Tongass was thus not added to the 2001 Roadless Rule until the Record of Decision was promulgated. Fed. Reg. Vol. 85, Oct. 29, 2020, at pages 68690-68691. So, there is every reason to remove it from Roadless designation. The Final EIS exempting the Tongass on October 29, 2020, pointed out that road construction would increase from 994 miles under the No Action Alternative to 1043 miles (49 miles) under Exemption over the next 100 years. Only 186,000 more acres of the 16.9-million-acre Forest would be available for timber harvest. Fed. Reg. Vol. 85, Oct. 29, 2020, at page 68691 (middle column). Additionally, a repeal of the Roadless rule would advance hydroelectric capabilities for a region that sees some of the highest rainfall on average. The 1947 Waterpower of Southeast Alaska Report, conducted in part with the Forest Service, identified over 200 potential hydropower sites in Southeast Alaska. There is thus no reason why all Southeast Alaska should not be on hydropower. Moreover, excess power from Southeast Alaska can be exported to the Lower 48. On November 13, 2000, Congress authorized construction of a Southeast Alaska-wide intertie, which included the Tongass National Forest. Pub. Law 106-511, 114 Stat. 2365 (Nov. 13, 2000). Future hydropower and support facilities, such as those envisioned by Report #97- 01, are subject to the prohibition on road construction. See 66 Fed. Reg. at 3256 (“The final rule retains all the provisions that recognize existing rights of access and use. Where access to these facilities is needed to ensure safe operation, a utility company may pursue necessary authorizations pursuant to the terms of the existing permit or contract.”) (Emphasis added). This exception is subjective and fails to provide clear direction. Future transmission projects do not fall within that exception. The Swan-Tyee Intertie (STI) is an example of a transmission project that, because of no road access, resulted in exceedingly high construction costs. If road access is unavailable for construction, the utility is limited to the use of helicopters. Helicopters are extremely expensive. This resulted in a construction cost for STI of about $2 million dollars/mile. The STI is 57 miles long and the total construction cost including permitting, design, etc., was about $110 million. To put that in perspective, the proposed Kake-Petersburg (KPI) line, which has roads in place, has an estimated cost of around $45 million. The length of the KPI is about the same as the STI. Of more significance is the cost to maintain a line that is constructed without road access. The rights-of way (ROW) for these lines have to be maintained and brushed continually. The structures must be inspected on a rotating annual basis. With roads, this work can be done by a crew in a truck. Without roads, this work must be helicopter supported, which is very expensive. Moreover, transmission lines that do not have road access must also have helicopter pads near the structures. These pads must be maintained and brushed every couple of years. This work must be done by helicopter. For these reasons above, I support repealing the roadless rule, and allowing for Alaskans to finally have the opportunity to make decisions on our forest as we see fit. Thank you for your time.

To the U.S. Forest Service: I write in strong support of rescinding the 2001 Roadless Area Conservation Rule, particularly as it applies to the Tongass National Forest. [Personal line, e.g.: "As a lifelong Alaskan who has worked for decades on resource development in this state, I have seen firsthand what this rule has cost Southeast Alaska communities."] Rescission is consistent with Executive Order 14192, Unleashing Prosperity Through Deregulation, which directs agencies to remove overly complicated and burdensome barriers to American business and innovation. It also implements Executive Order 14153, Unleashing Alaska's Extraordinary Resource Potential, which specifically directs the Forest Service to exempt the Tongass from the Roadless Rule. The Roadless Rule's blanket prohibitions were never necessary on the Tongass. When Congress enacted the National Forest Management Act in 1976, it established a forest planning process designed to weigh conservation and use on a forest-by-forest basis. That process is fully capable of protecting the Tongass's important ecological values without a one-size-fits-all national rule. Congress has also already struck the balance on the Tongass. Before the Roadless Rule was adopted, Congress designated more than 6.6 million acres of the forest as Wilderness and other restrictive land use categories through the Alaska National Interest Lands Conservation Act (ANILCA) and the Tongass Timber Reform Act (TTRA). The lands Congress left out of those designations were left out deliberately, so they could support local employment, including year-round timber manufacturing jobs in a region where almost no state or private timberland is available to supply the mills. The Roadless Rule effectively overrode that congressional judgment, and in doing so it conflicts with both ANILCA and TTRA. The consequences have been severe. Sustainable timber harvests on the Tongass have plummeted, and timber employment in Southeast Alaska is now a fraction of what it was before the rule took effect. The loss of these jobs has damaged the social and economic fabric of communities that have few alternatives for year-round work. The rule also stands in the way of mineral and energy development that matters to the entire nation. The Tongass is highly mineralized, including volcanogenic massive sulfide deposits that contain critical and rare earth minerals needed for national security. Southeast Alaska also has more than 200 potential hydropower sites that could provide clean, affordable, renewable power to the region. Under the Roadless Rule, access to these resources depends on the subjective judgment of individual Forest Service officials. The "reasonable access" the rule guarantees to mining claims does not necessarily mean road access. A Forest Supervisor can instead require costly helicopter access, an outcome that the authors of the Mining Act of 1872 could never have contemplated. Leaving it to an individual official to decide what access is "reasonable," or when a road is "needed," creates uncertainty that discourages investment and fails to protect access rights established in law. Finally, the practical footprint of rescission is modest. Rescinding the rule would make only about 186,000 additional acres of the 16.9-million-acre Tongass available for timber harvest, roughly 1 percent of the forest. That is a small and reasonable change that would restore the balance Congress intended and give Southeast Alaska communities a real chance at economic stability. I urge the Forest Service to finalize rescission of the 2001 Roadless Rule. Sincerely, Sarah Ward Anchorage, AK

2026 September 5 Monday To: Donald J. Trump, President of the United States Brooke Rollins, U.S. Department of Agriculture Secretary Tom Schultz, U.S. Forest Service Chief Subject: Recission of the 2001 Roadless Area Conservation Rule (2001 Roadless Rule). Identified by docket number FS-2025-0001 or RIN 0596-AD66. Dear Mr. President, Secretary Rollins, and Chief Tom Schultz; I encourage you to rescind and purge the 2001 Roadless Rule from the Tongass National Forest (Tongass) because it violated the ‘no more wilderness clause’ of the Alaska National Interest Lands Conservation Act of 1980 (ANILCA). The 2001 Roadless Rule also usurped Congress’ powers that it reserved to itself in designating wilderness. I encourage you also to do the same for the other national forests across America where Congress did not give explicit approval by legislation that became an actual law. The 2001 Roadless Rule was simply an executive or policy directive by the administration of former President Bill Clinton shortly before leaving the White House and the inauguration of the incoming former President George W. Bush. In the case of the Tongass, the 2001 Roadless Rule violated ANILCA’s Section 708 (b)(4), which reads in part, “unless expressly authorized by Congress the Department of Agriculture shall not conduct any further statewide roadless area review and evaluation”. ANILCA was amended in 1990 by Congress with the Tongass Timber Reform Act. The Roadless Rule created defacto wilderness, without lawful Congressional authority that was given exclusively to Congress within the Wilderness Act of 1964. The term “Roadless” is simply wilderness by another name. And it has been insidiously as well as unlawfully imposed on Americans for a quarter century. I encourage you to rescind the 2001 Roadless Rule and end it once and for all. Sincerely, David Spigai Ketchikan, Alaska

October 5, 2026 Director Ecosystem Management Coordination 201 14th Street SW Mailstop 1108 Washington, DC 20250-1124 Re: 2001 Roadless Area Conservation Rule Rescission Draft EIS - RIN 0596-AD66 Dear Director, The Custer Gallatin Working Group is a collaborative that works to develop agreements around priority areas and approaches for project work on the Custer Gallatin National Forest. The CGWG represents a wide range of stakeholder interests including County Commissioners, representatives of conservation NGOs, the ski industry, agriculture and ranching, recreation, hunters, anglers, outfitters, mining, and the timber industry. We support active and balanced approaches to public land management based on common sense, credible research and the values and priorities of the public. We support forest restoration, fire risk reduction, commercial harvesting, and timber stand improvement that can help sustain the forest products industry at the same time protect healthy wildlife populations. We also support a variety of recreational opportunities in our national forests, both motorized and quiet. And we believe the Forest Service must be fiscally responsible in recognizing their deferred maintenance backlog and the need to maintain their roads to standard. We do not see these things in conflict with one another. Based on our experiences we believe there are opportunities to strategically modify the management of Inventoried Roadless Areas, to better enable the Forest Service to increase active management in areas where it makes sense and retain protections for priority backcountry roadless areas. However, the approach to Roadless Rule modifications in Alternative 3 is not adequate. Revisions to the rule should be informed by hosting public meetings and listening to local stakeholders. Affected communities should have a say in decisions to increase access to some roadless lands, while balancing the important natural values of these lands. For example, communities should have the opportunity to apply craft locally-informed boundary adjustments that met the needs and interests of affected communities. Rescinding the rule with no public meetings and a three-to-four-week comment period is insufficient for our groups, who primarily meet monthly, to review and understand the DEIS and to craft meaningful comments that members can support. Therefore, we request the Forest Service to offer a longer comment period for this DEIS, public meetings, and other forms of stakeholder engagement. We also would suggest that instead of relying on expensive and time-consuming forest-by-forest updates to Forest Plans, that the Forest Service reconsider the merits of state-level rulemaking. A Montana Roadless Rule, guided by a non-partisan committee of scientists and forest stakeholders, could build on the good work being done through state Stewardship Agreements, the Good Neighbor Authority, and the long history and experience of collaboration occurring across the state. We know from experience that differing perspectives can find common ground on forest management when conversations are grounded in shared values and time is invested in working to build consensus. We encourage the Forest Service to reconsider its approach to this process and follow the examples set by the successful forest collaborative movement in Montana. Sincerely, John Prinkki, Chairman, Custer Gallatin Working Group

I am for rescinding the Roadless rule. I have see it used in Forest Plan and Travel Management plans to close roads and trails that were used by me and my family since the 1940s in 12 mile Canyon near Gunnison, Utah. I value motorized access to our forests. I also am in favor of constructing new trails for motorized and non motorized use for our growing population. I also believe we can utilized good judgement and management practices to build and maintain roads and trails. As a professional geologist and the local county trail coordinator I have had both scientific and on the ground training and experience in designing, building and maintaining trails. If the Forest Service's own guidance documents and best management practices are followed, trails and narrow forest roads can be build to have very little impact on watersheds. I am for allowing access for timber harvesting as well as fire mitigation operations on our forests. I am for allowing local rangers to make decisions on local forests regarding roads rather than one size fits all managment directives from Washington DC. Many anti access groups have used the roadless rule in countless lawsuits on proposed forest projects and on forest travel management plans, resulting in financial resources being pulled away from critical forest service tasks and spent on lawsuits. Repealing this rule will safe the Forest money in the long run and allow for more efficient and timely management. I recently traveled over the Wolfcreek pass in Utah between Kamas and Hanna and observed the large amount of standing dead timber for miles and miles along the highway. The fire was over two summers ago. This timber could be harvested in a salvage operation but I suspect that it is in a roadless are and therefor will not be harvested and will be allowed to fall and create a labyrinth of dead and rotting trees almost impossible to hike through. I think this is such a waste of a resource. I think forests should have active management in non-wilderness areas. Active management requires roads. Active fire management requires roads. More recreational opportunities require roads and trails. I am a senior and no longer am spry enough to hike 5-10 miles for hunting and backpacking. I use motorized access in a truck, a UTV, on a motorcycle to access the forest. Roads and trails are very important to me, my family and also to the 300 plus members of the Utah Trail Machine Association, of which I am the vice president of. Those are my thoughts on the roadless rule. I agree with the aguments and facts presented by groups like UPLA and Blue Ribbon Coalition that I belong to. Sincerely Wes Thompson P.G.

1. The Rule used administrative rulemaking to do what the Wilderness Act reserves to Congress Section 2(a) of the Wilderness Act of 1964 provides that wilderness is designated by Act of Congress. Congress then built a durable process around that principle. The Forest Service inventoried roadless lands in RARE I and RARE II, the National Forest Management Act of 1976 directed forest-level planning with public participation, and Congress took up state-by-state wilderness legislation, area by area, with local debate and local compromise. The 2001 Rule applied to inventoried roadless areas nationwide the central management constraint of wilderness, a prohibition on road construction and most timber harvest, without a designation by Congress and without the area-by-area record that legislation requires. I do not argue that the Rule created legal wilderness. It did not, and recreation uses differ. My point concerns function and process. A category of land that operates in practice as wilderness for roads and timber was created by a single agency rule, and the legislative path that Congress established for that purpose was bypassed. If a roadless area merits permanent protection of that kind, the Wilderness Act supplies the means to secure it, and rescission leaves that means fully intact. 2. The Rule overrode more than two decades of forest planning When the Rule was adopted, the national forests had spent more than twenty years developing land management plans under the National Forest Management Act. Those plans allocated roadless acreage among competing uses, and the allocations reflected negotiation among local governments, industry, recreation interests, conservation organizations, and agency specialists. Some plans recommended wilderness. Others provided for active management. Many produced compromises that no single party preferred and all could accept. The Rule replaced those plan-level allocations with one uniform national prohibition. The documented fact is the Rule's text and its effect on existing plan decisions. My inference, drawn from participating in that planning era, is that the participants in those processes had good reason to see the Rule as discarding the product of their work. Rescission restores the standing of the plans and the public processes that produced them. 3. The Rule's effect on management went beyond its text The Rule contains exceptions, including provisions for certain small-diameter cutting and for fuel reduction near communities. A reader of the text alone might conclude that management in roadless areas remained workable. In my experience it did not. Added approval requirements, the cost of building a defensible record, and exposure to litigation led managers to stop proposing even the activities the Rule allowed. The practical result was that roadless areas were treated as places where management does not occur, regardless of what the regulation said. 4. Decisions belong in public, site-specific planning I am aware that the 2025 scoping period drew a large volume of comments, and that many commenters oppose rescission. I take that seriously. But the question before the agency concerns the proper process for making these decisions, and a count of comments does not settle it. A national prohibition written in Washington cannot distinguish a dry ponderosa pine slope with a century of fire exclusion from a high-elevation spruce basin that burns on a long return interval. Those differences decide whether management is warranted, and they can be seen only on the ground. You have to touch the land to know the land. Forest plan revisions and project-level review under NEPA provide notice, comment, objection, and judicial review, applied to specific acres and specific proposals. The Idaho Roadless Rule and the Colorado Roadless Rule, both developed through state-specific processes, show that locally tailored approaches can be built when decisions are brought closer to the land and the people who live with it. 5. Requests I ask the Forest Service and the Department to finalize rescission of the 2001 Rule. I further ask that the final rule and record of decision commit the agency to address roadless areas through forest plan revision and amendment, with full public participation, so that rescission is followed by open planning and not by project decisions made without it. I ask that the final environmental impact statement present the management-outcome data described above, including results unfavorable to rescission. And I ask that areas for which broad local support exists for permanent protection be advanced to Congress under the Wilderness Act, where that decision belongs. Thank you for considering these comments. I am available to discuss them or to provide supporting material on request. Respectfully submitted, Franklin O. Carroll Managing Partner, Professional Forest Management, LLC (PFMc) Licensed Professional Forester Pueblo, Colorado

RIN 0596-AD66, https://www.regulations.gov, identified by docket number FS-2025-0001 or RIN 0596-AD66. I support the Rescission of the Roadless Rule! The Roadless Rule bypassed the official Congressional designation of Wilderness under the Wilderness Act of 1964. These quasi-Wilderness areas have been essentially managed as Wilderness. Millions if not billions of dollars have been spent on closing, re-contouring, removing culverts and bridges, and gating roads in these areas. Until Roadless areas are designated by Congress as Wilderness, they should be returned to General Forest designation and kept open to public access, logging, and recreational use and development. In context to the amount of Wilderness and Roadless Areas in our National Forests, they are disproportionate to the amount of non-wilderness in acres and use. Wilderness and Roadless Areas make up nearly ½ of all National Forest lands, totaling 46 to 48 %. Of that, total Roadless areas are shown to be 58.2 million acres which is 30 % of all National Forest land. The National Visitor Use Monitoring Program shows that only 9 percent of Recreation use occurs in the Wilderness of the United States. Even more revealing is the Visitor use on the Payette National Forest of Idaho, my home forest. Wilderness area on the Payette National Forest occupies 790,000 acres or about 1/3 of the Forest. Of the 519,000 visits on the Payette National Forest in the 2018 monitoring year, only five thousand visits were in the wilderness. That is a 0.96 % use rate, or less than 1 %. Designated Roadless occupies 1.7 million acres. Combined, Wilderness and Roadless designation makes up 74% of the total Forest acres. If those numbers hold true, 514,000 visits occur on 26 percent of the Payette National Forest, leading to overcrowding and overuse. As a result, the opportunity for multiple use is very limited and restricted. Recreational businesses in these areas are very depressed. I am very much in favor of rescission of the Roadless rule, and increasing roaded recreation. In addition, I challenge the statement that 0.5 to 1 mile per section of roads exists within our national forest system. If 74% of the forest is Roadless or Wilderness designation, this statement cannot be true. This measure is misleading and unreasonable. The numbers above do not support that statement. In addition, I would support rescission of the Roadless Rule in Idaho. As a retiree Forest Service employee, I volunteered to be an Access Management Collaborative Team Member. The process that I was a part of is flawed and dominated by payed environmental groups, tribes, and likeminded members that have closed most of Forest Service designated roads on the Payette National Forest. Membership and goals of these groups represent only a small percentage of the population of Idaho and the nation. As an example, the Nez Perce Tribe only has 3,500 designated members. The collaborative process needs to be restructured. The roads that remain open on the Payette National Forest resulting from these collaborative processes are the ones protected by law and managed by the County. These roads access communities and are primarily “pass through” travel ways. This road strategy does not support distribution of recreation use or development of reasonable forest access portals. The current (and past) collaborative processes provide very little if any multiple use access. Nearly all Forest Service Roads built for logging, which cost millions of dollars to construct, have been closed. Our Roadless areas are extremely steep rugged mountainous terrain. They are very difficult to access and manage fires without portal access roads. These Roadless Areas are beyond most people’s capabilities to physically access. The extremely low use rates support this reality. We the public need a better balance. Thank you for the opportunity to comment. I hope these comments are seriously considered and a better, fairer access strategy can be developed for the rest of the 1.7 million Idahoans, and nearly 350 million US citizens, rather than those represented in these collaborative groups.

I would like to comment on the proposed repeal of the Roadless Rule for National Forests. I am a USFS retiree with a good familiarity with the forests in Northen California and Southern Oregon. I worked in planning for timber harvest and other uses, and was also a fire fighter when extra help was needed. I like to hike and fish in national forests. If you are just putting all of these letters in two piles, I will start by saying the roadless rule should definitely be repealed. It is basically an executive order, which was contrary to the intent of congress, and makes a broad-brush general decision which is not always in the public interest. The roadless areas in question are for the most part lands which were released for multiple use management in the various state wilderness Acts. The release language does not mandate that each roadless area be managed for timber production, but it does direct the USFS to look at each roadless area individually and make a case-by-case decision on how to manage it in the public interest. Any proposals to actively manage roadless areas would still be subject to the requirements of the Endangered Species Act, the Clean Water Act, the NEPA Act, and the National Forest Management Act of 1976. The repeal of the roadless rule would not mean that all or a majority of the roadless areas would be roaded and logged or mined. In the forests I am most familiar with, during the time period after the Northwest Forest Plan but before the roadless rule, about 80% of the released roadless areas were put into a land allocation that basically called for preservation, such as late successional reserve or semi-primitive recreational use. The 80% might have been available for some form of thinning or fire salvage, but were always the lowest priority. Some of the inventoried roadless areas are not really roadless, either because old roads were left out of the inventory or because they were roaded in the interval between the California Wilderness Act and the listing of the Northern Spotted Owl. However, once the roadless rule was finalized, it seemed that the boundaries were practically impossible to change. As the climate changes, disastrous wildfires are becoming larger and more frequent, especially in the west. Thinning of smaller trees, with removal of usable wood and disposal by piling and winter burning of the unusable slash, is an important tool to make the forest more resilient, leaving a stand consisting of the more fire-resistant species and the healthiest trees, at a spacing which is dense enough to allow canopy closure within 15 years, but open enough to allow the development of a good root system for better drought resistance, and thicker, more fire resistant bark This treatment can not be done economically more than a quarter mile from a road, In theory, section 294.13b of the roadless rule allows commercial thinning which would remove usable wood to reduce the cost of the fuels reduction. But in practice, the designation of roadless has been a lawsuit magnet preventing active management. The oft repeated argument that approximately 80% of all man caused fire ignitions occur close to a road is a very flawed analysis, for several reasons. First, it does not break it down by type of road. The roads going through national forests include state highways with a traffic of thousands of vehicles daily, county roads which might see over 100 vehicles per day, and main forest service roads which would see dozens per day. A single lane, unpaved road in a former roadless area, in contrast, would probably see only a few vehicles per week, and might well be gated or otherwise closed during high fire season. On which roads are fires more likely to occur? The second flaw is that the study ignores lightning fires. In a typical year, lightning may cause only 10% of the ignitions, but some of the worst fire seasons in recent history have been caused by late summer dry lightning storms up and down the state of California, which ignited hundreds of fires at once. These dry lightning storms seem to be getting more common, which could be an effect of climate change. The location of lightning strikes is pretty random. I don’t know whether anyone has studied the distribution of lightning strikes, but I suspect that, if anything, they would be concentrated in higher elevation areas that are more likely to be unroaded. The third flaw is that ignitions need to be evaluated together with ease of suppression access, rate of fire spread and resistance to control. Water quality and fish protection is not a real issue in this decision. The forest service has a good record in the past 30 years of locating roads where they will not adversely affect streams, and using skyline techniques on steeper slopes which minimize soil disturbance, as well as respecting the riparian reserves established in the Northwest Forest Plan.

Agency: U.S. Forest Service 
Docket: Proposed Revision/Rescission of the 2001 Roadless Rule To Whom It May Concern: My name is Dede Smullen, Co-Founder, Owner, and Board Chair of Earth Foundries, and a current Board Member, former Board Chair, former CEO, and former President of the Santa Clara County FireSafe Council. My work focuses on forest health, biomass utilization, wildfire resilience, and community wildfire risk reduction. I support revising the Roadless Rule to provide the U.S. Forest Service with greater flexibility to construct, maintain, and improve roads where necessary for wildfire mitigation, forest restoration, hazardous fuel reduction, and emergency response. Roads are a management tool and are often essential for the responsible stewardship of our public lands. This issue is personal to me. I have been directly impacted by both the Dixie Fire and the Park Fire in the Lassen National Forest region. These fires demonstrated the consequences of fuel accumulation and the challenges of managing large forest landscapes where access for restoration, fuel reduction, and suppression activities can be limited. Through my work with Earth Foundries, I have seen firsthand how inadequate access can increase the cost and complexity of forest restoration projects. Roads are often necessary to conduct mechanical thinning, remove hazardous fuels, and transport excess woody biomass to productive uses. Without access, many restoration projects become economically infeasible, leaving dangerous fuel loads on the landscape and reducing opportunities to utilize material generated through restoration efforts. Likewise, through years of leadership with the Santa Clara County FireSafe Council, I have seen the value of strategic access for fuel breaks, vegetation management, prescribed fire, and emergency response. Effective wildfire resilience depends on giving land managers the practical tools needed to reduce risk before catastrophic fires occur. I am concerned that the discussion surrounding the Roadless Rule increasingly emphasizes recreation and recreational access while overlooking the urgent need for active forest management. Recreation is an important use of our National Forests, but healthy forests, protected watersheds, resilient wildlife habitat, and safe communities must remain the highest priorities. I encourage the Forest Service to adopt a balanced approach that allows roads when they are necessary to improve forest health, reduce wildfire risk, support restoration activities, and protect communities and natural resources. Project-specific environmental review and modern best management practices can address resource concerns more effectively than blanket restrictions on access. Our public lands should be managed for long-term ecological resilience, not maintained under policies that can limit the ability to address conditions that contribute to catastrophic wildfire. Thoughtfully planned roads can help ensure that forest managers have the access necessary to restore and steward these landscapes for future generations. Thank you for considering my comments. Sincerely, Dede Smullen 
Co-Founder, Owner & Board Chair, Earth Foundries 
Current Board Member, Former Board Chair, Former CEO & Former President 
Santa Clara County FireSafe Council

PROPIN CONFIDENTIAL FS-2025-0001 RIN 0596-AD66 OMB 0596-0178 Title: USDA Forest Service - CAT Notification of Declaration of Direct Final Rule and Declaration of Policy I am Requesting the Exception for the Application for the Associated land management planning process and plans, and this written Request to File a Petition, to the Secretary of the Department of Agriculture, the Administrator of the Environmental Protection Agency, the Secretary of the Interior, the Secretary of the Department of State, Treasury, DHS, DOT, DoW, Department of Navy, Coast Guard and National Guard, the Directors of the Office of Management and Budget, the Department of Justice Attorneys General, Office of Special Counsel, Assistant Attorneys General, OLC, Solicitor General, and the Director of Forest Service, confirming the commitment by Petitioner as a cooperating agency in any environmental analysis for rule-making processes to Rescind to 2001 Roadless Area Conservation Rule. Effective 09/18/2026 for immediate effect upon review. To establish National Park Service under the Forest Service, by the implementation and enactments of the Forest and Rangeland Renewable Resources Planning Act of 1974 as amended by the National Forest Management Act of 1976, shall allow for the Submission of voluntary Petition under the Federal Advisory Committee Act consistent with the Multiple-Use Sustained-Yield Act of 1960, to sustain the multiple use of renewable resources in perpetuity while maintaining the long term health and productivity of the land, human benefits, and the integrated resources within this plan area in the context of the broad landscape. By this Declaration of Policy, the Construction or reconstruction of a highway or any project eligible for assistance, including bond costs incurred by the State in performing Federal-aid project related audits that directly benefit the Federal-aid highway program, including mapping, engineering, project development and management, replacement of housing sites, restoration, rehabilitation, determination of rights-of-way, improvements to wild-life crossings, and capital improvements that directly facilitate an effective vehicle weight enforcement program, such as scales fixed and portable, scale pits, scale installation, and scale houses, shall be carried out of the Federal-Aid Highway Act of 1956 as amended, for the regulations and the provisions of this Act to be provided for by the enactment of MP-21 and the enactment of the Federal Public Transportation Act of 2012 and the Amendments made to the Surface Transportation Reauthorization Act of 2021, to be carried out by the Secretary of the Department of Transportation the provisions of Title I - Authorizations and Programs to be appropriated out of the Highway Trust Fund and the Federal-Aid Program for all national highway performance programs under Section 119, improvement programs under Section 149, freight programs under Section 167, and carbon reduction under Section 175, in order to carry out the PROTECT program under Section 176, to further carry out Section 134 for the fiscal years 2022, 2023, 2024, 2025 and 2026, shall include Transportation Infrastructure Finance and Innovation Program and Tribal Transportation Program under Section 202 accordingly for the fiscal years of regulation. Please accept this Direct Final Rule Determination and Declaration of Policy of Rule-Making policy under the Administrative Procedure Act as amended, to all for this final declaration for the required Review of Final Judgments, Cooperative agreements, Appeals, Revocations, or any other legal actions necessary under the Office of the Assistant Attorney General, and OPM, the Executive Department, for projects stated and affirmative action, shall be authorized by this written statement of final actions for the purposes and the Paperwork Reduction Act as amended. Thank you for your attention to this matter. God bless. Direct Final Rule Declaration

To it May concern I’m in favor of the opening on the forest to allow maintaining the roads wildlife opening and doing controlled burns. I m disabled and have difficulty accessing the Shawnee national forest. I’ve hunter there since 1978 and since then have seen a noticeable drop in wild life numbers today compared to back then.Fewer Whitetail deer , rabbits , Turkey almost no quail now and fewer bat sightings. The. roads are need to access the go rest incase of fire and to maintain forest habitat and create a biologically important area for wildlife. The opening were historically created back in the 1930s . I’m not in favor over cutting the old growth the bats need just maintaining the small openings.As some who is disable I need roads where I will have access to the Shawnee National Forest Thank you for your time and maintaining our Forest

September 17, 2026 Director, Ecosystem Management Coordination 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124. RE: Docket number FS-2025-0001 or RIN 0596-AD66. Dear Director, As a child growing up in East Linn County there was commonly a fear of forest fire. When a fire broke out a couple of logging crews used well-maintained logging roads to access and extinguish the fire. The logging industry was very proactive because timber was how these people made their living; they wanted to protect that. There was a fear that a fire would get out-of-hand and there would be another great burn like the Tillamook Burn. Then sometime in the late 1980's the care of our timber resources took a shift. Major cutbacks on logging federally owned forests; no longer maintaining logging roads and no longer maintaining the forest but allowing underbrush to overtake the forest floors. The results have been obvious and it’s unbelievable that we continue to allow this inadequate forest fire management to continue. Some 40 years ago when this shift in forest management was proposed, my late mother's words were prophetic. "They can't do that! The forest will burn up!" Here we are in the 2020's and every year there is “Tillamook Burn” size fire. Every year for the last 20 years wildfire has been a great problem. You hear often of fires that are allowed to burn and burn because there is no road access. The saddest part of it all is we are not big enough to admit our error. We do not come out and say, "Our current forest management is not working, and we are paying the price; therefore, we need to make a change." I know many want to say, “the cause of all these fires is due to global warming” but that is ridiculous! Rescinding the national 2001 Roadless Area Conservation Rule would be a start to restoring our forest land to health and productivity and keeping our communities safe from intruding forest fires!

Roadless Rule and Travel Management Rule Statement Entering the public comment process, I am particularly interested in nearly one quarter of Inventoried Roadless Areas that today lie in the Wildland-Urban Interface (WUI). Upon reviewing the details of the proposed rule, alternative 3 appears to address these specific areas. Alternative 3 presents several items we support, including: Increased opportunities for hazardous fuel treatments in the Wildland-Urban Interface, where 9.8 million acres (or 24 percent) overlap with IRAs, and, where justified, would allow strategically placed roads that can improve suppression effectiveness near communities and critical infrastructure Expanded scope and applicability with the addition of boundary modifications. This supports local assessment and decision-making on the remaining 13 million acres that would be retained as roadless Expanded opportunities for active forest management and improving big game habitat Alternative 3 also presents some items that are of concern or require greater detail, including: I am seeking clarity as to why the mapping analysis used WUI as defined by Healthy Forests Restoration Act of 2003. The data source used may significantly alter the acreage removed from—or remaining in—roadless boundaries Modification to USFS Chief authority under § 294.14 Scope and applicability. As currently written, the Chief may make roadless boundary modifications to conform with new “statutory or regulatory requirements.” Modifications under these situations should follow typical processes to ensure compliance with the National Environmental Policy Act and other relevant laws and regulations

I am writing in support of the proposed rescission of the 2001 Roadless Area Conservation Rule. I am a forester in Clearwater County, Idaho, working with the Idaho Department of Lands under the Good Neighbor Authority program on the Nez Perce-Clearwater National Forest, with direct involvement in implementing forest health and fuels treatment projects on National Forest System lands. My comments address four substantive issues: (1) the de facto prohibition that results from litigation risk regardless of Idaho's state-petitioned rule; (2) the direct consequences I observed during implementation of the Dixie-Comstock Community Protection Project, where burned roadless areas adjacent to communities could not be treated; (3) the severely diminished working land base on the Nez Perce-Clearwater and its cascading economic and workforce impacts; and (4) the need to rebalance the multiple use mandate that has shifted persistently toward preservation at the expense of forest-dependent communities. My full comment is attached as a PDF document. Docket: FS-2025-0001 | RIN 0596-AD66 Jarel Bruce Good Neighbor Authority Forester Idaho Department of Lands — Nez Perce-Clearwater National Forest

The 2001 Roadless Rule is more complex than simply rescinding it. The National Forests were established to provide public benefits and access. I worked for the US Forest Service in the Sierra Nevada on multiple forests in California for 33 years between 1979 -2012 in a range of positions including timber management, special uses, recreation and forest health protection doing implementation, environmental planning as a line officer and program manager. I strongly support timber management, fire & fuels management and forest health management. While I believe the 2001 Roadless rule could use some adjustments over the years prior to the roadless rule I saw sensitive soils such as highly erosive granitic soils, wetlands, meadows and stream course crossings highly impacted by indiscriminate vehicle and off-road vehicle use, and mining activity. Roads in these sensitive areas caused substantial impacts to water quality and sensitive habitats. Road maintenance on national forest lands dramatically decreased after timber management was severely curbed by spotted owl management and the public who was against seeing short term impacts from logging. Given that the federal government is 40 trillion dollars in debt, the Iran war is up-to about 38 billion dollars, and the arbitrary firing and forced retirement of much of the skilled US Forest Service workforce I am skeptical that this administration is capable of following through to actually provide adequate road maintenance and a program to close temporary roads. Local community involvement in decision making to adjust roadless area access with temporary roads must be a criteria in the proposed rule. Authority for approving temporary roads into road less areas must be delegated to the Forest Supervisor level. And there needs to be a commitment to road maintenance and road closure budgets that will provide for water quality protection. Do Not send the US Forest Service back to the era where no management was accomplished due to public outrage and constant litigation. Be thoughtful, staff the US Forest Service adequately and provide the necessary funding to carry out its mission.

I am a retired USDA Forest Service entomologist who served from 1991 to 2019 in a group that is currently known as Forest Health Protection. Under the Cooperator Forestry Assistance act as amended, this group has forest pest management responsibility on all federal forested lands including those held in trust for tribes and tribal members. I therefore speak from experience having worked on national forests in Montana, Wyoming, South Dakota, Nebraska, Colorado, and Oregon. During my career, the roadless rule was created specifically that Congress, the sole designator of wilderness, would review the existing inventoried roadless areas for potential candidate consideration as additional wilderness areas. The purpose of the roadless rule was to halt temporarily any active land management nationwide that might interfere with Congressional consideration by potentially disqualifying inventoried roadless areas through active land management or other disturbances. The current roadless rule recision proposal summarizes the initial purpose of the roadless rule as follows,"In 2001, USDA and the Forest Service asserted that a national prohibition was the best means to reduce conflict and potential for incremental impacts to the ecological and social values of these areas." This is a serious error, as it is essentially incomplete. The temporary nature of this rule, as well as the essential purpose and need that Congress was to fulfill by review and decision regarding candidate wilderness areas are missing. In my experience, Congress never made a reasonable effort to perform this review and remained mute while misinformation and seemingly endless, frequently conflicting judicial decisions transmogrified the roadless rule's intent and purpose to become a permanent halt to active land management in all inventory roadless areas. In addition, candidate roadless areas, proposed though not officially designated by inventory, somehow became included in what I would describe as a widespread social movement to preclude permanently any active land management in all of these areas. Where we find ourselves today is ever so far from how the roadless rule began and what was intended. During the time that I worked on national forest lands, the roadless rule "evolved" into the single greatest obstruction to active land management. It has failed and fouled miserably, now a total mess. Both society and apparently the authors of the recession proposal do not understand the purpose, intent, and need of the original roadless rule. Congress dropped the ball, which metaphorically has crushed we who worked diligently to care for the land and the people. Because of its failure and what it has become through evolving public opinion and judicial inconsistency, I write in favor of the rescission of the roadless rule as stated in the proposal. I am, however, a staunch advocate for the creation of additional wilderness through Congressional designation and urge the USDA Forest Service to return to the original purpose of the roadless rule and get proposals submitted to Congress, individual forest by forest. Such a proposal should halt active land management until a decision is made by Congress. Meanwhile, we cannot just sit on our hands waiting to find out what might be preserved as wilderness while so much public land needs so much careful attention. Thank you for your consideration of my input. Yours truly, Willis C. Schaupp, Jr., PhD USDA Forest Service (retired)

I am in full support of removing the roadless rule. I’ve been a wildland fire fighter and forester for 20 years. I remember the forest service of my youth where every road was open and you could explore and truly enjoy our public lands. Teddy Roosevelt and Gifford Pinchot established the forest service to be managed and enjoyed for multiple uses. They said the Muir ideology was for the parks service. The national forests are not parks and their resources are supposed to fund the management and protection of the forests. They were always intended to be working forests to be managed for the greater good. What I see under the roadless rule is no access, no money for maintenance, terrible existing roads and infrastructure. Fires have become giant in area as well as costs. Aerial resources are great but they do not put out fires. It takes boots on the ground to put a fire to bed. Greater access and fuels reduction would lessen the size, duration, and costs of fires. The roadless rule must be rescinded and common sense management reinstated.

I am a long time Ontonagon county resident and user of the northern Ottowa NF. Please do rescind the road less rules. There is little actual use of these areas. The areas were not virgin forest when the lands were locked away. Allowing some of these logging roads to be used to access the lands now locked away will benefit more people wanting to access the lands for wildlife viewing; camping; berry, nut and mushroom gathering; hunting, fishing, and trapping. Much of the North Country Trail people write about as a wonderful wilderness walk are along the Norwich Bluffs and the Keeweenaw Escarpment are road less wonders of nature. The terrain will keep motorized vehicles away.

As a Lincoln National Forest Grazing allotment owner, I support the rescission of the 2001 Roadless Area Conservation Rule and offers the following comments: •Since 2001, I have witnessed the Roadless Rule—through centralized management and an extensive history of litigation—prove ineffective and costly. The rule never produced the expected results. •The results from widespread mismanagement as resulted in the loss of millions of acres of overgrown forests to wildfire, disease, and drought. •These losses represent billions of dollars in natural resources, including timber that could have been used to build affordable housing to replace homes lost to wildfires and to address the severe housing shortages frequently highlighted in media coverage of homelessness in major urban areas. I support rescinding the 2001 Roadless Rule because it will decentralize road management and place responsibility for creating, decommissioning, and maintaining roads with individual National Forest Supervisors. •Each National Forest is unique, and local supervisors are far better positioned to understand the environmental conditions and management needs of their respective forests than staff located in Washington, D.C., thousands of miles removed from on the ground realities. •Local decision making regarding road creation, maintenance, or decommissioning must consider multi use objectives such as recreation, grazing, forest thinning for fire mitigation, and overall forest health. I want to point out that having more trees does not translate into having a healthy forest, especially during droughts in the southwest. •Roads that were decommissioned under the Rule rarely received the funding necessary to address erosion issues either before or after decommissioning. Forest Supervisors should work directly with local Soil and Water Conservation Districts to resolve these problems. •Each National Forest’s Land Management Plan should address road system needs based on local conditions and priorities. •Roads identified as Potential Operational Delineation (POD) boundaries must be thinned and upgraded to standards that ensure safe ingress and egress during wildfire events. •Individual National Forests must be adequately resourced—with both funding and personnel—to maintain existing roads and prevent the creation of illegal user built roads and illegal dumping on Forest Service lands. •Individual National Forests should provide clear, detailed information in their Land Management Plans describing how they will manage the road system. Additionally, taking more than seven years to revise a Land Management Plan is unacceptable; for example, the revision of the 1986 Lincoln National Forest Plan, ongoing since 2019, has taken far too long with no clear end in sight.