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To the U.S. Department of Agriculture and U.S. Forest Service: I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. This action would gut protections for roughly 45 million acres of national forest land that belong to all Americans. I urge the Department to withdraw the proposal and keep the Rule in place. Drinking water. Roadless areas protect some of the last wild forests in the country. These watersheds help provide drinking water to about 25 million people, including 1 in 4 Californians. Road construction and logging in these areas threaten water quality for communities that depend on them. Wildfire. The Department has justified this proposal as a wildfire measure. That justification does not hold up. Research shows that roads increase the risk of human-caused ignitions, and roadless areas are less prone to them. Old-growth forests are also naturally more fire resistant. Importantly, the existing Rule already allows small-diameter tree removal to reduce underbrush and lower fire risk, so rescinding it is not necessary to manage fuels. Capacity. The Forest Service has lost staff, including wildland firefighters, under this administration. Weakening protections while cutting the workforce that manages and defends these forests does not make communities safer. Public support. More than one million people have already submitted comments on this proposal. Thousands more have signed petitions urging the Department to keep protecting roadless forests. These lands are held in trust for the public, and the public has made its position clear. I respectfully request that the USDA abandon the proposed rescission and retain the Roadless Rule in full. Respectfully Randy Kalp Barnstable, MA 02632

Dear Special Areas: Roadless Area Conservation, se01nsnn se01nsnn , As someone who cares deeply about national parks, national forests, complete ecosystems and the public lands that sustain them, I urge you to choose the No Action alternative and keep the Roadless Rule in place. For more than two decades, the rule has protected roughly 44.7 million acres of ecologically intact national forest lands, including areas near Yosemite, Yellowstone, and Great Smoky Mountains national parks. These wild places safeguard clean water, provide essential wildlife habitat, support outdoor recreation, and help keep park ecosystems connected and healthy. Rescinding the rule would expose these treasured landscapes to new roads and development, fragmenting habitat, degrading waterways, and putting our parks at risk. Many public lands are already available for timber and energy development. Roadless protections apply to only about 30% of National Forest lands, making these remaining intact areas especially important for future generations. Moreover, roadless areas in our national forests protect the headwaters of numerous rivers that provide cities miles away with the water resources they need to keep the economy running. Clean water and clean air is essential for everyone's health and supports future generations. Wildfires start near roads, so more roads are more risky! A study highlighted by science communicator Ross Reid found that one of the strongest predictors of wildfire risk may be something many people use every day: roads. The finding is prompting renewed scrutiny of federal officials' claims that building more roads into forests could help with fire response and prevention. In a TikTok post, Reid said researchers at the U.S. Forest Service found a strong link between roads and wildfires, with most ignitions occurring within 164 feet (50 meters) of a roadway. Please do not move forward with this unnecessary rollback. Keep the Roadless Rule in place to protect the forests, wildlife, clean water, and the national parks. Dawn Tesorero 18 Wellsmere Park Roslindale, MA 02131 Sincerely, Dawn Tesorero

Subject: Public Comment: Strong Opposition to the Proposed Repeal of the 2001 Roadless Area Conservation Rule Dear Secretary of Agriculture and Chief of the U.S. Forest Service, I am writing to submit my formal opposition to the proposal to repeal the 2001 Roadless Area Conservation Rule. As a Massachusetts resident who frequently hikes the rugged, intact trails of the Berkshires, I know firsthand how vital undisturbed forest lands are to our environment, wellness, and local economy. In a densely populated region like New England, our remaining wild spaces are already rare and highly fragmented. Allowing road construction and industrial exploitation in our nation's remaining roadless areas is an irreversible mistake. I urge you to maintain the current rule based on the following evidence: • Protecting Rare Eastern Refugia: Unlike the vast public lands of the American West, intact forest ecosystems in the Northeast are scarce. The Roadless Rule protects critical, contiguous blocks of mature forest that act as essential climate refugia. These unfragmented habitats allow regional wildlife—from native brook trout to migratory birds—to adapt to a changing climate. Industrializing these areas destroys corridors they cannot afford to lose. Please. • Escalating Wildfire Vulnerability: The premise that road building mitigates wildfires contradicts established fire science. Forest Service data demonstrates that timber roads actually increase human-caused wildfire ignitions and alter forest microclimates, making them more combustible. As someone who treasures the peace and safety of hiking trails country wide, I object to policies that introduce unnecessary fire risks into pristine public lands. • Securing Clean Drinking Water: Roadless areas safeguard the headwaters of watersheds supplying clean drinking water to over 60 million Americans. According to hydrological research, road construction triggers severe soil erosion and sedimentation. In New England, preserving forested watersheds is our most cost-effective tool for protecting municipal water quality and avoiding multi-million-dollar water treatment upgrades. • Fiscally Destructive Policy: The U.S. Forest Service currently faces an estimated $4 billion to $5 billion backlog in maintaining its existing network of over 370,000 miles of roads. Subsidizing new road construction for private commercial interests while failing to maintain existing infrastructure is a gross misuse of taxpayer resources. • Ignoring the Public and Tribal Nations: Past public comment periods regarding the Roadless Rule have yielded an unprecedented 99% consensus from millions of Americans demanding these lands remain protected. Furthermore, this rollback disregards resolutions from numerous Tribal Nations. Federal land management must respect indigenous sovereignty and the overwhelming public desire to preserve our shared natural heritage. The 2001 Roadless Rule is an incredibly successful, cost-effective conservation policy. For the future of our forests, our climate, and the millions of Americans who find solace in places like the Berkshires, Yosemite, Bryce Canyon, and Sequoia (all places I hike and love as well), I strongly urge the USDA to reject commercial rollbacks and keep the Roadless Rule fully intact. Thank you for your time and your review of this evidence. Sincerely, Lilian Correa, Northborough, MA 01532

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The White Mountains are sacred. I cannot think of another word for them. I do not get there as often as I would like, but roadless areas in the White Mountain National Forest are places I hold as genuinely irreplaceable. Wildlife and the natural spaces they depend on have been pushed and pushed already. They have more value left as they are than anything else that can be imagined. These lands belong to the people of this country, those of the past, present, and future. The people of the past and the people of the present have paid for these lands with their tax dollars to preserve them for nature, and for those in the future who will continue preserving them. The proposed rescission of the 2001 Roadless Area Conservation Rule works against that obligation, and I ask the agency to answer the following points in the record before proceeding. The proposal invokes wildfire and fuels management as part of its rationale. The agency's own findings directly contradict that reasoning: "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 White Mountain's 16 inventoried roadless areas total 240,669 acres and serve as headwaters for rivers flowing to the Connecticut, the Merrimack, and the Saco, supplying drinking water to communities across New Hampshire, Vermont, and Massachusetts. Opening roads into those drainages increases ignition risk by the agency's own measure. I ask that the agency explain why this proposal departs from its own prior findings, and that it reconcile the rescission with the ignition data in DEIS Table 21, which shows far higher fire density on roaded land than inside affected roadless areas. The economic justification for rescission does not hold up against the agency's own numbers. The record states that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." New Hampshire alone holds 15 inventoried roadless areas totaling 234,681 acres, and across the Eastern region, which includes New Hampshire, 286 municipal water intakes sit in watersheds containing affected roadless areas. The recreational and watershed values at stake in places like the Pemigewasset and Wild River are not marginal. I ask that the agency reconcile the proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue to the Forest Service against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog constitutes sound management when the agency's own analysis cannot establish a net benefit. The proposal argues that state-specific approaches can substitute for a national rule. The agency's own record notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency tried that state-by-state substitution before, and it failed in court. Moose, black bear, American marten, Bicknell's thrush, brook trout, Canada lynx, and the northern long-eared bat all inhabit the White Mountain roadless areas. Their habitat does not respect state lines, and neither do the watersheds these areas protect. The agency must address its own prior finding that local decision-making incrementally erodes nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified the last time a state-by-state approach was attempted. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. That question was already answered. 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." The court found the 2001 rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The Weeks Act of 1911 itself was passed specifically because of what happened when New England's mountains were clearcut. The White Mountains are what they are because of federal protection, not despite it. The agency must explain the legal basis for any position contrary to the Tenth Circuit's holding before this rescission proceeds further. Sincerely, John Minkle Malden, MA 02148

I write in opposition to rescinding the 2001 Roadless Area Conservation Rule. I grew up hiking and camping in the White Mountain National Forest and have spent weeks in the Green Mountain National Forest. I visit less often now that I am older. Yet I return to the White Mountains to be embraced by forested lands for a refreshing respite from my urban life, breathing the bracing, scented air deeply. The Roadless Rule safeguards nearly 45 million acres of national forest lands. We came to these stewardship protections the hard way, after suffering great losses whose lessons we risk forgetting. During Reconstruction after the Civil War, demand for timber was high and forest clearing widespread. In 1873, the young superintendent of the Adirondack Survey, Verplanck Colvin, age 26, could see the forest for more than the trees. He warned that continued clear-cutting would reduce water flowing to the Erie Canal and Hudson River, commercial waterways on which New York’s burgeoning economy depended. Vermonter George Perkins Marsh’s book, Man and Nature; or, Physical Geography as Modified by Human Action, helped people understand how destroying forests could undermine the watersheds sustaining their prosperity. New York established the New York State Forest Preserve in 1885, protecting approximately 681,000 acres in the Adirondacks and another 34,000 acres in the Catskills. Much of this land had come into state ownership through unpaid-tax forfeitures after logging and abandonment. Subsequent purchases and other acquisitions expanded the protected forests. New York recognized that these watersheds' public value extended far beyond the timber standing on them. The Green Mountain and White Mountain National Forests also protect headwater streams that feed rivers across state boundaries. The White Mountain National Forest contributes to the Connecticut, Merrimack, Saco, Androscoggin, and Presumpscot river systems. The Green Mountain National Forest shelters headwaters of the White, West, and Deerfield Rivers, which feed the Connecticut; the Batten Kill, renowned for trout fishing, which feeds the Hudson; and Otter Creek, which flows into Lake Champlain. Opening inventoried roadless areas to additional roads and timber harvesting would put these upstream protections at risk. The consequences could reach downstream communities through erosion, sedimentation, and damage to water quality and aquatic habitat. Decisions made within one national forest can affect people far beyond its boundaries. Rescinding the Rule would be penny-wise for logging industries and pound-foolish for Americans. I urge USDA to retain the 2001 Roadless Rule. Rob Moir, PhD Executive Director Ocean River Institute 12 Eliot Street Cambridge, MA 02138

Dear Special Areas: Roadless Area Conservation, se01nsnn se01nsnn , As someone who cares deeply about national parks and the public lands that sustain them, I urge you to choose the No Action alternative and keep the Roadless Rule in place. I have enjoyed many visits to public lands and know how important it is to protect wildlife and pristine places. Please do not move forward with this unnecessary rollback. Keep the Roadless Rule in place to protect the forests, wildlife, clean water, and the national parks. Tova Soyt 91 Carlton Circle Brewster, MA 02631 Sincerely, Tova Soyt

I’m an American citizen. Please maintain protections for the 45 million acres of wild and roadless forests and don’t rescind or alter the Roadless Area Conservation Rule. These forests are full of mature and old-growth trees that provide important wildlife habitat. They’re our favorite places to hike, fish and camp. Wild forests should remain protected from road-building, commercial logging and mining. Industrial activity would destroy these beautiful trees and many trails we love. Keep our national forests wild. Please respond. Thanks very much. Sincerely, Christopher Herlihy 47 Tileston St Apt 8 Boston, MA 02113-1933 chris47t@yahoo.com

Please maintain protections for the 45 million acres of wild and roadless forests and don’t rescind or alter the Roadless Area Conservation Rule. These forests are full of mature and old-growth trees that provide important wildlife habitat. They’re our favorite places to hike, fish and camp. Wild forests should remain protected from road-building, commercial logging and mining. Industrial activity would destroy the trees and trails we love. Keep our national forests wild. These forests, owned by the people, not corporations, are public and require our stewardship for the additional, more important reason that they are environments that support life, including ours. They promote biodiversity, the water cycle, and the cooling of the planet. It's not just that they are great places to recreate. They are imperative to protect from destruction because they support Life on Earth. Sincerely, Laurel Facey 47 Davis Rd Millers Falls, MA 01349-1313 lfacey88@crocker.com

I’m an American citizen. Please maintain protections for the 45 million acres of wild and roadless forests and don’t rescind or alter the Roadless Area Conservation Rule. These forests are full of mature and old-growth trees that provide important wildlife habitat. They’re our favorite places to hike, fish, and camp. Wild forests should remain protected from road-building, commercial logging, and mining. Industrial activity would destroy these beautiful trees and these trails that we love. Please make sure to keep our national forests wild. Thanks very much. Sincerely, Christopher Herlihy 47 Tileston St Apt 8 Boston, MA 02113-1933 chris47t@yahoo.com

The current administration is opening protected lands to development, mining, oil & gas drilling. With the intention of getting more money for himself, his family, his friends and any billionaire willing to back him. I’m disgusted by the way everyone just gives him what he wants. There are no consequences for any of these people that would deter them from making money. They’d sell their mother’s pacemaker right out of her (still alive) warm body. The Forest Service has to keep the Roadless Rule intact, exactly as it is, utilizing Alternative 1 in the current DEIS. No change. Leave the rule as it stands today. Rescinding the Roadless Rule serves no one but the filthy rich glutinous pigs that benefit financially from the rule ending. Roadless areas provide important benefits to everyone, including clean drinking water, wildlife habitat, and protection from the impacts of development. Nature is paramount to physical, psychological and spiritual wellbeing. Rescinding the Roadless Rule will increase development, reduce natural wildlife habitat, and increase wildfire risk. The local economy will be affected by rescinding the Roadless Rule. Local businesses that depend on the outdoors to bring people into their businesses will lose their main source of income. This includes all vacation rentals, grocery stores, restaurants & gear rentals, all of whom will undoubtedly loose enough business that employees are released and businesses close. The Roadless Rule has provided consistent, nationwide protections for these special places for decades. The Forest Service must not weaken those protections or open currently protected roadless lands to new development, and you should be helping and supporting Alternative 1 and retain the existing Roadless Rule protections. Sincerely, Lisa DeChiara 3 Millenium Way Rockland, MA 02370-1277 lisadechiara@ymail.com

I urge you to suspend the current proposal to rescind the 2001 Roadless Area Conservation Rule (i.e., “Roadless Rule”). The Roadless Rule was created with overwhelming public support and has protected forests for more than 25 years. Decisions about these areas should be based on science, not short-term corporate interests. These protected forests provide important habitat for wildlife, protect clean water, and give people opportunities to enjoy and connect with nature. These places should continue to be protected, not fragmented, logged, and mined for private or corporate benefit. I have a deep connection to the forests surrounding the Caribou-Speckled Wilderness, some of the now-threatened Roadless Areas in Maine. These intact ecosystems are special places for people to visit, explore, and learn about nature, provide habitat for several threatened species, and are home to some of New England's last remaining old-growth forests. Mainers cannot afford to lose the habitat and water quality benefits provided by these Roadless Areas. I urge you to protect these places for future generations by suspending the current proposal to rescind the Roadless Rule. Sincerely, Karina Tuting 3 Thomas Ave Scituate, MA 02066-4713 ktuting@gmail.com

Dear Special Areas: Roadless Area Conservation, I see habitat loss where I live on Cape Cod. I urge the U.S. Forest Service to keep intact the existing Roadless Area Conservation Rule (“Roadless Rule”), which protects nearly 45 million acres of our nation's forests and grasslands. Prior to the rule's implementation in 2001, industrial logging and accompanying roadbuilding disrupted and destroyed 3.2 million acres of fragile habitat annually while also degrading clean water supplies and limiting outdoor recreation opportunities. For a quarter century, the Roadless Rule has protected ecologically sensitive landscapes, wildlife populations and habitat, and communities dependent upon their services. The rule protects countless wild animals, including imperiled species who rely on intact habitats for survival. Additionally, these lands provide clean water and support numerous recreational activities that sustain local jobs and economies. The rule allows for flexibility in resource management, with exceptions for vegetation management and road construction projects in the interest of public health and safety. The American public overwhelmingly supports the Roadless Rule; recent bipartisan polling shows that 77% of voters support conserving roadless lands. Indeed, the rule was created with input from over 1.6 million comments and, in September, over half a million Americans responded to the U.S. Forest Service's notice of intent to repeal the Roadless Rule with comments voicing strong opposition. We have made our opinion clear time and time again–our public lands should remain public, not be degraded for the interests of private industry. I strongly urge the U.S. Forest Service not to repeal the Roadless Rule, as keeping the rule intact will protect our shared forestlands for generations. Sincerely, Denise Perrault 28 Lake Drive South Dennis, MA 02660 Sincerely, Denise Perrault

I am writing to express my strong opposition to the U.S. Department of Agriculture’s (USDA) proposed rule to remove 36 CFR Part 294 Subpart B, which rescinds the 2001 Roadless Area Conservation Rule. Nationwide prohibitions on road construction and timber harvesting in Inventoried Roadless Areas (IRAs) provide essential protections for 58.5 million acres of National Forest System lands. Scrapping national protections for fragmented, forest-by-forest planning fails to ensure sustainable resource management. I urge the USDA to select the No Action Alternative and retain the 2001 Rule. 1. Flawed Rationale on Wildfire Risk & Active Management The preamble claims national prohibitions constrain necessary fuels management and wildfire response. This misstates the existing rule's provisions. Under 36 CFR 294.13(b), the 2001 Rule already allows timber cutting and fuel reduction to reduce wildfire risk, clear hazardous fuels in the Wildland-Urban Interface (WUI), and control insect or disease outbreaks. Furthermore, industrial road building opens contiguous forest canopies, dries out forest floor fuels, and introduces invasive plants that carry higher fire frequencies. The preamble acknowledges that increased road access elevates human-caused ignition risks. Rescinding the rule will likely compound wildfire hazards rather than mitigate them. 2. Fiscal Inefficiency & Road Maintenance Backlog The Forest Service faces an estimated $6.9 billion deferred maintenance backlog for existing roads and bridges. Expanding permanent or temporary road networks into remote areas creates long-term financial liabilities the agency cannot support. Economically, the USDA’s analysis estimates potential timber revenue gains of $5.2 to $11.4 million per year, while acknowledging annual losses of $6.1 million to the outdoor recreation economy in operable areas alone. Negligible timber gains do not justify permanent damage to recreation, outfitters, guides, and local tourism economies reliant on unsegmented public lands. 3. Inadequate Assessment of Cumulative Impacts Under NEPA Delegating roadless management entirely to 192 individual forest planning processes violates landscape-level conservation standards: Habitat Fragmentation: IRAs serve as core habitat buffers and migration corridors for threatened, endangered, and sensitive species. Evaluating impacts piecemeal across individual forest units ignores cumulative, landscape-scale ecological degradation. Drinking Water Protection: Over 60 million Americans rely on National Forest lands for clean drinking water. Removing baseline protections risks sedimentation, soil erosion, and water degradation in headwater streams across critical watersheds. 4. Failure to Uphold Tribal Trust Responsibilities The majority of Tribal governments consulted oppose this rescission. Shifting from a protective nationwide standard to unit-by-unit planning forces an unsustainable administrative burden onto Tribal resources to repeatedly contest individual project proposals that threaten sacred sites, traditional gathering areas, and treaty-reserved rights. Proceeding despite widespread Tribal opposition undermines the Federal Government’s trust responsibilities and Executive Order 13175. Requested Action The 2001 Roadless Rule provides a stable, ecologically vital framework for managing national forests. Returning to fragmented management will increase litigation, inflate maintenance costs, and permanently degrade public lands. I respectfully request that the Department: 1. Reject the proposed rescission (RIN 0596-AD66). 2. Adopt the No Action Alternative in the Final EIS. 3. Preserve 36 CFR Part 294 Subpart B to safeguard Inventoried Roadless Areas. Respectfully submitted, DiMari D’Agostino Massachusetts State Constituent Swampscott, MA 01907 (845) 492-6268