Read the comments.

Under Secretary Boren Chief Schultz Secretary Rollins I am writing to ask you to support the “No Action Alternative” regarding eliminating the Roadless Rule Recission. After retiring from working for the USFS for 30 years I would love to go into the reasons why I am asking this but this Administration is short on Science/facts & long on stupid so I feel I’s be wasting my time; besides, I believe the die has been cast & the decision already made. However, I want my name to go on the record as opposing eliminating the Roadless Rule. FYI – I am a member of the Backcountry Hunters & Anglers, the National Association of Forest Service Retirees & the National Parks Conservation Association.

The Roadless Area Conservation should not be eliminated or even compromised. The chunk of protected areas that are already being destroyed my trump's reckless and selfish administrative choices are going to cause a lasting impact that we cannot even begin to comprehend because even our research budgets are being slashed or outright obliterated. There is a point when humanity needs to take priority, and protecting the earth we stand on in the biggest and most important way to show that we have not lost said humanity. We need to care, we are at a time in our history where being jaded can no longer be the justification for watching the world crumble. Alternatives always exist, lets not commit the same crimes the Europeans caused when they set foot in the Americas, the crimes against nature, for which there is no undoing. Please protect out Nature, Please help keep our humanity

This proposed rule is unnecessary. The Roadless Rule already explicitly allows the government to manage these places for forest health and fire prevention. Actions like tree cutting and other fuel removal work—and even road construction in cases of imminent fire threat—are allowed. The existing rule also allows habitat restoration and post-fire recovery projects while avoiding unnecessary heavy road construction. Research has found that roughly 90% of all wildfires start within a half-mile of a road, and that 88% are human-caused—with roads acting as corridors for human error, including accidental sparks, unattended campfires, and other ignition sources that can spark blazes. A separate analysis of four decades of satellite data found that Roadless Areas have not burned at significantly higher rates or severity than roaded forest lands, and that in the most recent decade, roadless areas burned at a slightly lower rate than forests with roads. That intention of this proposed rule was evident in August 2025, when Secretary Rollins first announced a potential rule rescission. She declared a “timber emergency” and called the Roadless Rule an “absurd” obstacle to common-sense management because it prohibited the Forest Service from fulfilling its mandate to get more “logs on trucks.” Yet, roadless areas provide clean drinking water to 60 million Americans. And, the outdoor recreation economy generates $730 billion annually, far more than timber sales.

I oppose rescinding the roadless rule on the grounds that it would increasing the risk of wildfire in this country. In a study published in the journal Fire Ecology in January of 2026, scientists analyzed 32 years of data from across all U.S. forest regions and found that areas within 50 meters of roads were four times more likely to catch fire than areas that were roadless. It stands to reason, then, that building more roads into forests will increase wildfires. Wildfires not only harm the biodiversity living in our national forests, they put more carbon dioxide into the air, speeding up climate change. They also fill the air of cities and towns with smoke, endangering the health of U.S. citizens, and especially vulnerable people, such as myself. At a time when fire crews are tasked to their limits and barely able to contain the fires that have already been on the increase each fire season, rescinding this rule poses a grave threat to our country. I am citing the following study as evidence: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 I would also like to submit the following additional evidence: Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography.

I oppose the rescinding of the 2001 Roadless Area Conservation Rule by removing and reserving 36 CFR part 294, subpart B. If Secretary of Agriculture Brooke L. Rollins were truly interested in sustainable forests, there are other routes to take than creating roads that bring in more risk of fire and threaten healthy habitat. There would be more (not less) foresters at work, there would be more investment in community/ federal cooperation, and the roadless rule would be amended as needed --- not revoked wholesale. Currently the Forest service and the BLM are failing to protect old growth from logging by the government, failing to fund for research centers that provide data and best practices for forwst management and firefighting. Elimination of the road this rule is simply a way to make money for certain corporations aligned with the government. It is not for the benefit of communities and the United States people. We want our land protected. We want old growth and medium grows Forest to stay established to help fight climate change. We want more research more funding and more Foresters. Not more roads.

Dear USFS, I'm asking you to reconsider rescission of the Roadless Rule. I am a hiker and researcher who spends a great deal of time in wilderness. In areas where there are roads, the character of the forest is completely different and cannot be studied in the same way as areas that have not been trammeled by humans. I also lost my home in the 2020 Castle Fire, and so I speak as someone well aware of fire and the effects on the landscape. I witnessed first hand how the wind-driven fires simply blew through areas with roads that were supposed to act as fire breaks. Sequoia National Forest is already overrun by grazing (cows are squashing brand new sequoia seedlings that came up post-fire) and logging. There is so little intact forest left, especially old growth, and these areas need to be left alone. Rescission would harm me by further disabling my ability to do research and documentation as well as personal enjoyment. I am deeply connected to the sequoias, especially the more remote groves, and implore you to keep these few remaining areas wild. Thank you, Kim Dicso

The Roadless Rule is essential is preserving biodiversity in the United States. Study after study demonstrate that our current protected areas, including national parks, wilderness areas, and wildlife refuges, are simply too small and fragmented to adequately preserve biodiversity. However, the addition of the roadless areas that are not directly impacted by humans make a big difference by extending the size and reducing isolation of fully protected areas. As an example, I suggest you review the study of Crist et al (2005), which shows that in the northern Rocky Mountains, roadless areas add 2.6 million hectares of additional protected land. This additional land increased all land cover types, including increasing 15 types by more than 40%, which demonstrates the diverse ecosystems that the roadless areas protect. The paper also shows that landscape connectivity was improved in terms of area, isolation, and aggregation. I'll provide the citation at the end of this comment for closer review. The National Forest Service manages approximately 193 million acres of land and only about 58 million of which are protected by the Roadless Rule. This leaves 135 million acres to be managed in the typical way, which allows for road construction, road reconstruction, and timber harvesting. That is an ample amount, and the costs associated with conducting these activities in roadless areas is simply too much. Losing biodiversity reduces the ecosystem services that this land can provide and jeopardizes the persistence of species. Resending the Roadless Rule will have a tremendous negative impact on these ecosystems and on the United States. Let us be thoughtful and good stewards and not make this mistake, which will have long lasting negative impacts. Reference: Crist, Michele R., Bo Wilmer, and Gregory H. Aplet. “Assessing the Value of Roadless Areas in a Conservation Reserve Strategy: Biodiversity and Landscape Connectivity in the Northern Rockies.” Journal of Applied Ecology 42, no. 1 (2005): 181–91. https://doi.org/10.1111/j.1365-2664.2005.00996.x.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking and looking for birds in these landscapes has shaped what I understand our public lands to be. I hike and camp for my happiness and to enjoy the beauty of our country. I travel frequently to locations this proposal will impact, exploring for the local birds and wildlife. I have visited many of these locations and cannot imagine our country without these incredible habitats. The agency's own environmental review documents harm to birds and then sets that documentation aside. The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. These are not contested findings introduced by opponents; they come from the agency's own review. Yet the proposal moves forward without projecting what those documented effects mean for the bird communities I travel to find. I ask the agency to explain, in its final environmental review, how it reconciles those cited findings with a decision that expands road construction across these habitats. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is wide, and the science behind it is the agency's own cited source. What the document never does is carry that number forward. The 40.1 million acres of inventoried roadless areas potentially affected by rescission sit in the analysis without any projection of what a 13 to 75 percent reduction in biodiversity would mean across that area. The agency should apply the fragmentation range it cited to the 40.1 million acres of potentially affected environment and publish that analysis before a final rule issues. The same pattern appears with big game. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed, and that elk avoid roads and select unroaded habitat. Those findings are in the record. A population-level projection from them is not. The birds and wildlife I go looking for do not exist separately from the broader ecological communities these areas support. I ask that the agency project the effects on big game populations and hunter opportunity under each alternative it is considering. Carbon storage receives the same treatment. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The DEIS then concludes these lands will continue to sequester and store carbon, without analyzing what timber harvest and road construction would do to that figure under any of the alternatives. That conclusion is not supported by the analysis provided. The agency must quantify the change in carbon storage and sequestration under each alternative. The most serious gap in the record concerns protected species. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. The agency wrote those words. It anticipates the harm. The proposal identifies mitigation for none of it. The birds and wildlife I visit these areas to find are part of that 327. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule. I oppose rescission of the 2001 Roadless Area Conservation Rule. The habitats these areas provide are not replaceable. The agency's own documents establish the harm; what is missing is any serious accounting for it.

Please select Alternative 1- No Action. There is insufficient evidence in the DEIR to repeal the Roadless Rule.

I oppose the Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule. The Forest Service should strengthen the Roadless Rule, not eliminate it. The current rule provides essential protections but still permits damaging activities in Inventoried Roadless Areas. Research examining 1,500 fires shows that protected (unroaded) forests burn at lower intensity and have lower rates of fire spread when controlled for weather conditions. Roads can increase human-caused fire ignitions and spread invasive plants.

I do not support the rollback of the roadless rule. It is an important environmental protection tool that keeps america beautiful. This proposed change to the roadless rule is not scientifically supported and it is not wanted by constituents. Please listen to our concerns and do not approve the rule changes.

I was born and raised in the Pacific Northwest, and the national forests of this region have shaped my entire life — as places of work, recreation, and deep personal connection. Because of that lifelong relationship with these landscapes, I follow Forest Service planning efforts closely and care deeply about decisions that affect the long‑term health and accessibility of our public lands. I appreciate the opportunity to comment on the proposed revision to the 2001 Roadless Rule, a policy that has played a critical role in protecting the ecological integrity of some of the most valuable remaining undeveloped forest areas in the country. The proposed repeal of the Roadless Rule is legally and analytically deficient, particularly in its treatment of wildfire risk. The DEIS does not adequately analyze the Forest Service’s own fire‑history datasets — including ignition sources, burn severity, suppression access, and comparative fire behavior in Inventoried Roadless Areas versus roaded landscapes. These datasets are well‑established, widely used in other Forest Service analyses, and essential for understanding whether roadless areas actually present elevated suppression challenges or increased fire danger. By omitting this evidence, the DEIS relies on assumptions rather than data, understates the ecological and fiscal costs of expanded road networks, and fails to meet NEPA’s requirement for a reasoned, evidence‑based evaluation. For these reasons, I urge the Forest Service to ensure that any revision to the Roadless Rule is guided by transparent scientific analysis rather than political ideology. Sound policy must be grounded in accurate data, ecological integrity, and long‑term stewardship — not in predetermined outcomes.

To the United States Forest Service: I am writing to strongly oppose the Department of Agriculture’s proposal to repeal the 2001 Roadless Area Conservation Rule. Intact inventoried roadless areas are critical for safeguarding clean drinking water for millions of Americans, preserving old-growth ecosystems, and supporting robust local outdoor recreation economies. The number of ecological services provided by contiguous wilderness are inumerable. Not to mention the importance for wildlife conservation, maintaining plant diversity, increase erosion risk, buffer against flooding and increase water filtration efficacy. In our region, intact forest ecosystems—like the mature woodlands of the New Jersey Highlands and the critical catchment areas around the Stony Brook, Lower Millstone, and Raritan River watersheds—directly shield our water quality. Undisturbed forest floors prevent heavy sediment erosion, buffer against severe flooding, and keep critical tributaries free from high turbidity and pollutant loads. Beyond the immediate region, contiguous forests in and around the great lakes are critical in maintaining the water qualtiy of the largest fresh water source in the world. As climate disruption and water scarcity accelerate globally, secure access to clean fresh water has transitioned from a local conservation issue to a primary metric of national infrastructure resilience. Allowing industrial development and new road infrastructure to compromise these headwaters weakens the defense-in-depth of our public water grid, introduces long-term economic vulnerability, and degrades a finite strategic asset that cannot be engineered back to health once polluted or disrupted. Decades of peer-reviewed ecological research further affirm that maintaining the Roadless Rule provides profound, quantifiable scientific benefits: • Water Filtration & Grid Resilience: A recent study published in PLOS Water confirms that inventoried roadless areas protect over 80,000 miles of domestic rivers, naturally filtering out contaminants through undisturbed plant roots and forest soils. This green infrastructure supplies clean drinking water to 25 million Americans and lowers chemical treatment costs for downstream municipal utility grids. • Wildfire Mitigation: Spatial data shows that nearly 90% to 95% of human-caused wildfire ignitions ignite within a half-mile of a road corridor. Introducing new road infrastructure into pristine backcountry exponentially increases fire risks, whereas unroaded areas act as natural, resilient buffers. • Biosecurity & Habitat Integrity: Forest Service data indicates that non-native, highly flammable invasive plants (such as cheatgrass) are twice as common within 150 meters of a road cut. Keeping lands roadless prevents the severe ecosystem fragmentation that drives habitat loss and allows biological invasions to degrade native wilderness. The Department of Agriculture’s own draft environmental impact statement confirms that rolling back these protections threatens undeveloped backcountry ecosystems, water resources, and local wildlife corridors. New road construction and logging infrastructure would fragment these fragile habitats, introducing invasive species and The justification that rescinding this rule will mitigate wildfire risks is contradicted by existing science and the Forest Service’s own data. Research shows that human-caused ignitions are significantly more common near roads, and building new infrastructure fragments fragile habitats and invasive species corridors. Furthermore, the Forest Service already manages a multi-billion-dollar road maintenance backlog; adding more unmaintained roads will worsen fiscal and environmental strains rather than alleviate them. I urge the agency to listen to the overwhelming public, tribal, and bipartisan opposition to this repeal and maintain full protections for our remaining backcountry national forest lands. Sincerely, Cara Love

Hello! I am writing to express my concern regarding the proposed rescission of the 2001 Roadless Area Conservation Rule and to encourage the U.S. Department of Agriculture and U.S. Forest Service to retain the protections provided by the Rule. I am a scientist with a master’s degree in biology, with a particular academic and professional background in ecology, biological invasions, and conservation. My research has focused on the interactions between organisms and their environments, ecological disturbance, habitat conservation, and the management of biological resources. Through both research and field experience, I have developed a strong appreciation for the importance of maintaining intact ecosystems and for the difficulty of restoring ecological functions once they have been disrupted. From an ecological perspective, I am particularly concerned about the cumulative effects of expanding road networks into currently roadless landscapes. Roads are not simply lines on a map. They permanently alter habitat structure, hydrology, soil processes, wildlife movement, vegetation communities, and patterns of human access. They can fragment otherwise continuous habitat and create additional pathways for the movement and establishment of invasive species. These effects can persist well beyond the original construction or timber-harvesting activity. This is particularly important in the context of biological invasions. Disturbed environments and newly created transportation corridors can provide opportunities for non-native species to establish and spread. Once established, invasive species can alter plant communities, nutrient cycling, fire regimes, and habitat quality, sometimes creating ecological changes that are extremely difficult and expensive to reverse. Maintaining large areas of relatively undisturbed habitat is therefore not simply a matter of preserving scenery. It is an important component of preventative ecological management. Roadless areas also provide ecological connectivity that is increasingly valuable in a landscape experiencing development, climate change, and other forms of habitat fragmentation. Large, relatively intact landscapes allow wildlife populations to move between habitats, provide refugia from disturbance, and preserve ecological processes that are difficult to replicate in fragmented landscapes. These functions become increasingly important as environmental conditions change. I recognize that the Forest Service faces legitimate challenges involving wildfire, forest health, insect and disease outbreaks, hazardous fuels, and access for management activities. I also recognize that the existing Roadless Rule contains restrictions that can complicate certain management decisions. However, eliminating the national protection for inventoried roadless areas represents a much broader policy change than simply improving the ability of land managers to address specific forest-health concerns. A more targeted approach would allow the Forest Service to address legitimate management needs while retaining protections for areas where the ecological benefits of maintaining roadless characteristics are particularly significant. The existence of management challenges should not automatically mean that the underlying protection must be removed altogether. The Forest Service’s own recent research also demonstrates that roads carry environmental costs that require careful consideration. Current Forest Service research is being used to evaluate road erosion and mass-wasting risks at a national scale, including in the analysis supporting the Roadless Rule environmental review. (USFS Research & Development) These impacts illustrate why road construction should be evaluated not only in terms of the immediate purpose of a road, but also in terms of its long-term effects on watersheds, soils, habitat, and ecological connectivity. As a scientist, I believe land-management decisions should be guided by the best available evidence and by consideration of both immediate and cumulative ecological consequences. Roadless areas represent one of the remaining opportunities to preserve relatively intact ecosystems on a large landscape scale. Once roads, associated development, and repeated disturbance fragment these areas, the ecological condition being protected cannot necessarily be recreated. For these reasons, I respectfully request that the Department of Agriculture reconsider the proposed rescission of the 2001 Roadless Area Conservation Rule and retain a meaningful national framework for protecting inventoried roadless areas. Where legitimate management needs exist, I encourage the agency to pursue targeted, science-based mechanisms that address those needs without eliminating the broader protections that preserve the ecological integrity of these landscapes. Thank you for considering my comments and for recognizing the importance of sound ecological science in the management of our public lands.

As a hiker, camper, hunter, and general enjoyer of the great outdoors, there is no place like those far away from roads. The experiences of nature that you have far from human activity is exponentially different than those near roads. These wild, remote, roadless backcountry area are vital to healthy wildlife, natural beauty, and enjoyment of wild places. Rescinding the roadless rule is nonsense that is not supported by research and science. Do not rescind this rule!

I strongly oppose the rescission of the Roadless Rule. Rescinding the rule will lead to the degradation of watersheds and water quality, harm wildlife habitat and populations, increase the incidence of human-caused wildfires, and eliminate areas of solitude that are necessary for human well-being. This rescission will not result in greater management flexibility at the local level. Instead, it will allow bureaucratic administrators in Washington, D.C., to direct local forests to favor extractive industries over other multiple-use and sustained-yield values in the relatively small portion of the National Forest System where they do not already do so. This is particularly concerning given that the majority of the National Forest System is not roadless, and that some roadless areas are required for sustaining non-extractive values. Specifically, I oppose the rescission of the Roadless Rule because scientific research has repeatedly demonstrated the importance of roadless areas to elk reproduction, and I hunt elk for subsistence purposes.

Please see attached document for my full comments and argument for strongly opposing rescinding the roadless area conservation act. Below is my conclusion from the document. The current roadless area rule already recognizes that there can be exceptional circumstances. It allows road construction in inventoried roadless areas when it is needed to protect public health and safety, including in response to an imminent threat of fire. This means the Roadless Rule does not require the Forest Service to ignore legitimate emergencies or community safety needs. Rather than removing the rule's protections across the board, I believe the existing exceptions and site-specific processes should continue to be used when a particular need can be demonstrated. Individual needs do not necessarily justify removing a national protection from millions of acres. What concerns me most is that some of the justification for rescinding the rule conflicts with the Forest Service's own history and research. The agency's 2001 analysis recognized the wildfire and ecological risks associated with roads (USDA Forest Service, 2001). More recent research conducted through Forest Service Research and Development found that roadless areas have not prevented fuel management and have not experienced higher rates of fire (Healey, 2020). Independent research has also found substantially higher wildfire-ignition density near roads (Aplet et al., 2026). Given that record, I urge the Forest Service to retain the 2001 Roadless Area Conservation Rule. References Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, 8. https://doi.org/10.1186/s42408-026-00450-2 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. https://doi.org/10.1088/1748-9326/aba031 Pew Charitable Trusts. (2026, October 5). U.S. Department of Agriculture proposes eliminating the Roadless Rule. U.S. Department of Agriculture, Forest Service. (2001). Roadless area conservation; Final rule. Federal Register, 66(9), 3244–3272.

Dear Chief Tom Schultz: As someone who has been on public land in all kinds of conditions and has noticed which policies have held and made a difference. The impact is has made is now at risk, and I have to put my voice to this issue as someone who lives near and who loves to be an outdoor tourist. As wildfire prevalence rises, more and more land is at risk for destructive fires. Doing all we can now to prevent the forests and roadless areas from being destroyed is important for our future on the planet. Furthermore, fires are costly to contain and can damage expensive infrastructure and take human lives when ignited. Regarding the Mt. Olympus in the Wasatch-Cache National Forest, Utah: For Pinyon Jay in Mt. Olympus, the connection between road construction and 7.1.1 - Increase in fire frequency/intensity is direct: roads deliver the disturbance vectors — sediment, access, fragmentation — that NatureServe identifies as driving Slight or 1-10% pop. decline severity impacts on this population. The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system that the agency cannot afford to maintain: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. Road building has been proven to increase wildfires, not lessen their risk. Roads bring in humans, equipment, and vehicles that all pose fire risk. 84% of wildfires are human-caused, meaning more roads built to bring in more humans to cause those fires. The Fire Ecology study done in 2026 by Aplet, Hartger, and Dietz proved that roadless areas have lower wildfire ignition density than those areas within 50 meters of a road. What really protects forests from fire is keeping them wild. Yours sincerely, Sydney Yoder

As a resident of Castle Rock, Colorado, a lifelong birder, and a former ecology laboratory and field technician with graduate training in quantitative biology and statistics, I write in support of retaining the 2001 Roadless Area Conservation Rule. Inventoried roadless areas serve as intact reference ecosystems: experimental controls against which the effects of management in roaded forests are measured. Removing them from the baseline would degrade the scientific value of the National Forest System for long-term ecological research. Road construction fragments forest interiors, and the literature documents the consequences for breeding birds: elevated nest predation and brood parasitism near edges, and avoidance of fragmented habitat by interior-obligate species. These are measured gradients, not speculative harms. I recognize that Colorado's state-specific roadless rule would remain in force. The national rule nevertheless protects connectivity corridors and watershed integrity across state lines, functions no single state rule can replicate. I support retention of both the national rule and Colorado's rule.

I submitted comments to the proposed rule in Sept 2025. Attached below. Consider these integral to my current comments. I strongly oppose recission of the 2001 Roadless Rule. I served on the roadless rule Content Analysis Team (CAET) in 2000, we read and synthesized all comments. Sentiment strongly favored protecting roadless areas and benefits they provide: clean water, biological diversity, wildlife habitat, forest health, and recreation. Climate change and population growth have increased support for roadless areas. I worked on the WMPZ Forest Plan Revision Team for forests in Western Montana; Flathead, Lolo, and Bitterroot. Despite efforts and substantial expense by American taxpayers, these were shelved due to a national lawsuit. Courts ruled the 2005 planning rule was inconsistent with the National Forest Management Act. The Flathead National Forest completed its forest plan revision in 2018 under the 2012 planning rule. My September 2025 comments must be considered in conjunction with my current comment for 53828 Federal Register/Vol. 91, No. 160/Thursday, August 20, 2026/Proposed Rules, which states, “As resource conditions and national policy have evolved, the Department has determined that a single, national blanket approach to the management of inventoried roadless areas taken in the 2001 Roadless Rule constrains responsible officials from exercising the timely, place-based discretion needed to meet the Forest Service’s multiple-use mission.” NOTE: While the 2001 roadless rule constrains officials from exercising their absolute place-based discretion, it does not follow such discretion is needed to meet the Forest Service’s multiple-use mission. On the contrary, NFMA was driven by management skewed to commodity production over multiple use values: watershed, wildlife, wildlands, recreation. Conditions on the Bitterroot amd the Monongahela national forest were evidence a more balanced approach was needed, resulting in NFMA. “In addition, evolving national priorities and changed conditions have required more active management approaches. The 2001 Roadless Rule limited the Forest Service’s ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns.” NOTE: See pg 8 from my 2025 comments for a research being done. There are volumes that dispel lack of active management as a driver of forest health concerns. On the contrary, there is evidence forest management itself fosters such concerns. “This proposed rescission is intended to return primary authority for determining the appropriate management of inventoried roadless areas at the local level to the land management planning process mandated by the National Forest Management Act of 1976 ……The National Forest Management Act establishes the requirement for the Forest Service to develop land management plans, including direction in 16 U.S.C. 1604(a) and (b) for interdisciplinary planning and consideration of landscape-level conditions. These statutory requirements are implemented through the Agency’s land management planning framework, which require consideration of the plan area in the context of the broader landscape and requires that each plan reflects the unit’s expected distinct roles and contributions to the local area, region, and Nation. “ NOTE: Interdisciplinary planning and consideration of landscape-level conditions was done on the Flathead NF and ongoing revision on the Lolo NF. Refer to my Sept 2025 comment using Flathead as an example. Of 500,000 roadless acres, fewer than 200,000 remained. The rest were assigned management areas based on conditions and public input. Decision-makers balanced conflicting uses and devised management area prescription for roadless areas. “At the same time, this planning approach allows for place- based, collaborative decisionmaking that is responsive to specific on-the- ground resource conditions, rather than a ‘‘one-size-fits-all’’ national mandate. While national-level considerations are important, land management planning efforts by local decisionmakers at the national forest or regional scale are best positioned to make decisions about inventoried roadless areas because they understand the unique ecological, economic, and social needs of their communities.” Note: Yes, this is being done for revisions under the 2012 planning rule. Ironically, the Roadless Rule Recission is itself a blanket one-size-fits-all mandate that the rule dispesl. I requested the DEIS disclose forests that have done plan revisions, those in the process, and those not started. Only those that have not started could be subject to the recission. Those completed or undergoing revisions have engaged in place-based, collaborative decision-making responsive to on-the-ground conditions. The DEIS fails to respond to my request.