Read the comments.

RE: Docket Number FS-2025-0001 or RIN 0596-AD66 I am writing to submit my comments regarding rescinding the Roadless Rule, Docket Number FS-2025-0001 or RIN 0596-AD66. I respectfully request that the Roadless Rule remain in full force. I reside adjacent to the Gifford Pinchot National Forest in Klickitat County. As a lifelong resident of the Pacific Northwest, I treasure the natural beauty it offers and hold dear the preservation of areas intended to serve nature solely for itself without the threat of human pressures. As a small forest owner/steward I know how impactful any type of disturbance can be to the ecosystem. We spent five weeks witnessing the destruction of 44 acres of the parcel that borders us on two sides while they installed roads and clear-cut last summer (June 2025). The logging trucks start rolling (four per hour at a minimum) in at 2:30 AM and the feller buncher fires up at the very same time, running for ten to twelve hours- six days a week. A decibel meter registered readings of 95 db. for many hours over the course of the day. It was impossible to sleep and the production of our flock of chickens dropped to less than half for the duration of the logging operations. Those are just two of the impacts, there were many more to ourselves and the surrounding community. Every type of wildlife left for the duration of the logging, and it took until this spring for them to begin to return. Our forests had been planted at the same time, and the trees were more than 75 years old- young in the life of a forest and a lifetime for most humans. Our adjoining parcels contain extensive wetlands, seasonal waterways, and ponds. None of these were protected from the destruction and oversight to ensure that setbacks were observed was non-existent. The impact was and has been intense, causing tremendous flooding where it had not occurred previously. Water and precipitation at our elevation (2000’) is precious and would have stayed higher in the watershed had those trees still been there and the wetlands not been demolished during the logging. We are in our fourth year of drought here in the northwest and every drop feels precious. Our pond is the lowest we’ve ever witnessed in the 10 plus years we’ve owned. I share our experience in the hope that you will closely consider the ALL of the potential impacts of rescinding the Roadless Rule- both short term and long term. Our forests are under tremendous pressure, at a time when we need them more than ever to help offset climate change. Humans have spent the past three centuries creating monocultures, including in our forests. The lack of complex ecosystems has dramatically impacted the health of our forests, and now policy makers, Department of Natural resources, and logging interests are using the perceived threat of forest fires to push a narrative of burning to enhance forest health. Rescinding the roadless rule will have tremendous impacts that will take generations to repair. The Roadless Rule helps preserve: •Clean Water for Communities •Wildlife Habitat and Biodiversity •Outdoor Recreation and Local Economies •Natural Resilience •Threaten Tribal Sovereignty and access to traditional, sacred gathering grounds. Any action taken that will reduce these restrictions puts these pristine areas at risk. Most Sincerely, Jennifer Sharp 12 Pyatt Rd., White Salmon, WA 98672

Dear Regulators As a life-long lover of both roads and forests, I am writing to strongly reject repealing the 2001 "Roadless Rule". I understand that this rule was put in place to protect vital habitats across the United States - and to slow the spread of development and deforestation. In my lifetime, I have seen how one road can lead to many roads which then create a criss-cross effect that breaks up and ultimately destroys habitats. I have seen water rights extended to commercial operators in National Forests - with roads and pipelines damaging the ecosystem and taxpayers footing the bill for their access. I do not believe local forest leaders should be able to remove protections from these designated lands - overseeing their activities would be costly and complicated - who would provide oversight or enforcement of local protections? • The Proposal: The U.S. Department of Agriculture (USDA) and U.S. Forest Service proposed repealing the 2001 rule, which protects roughly 45 to 58.5 million acres of inventoried roadless national forest lands from most commercial logging and new road construction. • The Administration's Rationale: Proponents of the repeal argue it will reduce regulatory burdens, transfer management flexibility to local forest leaders, and help mitigate severe wildfire risks and insect outbreaks through active forest management. Removing national protections threatens critical wildlife habitats, compromises clean drinking water sources for millions of Americans, and could increase wildfire risks by opening remote backcountry areas to commercial activities. If you are truly concerned about mitigating severe wildfire risks, then consider a different kind of de-regulation: one in which the First People lead the management of these forests - this would achieve the same result, transferring national control to regionally-relavant managers, while still maintaining a cohesive protection that extends across all National Forests. The federal government would still provide oversight and enforcement, but local indigenous management would be able to steward the forests regionally. Thank you for your consideration, J. DIDIER, Los Angeles, CA

Submit your public comment opposing the repeal of the Roadless Rule. Here's a comment you can use: I am firmly against USDA’s proposal to rescind the 2001 Roadless Rule. Roadless national forests represent some of the last unspoiled public forest landscapes. They safeguard clean drinking water, wildlife habitats, salmon streams, old growth forests, outdoor recreation, and essential areas relied upon by communities, Tribal Nations, and future generations. Once these lands are disrupted by new roads, logging, and industrial access, the damage cannot be easily reversed. The USDA should not dismantle a national protection that has shielded roadless forests for over twenty years. The current Roadless Rule already enables necessary measures to mitigate wildfire risk, so rescinding it is unnecessary for community safety. In reality, more roads may increase human ignition risk, habitat fragmentation, erosion, and long-term management costs. Additionally, rescinding the rule could transfer protection decisions to local planning processes, making intact forests more susceptible to political pressure and short-sighted extraction. Public forests should be managed for clean water, biodiversity, climate resilience, Indigenous stewardship, and public good, not for increased roadbuilding and logging. Please withdraw the proposed repeal, retain the 2001 Roadless Rule, and select the strongest alternative to protect roadless areas throughout the National Forest System. Thank you for taking my comment into account.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 We are already seeing what happens when we use too many resources. Let's back off taking from the earth for awhile. Water from national forest country in the Pacific Southwest Region reaches as many as 2,264,400 people downstream, by the agency's own data. My tap may be one of them. I am writing in opposition to the rescission of the 2001 Roadless Area Conservation Rule. I raise the following issues for the record and ask that the agency respond to each of them: Issue 1: The substance of round one is never answered I commented in the first round, and I have read what the agency says it did with everything we sent. Its own account describes counting, not answering: By the agency's own count, over 220,000 comment letters were received, representing over 625,000 submissions, and approximately 99 percent were generally opposed to the rescission. The DEIS says the comments helped inform the alternatives and identifies no issue that changed anything. Counting comments is not responding to them. I ask that the agency state which substantive issues from the first comment period altered the proposal, and which were rejected and why. Issue 2: Tribal consultation is incomplete and its summary is withheld from comment I commented in the first round and waited to be heard. By the agency's own record, others owed a far more formal hearing are still waiting too: The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule. Tribal governments proposed alternatives, including a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analysed; the final impact statement arrives only when comment is closed. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule. Issue 3: Every conservation alternative was eliminated by how the purpose was written I took the time to comment before, and I expected the alternatives to reflect what the public asked for. The agency's own document shows how it wrote every protective option out of consideration: Alternatives with more protection were dismissed as not responsive to the deregulatory executive orders, and the keep-boundaries option was cut because it "would continue to restrict local decision-making discretion" and because analysing roadless values is "an administrative and legal burden for the agency." A purpose written as deregulation forecloses the comparison NEPA requires. I ask that the agency restate the purpose and need in terms of forest conditions and analyse at least one protective alternative in full. Issue 4: Reliance interests are invited and never assessed How this reaches me is stated above in my own words, and that is a reliance interest. The agency asked for exactly this and then weighed none of it: The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. Under Encino Motorcars and Regents, an agency changing course must assess the reliance interests its prior policy created. This comment is such an interest. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. I request that the agency respond in the record to each of the issues raised in this comment, and that it analyze in the DEIS an alternative that retains the 2001 rule's protections. Where this proposal rests on factual conclusions that differ from the agency's own prior findings quoted here, I ask that the agency acknowledge the change in position and provide a reasoned explanation for it on the record. Sincerely, Brenna Geehan San Francisco, CA

I stand with the majority of the native tribes in opposition to rescinding the 2001 Roadless Area Conservation Rule. After reviewing all the information provided, it is clear that this change is intended to open land for tree harvesting. The only outcome from removing the rule is roads built where there should not be roads, no trees where there should be trees, and habitat lost for wildlife. While it could be argued that this repeal would lead to an increase of tourism, I counter that we already have places for people to visit to hunt, fish, and camp. The framing of this proposed change is removal of federal control in favor of local control. The true intent of the removal of this rule is to allow these lands and their resources to be sold. This land was protected for a reason. Trading our protected land for profit is undeniably vile. Shame on you if you choose to go through with this.

I oppose any change to the 2001 Roadless Area Conservation Rule. Many agencies spent thousands of hours painstakingly collecting data before enacting the 2001 Rule, and there is no need to change it. It seems disingenuous to state that "the management direction for inventoried roadless areas would continue to be governed by the applicable land management plans for each unit of the National Forest System," when the Trump administration has fired 6000+ people from the Forest Service, and appointed a Timber Industry executive with no former forest service experience, to the position of Chief of the Forest Service, . The claim that building new roads and allowing new access into roadless areas is necessary for wildfire management, is contradicted by many wildland firefighting organizations, with a direct quote from FUSEE (Firefighters Unted for Safety, Ethics and Ecology); "Constructing new logging roads into roadless areas will increase human-caused wildfire ignitions by careless recreationists, criminal arsonists, or simple accidents," said Carson States, a 10-season veteran firefighter and Type 6 engine boss from Oregon. "More roads mean more fires, so the broadened access to a wildfire incident will be undermined by the increased number of wildfires that will need to be suppressed." With tens of thousands of scientists around the world agreeing that forest preservation is vital to the survival of all life on earth, the idea that more logging and more roads into pristine wilderness is somehow in anyone's best interest is ludicrous. I am in complete agreement with the Tribal assessment that " removing this layer of national protection shifts the unsustainable burden of project-level review onto their limited resources and exposes previously untouched areas to industrial activity, mining interests, and destructive recreational access, all of which threaten sacred sites, traditional gathering areas, water quality, and subsistence resources." Further the " Proposed alternatives that were frequently requested: "retaining the existing rule (“No Action”) or establishing new co-management structures, such as a “Strengthened Roadless Rule Alternative” or a “Traditional Homelands Conservation Rule” that integrates Traditional Ecological Knowledge, Tribal co-stewardship, and Tribal consent for major decisions, would be critical to any change. I absolutely object to rescinding any part of The 2001 Roadless Area Conservation Rule. Even though I live in a state with it's own Roadless Rule, I am a property owner in Nevada, and spend much time in the wilds of our country, and it is plain to see the impact of human overuse already in our wide open spaces. We have to preserve what we have for the future of all life on earth to survive. With deepest concern for our vital roadless wilderness, Laralee Leavitt Idaho Resident

Eliminating the 2001 Roadless Rule, giving individual national forests more control over their land, and allowing flexibility to make changes based on local environmental conditions weakens the protection the Rule was meant to provide. This would impact wildlife habitats, increase erosion, worsen water quality, and possibly lead to logging and road development. Have we not done enough damage to our environment, so we need to figure out how to deplete it more? Have we not imposed enough environmental injustice on Tribal lands, disrespecting their ancestral ways? “Tribes consistently argued that removing this layer of national protection shifts the unsustainable burden of project-level review onto their limited resources and exposes previously untouched areas to industrial activity, mining interests, and destructive recreational access, all of which threaten sacred sites, traditional gathering areas, water quality, and subsistence resources.” As government and federal agencies continue to change and repeal legislation that was put in place to protect the environment, and as climate change and greenhouse gases increase, you would think preservation would be the main goal, not unwinding nationwide protections that help prevent environmental damage.

Re: RIN 0596-AD66; Docket FS-2025-0001 — Roadless Area Conservation To the U.S. Dept. of Agriculture and U.S. Forest Service: I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and request that USDA select the No Action Alternative and retain the Rule. If changes are necessary to address wildfire, forest health, or unusual local conditions, USDA should adopt targeted amendments rather than eliminate the nationwide conservation framework. USDA argues that rescission would provide greater local flexibility. Local conditions certainly matter, but local decision-making and national minimum protections are not mutually exclusive. The Roadless Rule establishes a conservation baseline while already allowing exceptions. USDA should identify specific situations in which those exceptions are inadequate and address those problems directly. Road construction and fiscal responsibility-USDA's analysis states that approximately 18.2 million acres of affected inventoried roadless areas are covered by existing plans that could allow permanent road construction following rescission. At the same time, the Forest Service has a $6.9 billion deferred-maintenance backlog for existing roads and bridges. Before making millions of additional acres potentially available for roads, USDA should fully consider the long-term costs of constructing, maintaining, repairing, monitoring, and eventually decommissioning them. Forest Service research also documents hydrological, ecological, aquatic-habitat, wildlife, biodiversity, and other effects associated with forest roads. Wildfire-I recognize the need to reduce wildfire risk and protect communities. However, USDA has not demonstrated that complete rescission is necessary to accomplish these objectives. The proposal itself acknowledges that increased public access can increase human-caused wildfire ignition. Where a community, watershed, or infrastructure faces a demonstrated wildfire threat that cannot reasonably be addressed under the existing Rule, USDA should create a narrowly tailored exception. Roads genuinely necessary for community protection or ecological restoration should be distinguished from roads facilitating commercial timber harvest, mining, energy development, or other resource extraction. Forest plans are not an equivalent replacement-Individual forest plans do not provide the same consistent national protection as the Roadless Rule. USDA acknowledges that plans may later be amended, potentially allowing additional roads and timber harvest. Rescission therefore replaces a national conservation standard with protections that can vary by forest and change over time. It also shifts the burden to citizens, Tribes, communities, and other interested parties to repeatedly participate in forest-plan amendments and individual project decisions to protect areas currently covered by a national rule. Roadless lands have multiple values-Roadless areas should not be evaluated primarily according to resources that might be extracted from them. They provide watersheds, wildlife habitat, biodiversity, hunting and fishing, recreation, scenic landscapes, cultural resources, carbon storage, scientific value, and opportunities for quiet and remote recreation. Once roads fragment an intact landscape, restoring its previous roadless character can be difficult, expensive, or impossible. The potential permanent loss of these values deserves substantial weight. Tribal concerns-USDA reports that the majority sentiment among Tribal governments consulted was opposition to rescission. Concerns included sacred sites, gathering areas, water quality, subsistence resources, cultural survival, ancestral homelands, and the burden of repeatedly participating in project-level reviews. These concerns demonstrate a significant problem with replacing national protection with project-by-project decision-making. USDA should give substantial weight to Tribal consultation before making such a consequential change. A better alternative-I urge USDA to retain the 2001 Roadless Rule while addressing demonstrated management problems through targeted amendments. Any new exception should require a showing that road construction is necessary and that a less environmentally damaging alternative is not reasonably available. USDA should also fully account for lifecycle road costs and preserve national protections for watersheds, wildlife, biodiversity, cultural resources, Tribal interests, and remote recreation. A national conservation standard and responsible local forest management can coexist. Where the Rule creates a demonstrated obstacle to necessary management, USDA should address that specific problem rather than rescind nationwide protections covering millions of acres. For these reasons, I respectfully request that USDA withdraw the proposed rescission of 36 CFR Part 294, Subpart B and retain the 2001 Roadless Area Conservation Rule. Thank you for considering my comments.

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule under Docket FS–2025–0001. Our national forests embody the vastness, natural beauty, and freedom to roam that make the United States extraordinary. These public resources should be protected for current and future generations. Removing nationwide safeguards against road construction and timber harvesting would expose roadless areas to increased development pressure and risk lasting damage to our water quality, precious wildlife habitats, and cherished natural landscapes. Local forest planning should complement a consistent national conservation standard, rather than replace it. I support responsible forest management and efforts to protect communities from wildfire, but these goals do not justify the broad elimination of roadless protections. The existing rule includes exceptions, and the Forest Service should demonstrate why targeted approaches cannot address specific management needs before removing these safeguards. Substantial opposition from Tribal governments also deserve serious consideration, particularly their concerns about protecting sacred sites, ancestral lands, and subsistence resources. These places sustain living cultures and are integral to our nation’s heritage and history. Please reject the proposed rescission and retain the 2001 Roadless Rule.

The Roadless Rule protects river headwaters that sustain native salmon, steelhead, bull trout, and treaty-protected fisheries. USDA has not shown that the existing Rule prevents necessary fuels treatments; the Rule already permits substantial hazardous-fuels work. Removing protections is inconsistent with the Forest Service’s documented inability to maintain its existing road system. The DEIS fails to quantify foreseeable new road mileage, stream crossings, sediment and passage risks, and human-caused ignition risks. The proposal requires a fuller analysis of effects on treaty fisheries and meaningful government-to- government consultation with affected Tribes. USDA should withdraw the rescission and retain the 2001 Roadless Rule.

I oppose the rescission of the Roadless Area Conservation Rule and request that it be abandoned forthwith as a waste of taxpayer dollars, a dangerous flouting of established wildfire and water science, and a top-down, anti-democratic, anti-local forcing through of something that was overwhelmingly opposed at the NOI stage. I also protest the inadequate process surrounding the proposed rescission; if the rescission is not abandoned, the process must be corrected. Regarding process, the 2001 Roadless Area Conservation Rule received extraordinary public input, largely positive, through 2 60-day comment periods and over 600 public meetings drawing over 23,000 participants. This rescission proposal initially allowed only a 21-day comment period on the NOI and a 30-day comment period on the DEIS, inadequate to a broad rule that affects nearly 45 million acres all across the nation. Even with the DEIS comment extension, the total comment period is little half that of the original rule. If the rescission is not abandoned, the comment period should be extended another 45 days and it should include at least one meeting per forest—half of what was provided for the original rule. Communities surrounding the forests should have every opportunity to state their opinions and share the likely impact on their livelihoods and lifestyles. Also, although the USDA correctly determined that Tribal consultation is warranted by the proposal, it has held fewer than half of the requested consultations, per the TSIS has held no consultations since the DEIS has been released, and it misconstrued what consultation means. Sending line officers without decision-making power to record opinions before alternatives have been publicized is not the same as decision-makers meeting with Tribes regarding the actual impacts of proposed alternatives. The TSIS nonetheless shows that the majority of Tribes oppose the rescission, and yet this rescission is being forced through. Furthermore, alternatives proposed by Tribes were not analyzed in detail. If this rescission is not abandoned, government-to-government consultation should be correctly held with the requesting Tribes, a Tribally-proposed alternative should be analyzed in a supplemental DEIS, and an updated Tribal Summary Impact Statement should be issued for comment before the final rule. As for the impacts of the rule itself, as a tax-payer I am infuriated that the enormous backlog of deferred maintenance on current Forest Service roads is being passed over in favor of building new roads in areas that, if they were easy to build roads in, would already have them. I have recently traveled Forest Service roads in Mendocino National Forest, where my companions and I had to navigate a landslide and a washout. While fire trucks might have been able to navigate the landslide, after a delay for digging it out, the washout was barely navigable in a passenger vehicle. In the best case trying to get engines through there would have delayed fire response by forcing the engines to be rerouted; in the worst case it could have caused injuries or even deaths to our firefighters. Rather than attempt to build new roads, the backlog should be better funded and roads should be prioritized for repair according to their impact on public safety. Adding insult to potential injury, timber sales from areas newly opened to logging are unlikely to pay for themselves or the roads; essentially, they are a corporate giveaway. The rescission will not, as claimed, make it easier to manage fire in forests. I have seen fuels management in Caples Creek, one of my favorite inventoried roadless area, that successfully protected the area from the massive, severe Caldor Fire 2 years later, and the DEIS acknowledges that the 2001 Roadless Rule does not "meaningfully constrain hazardous fuel treatment activities". It also acknowledges that IRAs have far fewer ignitions than roaded lands. In other words, rescinding the rule—according to the DEIS—can be expected to increase ignitions without improving fuels management. Firefighters themselves state that in rugged areas air support is preferable to trying to get engines in, and point to delays caused by poorly maintained roads. More roads will not make this better. Adding more roads also decreases water quality at a time when fresh, clean water is of utmost importance and in short supply. Roads increase erosion and sediment, while maintaining forests captures sediment. Turbidity is a major, costly problem for downstream water users, who have to bear the indirect costs of the new roads. The DEIS barely addresses this impact other than to say that it likely exists. There are far more reasons to oppose rescinding a rule that preserves our forests and clean water for the generations to come. The rescission should be abandoned and our taxpayer dollars used for something useful like restoring the many fire fighter support personnel who have left the Forest Service.

Roadless Rule Comment — Working Draft I live in the Sierra Nevada foothills of California. Here, wildfire is not an abstract idea. We watch the weather, and our hearts drop when we see smoke. We clear our land, check Watch Duty, and know what evacuation warnings mean. Our forests must be actively and intelligently managed, and we need the Forest Service and firefighters to have the tools they need to keep communities safe. I also oppose rescinding the Roadless Rule. I understand the problem the Forest Service is trying to solve. Forests and wildfire have changed, and a twenty-five-year-old rule cannot anticipate every management need, but 44.7 million acres is an extraordinary amount of land to remove protection from in order to gain flexibility where it may sometimes be needed. “Roadless” does not need to mean “unmanaged.” These are living places, containing headwaters, wildlife habitat, migration corridors, threatened species, soils, carbon stores, and places people hunt, fish, hike, and play. Many are also ancestral homelands Indigenous peoples knew, tended, burned, harvested, and cared for long before there was a Forest Service. Some western forests desperately need active management, but that can mean prescribed and cultural fire, targeted thinning, selective harvest, habitat restoration, and temporary access where genuinely necessary. The Forest Service’s own research has found that lack of roads has not prevented fuel-management work in inventoried roadless areas. A forest can be both protected and actively stewarded. The Forest Service's consultation found that “the majority sentiment among Tribal governments consulted is opposition to the proposed rescission,” citing concerns including sovereignty, cultural survival, ancestral homelands, sacred places, water, subsistence resources, and repeated project-level review. I am not asking the Forest Service to listen to Tribal Nations because I assume they will agree with me. They may not. A Nation may support burning, harvesting, thinning, or access I wouldn’t personally choose. Sovereignty means very little if we respect it only when we get the answer we want- that being said, I believe they deserve the respect and trust to make decisions about the land they know best. Please keep national protection while allowing Tribal Nations a stronger role in deciding how these areas are stewarded. Expand co-stewardship and cultural fire programs, provide resources for meaningful participation, and recognize Indigenous knowledge as expertise where Nations choose to share it. We do not need one answer for every acre. If an important fuel treatment genuinely requires temporary road access, build the temporary road, do the work, and then restore it. Burn where fire is needed. Thin where thinning is needed. And if a roadless watershed or habitat is healthy and there is no compelling reason to disturb it, leave it roadless. Roads are useful tools, but Forest Service research also recognizes their potential costs to wildlife habitat, water, aquatic ecosystems, and the spread of invasive species. That doesn't mean “never build a road;” it means a road should solve a problem worth the cost of the road. Timber, minerals, jobs, and economic development have real value. So do intact watersheds, wildlife habitat, cultural landscapes, and forests that have remained largely undeveloped. Some of these can be replaced. Others, once lost, may not be recoverable at all. Please, choose the more careful path. Change the parts of the Rule that genuinely prevent necessary work. Create carefully limited exceptions. Allow temporary access where evidence shows it is needed. Expand prescribed and cultural fire. Work with Tribal governments as partners. Target resources where wildfire risk is greatest. But keep protection as the starting point! A regulation can be amended again. A forest treatment can be repeated. A temporary road can be restored. An intact watershed, an old habitat corridor, a cultural landscape, or a species population cannot always be reconstructed after we find out we made the wrong decision. That is what I believe is at stake here: not whether we manage our forests, but how we manage them. Not whether a twenty-five-year-old rule can change, but whether the problems we’ve identified require us to discard the protection itself. Please retain the Roadless Rule, improve it where experience shows improvement is necessary, and build the next generation of forest management around careful intervention, good science, Tribal sovereignty and stewardship, and the humility to recognize that sometimes the wisest management decision is to act- and sometimes it’s leaving a living landscape whole.

I am an outdoor enthusiast located in a western state, so I will start with the most obvious effect rescinding the 2001 Roadless Rule will have on me: Recreation and Wilderness Areas. In EIS Table 3: Summary of effects, you state: "Alternative 2 has the greatest potential impact on recreation settings and scenery. Short-term timber harvest and road construction effects could include noise, visible infrastructure, and temporary closures. Long-term, recreation settings could shift toward more developed conditions with future activities more likely in the semi-primitive and roaded areas." The simple response is, I don't want that. I can't think of anyone outside of those who stand to profit from timber or mineral harvesting who does. The stated intent of "Alternative 2 – Roadless Rule Recission" is to adhere to a series of Executive Orders. None of those orders prioritize the health or maintenance of forests, wilderness areas, recreation sites, etc. They prioritize widespread deregulation and an increase in energy/natural resource production on public lands. I do not want roads and infrastructure built for the purpose of extracting more resources from our public lands. The USDA does not need to rescind this rule to properly maintain roads, trailheads, and fire breaks. In public the USDA consistently claims this decision will improve firefighting, benefit recreation, and allow more state, local, and tribal inputs. One example: https://www.usda.gov/about-usda/news/press-releases/2026/08/18/usda-acts-remove-roadless-rule-restrictions-exacerbate-rising-wildfire-risk Those goals are clearly at odds with the goals stated in the EOs and throughout the docket. The claims are either based on the false premise that resource extraction motives will yield meaningful second order benefits, or a deliberate misrepresentation of the goals of this administration. The lip service paid to tribal interests is particularly galling, as those interests are consistently ignored throughout the EIS and Tribal Summary Impact Statement. At best, the discrepancies between public-facing statements and the plain text and intent of the rule rescission show a shocking lack of respect for the American public from USDA leadership. More likely, they are an intentional obfuscation of the far less palatable goals behind this action. Do not rescind the 2001 Roadless Area Conservation Rule.

I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the USDA to keep it in place. I'm a documentary filmmaker in Port Townsend, Washington, currently making a film about the Tongass National Forest. Roadless forests and standing old growth are irreplaceable. As conditions shift across the country, longer, hotter fire seasons, warmer winters, and more extreme weather, we need more intact forest, not less. The proposal is framed around wildfire management, but the evidence points the other way. A 2026 study in Fire Ecology, covering national forest fires from 1992 to 2024, found that wildfires were four times more likely to ignite within 50 meters of a road than in roadless forest, and the result held in every Forest Service region. Even lightning fires were more common near roads, because openings in the canopy dry out the forest floor. Congressional Research Service data show about 89% of U.S. wildfires are human-caused. Roads bring people, and people bring fire. Building roads into roadless areas to reduce wildfire makes no sense. I am not anti-logging. We need wood but there is a good way to do it, and a bad way to do it. One aspect of the forest that needs to be carefully considered is that of old growth. Old growth forests hold some of the densest carbon stores on the planet. In their trunks, roots, and deep soils. Big old growth also keeps adding carbon as they age. Logging releases that stored carbon and replanting forests takes centuries. Many of the trees in the Tongass are 300-800+ years old. Once it is cut, no one alive will see it come back, in fact the next 7 generations will not. Old trees are more fire resistant. Old growth stabilizes steep slows, filters water and shades streams to improve the lives of Salmon which annually feed millions of species and people. Old growth shows what healthy forests look like without human disturbance, which makes it a reference for managing everything else. The Tongass is the only national forest where raw, unprocessed logs can be exported, and much of its timber has historically been shipped to Asia. Meanwhile the U.S. imports about 30% of the wood it uses. Opening the last intact old growth rainforest in the country to send raw logs overseas is not a good use of a public resource. Repeal would open nearly 45 million acres nationwide to road building and logging. Roads and clearcuts degrade salmon streams with sediment and warmer water, fragment habitat for brown bears, deer, and other wildlife, and raise landslide risk on steep, wet slopes like those in Southeast Alaska. These effects ripple through entire ecosystems and the fishing and tourism economies that depend on them. Finally, in the Tongass, the Tlingit, Haida, and Tsimshian peoples depend on this land for food, cedar, and cultural sites. Any change must fully account for Tribal and subsistence use, with meaningful consultation. For these reasons, I ask the USDA to withdraw the proposed rescission and keep the Roadless Rule in place.

The Roadless Rule has been in place since 2001 for very good reason. The 58 million acres of untrammeled wilderness which is protected by this Regulation will immediately fall under threat of logging & mining interests if removed from the Federal Register. The climate crisis is already past a tipping point. We need those trees. The wildlife needs those areas to remain wild. The current US administration, under Trump, has made its intentions clear when it comes to removing environmental protections: drill, cut, profit. The removal of Roadless goes against the preservation of life on this planet, and goes against the will of all Sovereign Nations who inhabit the areas surrounding those which are currently protected under roadless. We need to listen to the Tribes, Scientists, and Environmental Advocacy groups and keep these areas Roadless under the Federal Register. Please don't make a huge mistake which cannot be undone. The Ambler Road has already been approved by Trump, and that ONLY benefits the Ambler mine. The environmental impacts of this road construction have been well-studied and fought against by local and national groups for years already. One swipe of the pen by those who have not been to these areas and do not understand the implications of the removal of their Roadless protections is all it takes to set us back even further in our efforts to preserve Public Lands, Wild Places, and a chance at our own survival in an environment of extreme human-induced Global Climate Change crisis. Please preserve the Roadless Rule under the Federal Register. Let the corporations find other ways to profit than by attacking the last remaining great wild places on Earth.

As a citizen who accesses our nations forested areas, and values the protections that have been in place to maintain their scenic beauty, I strongly oppose the repeal of the roadless rule, and urge policy makers, deciders and leaders involved to strongly consider preserving this beauty for our younger generations and tribal nations.

I am in opposition to the plan the rescind the 2001 Roadless Area Conservation Rule. The proposed regulation claims that road construction in previously preserved areas will decrease wildfire risk. However, evidence from a 2020 study by USFS ecologist Sean Healy (1) showed that areas with and without roads burn at the same rate, suggesting that fires caused by humans using the roads offset the benefit of areas being more accessible by fire control services. Furthermore, a lack of roads in protected areas has not deterred fire prevention. The discontinuation of the Roadless Rule will have no positive effect on wildfire control and will likely increase wildfire prevalence due to logging. A 2006 study investigated wildfire severity in Sierra Nevada's unthinned and mechanically thinned forests, finding that thinned forests are more likely to be overtaken by wildfires (2). I trust the judgement of the peoples who have lived across this continent since time immemorial. As expressed in the Regulatory Certifications section of the Supplementary Information, Tribal governments majorly oppose the rescission of the Roadless Rule. Conservation of roadless areas preserves water quality, gathering areas, and sacred ancestral lands. I am in assent with either of the most frequently requested alternatives by Tribal Nations: retaining the existing rule or a strengthened roadless rule. In order to protect our forests, our wildlife, the communities who depend on them, and most importantly our Earth, it is integral that the Roadless Rule is retained. Thank you. References (1) Healy, S. P. 2020. Long-term forest health implications of roadlessness. Environ. Res. Lett. 15, 104023. (2) Hanson, C.T., Odion, D.C. 2006. Fire Severity in mechanically thinned versus unthinned forests of the Sierra Nevada, California. In: Proceedings of the 3rd International Fire Ecology and Management Congress, November 13-17, 2006, San Diego, CA

I oppose the proposed repeal of the 2001 Roadless Area Conservation Rule and urge USDA to retain the existing protections. As a Washington resident and accountant, I do not believe the projected timber revenues justify the costs and risks of opening protected forests to additional roads and logging. Revenue alone does not establish a public benefit. A responsible financial analysis must account for road construction, ongoing maintenance, environmental damage, and losses to recreation and other local economic activity. USDA’s acknowledgment of a substantial existing road and bridge maintenance backlog makes expanding those obligations especially concerning. The greatest value of these lands is that they remain largely untouched. Clean water, connected wildlife habitat, carbon storage, cultural resources, and opportunities to experience undeveloped forests have lasting value that timber receipts cannot adequately measure. Once roads fragment a forest or mature trees are removed, those values cannot simply be purchased back. I am also concerned about the burden repeal would place on Tribal governments and communities seeking to protect sacred sites, traditional gathering areas, and subsistence resources. Requiring them to defend these places project by project weakens the certainty provided by national protections. Wildfire management deserves serious attention, but it does not justify a nationwide repeal. USDA should demonstrate why targeted measures under existing protections cannot meet specific needs and weigh the increased risk of human-caused fires associated with greater access. Please retain the 2001 Roadless Rule. These forests are public assets held for future generations. Their enduring value deserves greater weight than uncertain revenues from extraction.

Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Tongass has shaped my life in Sitka in ways I am still learning to name. In two years here it has molded how I move through the landscape, what I am grateful for, how I eat, what I notice. The sheer grandeur of an intact temperate rainforest does that. It is hard not to be enamored, and even harder not to feel grateful for what the Tongass is: a main pillar of subsistence, culture, recreation, and ecosystem in Southeast Alaska. The Tongass makes life whole here. As someone who lives inside that wholeness, I submit these comments opposing the rescission of the 2001 Roadless Area Conservation Rule under Docket FS-2025-0001. The forest I am writing from is the largest intact temperate rainforest left on Earth. It holds 110 inventoried roadless areas totaling 9,339,575 acres, more than 12,930 miles of salmon-producing streams, and roughly 44 percent of all the carbon stored by United States national forests. Executive Order 14153 directs the agency to expressly exclude the Tongass from the 2001 Roadless Rule, and the Federal Register rescission notice says so in writing. Under both action alternatives the Tongass keeps zero acres of roadless protection. That means the salmon streams, the Sitka black-tailed deer, the brown bear, the wolves, the bald eagle, and the five species of Pacific salmon that anchor subsistence life here are all subject to what follows from that zero. The nine municipal watersheds named in DEIS Table 2, including Sitka, are also subject to it. I ask the agency to explain in specific terms what protection, if any, replaces the rule for those watersheds and that wildlife. The agency's own Tribal consultation record makes the procedural posture of this rescission indefensible. "The Forest Service received 64 requests for Tribal consultation; 29 consultations have been held and 5 more scheduled, with the published Tribal Summary Impact Statement records that the majority sentiment among consulted Tribal governments is opposition, viewing the rescission as a threat to inherent rights, Tribal sovereignty, cultural survival and the ecological health of ancestral homelands; the final Tribal Impact Summary Statement is deferred to the final rule." Tribal governments proposed alternatives, among them a strengthened roadless rule and a Traditional Homelands Conservation Rule, and none was analyzed. I find it deplorable that the summary of that consultation arrives only after the comment period closes. I ask that the agency complete all 64 requested consultations and publish the Tribal Impact Summary Statement for public comment before any final rule is issued. The economic case for rescission is not established by the agency's own numbers. The agency acknowledges that "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." Against that marginal contribution, the agency's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning -$92 million to +$199 million, and the road system this rescission would expand already carries a $6.9 billion maintenance backlog. The agency must reconcile the proposal with that record and explain how an action whose own analysis cannot establish a net benefit is justified. The legal foundation here is also troubled. The agency's record states 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 proposal argues that state-specific approaches can substitute for a national rule. The Ninth Circuit already reviewed that argument the last time the agency replaced the national rule with a state-by-state approach and found it wanting. The agency must address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids those same deficiencies. Finally, the DEIS itself quantifies a consequence it does not then apply. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the record. No projection across the 40.1 million acres of potentially affected environment follows from it. The agency should apply its own cited finding at the scale of the action it is proposing. I implore policymakers to visit Southeast Alaska, bring your kids, show them what an intact temperate rainforest looks like, gaze upon it with gratitude for all the life it supports, be humbled. A logged stand grows back. The agency should say plainly what does not. Sincerely, Zia NoiseCat Sitka, AK

I strongly oppose the proposal to rescind the 2001 Roadless Area Conservation Rule. The National Forest System belongs to the American people, and the remaining roadless lands represent some of the last large, relatively intact forest ecosystems available to the public. These places should be conserved for their ecological, recreational, cultural, and intrinsic values—not opened further to roads, commercial timber extraction, and mineral development. The argument that rescinding the Roadless Rule is necessary to reduce wildfire risk is particularly concerning because the available evidence does not support it. A recent nationwide study of wildfire ignitions on National Forest lands found that fires, particularly human-caused fires, occur at substantially higher rates near roads than in remote roadless areas and concluded that expanding roads into roadless areas is likely to increase fire ignitions. If wildfire prevention is genuinely the objective, we should be extremely cautious about expanding one of the landscape features most strongly associated with human-caused fire ignition. There is also little justification for sacrificing some of America's most intact forests in the name of timber production. Roadless areas are not disposable lands waiting to be converted into industrial forests. They provide clean water, wildlife habitat, carbon storage, biodiversity, recreational opportunities, scenic value, and opportunities for people to experience landscapes that remain genuinely wild. Roadless recreation is not an incidental use of these lands—it is the defining characteristic that makes them valuable. Many Americans deliberately seek places where roads, motor vehicles, heavy equipment, and commercial development are absent. Hiking, backpacking, hunting, fishing, horseback riding, wildlife observation, camping, and simply experiencing solitude are fundamentally different experiences when a person must travel beyond a road rather than having a road constructed into the landscape. Once a road is built, the roadless character of that landscape cannot simply be restored by removing the pavement or closing the gate. Road construction also has consequences that extend far beyond the physical width of the road itself. Roads fragment habitat, facilitate human access - often with negative outcomes, increase disturbance, introduce invasive species, alter drainage and erosion patterns, and create permanent corridors through otherwise intact ecosystems. Opening roadless areas to mineral extraction would compound these impacts and undermine the very reason these areas were designated for protection. The concerns of Tribal Nations deserve particular weight. Roadless areas are not simply empty spaces on a map. Many contain places with continuing cultural, spiritual, historical, and traditional significance. The Forest Service's own consultation records indicate substantial Tribal opposition to rescinding the Roadless Rule because of concerns regarding inherent rights, Tribal sovereignty, cultural survival, and the ecological health of ancestral homelands. Finally, I am deeply concerned about granting this administration additional opportunities to exploit or diminish protected public lands when its recent record provides insufficient reason to trust that ecological, wildlife, and cultural resources will be given priority when they conflict with extraction and development objectives. An administration seeking to remove longstanding conservation safeguards while expanding opportunities for resource extraction should not be given greater discretion over irreplaceable public lands. Trust in public-land management must be earned through stewardship, not assumed in advance. The American people already possess an enormous amount of developed and roaded forest land. We do not need to turn every remaining remote landscape into another resource-access corridor. Some places should remain difficult to reach. Some forests should remain intact. Some landscapes should remain quiet. And some public lands should exist primarily because their value cannot be adequately measured in board-feet, tons of minerals, or miles of road. I urge the Department of Agriculture and the U.S. Forest Service to reject the proposal to rescind the 2001 Roadless Area Conservation Rule and retain permanent protections for Inventoried Roadless Areas. These lands belong to all Americans, including generations who have not yet been born. We have a responsibility to leave them with forests, watersheds, wildlife habitat, cultural landscapes, and wild places that are at least as intact as those entrusted to us.