Read the comments.

Protect the Roadless Rule. It is good for wildlife and our lands.

Forests are very important for wildlife, but forests also mean many different things to many different people in ways i cannot describe, we don't need roads that cut through these untouched places. so please keep these forests safe

I strongly oppose the repeal of the 2001 roadless area conservation rule because building new roads in our national forest harms wildlife increases erosion, and risks human caused wildfires.

Roadless areas matter to me Greatly because they are critical for biodiversity and biodiversity is critical for life on earth as we know it. Roadless areas allow for species to survive and thrive - as soon as you cut a road through, the species depending on roadless areas suffer and then everything downstream suffers as a result. Everything is and all species are interconnected in the web of life. Protect and defend our roadless areas. They are a public treasure not to be tampered with.

To the USDA Roadless Rule Team: As a Coloradan, and a wildlife enthusiast, I believe the 2001 rule is the single most important land management instrument and the threat of its removal is not only catastrophic but infuriating. Every year, I take a fall trip to explore these beautiful mountains and every year I am left with wonder. Seeing new wildlife, a new sunset, a new plant, a riverbed - it never ceases to amaze me. The protection of these ecosystems are imperative for us, but also for all. Being able to backpack through these undisturbed mountains and connect with other life is one of the few things that bring me joy and peace in such a hectic world. Roads end that possibility. Regarding the Mount Antero in the Pike & San Isabel NFs- Alpine and Subalpine Climate Refugia Connectivity — The area spans from 13,600 feet to 14,276 feet across multiple subalpine and alpine ecosystem types—Rocky Mountain subalpine spruce-fir forest, alpine tundra, and bristlecone pine woodland—creating an intact elevational gradient that allows species to shift their ranges as climate conditions change. This vertical connectivity is critical as warming temperatures push suitable habitat upslope; species dependent on cool conditions can only persist if they can move continuously to higher elevations without fragmentation. Road construction fragments this gradient by creating edge effects, altering microclimate through canopy removal, and introducing invasive species along disturbed corridors, which would trap populations in lower-elevation refugia that are becoming increasingly unsuitable. DEIS Narrative Exceeds the 150-Page Statutory Limit With No Extraordinary-Complexity Determination on the Record The Draft EIS exceeds the statutory page limit and contains no determination authorizing it to do so. Volume I of the Draft EIS is 333 pages. Its narrative text runs from the Introduction at page 9 through page 248. References Cited occupies pages 249 through 285, and the List of Appendices and Appendices 1 through 5 occupy pages 286 through 333. Excluding citations and appendices, as the statute directs, the environmental impact statement is therefore approximately 240 pages long. The applicable limit is 150 pages. 42 U.S.C. 4336a, enacted by the Fiscal Responsibility Act of 2023, limits an environmental impact statement to 150 pages excluding citations and appendices, and permits 300 pages only where the proposed agency action is of extraordinary complexity. USDA's NEPA procedures implement the same limits at 7 CFR 1b.7(a) and (i). The Draft EIS expressly adopts those procedures, stating at page 9 that the Forest Service "has prepared this draft environmental impact statement (EIS) in compliance with the National Environmental Policy Act (NEPA) and other relevant laws and regulations," and that "all references to 7 CFR 1b within this document refer to the interim rule." The document therefore exceeds the 150-page limit by approximately 90 pages. The only lawful basis for an environmental impact statement of this length is a determination that the proposed action is of extraordinary complexity. Volume I contains no such determination. The phrases "extraordinary complexity," "page limit," and "Fiscal Responsibility Act" do not appear anywhere in the document, and 42 U.S.C. 4336a is cited nowhere in it. The Draft EIS asserts compliance with "other relevant laws and regulations" while exceeding the one quantitative constraint those laws place on the document itself, and without invoking the exception that would authorize the excess. This is not a matter of formatting. The page limit operates together with 7 CFR 1b.7(i), which directs that issues not of a substantive nature receive the briefest possible discussion. A ceiling of 150 pages applied to a rescission affecting approximately 44.7 million acres of National Forest System lands compels the agency to compress its effects analysis, and the extent of that compression depends directly on which ceiling the responsible official was working to. A document written to 150 pages must omit substantially more analysis than one written to 300. The public reading this Draft EIS cannot tell which constraint shaped it, because the document never says - and the difference is roughly 90 pages of effects analysis across 44.7 million acres. I request that the responsible official make and document the extraordinary-complexity determination required by 42 U.S.C. 4336a and 7 CFR 1b.7(a) as the predicate for a Final EIS exceeding 150 pages, or, if no such determination is made, that the Final EIS text comply with the 150-page limit. Under 7 CFR 1b.7(f)(3), the response to this comment should cite where in the Final EIS or the supporting proposal record that determination is accounted for. A rule that has survived twenty-five years, multiple administrations, and repeated judicial review deserves more deference than this. CommentID: RLC-20261006-9WBQV3

I respectfully request that you continue to protect our Roadless Area Conservation. As a Californian I treasure our wildlife and protection of their habitat. Please don’t allow roads to be built through our wilderness areas.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Backpacking and hiking through places like Pyramid in the Lake Tahoe Basin and the Paiute roadless area in Inyo National Forest to commune with nature, watch birds, and observe wildlife, I have come to understand what these landscapes hold. Rescinding the 2001 Roadless Area Conservation Rule would put that at risk, and the agency's own analysis does not support the step it is proposing to take. I am an avid backpacker and day hiker who lives in Northern California. I have travelled all over the United States to hike and backpack. The impact of roads and off road vehicles on wildlife, the land and the experience being in the “wilderness” is obvious and depressing. Bird watching is not incidental to why I go into roadless areas. It is a central reason. The agency's own record, drawing on research the DEIS cites, documents 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. California already holds 381 inventoried roadless areas totaling 4,389,760 acres, and the birds I go to find depend on the quiet and the unbroken canopy those areas provide. Opening that landscape to road-building does not simply alter the scenery. It restructures the acoustic and ecological conditions that determine whether those species stay or go. I ask the agency to explain, with specificity, how the benefits it claims from rescission can be weighed against documented declines in bird abundance and species presence that its own cited science predicts. The wildfire rationale the agency offers for this rescission conflicts directly with what its own record says. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." The DEIS further reports human-caused ignition density of 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas, and states that human-caused ignitions increase in abundance with proximity to roads. The agency must explain why its proposal departs from these findings, reconcile the rescission with the ignition data in DEIS Table 21, and quantify the expected increase in human-caused ignitions from new road access weighed against any claimed reduction in wildfire hazard. The regulatory flexibility certification also cannot stand as written. The agency certifies no significant impact on small entities while its own DEIS names outfitters, guides, and tour operators as affected, and its Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification is reached by spreading expenditure loss across every small firm in the sector nationally rather than examining the guides and outfitters holding permits in the specific affected areas. The agency concedes some firms may lose those receipts. It should withdraw the certification and assess impact on the small entities actually operating in and permitted for the potentially affected roadless areas. The Chugach National Forest in Alaska is the most roadless national forest in the entire system. Ninety-nine percent of it has never had a road built through it. It holds 40 inventoried roadless areas totaling 5,439,110 acres. The Copper River Delta within it hosts the largest concentration of shorebirds in the Western Hemisphere during spring migration, including western sandpiper in the millions. Bald eagles, trumpeter swans, brown bear, moose, and mountain goat depend on this landscape at a scale that exists nowhere else in the national forest system. The 2001 rule is the structural protection that has kept those conditions intact. A state-petition process substituted for a national rule creates no guarantee that protection continues, and the agency's own record does not model what happens to that ecosystem if the rule falls. Finally, the proposal itself 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. My years of hiking, birding, and backpacking in California's roadless areas, and my expectation that federal policy would continue to protect them, are exactly the kind of reliance interests the agency invited and then declined to assess. The agency must identify and weigh those interests as part of this proceeding, including what this comment represents. Sincerely, Kristen Sorensen Petaluma, CA

I am writing to strongly oppose the proposed changes to the roadless rules. Resending this rule will have monumental impacts on our country’s national forests, which are some of the most pristine and valuable resources for recreation and ecosystem preservation. Once they lose their integrity through road construction, it will be difficult to get them back. Removing the rule will increase wildfire risk, as wildfires are much more likely to begin near roads. Our country already spends $3 billion each year fighting fires on federal lands and rescinding this rule will only increase that number. Resending the rule will also affect wildlife populations, whose habitat will be further fragmented and lost by roads and other activities. I often frequent national forest areas in my free time for recreation and would be devastated to lose any of these areas that help make our country so great.

Dear Secretary Rollins, I grew up on the edge of the El Dorado National Forest; a place that will forever be dear to my heart, though I now live in the also-magical realm of the Gifford Pinchot National Forest. As someone who recreates in these public lands, I am -not- in support of building more roads in them. I have seen the tragedies of additional road-building in these wild areas too often; habitat is fragmented and animals are often killed trying to access breeding grounds, forage, and other essential habitat. Hazardous chemicals and tire dust from vehicles are dispersed into these environments, threatening drinking water and our Western salmon populations. Though some claim that the Roadless Rule has increased the incidence of wildfire, this is untrue, and wildfires are more likely to ignite near roadsides.(1) Please leave the Roadless Rule in place as it is. I absolutely do not support any of the proposed alternatives that would weaken it. Please spend taxpayer money responsibly on conservation endeavours that support these irreplaceable lands instead of paving them over. References: (1)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 Sincerely, Nicole Johnston Vancouver, WA 98683 nljohnston.ast@gmail.com

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I've spent my career in climate, helping some of the world's largest companies reduce their environmental impact. I know lasting progress depends on clear, enforceable rules that protect shared resources. Before this work, I watched public lands opened to private interests in ways that degraded public welfare and left communities to bear the costs. Any repeal would repeat that pattern. Repeal would open millions of acres to road building, logging, mining, and drilling. Wildfire is the stated reason, but the clearer motive is more timber for private industry. These forests store carbon, shelter wildlife, and protect drinking water for millions. Please reject this repeal and protect them for future generations. The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

Hello, I strongly believe the Roadless Rule should not be rescinded. Roads and culverts are the number one source of degradation for our sensitive meadow systems that clean and store water at the top of all watersheds. We have so many roads that are unused wreaking havoc in forests that should be decommissioned or reused rather than building more roads and subjecting the last remaining slices of surviving complex ecology to constant noise and violence. Leave these spaces as they are to recover as much as they can as we continue to degrade their edges. Why are we accelerating some kind of technology-fueled heat death? We have solutions available to us. My heart breaks for future children and wildlife should this rule be passed. With love and human kinship, Ash Waters

I writing to urge you to choose Alternative 1: Status Quo/No Action in your final ruling on the proposed Roadless Rule Rescission. There are many compelling reasons to oppose the rescission. I’ll list just a few of them, focusing on ones that are particularly pertinent in Montana, which is where I live. I’m sure that you’re hearing about most of these from other folks, so I don’t think there’s a great deal of need for me to go on and on. The public is opposed—overwhelmingly so—to removing protections for roadless areas. More than 99% of responses received thus far are against the rescission of the Roadless Rule. Even amongst folks who can’t be bothered with writing letters, support for Roadless Areas has been around 76%. These are public lands we’re talking about, and how the public would like to see them used ought to weigh heavily in the decision-making process. Municipal Watersheds will be degraded. Building more roads in our National Forests will increase erosion, which will add to run-off and water purification costs. More than a third of Montanan’s water comes directly from or is downstream of roadless areas. Wildlife habitat will be further fragmented. I’m lucky enough to make my home in the Greater Yellowstone Ecosystem (outside Livingston, MT), which is “the most intact temperate ecosystem in the world,” according to wildlife biologist Doug Smith. Removing the roadless buffer along the edges of this ecosystem will harm wildlife habitat if/when extractive industries move in. The Greater Yellowstone area draws visitors from around the world and has been studied and written about by many. We need more protections—not fewer—for an ecosystem as important as this one. Recreation Economy. Tourism is a big deal Montana, supporting 1 in 11 jobs. Outdoor recreation is also important to Montana residents, making up 4.9 percent of Montana’s GDP. 5.9 of Montanans work in fields related to outdoors recreation. Much of this recreation takes place on public lands that are easily accessible from cities and towns, and these places often include IRAs. It seems unlikely that the extractive industries enabled by rescinding roadless protections will provide a net gain for Montana’s economy, since tourism and outdoor recreation would likely suffer. Maintenance Backlog for Existing Forests Service Roads. If we can’t take care of the ones we already have, we probably don’t need more. Enough said. Private Inholding Access. This is a big one, especially for those of us who live near or like to recreate in the Crazy Mountains. The Crazy Mountains are made up of “checkerboard” public and private land ownership, though some sections (not the right ones, in my opinion) were consolidated a couple of years ago. Most of the checkerboard is currently within the Crazy Mountain IRA. If roadless protections are removed, it will be easier for owners of private inholdings to petition for permission to build a road to their property. These roads would fragment wildlife habit, disrupt public recreation, and have a negative impact on tribal resources. The boon this would provide for owners of formerly difficult-to-access private inholdings is substantial, and casts new light on the checkerboard consolidation deal brokered by the Yellowstone Club in 2025. Wildfire Reduction. This is one of the primary reasons given by the Forest Service for its need to rescind the Roadless Rule. However, scientific evidence does not support the building of roads as a way of reducing wildfire risk—in fact, human caused ignitions in Montana are more than 8 times higher within 100 yards of a road than they are on more remote forest service land. I live a couple of miles from an IRA that runs along the northern edge of Absarokas, and the wildfires we’d had in this area since I’ve lived here tended to be fought by air. Some ignitions occurred on private property (often, a vehicle was involved), others were caused by lightning strikes, but the outcome was the same: the sky was abuzz. At times, firefighters were dropped into wilderness areas to fight fire on the ground—but roads provided little in the way of meaningful firefighting access. Plus, there’s enough wiggle room in the current Roadless Rule to allow for forest thinning and controlled burns in the WUI. Though it will never be perfect, I believe that the Roadless Rule and wildfire protection for our towns and neighborhoods in the urban interface can successfully coexist. Thanks for hearing me out. There’s plenty more I could say, but I believe I’ve gone on for long enough. I hope you make a decision that serves the general public, not a select few. Please go with Alternative 1. The other options serve neither our forests nor the people who love them.

I support doing away with then roadless rule. The past 30 years of no management has led to more fires, less management, less access, and overall the declining of forest health. The hands off management practices are a failure and do not serve the public nor the environment. We need active management to restore forest and improve habitat for wildlife.

I support the current Roadless Area Conservation Rule. The current Roadless Rule helps to protect public land from threats to its protected water and wildlife, from human caused fire and from developments that decrease its value to this citizen who cherishes and enjoys wild lands. Our dry western lands are under threat. The Roadless Rule helps to protect our decreasing water resources on public lands. It supports the genetic connectivity that wildlife species need to survive. Limiting roads decreases the threat of accidental or intentional human-caused fire ignitions. Many of us who live in the western United States recreate in remote public lands. We are willing to put in the energy to access these lands because we know that they are untrammeled and provide home for creatures and plants we value. They have deep inherent value to us. The U S Forest Service has a huge backlog of work needed to maintain current roads on the public lands it manages. It has not been provided with the money to do this. Do not defile our lands further by increasing the number of roads. Do not diminish the value of our federally owned lands (read: owned by us, the citizens of the United States) by making it easy for mining or logging or other commercial interests to access and exploit them. Maintain the current Roadless Area Conservation Rule. Sincerely, Skip

I support increased flexibility for wildfire mitigation, forest health treatments, and community protection, but I want strong safeguards to maintain important wildlife habitat, water quality, hunting opportunities, and the roadless character of high-value backcountry areas.

I am a restoration ecologist with direct experience monitoring rare plants, including on Forest Service land that is currently protected by the 2001 Roadless Rule. I wholeheartedly oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. The Arizona willow, Salix arizonica, is a rare willow species that acts as an indicator species for the health of high elevation streams and wet meadows in the Four Corners states. The willow is listed as critically imperiled in New Mexico, where I was able to visit populations across its range to evaluate population health and wetland functioning. The results of those surveys were stark: the least accessible, most protected populations were by far the healthiest, with lower incidences of grazing and disease, taller individuals, and more reproductive individuals present. Populations in one of the inventoried roadless areas adjacent to the Latir Peak Wilderness are already at a tipping point, with stunted individual plants that were unable to flower due to cattle grazing in the area. Potentially subjecting this species to additional stressors from development and altered hydrology will have devastating impacts on their already fragmented and struggling populations. This example is just one in thousands of species, including over 400 that are protected under the Endangered Species Act, that will be negatively affected by opening large swaths of land to new road building and extractive industry uses. The purported benefits in no way outweigh the potential costs of loss of species and their habitats.

Please do not rescind the roadless rule. Rescinding or changing this rule and allowing roads and motorized vehicles has the potential to cause serious damage to our beautiful public lands, and the wildlife that lives on them, that could take decades, or even generations, to undo. U.S. citizens should be able to enjoy the beauty and peacefulness of nature and our public lands without worrying about vehicles causing damage or noise. Thank you

I urge you to keep the 2001 Roadless Area Conservation Rule fully in place. Roadless forests protect clean drinking water, wildlife habitat, and carbon storage, and they preserve places like the wild backcountry surrounding Crater Lake, where undeveloped forests help safeguard the watersheds and quiet landscapes that make the region so special. New roads and logging in these areas would fragment habitat, increase erosion and wildfire risk, and add costs to a Forest Service that already can't maintain its existing road network. Once these places are developed, they can't be restored, so please protect roadless areas for current and future generations. Thank you for considering my comment.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66). The Roadless Rule provides a clear, consistent standard for protecting national forest lands that have remained largely free from road construction. Rescinding the entire rule is unnecessarily broad when the Forest Service already has tools to address specific needs such as wildfire mitigation, forest restoration, public safety, and other necessary management activities. I am particularly concerned about the practical consequences of allowing additional road construction in currently roadless areas. New roads fragment wildlife habitat, increase erosion and sediment runoff into streams, and create continuing maintenance costs. They can also permanently alter areas valued for hiking, hunting, fishing, recreation, clean water, and their undeveloped character. These concerns are especially relevant in North Carolina and the Southern Appalachians, where national forests protect important watersheds and biologically diverse ecosystems and support local recreation and tourism. If the Forest Service believes changes to the existing rule are necessary, it should address demonstrated management problems through targeted modifications rather than eliminating nationwide protections altogether. I ask the Forest Service to consider the environmental, fiscal, and long-term consequences of rescission and retain the Roadless Area Conservation Rule.

I am against repealing the federal regulation regarding the roadless rule. I believe building roads increases human-caused wildfire starts, fragments wildlife habitats, and threatens clean drinking water for millions of Americans. This protection should not taken away. We need to protect our natural spaces.