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Dear Chief Tom Schultz: As an outdoor enthusiast, I respectfully urge the Department to consider that the 2001 Roadless Area Conservation Rule represents a policy conclusion reached after one of the most extensive administrative processes in Forest Service history — and that overturning such a conclusion requires a comparably rigorous administrative basis, which the proposed rescission has not yet provided. I live in and love this area, and I want to be able to continue to visit and bring my children in the future! Trails and bodies of water, like Castle Lake, are precious venues for the public to connect with and appreciate nature. Threatened species, such as the California condor, Monarch Butterfly, Northern spotted owl, and Rufous Hummingbird rely on these lands for habitat. Regarding the Castle Crags A in the Shasta-Trinity National Forest, California: Roadless forests provide undisturbed nesting, stopover, and wintering habitat for migratory birds protected under the Migratory Bird Treaty Act. Roads concentrate nest predators near edges. Predation by edge-following predators — Blue Jays, raccoons, snakes — is concentrated near roads, clearings, and forest edges. Distance to unpaved road was the strongest predictor of nest survival in a study of 463 nests across 17 songbird species. Nest predation, not parasitism, accounts for 75 to 100 percent of nest failures in most studies (DeGregorio et al. 2014; Akresh et al. 2024). — DeGregorio et al., 2014 (https://doi.org/10.1002/ece3.1049); Akresh et al., 2024 (https://doi.org/10.5751/JFO-00481-950212) Rescinding the Roadless Rule would open the Castle Crags A, Shasta-Trinity National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Losing federal protection for roadless areas threatens the very future of those areas. Please act to protect them for future generations.

Dear Secretary: I spend a lot of time in nature. Watching wildlife in roaded and unroaded country for a long time has shown me the rule is the variable that matters. The Rattlesnake wilderness is nearby where I live and provides habitat for a myriad flora and fauna. Roadless areas are important for migratory birds and animals. First time I ever felt a mountain lion watching me was in the Rattlesnake Wilderness. Access to roadless areas. Peace. I enjoy getting out to look for wildlife and watch the birds and rescinding this rule would take away peace and territory for many of God’s creatures. Regarding the Rattlesnake in the Lolo National Forest, Montana: Roadless forests provide undisturbed nesting, stopover, and wintering habitat for migratory birds protected under the Migratory Bird Treaty Act. Roads concentrate nest predators near edges. Predation by edge-following predators — Blue Jays, raccoons, snakes — is concentrated near roads, clearings, and forest edges. Distance to unpaved road was the strongest predictor of nest survival in a study of 463 nests across 17 songbird species. Nest predation, not parasitism, accounts for 75 to 100 percent of nest failures in most studies (DeGregorio et al. 2014; Akresh et al. 2024). — DeGregorio et al., 2014 (https://doi.org/10.1002/ece3.1049); Akresh et al., 2024 (https://doi.org/10.5751/JFO-00481-950212) Rescinding the Roadless Rule would open the Rattlesnake, Lolo National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. I think rolling back the 2001 Rule is just another bad idea by our current administration. Please don’t do it. The Department should close this proceeding by declining to rescind the 2001 Roadless Area Conservation Rule. With best wishes, CommentID: RLC-20261006-3D639I

I am writing to oppose any recision or reduction in the Roadless Area Conservation Rule. I live within a couple of hours drive of Mount Hood National Forest and the Gifford Pinchot National Forest and I hike, hunt, and fish in both places as well as further afield in Oregon and Washington. More roads are bad for everything I value in my public lands. Roads help predators chase down prey, like the birds and ungulates that I hunt. Roads increase predator effectiveness by giving predators easy travel routes to find and chase down prey. Anyone who has seen coyotes trotting down roads, and who has followed deer or antelope in a vehicle as they continue to follow the path rather than escape into the woods has seen how roads benefit predators. https://onlinelibrary.wiley.com/doi/full/10.1002/ece3.1049 Roads increase erosion and the silt from roads runs into waterways. Turbidity and sedimentation negatively impact salmonid habitat by filling in gravel beds (reds) where anadromous fish lay their eggs, smothering the eggs, or simply destroying the habitat. Roads destroy the quiet, remote character of the places that I want to visit. It is very difficult to find five contiguous miles within a day's drive where I can walk in any direction without encountering a road. Roads only provide access in the sense that a person wants to access a roadbed. There are plenty of roadbeds in urban, suburban, exurban, and rural areas, and the forest service alone has 380,000 miles of road, the majority of which it is already incapable of maintaining. We hear a lot about enforcing laws on the books, how about fixing the roads we already have rather than destroying more habitat to build more roads we will be incapable of maintaining? Roads invites heavy travel and heavy travel leads to trash, invasive species spread, and fire. Studies find that wildfires tend to start near roads. https://link.springer.com/article/10.1186/s42408-026-00450-2 The last thing our wild places need is more roads. Fire suppression and prevention is a dishonest pretext. Homes are not located in roadless areas, and these areas are relatively small compared to roaded areas. The administration is hostile to conservation, and this rule change is just one more example of that.

To Whom It May Concern at the U.S. Forest Service: In my retirement I have become a community scientist, and I am a very active volunteer with the Maryland Bird Conservation Partnership. I am deeply concerned about further forest fragmentation, which is a threat to forest interior dwelling birds. Losing bird species to extinction should be prevented for its own sake. But widespread species extinction, which is happening at a rapid pace, is a threat to humankind as well. In addition, as a practical day-to-day matter, I live in the Washington, DC, area, so I know how important clear, clean water from the mountains into the Chesapeake Bay Watershed is to the quality of life of all the people who live here. The 2001 Roadless Rule is policy that needs to stay in place if we are going to maintain hope for the survival of many species. Regarding the George Washington National Forest, Virginia: “More than half of migratory bird species in North America are experiencing population declines. Habitat loss and the resulting fragmentation on the breeding grounds are strongly correlated with observed population declines for the Connecticut warbler, which has experienced a total population decline of 62% since 1966 and declined by −8.99% per year between 2000 and 2017. Land-use practices that retain large, forested patches within landscapes will likely benefit breeding populations of this declining songbird. — PMC / Proceedings of the Royal Society B, 2021 (https://doi.org/10.1098/rspb.2020.3164)” “For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival rate. This model accounted for 78% of the total weight of evidence, and no other model was within 3.8 delta AICc units. From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. — PMC / Ecology and Evolution, 2014 (https://doi.org/10.1002/ece3.1049)”Edit quote One-Sided Purpose and Need Omitting Countervailing Conservation Values: The Purpose and Need section frames rescission almost entirely around administrative flexibility while giving only passing acknowledgment to the 2001 Rule's protective function. The DEIS itself states that the 2001 Rule was "intended to provide lasting protection for inventoried roadless areas," then pivots directly to the assertion that "increased management flexibility... is needed to better meet the multiple-use mission" (Purpose and Need for Action, pp. 18-19), without weighing that flexibility against the ecological values the Rule was designed to protect. Independent research found that 57% of wildlife species of conservation concern have suitable habitat in inventoried roadless areas, and that these areas often protect watersheds supplying drinking water to hundreds of thousands of people. The document does not address whether the agency considered this evidence or why it was rejected. NEPA requires forthright disclosure of trade-offs under Robertson v. Methow Valley Citizens Council, 490 U.S. 332 (1989) and 42 U.S.C. § 4332(2)(C). I request a revised, balanced Purpose and Need section addressing these values. This comment is against rescission. Most respectfully, Margaret Poethig

To the Roadless Rule Rulemaking Docket: As someone who values getting out into country that hasn't been made easy to access, I want to be straightforward: this rule protects something real, and rolling it back would have real consequences. As a Native American I consider this land part of my heritage. This land should remain protected and the woods, flora, fauna, and migratory species allowed to flourish. This land is unique, special, beautiful, and should never be open to logging, mining, or any destruction. If a single memory can stand for the whole of that attachment, it is this one. This land has been valuable to my healing as someone diagnosed with PTSD. These two facets of my connection to the lands at issue together constitute the basis of my opposition to the proposed rescission. Regarding the Bearwallow in the Pisgah National Forest, North Carolina: Under the standardized IUCN-CMP classification, threat 8.1 — 8.1 - Invasive non-native/alien species/diseases — is recorded against Carolina Northern Flying Squirrel (Glaucomys sabrinus coloratus, T2) in the Bearwallow Inventoried Roadless Area, Pisgah National Forest, at Slight or 1-10% pop. decline severity with Pervasive - restricted scope. The intact, unroaded condition of Bearwallow is the functional mechanism that currently limits 8.1 - Invasive non-native/alien species/diseases to its assessed severity and scope. Road construction removes this constraint and permits escalation. Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Carolina Northern Flying Squirrel (Glaucomys sabrinus coloratus) in the Bearwallow Inventoried Roadless Area, including the documented threat of 8.1 - Invasive non-native/alien species/diseases. "On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches)." — Iranian Journal of Environmental Health Science & Engineering (PMC), 2013 “We document over a one-quarter decline in bird abundance and almost complete avoidance by some species between noise-on and noise-off periods along the phantom road and no such effects at control sites—suggesting that traffic noise is a major driver of effects of roads on populations of animals. We replicated the sound of a roadway at intervals during the autumn migratory period using a 0.5 km array of speakers within an established stopover site in southern Idaho. — Proceedings of the Royal Society B: Biological Sciences (PMC), 2013 (https://doi.org/10.1098/rspb.2013.2290)” “From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar. — Ecology and Evolution (PMC), 2014 (https://doi.org/10.1002/ece3.1049)” “Mammal and bird population densities declined with their proximity to infrastructure. The effect of infrastructure on bird populations extended over distances up to about 1 km, and for mammal populations up to about 5 km. Data were gathered from 49 studies on 234 mammal and bird species. The main response by mammals and birds in the vicinity of infrastructure was either avoidance or a reduced population density. — Biological Conservation (ScienceDirect), 2010 (https://doi.org/10.1016/j.biocon.2010.02.009)” The Department is asked to close this rulemaking without rescinding the 2001 Roadless Area Conservation Rule. With hope, CommentID: RLC-20260902-WI0SYY

To the Roadless Rule Rulemaking Team: I'm a birder. The rule has worked. Don't change it. I write specifically regarding the Savannah in the Apalachicola National Forest, Florida: Roadless forests provide undisturbed nesting, stopover, and wintering habitat for many migratory birds protected under the Migratory Bird Treaty Act. Roads concentrate nest predators near edges. Predation by edge-following predators — Blue Jays, raccoons, snakes — is concentrated near roads, clearings, and forest edges. Distance to unpaved road was the strongest predictor of nest survival in a study of 463 nests across 17 songbird species. Nest predation, not parasitism, accounts for 75 to 100 percent of nest failures in most studies (DeGregorio et al. 2014; Akresh et al. 2024). — Brett A. DeGregorio, Patrick J. Weatherhead, Jinelle H. Sperry, 2014 · Ecology and Evolution (https://doi.org/10.1002/ece3.1049) Rescinding the Roadless Rule would open the Savannah, Apalachicola National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. This rule has been effective at preserving and protecting many birds who depend on these areas while migrating. Please leave it be, don't threaten these few places they have left to safely travel. This is a formal objection to rescission, entered for the record.

As a hiker and nature lover who plans a trip every year I urge the Forest Service to keep these protections in place. I've recently been getting into birding and its brought me such joy. Reading things like from a sample of 463 nests of 17 songbird species, landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival was devastating. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar. — Brett A. DeGregorio, Patrick J. Weatherhead, Jinelle H. Sperry, 2014 · Ecology and Evolution (https://doi.org/10.1002/ece3.1049). It's so important to preserve nature and animals - we're the stewards and protectors of this planet. Since 2001, the Roadless Rule has helped protect critical habitat for animals and plants protected under the Endangered Species Act, with more species protected each year. Rescinding the rule would harm the wild homes of more than 500 protected species, including American wolverines, gray wolves, Canada lynx, grizzly bears, Quino checkerspot butterflies, and northern spotted owls (as well as countless species not protected under the Act, like Alexander Archipelago wolves and Queen Charlotte goshawks). — Center for Biological Diversity, 2025 (https://www.biologicaldiversity.org/campaigns/Roadless-Rule-rollback/) My long-term partner is a firefighter. Keeping these areas roadless is what protects us against wildfires. From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.7 fires/1,000 hectares), followed closely by that in Inventoried Roadless Areas (1.9 fires/1,000 ha). The highest wildfire-ignition density was in lands within 50 meters of roads (7.4 fires/1,000 ha), and the second highest wildfire-ignition density was in lands outside of the 100-m road buffers, but not in wilderness or roadless areas (3.5 fires/1,000 ha). — Aplet, Gregory H.; Hartger, Phil; Dietz, Matthew S., 2025 (https://www.wilderness.org/sites/default/files/media/file/Summary%20NFS%20roads%20fire%20paper%20-%202025.pdf) Reading the statistics about how this will increase wildfires was infuriating. Even though these fires will, on average, be smaller than fires farther from roads, but there will be more of them, and some of them will grow to become large fires. — Aplet, Gregory H.; Hartger, Phil; Dietz, Matthew S., 2025 (https://www.wilderness.org/sites/default/files/media/file/Summary%20NFS%20roads%20fire%20paper%20-%202025.pdf)