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I am a conservationist, multi-state, multi-generational landowner, Master Naturalist, and former Georgia Native Plant Society President and wish to present my objection to the consideration of removing the 2001 Roadless Area Conservation Rule that has stood firm across multiple circuits and implemented by both parties. Protecting the biodiversity of these pristine areas is paramount to me as a voting citizen whose parents taught me to love, respect, respect science, and cherish our land and wild places and the value in education. I strongly oppose rescinding the Roadless Rule in its entirety based as wildfire protection. I am well aware that fire suppression has degraded fire-dependent ecosystems. A century of aggressive fire suppression — made possible by road access — has transformed fire-adapted forests like longleaf and ponderosa pine. This is why we are planting long leaf and potentially Montane Long Leaf on our farms once we have completed our controlled burns and invasive removals. We understand that without periodic low-intensity fire, fuels will accumulate as they have most recently with Helene and forest structure shifts toward conditions that support catastrophic, stand-replacing fires (USDA Forest Service 2001). — USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf) We are well aware that fire suppression has degraded fire-dependent ecosystems. A century of aggressive fire suppression — made possible by road access — has transformed fire-adapted forests like longleaf and ponderosa pine. This is why we are planting long leaf and potentially Montane Long Leaf on our farms once we have completed our controlled burns and invasive removals. We understand that without periodic low-intensity fire, fuels will accumulate as they have most recently with Helene and forest structure shifts toward conditions that support catastrophic, stand-replacing fires (USDA Forest Service 2001). — USDA Forest Service, Pacific Northwest Research Station, May (https://www.fs.usda.gov/pnw/pubs/pnw_gtr509.pdf). We have personally experienced that roads are where most wildfires start. A 2026 study covering 30 years of wildfire data across the entire National Forest System found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied (Aplet et al. 2026). — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2). Most ignitions near roads are also human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2). Best practices we personally witnessed in the Sequoia National Forest is done by workers using manual tools to collect and create burn pyramids to be left in tack until winter when conditions are right for controlled burns. We do not need to introduce roads which are proven to result in soil quality reduction to forest edges; introduction of invasive species and diseases to all areas through use of skid steers and other logging equipment; increased sedimentation in streams and rivers polluting water quality and impacting all aquatic lifeforms but also natural aquifers from which humans draw their drinking water; they create barriers to aquatic and terrestrial movement, increase potential for landslides and disturbances to forest roots and slope stability; introduction of cattle and other agricultural animals will lead to soil erosion, disease, invasive plant expansion and much more I can expand upon. Road construction in roadless areas is the primary cause of ecosystem destruction and endangering wildlife. For these reasons, in addition to the aesthetic loss of our national treasures, we vehemently oppose rescinding the Roadless Rule. Facilitating energy, mineral, and timber production “to the maximum possible extent” on public lands will cost our nation far more in ecological desecration than will be compensated by short-term revenues they generate. Now that the Endangered Species Act no longer defines what is "harmful", we absolutely must protect the habitats of our biodiverse habitats in our public spaces. Wildfires are without doubt attributed to roads and public interaction with our wilderness spaces. I urge you to support H.R. 3930, the Roadless Area Conservation Act, to provide lasting protection for inventoried roadless areas within our treasured National Forest System. With hope, Melanie Pollard

Dear Secretary: As an avid hiker and outdoorswoman, I am writing to strongly oppose repealing the roadless rule. I stand with the majority of Americans who support keeping the Roadless Rule - 76% according to the Pew Research Center, and over 90% of the comments during the last public comment period. Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Rescinding the Roadless Rule would open the Cedar Mountain, Chattahoochee 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. Areas protected by the Roadless Rule include more than 25,000 miles of trails - including the trail closest to my heart, and the most famous of our National Scenic Trails, the Appalachian Trail. Repealing the Roadless Rule would also impact a variety of other outdoor activities, including over 760 miles of whitewater routes, thousands of climbing and bouldering routes, world-class backcountry hunting grounds, and pristine fishing waters. These activities are not only beneficial for the economies of nearby, often rural communities, but also allow people an escape from industrial noise, traffic, and permanent roads. Eliminating the Roadless Rule is harmful to the environment in countless ways - impacting native species' habitats and migratory areas, worsening water quality, and harming endangered species' already limited populations, to name a few. The most concerning risk to me is the increased risk of wildfires. With higher temperatures and less water fall each year, we already have deadly wildlifes every year. Repealing the Roadless Rule has been touted as a way to reduce wildfires erroneously. The majority of fires are human-caused and the U.S. Forest Service data shows that 78 percent of human-caused fires on national forests begin within half a mile of a road. Bringing roads further into the backcountry means increased risk of more fires due to more humans having easier access to these remote areas. Additionally, thicker forests are better wind barriers to prevent the spread of wildfire, and older trees take longer to burn through than young trees. This comment joins the record in opposition to the proposed rescission action. Sincerely, Dr. Danielle Rustem

I am writing in favor of keeping the 2001 Roadless Area Conservation Rule as-is and in opposition to this proposed change that would rescind the 2001 Roadless Area Conservation Rule. Keeping roadless areas of our national forests is vital for long-term resource security, safety, and conservation. Rescinding the Roadless Rule and increasing the number and total length of roads will endanger our national forests by increasing the risk of wildfire and introduction of invasive species. Roads can increase the frequency of wildfires (eg, Narayanaraj and Wimberly 2012, Bowring et al 2024) - and even though fragmentation may reduce burn area, forest fragmentation is harmful to plants and animals in many ways and should not be viewed as an overall benefit or solution for wildfires. Similarly, roads (ie, human mediated travel) are a known dispersal pathway for invasive species (eg, Mortensen et al 2009, Ladin et al 2023, Solano et al 2021, Haubrock et al. 2026); many pest insects threaten our forests and to speed their spread into currently roadless areas could cause irreparable harm and economic loss (Lovett et al 2016). The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). Rescinding the roadless rule will be harmful to fish and wildlife by increasing forest fragmentation, destroying habitat, increasing soil disturbance and run-off into waterways, and increasing the likelihood of human-wildlife conflicts (Croke and Hairsine 2006, Robinson et al 2010, Boston 2016). These conflicts will be great in magnitude if the roads lead to more timber production and mining. Increased timber production and mining is harmful to fish and wildlife. Furthermore, increasing roads and areas where natural resources are extracted will reduce access for recreation and have a negative economic impact on the tourism industry. The Forest Service's own analysis shows economic losses from reduced tourism and recreation caused by rescinding the Roadless Rule. Our National Forests should remain intact and roadless so Americans can enjoy them now and for centuries in the future. Short-term gains from resource extraction are not more important that the long-term integrity and preservation of our natural areas and resources for all Americans and future Americans to enjoy. Finally The rule states that "local decision making would remain subject to the substantive requirements of the Endangered Species Act". However, current changes to the Endangered Species Act means that any roads, timber harvest, of mining that removes habitat and other resources necessary for endangered species to survive would not be a violation of the Endangered Species Act. Therefore, endangered species are at highest risk by rescinding the Roadless Rule. Species cannot survive if their habitats are destroyed, degraded, and fragmented. I urge the USDA to protect our natural resources and do NOT rescind the Roadless Rule. Narayanaraj and Wimberly 2012 - https://doi.org/10.1016/j.apgeog.2011.09.004 Bowring et al 2024 - https://doi.org/10.1038/s41467-024-53460-6 Mortensen et al. 2009 - https://doi.org/10.1614/IPSM-08-125.1 Ladin et al. 2023- https://doi.org/10.1038/s41598-022-25989-3 Solano et al. 2021 - doi: 10.1093/jee/toaa278 Haubrock et al 2026 - doi: 10.1002/brv.70121 Lovett et al 2016 - https://esajournals.onlinelibrary.wiley.com/doi/pdf/10.1890/15-1176 Croke and Hairsine 2006 - https://cdnsciencepub.com/doi/10.1139/a05-016 Robinson et al 2010 - doi:10.1139/A10-002 Boston 2016 - DOI 10.1007/s40725-016-0044-x

To the Department of Agriculture and the Forest Service: As an outdoor enthusiast, I am entering the record to observe that the 2001 Roadless Area Conservation Rule represents a considered administrative judgment that the public interest in roadless national forest — ecological, recreational, and watershed-related — outweighs the interests served by road-building authorization, and that the Department's proposed rescission has not offered a sufficiently developed basis for overturning that judgment. Regarding the Coconino Rim in the Kaibab National Forest, Arizona: Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Rescinding the Roadless Rule would open the Coconino Rim, Kaibab 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. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. “Although roadless areas tend to be cooler, moister, and higher elevation, they experienced greater fire extent than roaded areas over the past three decades. Critically, however, there was no significant difference in fire severity after accounting for biophysical differences. The authors suggest the greater extent of fire in roadless areas "may confer resilience to these landscapes in the face of climate change." — Johnston et al., 2021 (https://doi.org/10.1088/1748-9326/ac13ee)” Rescinding the roadless rule will create greater fire risk Keep the Roadless Rule. Don't rescind. Yours truly, CommentID: RLC-20261005-VOX7I2

As someone who has spent considerable time accessing national forests specifically in areas the 2001 Rule has kept outside the road system, I am in a position to observe that the qualities those areas retain — watershed function, interior acoustic character, landscape continuity — are not incidental but are direct products of the Rule's regulatory prohibition. Your statement1 Roadless areas in our national forests are absolutely mandatory for the preservation, health, and continuation of these invaluable treasures. They contribute to offset carbon, protect large areas from invasive species and the risk of fires that follow road incursions into pristine forests. Regarding fire, for example, most ignitions near roads are human-caused. One study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Roadless areas also protect wildlife and threatened plant and animal species. The wildlife communities reflect the vertical zonation of forest and alpine habitats. In the dense hemlock-fir forests, the federally threatened Northern spotted owl hunts small mammals under cover of old-growth canopy, while the federally threatened Marbled Murrelet nests in the largest trees. The federally endangered gray wolf moves through these forests as an apex predator, and the federally threatened North American wolverine ranges across high-elevation terrain. In streams and cold-water tributaries, the federally threatened Bull Trout and the proposed Similarity of Appearance (Threatened) Dolly Varden occupy distinct niches in the aquatic food web, with Chinook salmon moving through larger channels during spawning seasons. Above the forest, the federally threatened Mt. Rainier white-tailed ptarmigan inhabits alpine heather communities, where Suckley's cuckoo bumble bee, proposed for federal endangered status, pollinates alpine flowers. The proposed threatened Monarch butterfly passes through the area during migration, while the federally threatened Yellow-billed Cuckoo uses riparian corridors in lower elevations. Roadless areas protect water availability and water quality, increasingly critical as our planet undergoes wide fluctuations between drought and flood. Mt. Baker West spans 25,390 acres across the subalpine terrain of the Mt. Baker-Snoqualmie National Forest in Washington. The landscape rises from Bell Pass at 3,900 feet through a series of prominent ridges and peaks—Grouse Ridge, George Peterson Butte, Park Butte, and the Twin Sisters peaks reaching 7,000 feet—that form the South Fork Divide. Water originates in the highest elevations and flows downslope through a network of named streams: the Upper Middle Fork Nooksack River headwaters drain northward through Clearwater Creek, Rocky Creek, and Ridley Creek, while Skookum Creek, Bell Creek, Gallop Creek, Wallace Creek, Green Creek, Rankin Creek, and Cornell Creek carry water through the western and southern portions of the area. The Middle Fork Nooksack River integrates these tributaries into a major watershed system that defines the hydrology of this region. Finally, the Roadless Area Conservation Rule of 2001 established protections for the Mt. Baker West area, a 25,390-acre Inventoried Roadless Area, prohibiting new road construction and timber harvesting. In February 2023, the Nooksack Tribe signed a Memorandum of Understanding with the U.S. Forest Service to co-manage sections of the Mt. Baker-Snoqualmie National Forest, formalizing their ongoing role in the stewardship of these ancestral lands. The Roadless Rule for these national forests must be kept intact. Otherwise the dangers are incalculable - to flora, fauna, waters, agreement with the Nooksack Indian tribe, and with all the American people who actually hold these lands. PLEASE do not rescind the Roadless Rule. I have addressed some of the specific gaps in the Forest Service's EIS, and demand that the Roadless Rule not go into effect. Please listen to the forests. Thank you, Dana Jack

Dear Chief Tom Schultz, I write in opposition to the proposed rescission of the Roadless Rule as a birder and wildlife conservationist, as well as a homeowner with beloved cabins in a National Forest in Northern Wisconsin. I am familiar with the scientific findings, much of it generated by the federal government, that indicate that roads fragment forests, which affects the ability of birds to successfully breed. Roads also make wildfire more likely, not less. The science points against rescission of the Roadless Rule. The region surrounding Wheeler Lake was heavily logged during the late 19th and early 20th centuries. Initial harvests focused on virgin white pine from approximately 1835 through the 1860s, followed by hardwoods such as maple and oak. The Holt Lumber Company operated a specific line known as the Wheeler Spur, which ran a few miles south from Townsend toward the lake region. By the 1920s, the land was described as "over-cut, burned-over, and farmed-out." Much of the land became tax-delinquent and was abandoned by owners. The Roadless Rule has protected the Wheeler Lake Islands area from logging and logging roads for 25 years. The diversity of habitat and wildlife in this area is spectacular and too precious to lose. t's taken a hundred years for this area to recover from heavy logging. It’s now a beautiful area beloved by many. Let’s not ruin it again. If logging roads cut through this area the probability of wildfires will increase, not decrease. Roads are where most wildfires start. A 2026 study covering 30 years of wildfire data across the entire National Forest System found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied (Aplet et al. 2026). — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Wimberly, 2012 (https://doi.org/10.1016/j.apgeog.2011.09.004); Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Regarding the 09184 - Wheeler Lake Islands in the Chequamegon-Nicolet National Forest, Wisconsin: "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 “The Roadless Rule does not replace forest plans. It supplements them — adding a layer of protection against road construction and most commercial timber harvest across all 44.5 million acres of inventoried roadless area, regardless of what the underlying forest plan would otherwise permit (USDA Forest Service 2001)” This comment is against rescission. Thank you, Margaret Poethig

Dear Ms. Rollins, Climate adaptation needs intact landscapes. I follow the science. The 2001 Rule keeps them intact. Keep the Rule. I have seen the devastation that wildfires have on the community who is impacted, by the animals who lose their homes and the men and women who fight them at risk to their lives. Wildland firefighters risk their lives every day to save others, and the least we can do is make it easier for them to protect us (and our planet). What I've described isn't recreation. It's a relationship. Rescinding this rule ends it. During my time living in Upper Michigan, we were often impacted by the smoke from wildfires in Canada. It is scary to be kept indoors, watching the world around you covered in a thick smog, wondering if things would ever be safe again. I now live in fear that these same wildfires will take my families homes and lives in Montana, and I can do nothing to stop it. Forest canopies cool the ground beneath them. Under intact forest canopies, daily maximum temperatures average roughly 4°C cooler than in open areas, with peak cooling exceeding 5°C during heatwaves. During an extreme 11-day heatwave in 2003, forest understory was on average 5.2°C cooler than open areas, with peak differences reaching 11°C (Schnabel et al. 2025; Wang et al. 2025). — Florian Schnabel, Rémy Beugnon, Bo Yang, Ronny Richter, Nico Eisenhauer, Yuanyuan Huang, Xiaojuan Liu, Christian Wirth, Simone Cesarz, Andreas Fichtner, Maria D Perles‐Garcia, Georg J A Hähn, Werner Härdtle, Matthias Kunz, Nadia C Castro Izaguirre, Pascal A Niklaus, Goddert von Oheimb, Bernhard Schmid, Stefan Trogisch, Manfred Wendisch, Keping Ma, Helge Bruelheide, 2025 · Ecology Letters (https://doi.org/10.1111/ele.70096) “Rescinding this rule will remove prohibitions on road construction, reconstruction, and timber harvest on nearly 59 million acres of the National Forest System, allowing for fire prevention and responsible timber production. — U.S. Department of Agriculture, 2025 (https://www.usda.gov/about-usda/news/press-releases/2025/06/23/secretary-rollins-rescinds-roadless-rule-eliminating-impediment-responsible-forest-management)” “We found that human-caused ignitions were concentrated close to roads, in high road density areas, and near the wildland–urban interface. In contrast, lightning-caused ignitions were concentrated in low road density areas, away from WUI, and in low population density areas. Although previous studies have documented associations of human-caused fire ignitions with road corridors, less consideration has been given to understanding the multiple influences of roads on the fire regime at a broader landscape-scale. — Ganapathy Narayanaraj | Michael C. Wimberly, 2012 · Applied Geography (https://doi.org/10.1016/j.apgeog.2011.09.004)” “The 2001 Roadless Rule Final EIS predicted that extensive fire reduction work would not be needed within inventoried roadless areas for at least 20 years. In the 24 years since that analysis, the area encompassing the WUI has increased alongside increased insect and disease and wildfire activity throughout the National Forest System, including within inventoried roadless areas. — Department of Agriculture, Forest Service, 2025 (https://www.federalregister.gov/documents/2025/08/29/2025-16581/special-areas-roadless-area-conservation-national-forest-system-lands)” “wildfires are almost twice as likely to occur in roaded areas as in roadless areas, because roadless areas are generally located further away from communities and are harder to access — U.S. Senate, 2025 (https://www.congress.gov/bill/119th-congress/senate-bill/2042/text)” “Constructing roads into roadless areas would simply increase the number of fires that need to be suppressed without having a meaningful impact on the likelihood of a large fire igniting. — Aplet, G.H., Hartger, P., Dietz, M.S., 2026 · Fire Ecology (https://doi.org/10.1186/s42408-026-00450-2)” “Building new roads is likely to increase fire ignitions. — Aplet, G.H., Hartger, P., Dietz, M.S., 2026 · Fire Ecology (https://doi.org/10.1186/s42408-026-00450-2)” “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). — Aplet, G.H., Hartger, P., Dietz, M.S., 2026 · Fire Ecology (https://doi.org/10.1186/s42408-026-00450-2)” Rescinding the Roadless Rule will make wildfires even more dangerous and more prominent. My opposition is on the record. In solidarity, CommentID: RLC-20260830-8W6EF2

Hello, I am a resident of Madison County NC, and a small business owner running a native plant nursery focused on the native plants of the Blue Ridge. For a number of years have spent time outdoors in the Pisgah and Nantahala National Forests here. I am writing to express my opposition to rescinding the Roadless Rule which conserves over 170,000 acres in North Carolina alone. As those of you in charge of making these decisions tend not to be scientists, I'd like to make sure you are aware of a number of facts before deciding the fate of this currently conserved land. As we know from the study of ecology, human beings exist in an interconnected web with all other living beings on the planet. Making changes to one part of the web inevitably creates changes across the web, oftentimes leading to a crescendo of affect to areas of that web that were not originally targeted. Some of the ecosystem services that human society depends upon for its very survival include filtration of air and water, erosion control, crop pollination, and nutrient cycling. You may or may not be aware that the Southern Appalachian region is among the most biodiverse temperate areas on the globe. The term biodiversity refers to richness and variety not only in the many species of plants, fungi, archaea, etc., but also the genetic diversity contained within individual species. I'd like to direct you to this peer-reviewed scientific article which describes how conservation planning specifically for biodiversity can and does also preserve the ecosystem services which we rely upon for survival: Chan KMA, Shaw MR, Cameron DR, Underwood EC, Daily GC (2006) Conservation Planning for Ecosystem Services. PLoS Biol 4(11): e379. https://doi.org/10.1371/journal.pbio.0040379 That article also has an extensive reference list at the end in case you'd like to brush up on the subject. I see that some of the justification for reneging on the Roadless Rule has been "wildfire reduction." I would also like to direct you to another peer-reviewed article showing that human-caused wildfires (the bigger, more damaging catagory) tend to be started in much greater concentrations near roads and in areas where roads are in high density: Ganapathy Narayanaraj, Michael C. Wimberly, Influences of forest roads on the spatial patterns of human- and lightning-caused wildfire ignitions, Applied Geography, Volume 32, Issue 2, 2012, Pages 878-888, ISSN 0143-6228, https://doi.org/10.1016/j.apgeog.2011.09.004. It is well documented that roads lead to habitat loss and fragmentation, including biodiversity loss. Of course as we are aware, the proposed development in our precious conservation areas will not end with just roads. Further development and habitat alteration will have its own consequences in turn. Here is one more article to illustrate the point that road development is a net negative for ecosystem function: Bennett, V.J. Effects of Road Density and Pattern on the Conservation of Species and Biodiversity. Curr Landscape Ecol Rep 2, 1–11 (2017). https://doi.org/10.1007/s40823-017-0020-6 As a citizen and member of the local business community, I oppose rescinding the Roadless Area Conservation Rule as it goes against the best interest of the human population of the United States of America.

Dear Brooke L. Rollins, What I, as a wildlife observer, am in a position to attest — and what the agency's own monitoring data confirms — is that the species composition of inventoried roadless country differs measurably from that of proximate roaded country, and the 2001 Rule is what has preserved that distinction. The roadless areas around my home, which are many, are considered our backyards here. True pathways into nature. No heavy equipment and roads ruining the environment. No future high costs of more roads to maintain, while facing consistently reduced annual budgets. We have to do EVERYTHING to protect what we have. There's no UNDO button. Among many days in these forests, one has stayed with me. As a birder, I've seen so many firsts for my life list. And because many of these are migratory, they wouldn't have the successes here with so much interference from roads, equipment, car noise, auto/animal accidents, and more. The Department is urged to find, on the basis of this and similar testimony, that the burden of justification for rescission has not been met and that the 2001 Roadless Area Conservation Rule should remain in effect. Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Ganapathy Narayanaraj | Michael C. Wimberly, 2012 · Applied Geography (https://doi.org/10.1016/j.apgeog.2011.09.004) Rescinding the Roadless Rule would open the Green Mountain, Olympic 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. It's been proven with studies that road-building doesn't necessarily reduce wildfire risks. One big reason is man is more times than not the cause of wildfires. Roads across our protected areas will significantly increase these incidences. If there's a natural cause, such as lightning, that's going to happen regardless. The Federal Register Notice initiating the rescission states the goal explicitly: to "facilitate domestic production" of "timber, energy and mineral production... to the maximum possible extent." The proposal is being advanced under Executive Orders 14192 (deregulation), 14225 (timber expansion), and 14154 (energy unleashing), and follows other administrative actions calling for a dramatic increase in logging and oil and gas drilling on federal lands. An increase in these industrial activities would worsen climate change, destroy recreation areas, put the lands at greater risk of wildfire, destroy wildlife habitat, and threaten drinking water sources. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Research - Biodiversity Conservation” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Research - Fire Safety” “Literature synthesis shows roaded landscapes correlate with higher sediment loads, while roadless areas act as refugia for salmonids and freshwater biodiversity. — Research - Water Quality” “Maps mature and old-growth (MOG) forests across the conterminous U.S. using LiDAR-derived structural metrics. Finds 76% of MOG on federal lands (storing 10.64 Gt CO2e) is vulnerable to logging. Recommends elevating the conservation status of Inventoried Roadless Areas as a key step toward Paris Agreement compliance and 30x30 targets. — Research - Old-Growth Climate Solution” Kind regards, CommentID: RLC-20260824-4G8ORL

Brooke L. Rollins and Tom Schultz, Living next to these forests, I know where the water comes from. Introducing miles of road will inevitably and irrevocably harm the beautiful watersheds of Big Sur, and erode onto Hwy 1- already strained by landslides and harsh winter rains. I work for the Santa Cruz RCD and have made it my career to engage people around Forest Health and Community Resilience. Morr roads does nothing but exploit our wild lands to serve corporate greed while threatening the communities close to them. One occasion in particular illustrates what that relationship means in practice. The Timber Fire is currently burning through Big Sur, an area that historically had regular fire intervals that maintained the chapparal we all love along the coast. Bringing more roads will cause more fires and disrupt the regularity of the fire interval, potentially lead to type conversion, and cause catastrophic environmental change in an area many locals look to to appreciate the public lands of our great nation. What the preceding account reflects is not sentiment alone but a record of sustained public use and dependence that the Department is obligated to weigh in this proceeding. Regarding the Bear Mountain in the Los Padres National Forest, California: Road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Rescinding the Roadless Rule would open the Bear Mountain, Los Padres National Forest to road construction and associated ground disturbance. Road-building will absolutely increase fire risk and harm our beautiful natural ecosystems. This area is essential to the community and repeated devastating wildfire caused by human ignition will exponentially threaten and change the lands we love- eventually causing major erosion and disrupting our local natural resources and economy. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Most ignitions near roads are human-caused. The same study found that human-caused ignitions were concentrated near roads, near the wildland-urban interface, and in high-road-density areas. Lightning-caused ignitions, by contrast, were concentrated away from roads and in lower-density areas. The further from a road, the fewer human-caused fires (Narayanaraj & Wimberly 2012; Aplet et al. 2026). — Ganapathy Narayanaraj | Michael C. Wimberly, 2012 · Applied Geography (https://doi.org/10.1016/j.apgeog.2011.09.004) “Klamath-Siskiyou case study mapped ~500 roadless areas and found roadless tracts bolster habitat representation and landscape connectivity, including smaller roadless patches. — Research - Biodiversity Conservation” “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones.” “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Research - Fire Safety” “Finds Tongass & Chugach forests hold a disproportionate share of tree carbon in high-integrity landscapes among U.S. national forests—critical for meeting climate and biodiversity goals. — Research - Carbon Storage” The grounds articulated in this comment support one conclusion: the Roadless Area Conservation Rule should not be rescinded. CommentID: RLC-20260823-4E6CHL