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I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Our national forests are public lands held in trust for all of us. Once intact forests are opened to new roads and development, the ecological damage can extend far beyond the pavement. I urge the Forest Service to protect these landscapes rather than weaken one of the few safeguards that keeps them intact. Roadless areas are critical habitat. Dietz et al. (2021) examined 537 wildlife species of conservation concern and found that 308 species, or 57%, had suitable habitat within Inventoried Roadless Areas. These areas therefore provide meaningful protection for vulnerable wildlife. Roads also fragment habitat and disrupt ecological connectivity. Forman and Alexander (1998) documented road impacts including habitat fragmentation, barriers to wildlife movement, erosion, and altered hydrology. A road is not simply a line through a forest. It creates disturbance and access that can change how wildlife use an entire landscape. Fragmentation can prevent animals from moving between feeding, breeding, and seasonal habitats and can isolate populations that need connected habitat to survive. The argument that more roads will necessarily reduce wildfire risk is also not supported by the evidence. Aplet, Hartger, and Dietz (2026) analyzed more than three decades of national forest wildfire data and found approximately 1.97 fires per 1,000 hectares in Inventoried Roadless Areas, compared with 7.99 fires per 1,000 hectares within 50 meters of roads. Ignition density generally declined as distance from roads increased. Roads can improve firefighter access in some circumstances, but they also increase human activity and opportunities for ignition. Expanding roads should not be treated as an automatic wildfire solution. Road construction also has consequences for water and soil. Roads can compact soil, concentrate runoff, alter drainage, destabilize slopes, and increase erosion and sediment delivery to streams (Forman & Alexander, 1998). These impacts can degrade aquatic habitat and water quality far downstream. Protecting forests is also protecting the watersheds they sustain. Roads can further increase the spread of invasive plants. Healey (2020), using more than 15,000 forest inventory plots, found non-native plants were approximately twice as common within 152 meters of roads than farther away. Once invasive species become established, restoration can be difficult and expensive. I strongly oppose weakening the Roadless Rule because the burden of proof should be on those seeking to disturb intact public lands, not on those asking to preserve them. We already have roads and developed areas where infrastructure can be placed. We cannot recreate an old-growth forest, restore lost wildlife connectivity, or reverse decades of ecological change simply by deciding later that a road was a mistake. Protecting roadless areas does not prevent responsible wildfire management. Targeted actions can be evaluated where there is a demonstrated need without broadly opening protected landscapes to additional roads and development. The public has also demonstrated strong support for the Roadless Rule. A nationally representative 2019 survey found that 75% of Americans supported it, including majorities of Democrats, Independents, Republicans, and rural respondents (Pew Charitable Trusts, 2019). During a previous consideration of repeal, more than 625,000 public comments were submitted, with approximately 99% opposing repeal (Pew Charitable Trusts, 2026). Scientific evidence and public input point in the same direction: intact roadless forests are worth protecting. Public lands are a legacy we inherit and a responsibility we pass forward. I ask the Forest Service to reject the proposed rescission and retain the 2001 Roadless Area Conservation Rule. We should not sacrifice irreplaceable ecosystems for roads that can be built elsewhere. References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology. doi:10.1186/s42408-026-00450-2 Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32, e01943. doi:10.1016/j.gecco.2021.e01943 Forman, R. T. T., & Alexander, L. E. (1998). Roads and their major ecological effects. Annual Review of Ecology and Systematics, 29, 207–231. doi:10.1146/annurev.ecolsys.29.1.207 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. doi:10.1088/1748-9326/aba031 Pew Charitable Trusts. (2019). Americans Support “Roadless Rule” to Protect Remarkable Forests. Pew Charitable Trusts. (2026). U.S. Department of Agriculture Proposes Eliminating the Roadless Rule.

Please do not repeal the Roadless Rule. The Roadless Rule protects over 58 million acres of inventoried roadless areas (IRAs) in national forest land from road-building, commercial logging, and other industrial activity. These protections are important and should be maintained. The USDA’s stated Rationale for the Proposal to repeal, i.e., that the “Roadless Rule has limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns” (1) does not hold up and is not supported by the draft EIS. A study that carefully examined long-term forest health implications of roadlessness in terms of wildfires and invasive species concluded based on Forest Service data that “With the benefit of twenty years of monitoring, the best available records do not support speculation that roads are needed in IRAs to maintain forest health.“ (2). I am concerned that repealing the Roadless Rule would promote the spread of invasive plant and insect species (2). Invasive seeds and pathogens are actively moved along roads via construction equipment, logging trucks, and other vehicles. I am concerned that repealing the Roadless Rule would threaten clean water supplies on which millions of people depend. Inventoried roadless areas are home to numerous endangered and threatened species (3). Construction of roads in these areas would fragment and damage their habitats and contribute to their extinction. The draft EIS for the proposed rule rescission acknowledges on p. 233 that “By removing the Roadless Rule, roads and timber harvest are likely to penetrate much farther into roadless areas, resulting in a greater degree of fragmentation.” In addition, the draft EIS acknowledges on p.79 that “effects could also include long-term impacts such as invasive plant establishment and/or spread, a disruption in water relationships as would occur through diverting of surface or subsurface flow from road construction, or increased erosion potential through ground disturbance, and habitat fragmentation.” No evidence that those effects could be prevented is presented. Please avoid these damaging effects by keeping the Roadless Rule. I am also concerned that repealing the Roadless Rule would lead to the construction of roads through pristine and irreplaceable forests at immense public expense when there is already a huge backlog of maintenance on existing roads. I worry that the new roads would primarily serve the short-term interests of those who would profit from commercial logging and the extraction of minerals and fossil fuels, to the detriment of the environment and the public good. The knowledge that our nation’s roadless national forests exist, and that the native trees, birds, and animals within them are protected by the Roadless Rule, is a highly valuable intangible good that deserves consideration. The US public overwhelmingly supported adoption of the Roadless Rule and overwhelmingly supports keeping it (4). The draft EIS notes that of the comment letters received during the Notice of Intent comment period, approximately 99 percent were generally opposed to the proposed rule rescission. Please do not willfully ignore the evidence that the vast majority of people of this country want to keep the Roadless Rule. Please do not repeal the Roadless Rule. (1) See Published Document: 2026-16965 (91 FR 53827), Federal Register / Vol. 91, No. 160 / Thursday, August 20, 2026 / Proposed Rules, section entitled “Rationale for the Proposed Rule” (p. 53828). (2) See Healey, S. “Long-term forest health implications of roadlessness “ Environmental Research Letters. 15: 104023 (2020). DOI: https://doi.org/10.1088/1748-9326/aba031 (3) See Matthew S. Dietz, Kevin Barnett, R. Travis Belote, Gregory H. Aplet, “The importance of U.S. national forest roadless areas for vulnerable wildlife species”, Global Ecology and Conservation, Volume 32, 2021, e01943, https://doi.org/10.1016/j.gecco.2021.e01943. (4) See “Comment analysis finds over 99% opposition to repealing 2001 Roadless Rule”, report from Center for Western Priorities, September 19, 2025, updated Tuesday, September 23, and sources cited therein. (https://westernpriorities.org/2025/09/comment-analysis-finds-over-99-opposition-to-repealing-2001-roadless-rule/).

I am a student studying environmental studies and I am concerned about the environmental impacts of road construction in forests currently protected by the Roadless Rule. I strongly support the No Action alternative (Alternative 1) in the current Draft Environmental Impact Statement. While the proposed rescission claims to address conservation objectives such as preserving the diversity of plant and animal species, peer-reviewed research demonstrates that removing Inventoried Roadless Area (IRA) protections will directly contradict this objective. For example, Watson et al. find that “There is a direct correlation between the risk of species extinction and human footprint. Impacts such as direct habitat loss, habitat degradation through increased isolation of plant and animal populations, greater exposure to edge effects, and invasion by disturbance-adapted species are cumulative, leading to degraded ecosystems over time and, eventually, loss of regional connectivity and biodiversity” (doi.org/10.1038/s41559-018-0490-x). Additionally, Dietz et al. find that, “Of the 537 wildlife species of conservation concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA lands. If all IRAs were added to the protected-area system, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas.” (doi.org/10.1016/j.gecco.2021.e01943) As a concerned student who cares about nature, I urge the USDA to maintain 2001 Roadless Area Conservation Rule protections in full.

Dear Chief Tom Schultz, I am commenting to oppose the rescission of the Roadless Rule as a graduate student studying wildlife ecology; empirical research conducted throughout wild areas in the U.S. has shown that roadless areas are crucial in maintaining habitat quality and connectivity. Living and working in the Chiricahuas and other Sky Island mountains in Arizona is why I fell in love with the landscapes and wildlife of the American Southwest, and has played a key role in shaping who I am as a scientist and conservationist. Working at the Southwestern Research Station was my first taste of the Southwest, and made me decide to study ecology in Southwest desert and mountain ecosystems. While hiking near Silver Peak in a Roadless Area, I observed my first mountain lion in the wild. I am a graduate student focused on predator ecology and conservation, and I know that wilderness areas unfragmented by roads like those found in the Chiricahuas are critical for the population viability of large predators like mountain lions as well as endangered species like jaguar and Mexican gray wolves. These apex predators require occupy massive territories and require unbroken connected habitat to move. Roadless areas provide key habitat for countless animals, but are particularly crucial for threatened and endangered species. A study of carnivores in several Arizona protected areas, including the Chiricahuas, found that occupancy of common species like bobcat and coyote were less likely to decrease near roads, while the occupancy of rarer species like mountain lions increased farther from roads — Baker and Leberg, 2018 (https://doi.org/10.1371/journal.pone.0195436). Jaguars and Mexican gray wolves are even more sensitive to human disturbance and dependent on intact wild habitat. Individual jaguars and Mexican gray wolves rely on montane habitat in multiple "Sky Island" ranges, separated by lowland desert. Roadless areas that encompass elevational gradients connecting these montane habitat resources are necessary to allow individuals to move freely throughout their home ranges, and consequently, secure the health of populations across Southern Arizona, New Mexico and into Mexico. The "may affect" standard does not require proof of population-level impact or demonstrated mortality. A reasonable possibility that road building, timber harvest, or increased access in the Chiricahua IRA disturbs, displaces, or degrades habitat for Jaguar (Panthera onca, E) is sufficient to trigger the Section 7 formal consultation obligation. The below studies further detail the importance of roadless protected areas for habitat conectivity of wide-ranging threatened species: “Klamath-Siskiyou case study mapped ~500 roadless areas and found roadless tracts bolster habitat representation and landscape connectivity, including smaller roadless patches. — Strittholt & DellaSala, 2001 (https://doi.org/10.1046/j.1523-1739.2001.99577.x)” “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “A foundational, frequently-cited review documenting seven categories of negative road effects: mortality from construction, vehicle collisions, modified animal behavior, alteration of physical and chemical environments, spread of exotic species, and increased human use. Establishes the scientific rationale for keeping roadless areas roadless and is cited extensively across the roadless-rule literature. — Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “Identifies the most "natural" (least human-modified) corridors between large protected areas in the U.S. Many of the highest-priority corridors fall within or overlap inventoried roadless areas, providing direct evidence that maintaining roadless protections is critical to climate-adaptation connectivity strategies for wide-ranging species. — Belote et al., 2016 (https://doi.org/10.1371/journal.pone.0154223)” Decades of ecological research throughout North America confirm the value of roadless areas in preserving undegraded habitat and maintaining connectivity that is necessary for apex predators and other threatened species to sustain genetically diverse populations. Please act responsibly and in the best interest of America's biodiversity and natural heritage, and do not allow the Roadless Rule to be rescinded. With appreciation, Isabel DeVito MSc student studying predator community ecology Bachelor's in Organismal Biology and Ecology, Colorado College CommentID: RLC-20261007-ESFWD9

I am a PhD candidate in Earth Science and I am concerned about the environmental impacts of road construction in forests currently protected by the Roadless Rule. I strongly support the No Action alternative (Alternative 1) in the current Draft Environmental Impact Statement. While the proposed rescission claims that removing roadless area protections will reduce wildfire risks, a mounting body of research evidence proves the contrary. For example, a three-decade record of national forest wildfires finds that “The ignition density of human-caused wildfires within 250 m of a road was more than three times greater than at any distance beyond 500m during the study period and exceeded the ignition density of lightning fire near roads by almost twofold.” The authors conclude that “building roads into roadless areas is likely to result in more fires” (doi.org/10.1186/s42408-026-00450-2). While the proposed rescission claims to address conservation objectives including preserving sources of public drinking water, peer-reviewed research provides strong evidence that removing protections for Inventoried Roadless Areas (IRAs) directly threaten these sources. For example, DellaSala et al. find that “Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost.” IRAs make up 661 of the 914 national forest watersheds, with 55% of the 914 watersheds acting as source areas for facilities that treat and distribute drinking water to the public. Removing roadless area protections will have costly and damaging impacts on drinking water infrastructure: “The cost-savings to water treatment plants and highway departments from avoiding sedimentation caused by logging in IRA watersheds is estimated at up to $18 billion annually” (doi.org/10.2489/jswc.66.3.78A) While the proposed rescission claims to address conservation objectives such as preserving the diversity of plant and animal species, peer-reviewed research demonstrates that removing Inventoried Roadless Area (IRA) protections will directly contradict this objective. For example, Watson et al. find that “There is a direct correlation between the risk of species extinction and human footprint. Impacts such as direct habitat loss, habitat degradation through increased isolation of plant and animal populations, greater exposure to edge effects, and invasion by disturbance-adapted species are cumulative, leading to degraded ecosystems over time and, eventually, loss of regional connectivity and biodiversity” (doi.org/10.1038/s41559-018-0490-x). Additionally, Dietz et al. find that, “Of the 537 wildlife species of conservation concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA lands. If all IRAs were added to the protected-area system, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas.” (doi.org/10.1016/j.gecco.2021.e01943) As an outdoor enthusiast, scientist, and concerned citizen, I urge the USDA to maintain 2001 Roadless Area Conservation Rule protections in full.

I strongly oppose the USDA’s proposal to rescind the 2001 Roadless Area Conservation Rule. The Roadless Rule has been a cornerstone policy in protecting U.S. wild lands from industrial development, and according to countless peer-reviewed studies, it is a vital component in the protection of numerous species from encroaching habitat degradation as well as the provision of drinking water and recreational activities for local communities. Removing this policy would be devastating for both wildlife and communities that depend on these areas for their essential needs, and, antithetical to what the USDA proposes, this action could increase the risks that the USDA is attempting to prevent. Inventoried roadless areas (IRAs) are critical to the protection of vulnerable/endangered species and the biological diversity of U.S. wildlife. Many protected areas of wild lands serving as refuges for vulnerable species are bordered by IRAs, which increase the size of these protected areas and provide a vital buffer between protected areas and external stressors like commercial development and other human land use activity (Talty et al., 2020). These areas are of particular importance for species that require large areas free of human disturbance, and many species with conservation concern depend disproportionately on IRAs for their habitat needs, with eighty-six of these species having over 5% of their total suitable habitat in IRAs despite IRAs covering only 2% of the contiguous U.S. (Dietz et al., 2021). Wild protected areas often maintain their typical ecological processes and have fewer local extinctions and are thus more likely to sustain their biodiversity in the future (Talty et al., 2020). IRAs are also critical to maintaining the area of conservation reserves in ecoregions. When considering designated wilderness areas alone, without including IRAs, 40% of ecoregions have greater than 12% of their total area in conservation reserves. However, when including IRAs with designated wilderness, this jumps to 71% of ecoregions that exceed the 12% threshold. Additionally, the size of a conservation reserve positively correlates with biological diversity, so preserving these areas, again, is essential to keeping the biological diversity of U.S. species high and protecting species that may be sensitive to human activity. (DeVelice & Martin, 2001). Ultimately, fragmenting IRAs with roads and construction activity would massively offset the ecological benefits of these areas and endanger the protections of vulnerable species residing in these areas. In addition to wildlife conservation, roadless areas have a substantial role in decreasing the ignition of wildfires. Rather than being more likely to burn under high-intensity conditions, Inventoried Roadless Areas (IRAs) in all of the 8 contiguous-U.S. Forest Service regions have demonstrated the second-lowest wildfire-ignition density between 1992 to 2024 of 1.97 fires/1000 ha when compared to the wildfire-ignition densities in wilderness areas, “national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas,” and “lands within 50 m of roads,” only surpassed by the wildfire-ignition density in designated wilderness areas. Conversely, the highest wildfire-ignition density of 7.99 fires/1000 ha was seen in lands within 50 m of roads, more than four times the density seen in IRAs (Aplet et al., 2026). Allowing the construction of roads within roadless areas would greatly increase ignition frequency and the risk of wildfires within these regions due to greater opportunity for recreational negligence and arson, and this could subsequently affect nearby communities and be difficult to mitigate. I urge the USDA to reconsider this proposal and take no action to change or rescind the 2001 Roadless Rule. References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(1). https://doi.org/10.1186/s42408-026-00450-2 DeVelice, R. L., & Martin, J. R. (2001). Assessing the extent to which roadless areas complement the conservation of biological diversity. Ecological Applications, 11(4), 1008–1018. https://doi.org/10.1890/1051-0761(2001)011[1008:atetwr]2.0.co;2 Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32(e01943), e01943. https://doi.org/10.1016/j.gecco.2021.e01943 Talty, M. J., Mott Lacroix, K., Aplet, G. H., & Belote, R. T. (2020). Conservation value of national forest roadless areas. Conservation Science and Practice, 2(11). https://doi.org/10.1111/csp2.288

I would like to strongly urge the USDA & USFS to retain the 2001 Roadless Area Conservation Rule. The USDA may believe that rescinding the rule is necessary for wildfire prevention but current research rejects this notion. Instead, research from the USFS itself has indicated that forests with and without roads have burned at similar rates ever since the roadless rule came into effect (Healey, 2020). Given the neutrality of roads upon wildfire impact in Inventoried Roadless Areas (IRAs), it is then important to address the immense benefits of retaining IRAs in contrast to their other heavy downsides. IRAs have tremendous public recreation demand for activities like hunting and fishing. Rescission of the rule would risk destroying these opportunities against the public’s interest (Olden et al., 2026). Moreover, IRAs have been a triumph in protecting species of conservation concern (SCCs). Research shows that IRAs contain critical wildlife habitat across taxa with 57% of SCCs in the contiguous United States having suitable habitat in at least one or more IRAs. As for what we stand to lose, research suggests that increased road construction in IRAs will result in increased spread of invasive plants and damage to the watersheds that 25 million Americans rely on for clean drinking water (Healey, 2020 & Olden et al., 2026). Vehicles will bring in seeds of invasive species to IRAs that were previously undisturbed while increased industrial activity and sediment from road construction will pollute watersheds (Olden et al., 2026). Worst of all though, is that this proposed rule rescission is not fiscally sound. If the USDA truly wanted to mitigate the issues land managers and wildland firefighters face, then it would secure and commit funding resources to its already heavily backlogged maintenance requirements for the existing National Forest Road System. As of FY2023, the total cost for the USFS deferred maintenance is already at a whopping $8.6 billion. Instead the USDA is choosing to completely jeopardize all of the benefits IRAs bring us so that commercial logging can swiftly overcome this administrative hurdle for short term profit from irreplaceable old growth resources at exorbitant public expense. So, I ask once again that the USFS & USDA abandon this attempt to rescind the 2001 Roadless Area Conservation Rule. Instead, I urge them to see the tremendous cultural, social, economic, and conservation value in IRAs and the heavy threats people and ecosystems alike will face from the reckless increased road construction. I also urge the USDA & USFS to instead more closely collaborate with local land managers and state governments for the existing exceptions to IRAs backed by science and to fund the already underfunded National Forest Road System. Works Cited: Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32, e01943. https://doi.org/10.1016/j.gecco.2021.e01943 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15(10), 104023. https://doi.org/10.1088/1748-9326/aba031 Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), e0000538. https://doi.org/10.1371/journal.pwat.0000538

I am one of many who oppose the Roadless Rule Rollback. The Roadless Rule protects our environment and continues to shape how humans live . As someone for whom roadless national forest is not a policy category but a physical place — a specific and irreplaceable landscape that I have accessed, observed, and relied upon — I am submitting these comments to oppose the proposed rescission of the 2001 Rule and to request that the Department's final record reflect the full weight of the public interest the Rule was established to protect. I’ve spent time near Miller Creek. To have construction of roads near Miller Creek would not only raise the risk of human started fires, it would also be endangering a long list of animal and plant species. It would destroy historical sites of indigenous peoples. The CCC conducted reforestation projects throughout the Chattahoochee National Forest to repair damage from previous industrial-era clear-cutting and mining. We do not need any more destruction for our future generations to fix. Among many days in these forests, one has stayed with me. Traveling into nature is an escape for my husband and I. After meeting in New York, every vacation we've shared has been to escape into nature. Hiking and visiting Miller Creek was one of our many trips into nature. My husband was born and raised in Georgia. He is a hiker, an explorer and a lover of nature. He has shown me the true value of nature. Exploring forests, camping and experiencing wildlife is a gift. Protected lands need to stay protected. Not only to preserve wildlife existing for our future generations, but to protect these indescribable experiences. Nature is an escape for any of us, but for many people, nature is a way of life. An actual means of existence. For indigenous individuals, nature is their ancestry, their life purpose to protect, and apart of their beliefs that plant species like the Grandmother trees are a part of their family lineage. The Grandmother trees being stripped from Arizona is causing irreversible damage to the desert landscape of Arizona. It is also destroying indigenous legacies. The Department should understand that the Rule's rescission would produce real and lasting consequences — not only for the lands themselves, but for the people whose lives have been shaped by access to them. Regarding the Miller Creek in the Chattahoochee National Forest, Georgia: Roadless areas are disproportionately important habitat for federally listed threatened and endangered plants and animals. Roadless areas hold habitat for over half of America's wildlife species of conservation concern. A study of 537 imperiled wildlife species in the contiguous U.S. found that 308 — 57 percent — have suitable habitat in one or more Inventoried Roadless Areas. The median roadless area provides habitat for 10 such species, with a maximum of 62 (Dietz et al. 2021). — Matthew S. Dietz, Kevin Barnett, R. Travis Belote, Gregory H. Aplet, 2021 · Global Ecology and Conservation (https://doi.org/10.1016/j.gecco.2021.e01943) Rescinding the Roadless Rule would open the Miller Creek, 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. Construction runoff will lead to a large amount of sediment in the water, which will disturb aquatic life. Construction noise and air pollution will disturb animals on land and disturb their natural trails. Water moves through this landscape as both streams and subsurface flow, emerging in spring-fed seeps that support specialized, threatened plant and tree communities. Including Table Mountain pine and Flame Azalea. The understory in these moist forests is thick with great rhododendron and mountain laurel. The streams and seepage zones support aquatic and semi-aquatic wildlife. Including salamanders, eastern newts, and rainbow trout. In the forest, the federally endangered Northern Long-Eared Bat and federally endangered Gray bat hunt insects above the streams and in forest gaps. Here at Miller Creek, you’ll find everything from wild turkeys to monarch butterflies. There is a vast ecosystem and intricate workings of connectivity throughout and surrounding the areas of Miller Creek that cannot sustain construction of any kind. The Miller Creek roadless area, comprising 701 acres in Lumpkin County within the Blue Ridge Ranger District, is protected under the 2001 Roadless Area Conservation Rule and managed as part of the larger Chattahoochee National Forest established in 1936. The Rule should not fall; the Department should act to keep it in place.

Dear Secretary Brooke L. Rollins, I am writing to demand that roadless areas remain protected. These areas are invaluable and cannot be restored once lost. Future generation deserve no less. Short-sighted greed cannot be allowed to take away our children's future. I have visited the Canaan Valley for over 50 years. The chance to be in roadless areas as a young person actually changed my life. I learned to listen, hear, see, and love. I learned how to be quiet and know what is good about this life. The Canaan Loop is one of the most valuable recreational areas in West Virginia. The recreation economy is essential for the area. The chance to be in the wilderness is essential for both West Virginians and others (perhaps native West Virginians, like me) from surrounding states. Regarding the Canaan Loop in the Monongahela National Forest, West Virginia: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Rescinding the Roadless Rule would open the Canaan Loop, Monongahela 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. 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. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205)” “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Tongass roadless areas contain very large biomass and soil carbon stocks, underscoring old-growth protection as a critical climate solution with global significance. — DellaSala et al., 2022 (https://doi.org/10.3390/land11050717)” “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.” The forests covered by this Rule are irreplaceable. The Rule itself should be treated the same way. Yours truly, CommentID: RLC-20261006-OCPMQB

I strongly oppose rescinding the Roadless Rule and urge adopting Alternative 1 (no action). The currently intact wild lands are popular for recreation. Making up just 2 percent of the land in the lower 48 states, they irreplaceably provide important habitat for 57% of vulnerable terrestrial wildlife. Roadless areas help protect against human-cause wildfires — that’s because wildfires are four times more likely near roads, according to the DEIS. It states that “ignition density is approximately four times greater on other NFS lands compared to potentially affected IRAs and wilderness.” One reason the Roadless Rule was implemented in the first place was the Forest Service doesn’t have the money to maintain the roads it currently has. Roads are a costly expense. They also diminish water quality, fragment habitat areas, and irretrievably impact the scenery and self-renewal offered by hiking, hunting, birdwatching, backpacking and otherwise enjoying intact woods. The DEIS acknowledges the significant socio-economic loss in “non-commodity values” if the rule is rescinded. An economic analysis by Earth Economics found that the Roadless Area Conservation Rule brings $24 billion in benefits annually. I join the chorus of fellow citizens calling for abandoning the proposed rescission of the Roadless Rule. Select “No Action” on the DEIS. Sources: Dietz, M. S., et al. “The importance of U.S. national forest roadless areas for vulnerable wildlife species.” Global Ecology and Conservation, vol 32, e01943, 2021, doi.org/10.1016/j.gecco.2021.e01943. https://www.sciencedirect.com/science/article/pii/S2351989421004935?via%3Dihub Delaney, G. “Roadless Area Conservation Rule Brings $24B in Benefits.” Earth Economics, https://www.eartheconomics.org/news/roadless-rules.

Secretary Rollins, I urge you NOT to rescind the Roadless Rule. I have a BA, MA, and PhD in Geography, and currently serve as a cartographer at a large NGO, creating public-facing maps for ecological research being conducted around the globe. My work has made it very clear to me that roadless areas are critical to preserving ecosystems for research and recreational use. The benefits of roadless areas are empirically supported. Here are a few statistics: ignition density within 50 meters of a road was nearly four times that in roadless areas. Some (not all, or even most) fires are discovered because of road access, but those fires wouldn't have started if not for the road being there in the first place, bringing with it people; the primary source of ignition. The US Forest Service released a report: "“Building roads into inventoried roadless areas would likely increase the chance of human-caused fires due to the increased presence of people.” Furthermore, prohibiting road construction and reconstruction in these areas “would not cause an increase in the number of acres burned by wildland fires or in the number of large fires.” Roadless areas are extremely important for biodiversity as well. According to one study, "57% of [species of conservation concern] have at least some suitable habitat in one or more IRAs" (https://doi.org/10.1016/j.gecco.2021.e01943). Roads also bring with them invasive species, potentially decimating ecosystems that would have otherwise stayed intact, and reducing timber quality. Roads will also reduce the quality of water in otherwise pristine areas. The USFS itself has admitted that it cannot maintain at least 370,000 miles of roads with an existing backlog of road maintenance in the billions of dollars. Undeveloped areas are one of the unique treasures of the United States. So many parts of the world have fully developed or disturbed their ecosystems. We still have so much to learn from ours. It's one of the things that we can take pride in as Americans. Please do not take that away from us and from future generations.

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (36 CFR part 294, subpart B). The evidence-based science shows that Inventoried Roadless Areas (IRAs) provide clean water, carbon storage, wildlife habitat, and ecological integrity that would be put at risk if these protections were removed. The Forest Service's own analysis of the original Rule acknowledged that roads are the primary human-caused source of soil and water disturbance in forested environments (United States Department of Agriculture Forest Services 2000). Some IRAs protect watersheds supplying drinking water to hundreds of thousands of people (Talty et al. 2020). A 2026 study quantified the benefits IRAs provide for river protection, drinking water, and aquatic biodiversity, and warned that weakened protections could degrade drinking water quality (Olden et al. 2026). Removing road and harvest restrictions in these watersheds puts a service that cannot easily be replaced at risk. IRAs add disproportionately, relative to the area they cover, to the carbon captured by existing protected areas (Talty et al. 2020). IRAs hold 22% of the mature forest carbon stock and 27% of the old-growth carbon stock on national forest lands (Mildrexler et al. 2026). Mature and old forests also support biodiversity, water availability, and resilience to climate extremes (Mildrexler et al. 2026). Opening these lands to road building and commercial logging would release stored carbon and reduce future sequestration. Roadless areas on Forest Service lands are among the nation's most important biotic areas for conservation (Loucks et al. 2003). A later national analysis found that 77% of roadless areas had the potential to conserve threatened, endangered, or imperiled species, and that a handful of roadless areas hold a large share of suitable habitat for some species of concern (Dietz et al. 2021. Roads fragment habitat, introduce invasive species, and increase human disturbance, so losing roadless status would reduce the habitat these species rely on. A 2026 analysis found that IRAs contain higher-integrity forests than surrounding lands. Higher-integrity forests provide more clean water, biodiversity, cultural value, and climate regulation, and are associated with lower wildfire incidence (Mildrexler et al. 2026). The same analysis critiques the arguments offered to justify rescission. IRAs also buffer and connect existing protected lands, and about one-third of roadless forests border a national park or wilderness area (Talty et al. 2020). Rescission is sometimes justified to reduce wildfire risk. Research analysis associates intact forests with lower wildfire incidence (Mildrexler et al. 2026), and roads are a major source of human ignitions. I ask the Department to address this evidence in the final analysis and to explain specifically how new roads would reduce, rather than increase, fire risk, and costs. I also ask the Department to respond to the concern raised by commenters that the draft EIS itself shows increased fire, landslide, and cost impacts from rescission. I urge the Department to withdraw the proposal and retain the Roadless Rule. If the Department proceeds, it should fully analyze and respond to the peer-reviewed evidence above, including impacts on drinking water supplies, carbon stocks, and species of conservation concern, and consider alternatives that retain protections for the highest-integrity roadless areas. References Dietz MS, Barnett K, Travis BR, Aplet GH. 2021. The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation. 32:e01943. doi:10.1016/j.gecco.2021.e01943. [accessed 2026 Oct 3]. https://www.sciencedirect.com/science/article/pii/S2351989421004935. Loucks C, Brown N, Loucks A, Cesareo K. 2003. USDA Forest Service roadless areas: Potential biodiversity conservation reserves. Conservation Ecology. 7(2). doi:10.5751/es-00528-070205. Mildrexler DJ, Berner LT, Law BE, Booth MS. 2026. Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation. 321:111950. doi:10.1016/j.biocon.2026.111950. [accessed 2026 Oct 3]. https://www.sciencedirect.com/science/article/pii/S0006320726002624. Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L. 2026. Assessing the value of the U.S. roadless rule for people and nature. Ortega JCG, editor. PLOS Water. 5(7):e0000538. doi:10.1371/journal.pwat.0000538. Talty MJ, Mott Lacroix K, Aplet GH, Belote RT. 2020. Conservation value of national forest roadless areas. Conservation Science and Practice. 2(11). doi:10.1111/csp2.288. United States Department of Agriculture Forest Services. 2000. Forest Service Roadless Area Conservation . [accessed 2026 Oct 3]. https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf.

Dear Secretary Brooke L. Rollins: In my experience, roadless backcountry is not just scenery — it's functioning habitat, clean water, and quiet. Humanity finds refuge and redemption in wild places. The decision to rescind the roadless rule is one that forever destroys irreplaceable wilderness. Regarding the Devil's Den 09083 in the Green Mountain and Finger Lakes National Forests, Vermont: Forest plan consistency, multiple-use direction, and how proposed management would alter the roadless character of inventoried areas. Roadless areas fill gaps the existing protected-area system does not cover. Adding inventoried roadless areas to the U.S. protected-area system would increase representation of underprotected ecosystem types — including temperate grasslands (+57 percent) and cool temperate forests (+52 percent) — and would reduce the number of species of conservation concern considered "poorly represented" by 38 species. Forest plans alone do not provide the cross-forest consistency this network offers (Talty et al. 2020; Dietz et al. 2021). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288); Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943); UNKNOWN, 2021 (https://doi.org/10.1016/j.gecco.2021.e01943) Rescinding the Roadless Rule would open the Devil's Den 09083, Green Mountain and Finger Lakes National Forests 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. Four generations of our family have hiked and fished and explored the wilderness of the Green Mountains of Vermont. Destroying these areas destroys our history, destroys our ability to enjoy these areas forever. These lands belong to all of us. The rule that protects them should stay. Thank you, CommentID: RLC-20261005-VPYTWC

I really don't want this. If roads were to come into to place, the land around it would suffer. No more wildlife. No more clean water. No more beautiful forests. When I get older I desperately want to see the world. See it's animals and landscapes. But none of that is going to happen if these roads are built. Forests and mountains are a huge part of everyone's lives. It provides water for people to drink and can attract tourists to look at the environment. There are plenty of endangered and protected species on this land and all of them are going to die unless the roads don't go through. I know this comment is quite short but I'm glad I am able to express my view and where I stand in this. DON'T BUILD THE ROADS !! Critical-Habitat Counts Untraceable to the Incorporated Biological Assessments, and an Omitted Roadless-Specific Species Finding The DEIS's habitat baseline states, at page 141 (Chapter 3, "Assumptions Common to All Alternatives" - "Potentially Affected Environment" - "Habitat"): "Within the potentially affected environment there are 79 final or proposed critical habitats designated under the Endangered Species Act for species managed by USFWS and 19 critical habitats designated for species evolutionarily significant units or distinct population segments managed by NMFS." Two defects in that passage require correction in the FEIS. I state them as separate requests. The habitat baseline omits the one published finding in this record that is specific to inventoried roadless areas and to species of conservation concern. The baseline reports that the potentially affected environment "provides habitat for more than 300 threatened, endangered, and proposed species" and gives the two critical-habitat counts. It reports nothing about how concentrated at-risk wildlife habitat is inside inventoried roadless areas, although the record contains a published measure of exactly that. Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021), "The importance of U.S. national forest roadless areas for vulnerable wildlife species," Global Ecology and Conservation vol. 32, doi:10.1016/j.gecco.2021.e01943, examined 537 terrestrial vertebrate wildlife species of conservation concern in the contiguous United States and found that "308 species, or 57%, have at least some suitable habitat in inventoried roadless areas, even though inventoried roadless areas only cover 2% of the area of the contiguous United States." This is not "science or literature not previously considered" within the meaning of 7 CFR 1b.7(f)(2)(iv). The agency has held this study since scoping: it is cited in the DEIS's own Volume III by the Attorneys General of Washington, California, Arizona, Massachusetts, Minnesota, New Mexico, Oregon, and Vermont at pages 37 through 39, by a Member of the House Committee on Natural Resources at page 415, and by other commenters at pages 498 and 506. It nonetheless does not appear in the DEIS's References Cited. The cause-and-effect link to this analysis is direct. The DEIS measures the affected environment by counts of listed entities - species, critical habitats - and that metric is blind to how concentrated vulnerable-species habitat is within the specific land base whose protections the proposed rescission would remove. It is the concentration, not the count, that determines the magnitude of the effect: 57 percent of the national pool of vulnerable terrestrial vertebrates has suitable habitat on 2 percent of the land area of the contiguous United States, and that 2 percent is the land base at issue in this rulemaking. A baseline that omits this understates what the rescission places at risk, and every effects conclusion tiered to that baseline inherits the understatement. I request supplementation of the analysis under 7 CFR 1b.7(f)(2)(iii): incorporate the Dietz et al. 2021 finding into the habitat discussion of the affected environment, add the study to the DEIS References Cited, and carry a roadless-specific measure of species-of-conservation-concern habitat through the effects analysis for each alternative, including the no-action alternative. Under 7 CFR 1b.7(f)(3), I request that the response to each of the two items above cite where in the FEIS or the supporting proposal record the action taken is accounted for.

Dear Secretary and Chief: Dont let mans greed, ruin this countrys beauty - FDR Peace, I will personally lose peace. Peace on the water, peace in the woods, an escape from the busy go go go world we live in. As an angler who fishes for native trout in country most people drive past on the highway, the rule covering that country is doing real work. I'd ask you to keep it doing it. Regarding the Boggs Creek in the Chattahoochee National Forest, Georgia: We have already destroyed so much, why not hold onto the last bit of wilderness we have. Don't you want your children to enjoy the outdoors? What about their children? Almost 2000 species of animal or plant go extinct every single year. There are hundreds of endangered species in the Roadless Rule protected area. Keeping this rule intact can help these already endangered species. 30% of our National Forest system is protected by this rule. Almost One-Third. We are talking 58 million plus acres of wilderness. Untouched, unsoiled, unmolested land. For the religious folks, what would Jesus do? Roadless areas are disproportionately important habitat for federally listed threatened and endangered plants and animals. Roadless areas fill gaps in the existing protected-area network. Adding all Inventoried Roadless Areas to the U.S. protected-area system would reduce the number of imperiled wildlife species considered "poorly represented" in protected areas by 38 species. Roadless areas particularly increase representation of underprotected ecosystem types, including temperate grasslands (+57%) and cool temperate forests (+52%) (Talty et al. 2020; Dietz et al. 2021). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288); Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943); UNKNOWN, 2021 (https://doi.org/10.1016/j.gecco.2021.e01943) Rescinding the Roadless Rule would open the Boggs Creek, 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. If the Department is genuinely listening to the public, it should be hearing a consistent message: keep the Rule. Best, CommentID: RLC-20260930-PZP04F

The position set forth in this comment is that rescission is unwarranted and the Rule should be preserved. CommentID: RLC-20260930-NYAKV6 I oppose recission of the Roadless Rule. This Rule has demonstrated its benefits over many years and there is absolutely no justification for rescinding it. Benefits must continue to accrue to habitats, resident flora and fauna, fire prevention, carbon sequestration, and human enjoyment of wild places. Please do not allow the Roadless Rule to be rescinded. Our local roadless areas include areas of Mt. Baker-Snoqualmie National Forest, where I look forward to hiking and birding in two weeks. These natural areas must be protected. There are too few of them left. I submit the following information to support my position. "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." "The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling." “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” Respectfully submitted, Julie Kinder Anacortes, Washington 98221

Dear Chief Tom Schultz, As a freshwater ecologist, I understand the importance of intact and undisturbed ecosystems. Rescinding the 25-year-old Roadless Rule would put those untouched forests in jeopardy and would be a true loss for the American people. Pre-European settlement, Michigan was once home to 10.7 million acres of wetlands. Since 1978, that number has dropped to 6.47 million acres. Bear Swamp in the Huron-Manistee National Forest is an intact wetland protected by the Roadless Rule. Bear Swamp is home to federally protected species such as the Eastern Massasauga rattlesnake and Blanding's Turtle. Additionally, Bear Swamp is home to the Brook Trout, a species I studied in college and is an indicator of high water quality. “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” If this rule is rescinded, we lose the pristine headwaters of Muckwa and Black Creek that feed into the larger Big Sable River system. These waters protect important and imperiled cold-water species such as the brook trout. Building roads leads to disconnects in rivers that make fish migration difficult and alters the temperatures of those rivers. Additionally, roads are huge sediment polluters, especially when crossing critical stream/ river habitat. Regarding the Bear Swamp in the Huron-Manistee National Forest, Michigan: Communities downstream of the Bear Swamp IRA, Huron-Manistee National Forest, receive clean water because this watershed has no roads. Municipal water supplies, agricultural irrigation, and recreational fisheries all depend on the sediment-free, thermally stable flows that the roadless condition delivers. Road construction transfers the cost of degraded water quality to every downstream user. The Bear Swamp IRA, Huron-Manistee National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently. The DEIS must evaluate the cumulative effects of road construction in the Bear Swamp IRA, Huron-Manistee National Forest, on downstream water users, including changes to turbidity, temperature, and flow regime. The analysis must include the cost of increased water treatment required by downstream municipalities and the economic impact on downstream fisheries and recreation. "Riparian shade restoration (2000s climate) could decrease mean August stream temperatures by 0.62°C across the study network. Removing the current riparian shade resulted in a nearly 50% loss of habitat meeting the numeric temperature water quality criteria (12°C 7DADM) for char spawning and rearing, while restoring vegetation only increased the proportion of fish habitat meeting the criteria by ~10%. The linear relationship established in our models between reach shade and stream temperature indicates an increase of ~40% reach shade should cool a stream reach by ~1°C." — Restoration Ecology (PMC/Wiley), 2022 The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. The U.S. National Forests are the headwaters of our great rivers and the largest source of municipal water supply in the nation. According to DellaSala (2011), national forests supply drinking water to at least 124 million people in more than 3,400 communities across 33 states—roughly a third of all national-forest runoff originates in inventoried roadless areas. Roads are a major cause of water pollution: erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest. Because the 2001 Roadless Rule protects these headwaters, it is vital for maintaining clean drinking water for communities across the country. Major U.S. cities including Los Angeles, Portland, Denver, and Atlanta receive a significant portion of their water supply from national forests. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. I'd rather see the Department focused on strengthening forest protections, not rolling them back. This proposal moves in the wrong direction. Sincerely,

To the Roadless Rule Rulemaking Team: I live in Western North Carolina and moved here because I love the mountain and spend my time hiking and birdwatching. The 2001 Rule, by any honest reading of the federal monitoring record, has performed the biological function for which it was promulgated, and as a wildlife observer familiar with that record I urge the Department to retain it. My family has hiked and camped in these mountains and additional roads would impact the wilderness experience and effect the wildlife that we go to see. Regarding the Graveyard Ridge (addition) in the Pisgah National Forest, North Carolina: “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” Keep the protections, please. With best wishes, CommentID: RLC-20260926-JORZ54

I respectfully urge you to keep the Roadless Area Conservation Rule by supporting Alternative 1, the No Action alternative. As both an avid enthusiast of the outdoors and an aspiring wildlife biologist, I deeply cherish the beautiful places in nature I have the privilege to enjoy and work in. It deeply disturbs and hurts me to see our government push for the fragmentation and destruction of our country’s vast expanses of intact forest, which are one of the things that make the United States of America unique and beautiful. The almost 45 million acres of roadless forests across our country are also essential to protecting the nation’s iconic wildlife, supply of clean water, and many more benefits we reap from the ecosystem. Rolling back the Roadless Rule endangers important American values including access to public lands and waters. Since the policy was established in 2001, roadless areas have supported drinking water for millions of Americans and a multi-billion-dollar outdoor recreation economy. People hunt, fish, hike, and boat in both these remote, wild places and in the clean rivers and streams provided by the protection of their headwater forests. Furthermore, the presence of roads result in greatly increased wildfire risk, soil erosion and runoff of harmful chemicals into the surrounding areas, and the spread of invasive species. New research shows that from 1992-2024, wildfires were four times as likely to start in areas with roads than in roadless forest tracts (Aplet et al., 2026). Roadless areas are critical to protecting clean sources of water for millions of people; more than almost 62,000 miles of river in the continental U.S. are protected by ONLY the Roadless Rule, with that water reaching 25 million people across the country, often far downstream from roadless areas (Olden et al., 2026). If that wasn’t enough, roads have proved to severely reduce the amount of habitat available through fragmentation, as roads are an unnatural feature of the landscape that can make animal movement across them impossible. The result is much smaller patches of habitat that is often not enough to support larger animals that require large areas to roam and forage. This means that although there may be still a large amount of habitat, the splitting of contiguous areas of forests by roads renders those habitats to be of low-quality and disrupts the ability of the wildlife to thrive. Habitat loss is one of the leading causes of extinction in the current era. Roadless areas specifically have been found to provide important habitat to vulnerable wildlife species within the United States (Dietz et al., 2021). As it stands, the Roadless Rule is extremely flexible and allows for necessary local forest management and the construction of roads as needed to address fires, floods, or other catastrophic events, and other circumstances like the need to connect communities. National forest managers who live in our communities routinely conduct forest stewardship activities within roadless areas such as prescribed burning and wildlife habitat improvement activities. We cannot further jeopardize clean water, the outdoor recreation economy, and critical wildlife habitat by exposing almost 45 million forest acres to roadbuilding, commercial logging, mining, drilling and other extractive, industrial development. Please help keep the Roadless Rule in place for the health and happiness of this and future generations of our nation. Aplet, G.H., Hartger, P. & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22(8). https://doi.org/10.1186/s42408-026-00450-2 Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. National Forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32. https://doi.org/10.1016/j.gecco.2021.e01943 Olden, J.D., Postel, S.L., Dombeck, M.P., Kesting, H., Freeman, P., Comte L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538

Dear Mr. Schultz: I am a life long adventurer in exploring our nations lands and waterways. I've been exploring all over the USA and there are still many places I have yet to explore. I'm very concerned that the direction of climate change will prevent me from exploring some new places where I currently live. “Of the 537 wildlife species of conservation concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA lands. If all IRAs were added to the protected-area system, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas. — UNKNOWN, 2021 · Global Ecology and Conservation (https://doi.org/10.1016/j.gecco.2021.e01943)” “Of the nation's species currently listed as threatened, endangered, or proposed for listing under the ESA, approximately 25% of animal species and 15% of plant species are likely to have habitat within inventoried roadless areas (IRAs) on National Forest System lands. Inventoried roadless areas function as biological strongholds and refuges for many species. — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)” “Opportunities for solitude and primitive non-motorized experiences would be negatively impacted by the noise and disturbance of vehicles. Motorized trails change the character of these otherwise undisturbed landscapes. Noise pollution and visual impacts to landscapes are a concern for those who value quiet recreation, solitude, and viewing undisturbed landscapes. The creation of any additional motorized recreation is believed to be a threat to the recreational experiences and aesthetic values observed by visitors who enjoy quiet recreation. — USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)” “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)” Craggy Gardens is an incredible place that challenges all my senses and physical abilities. Part of the Pisghah Forest it is an area that I would love to explore further. But the constant change in the climate makes it difficult to go there. Hurricane Helene did so much damage to our forest there, that it still is not cleared. I remember the first time I explore Craggy Gardens and did this incredible hike through the woods that challenged my ability to hike over these big bolders. The water flowing through added to the mystic of the forest. Listening to birds I have never heard before. Trying to see if I could spot any salamanders or other reptiles in the area. Do not remove the protections of the forest and the wildlife by removing the roadless rule. It would be a disservice to any and all who have not experienced this area. I'm a member of the public with a stake in these lands, and my stake is in keeping them roadless. With gratitude, CommentID: RLC-20260912-UXKYBK