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Brooke L. Rollins and Tom Schultz, I am a masters student at Colorado state university studying ecosystem science and sustainability with a focus on water resources. I am also a business owner that advocates for better water quality for all. I strongly oppose any changes to the roadless rule because it will destroy our source water supply and decrease water quality for the Cache la Poudre river basin. Hundreds of thousands of people rely on this clean water! As a researcher, I have studied this area and seen the impacts that land change can have on the landscape and to our water quality. It is detrimental that this administration prioritizes the health of the people and the land. Water is needed for every human being on this planet and if that water is degraded, nothing can survive. If this rule is rescinded, the area that I have studied and recreated in will be destroyed along with our source water supply. The animal populations, healthy forests, and the people that live in and around this area will be threatened. It will also increase the chance of wildfire risk in the area. It is known that the majority of wildfires start from roads. Regarding the Comanche Peak Adjacent Area in the Arapaho & Roosevelt NFs, Colorado: Headwater Protection for the Cache la Poudre River System — This roadless area contains the headwaters of the South Fork Cache la Poudre River and multiple tributary streams (Fall Creek, Fish Creek, Beaver Creek, Buckhorn Creek, Joe Wright Creek) that feed into the Cache la Poudre River—a major water source for downstream communities and ecosystems. The subalpine and montane riparian shrubland ecosystems in Crown Point Gulch, Dadd Gulch, and Black Hollow maintain the cold-water conditions and riparian vegetation structure that regulate stream temperature and sediment load. Removing the forest canopy and riparian buffer through road construction would expose these headwater channels to direct solar radiation and erosion, degrading water quality for federally threatened Greenback Cutthroat Trout populations that depend on cold, clear spawning habitat in these streams. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 (https://doi.org/10.1029/WR020i011p01753); Sugden & Woods, 2007 (https://doi.org/10.1111/j.1752-1688.2007.00016.x) Rescinding the Roadless Rule would open the Comanche Peak Adjacent Area, Arapaho & Roosevelt NFs 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. The forest service is well aware of the impacts that this will have on our water and land. The forest service needs to protect public land and stop bending over backwards for the people in power to make a quick buck. It is not in the best interest of the people of the United States of America or our public land that we fought for! My comments are respectfully submitted in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule. With respect, CommentID: RLC-20261006-X32Z3G

Dear Chief Schultz, As a person who approaches stewardship as a moral and not merely a practical matter, I'm asking the Department to reconsider rescinding these protections. Little Lake Creek is the closest forest to my home, and one we enjoy. This area is special to me and my neighbors as a relatively accessible roadless area Regarding the Little Lake Creek in the National Forests in Texas, Texas: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 (https://doi.org/10.1029/WR020i011p01753); Sugden & Woods, 2007 (https://doi.org/10.1111/j.1752-1688.2007.00016.x) Rescinding the Roadless Rule would open the Little Lake Creek, National Forests in Texas 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. Once roads are allowed in an area it is changed forever--the plant and wildlife adapt to human presence. We need to have spaces where this does not happen. 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. Beyond the headline fights over wildfire, recreation, and water, the Roadless Rule plays a quieter but essential role in federal land law and ecological assessment. Section 7 of the Endangered Species Act requires the Forest Service to consult before any action that may affect listed species — and the rule's road-construction prohibition has shielded countless management decisions from triggering that consultation. The rule also props up federal forest planning: peer-reviewed analyses of forest plan adequacy consistently find that forest plans alone, without the Roadless Rule's overlay, fail to provide adequate safeguards for sensitive species and intact landscapes. And state-level conservation rankings (NatureServe and others) repeatedly identify roadless areas as concentrated in the rarest, most threatened ecosystems in the lower 48 — the kinds of places where a road, once built, cannot be undone. “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)” Don't dismantle what's standing. With gratitude, CommentID: RLC-20261002-QY0OUQ

To the Roadless Rule Rulemaking Team: 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. I am 74 years-old and have been enjoying the beauty of these Blue Ridge Mountains most of my life. I live near the Pisgah National Forest and have hiked with my children and grandchildren in the Craggy Mountain area and other parts of Pisgah Forest nearby. We have appreciated the diversity of the plants and rare species, the natural ecology, and the beautiful, clear streams and waterfalls and realize how important these places are as native habitats and our own fresh water sources. We live on the outskirts of Asheville, which draws its drinking water from that unroaded watershed. A rescission of the Roadless Rule could adversely affect the water quality. It would also open the area to more logging which would destroy natural habitats and scenic vistas. Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 (https://doi.org/10.1029/WR020i011p01753); Sugden & Woods, 2007 (https://doi.org/10.1111/j.1752-1688.2007.00016.x) Rescinding the Roadless Rule would open the Craggy Mountain, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. I am deeply concerned that the rescission of the Roadless Rule will degrade the natural areas we love and depend on. Not only does it affect our watershed and could adversely affect our clean water which has been why national breweries have located here, but could be disastrous for wildlife habitats. These landscapes are central to our region's identity and economy. Outdoor recreation is a huge industry in western North Carolina and what draws so many people to the area. Removing the Roadless Rule could open these areas to logging and mining and destroy what makes this area unique and valuable for outdoor recreation and backcountry experiences. The rescission of the Roadless Rule seems to advantage only the logging and mining industries and not the people who live and visit here who want to keep the area as natural and pristine as possible. Roadless areas are some of the most special places we have left in the Southern Appalachians. Once roads go in, they may never be able to be restored. The roadless areas deserve protection. That's what the Rule gives them. Keep it. With thanks, Carolyn Hill CommentID: RLC-20260914-F9631P

To the USDA Roadless Rule Rulemaking Team: As a person who lives where the Roadless Rule positively impacts my life, I am appalled that it may be repealed. The rule protects my community drinking water, the ecosystem that supports our recreation and tourism industries, and the health of our fishing and aquaculture. I remember the state of our forests before the Roadless Rule: an era of unchecked resource extraction that degraded the ecosystem in ways we have only now begun to see recover. Wildfires are more likely to start where roads are. Arson and human carelessness are the cause of most fires endangering humans and property. The Forest Service cannot maintain the roads it currently has https://www.fs.usda.gov/eng/road_mgt/Final-Forest-Service-EA/PDF/FINAL%20EA.PDFto 8.4 Billion in deferred maintenance https://www.fs.usda.gov/eng/road_mgt/Final-Forest-Service-EA/PDF/FINAL%20EA.PDF Roads make it more likely that humans will start fires, and most fires are caused by careless humans and criminal arsonists. https://link.springer.com/article/10.1186/s42408-026-00450-2 In my area, recreation and natural beauty create more jobs than logging would. Oysters and salmon are key elements in tourism. https://doi.org/10.1111/j.1465-7287.2009.00190.x Port Townsend gets its municipal water from the Big Quilcene and Little Quilcene Rivers in the Olympic Mountains via the Olympic Gravity Water System (OGWS). [1] (https://cityofpt.us/publicworks/page/olympic-gravity-water-system-ogws) The watersheds originate in the Olympic National Forest and Olympic National Park. The Big Quilcene River serves as the primary water supply. [1] (https://cityofpt.granicus.com/MetaViewer.php?view_id=4&clip_id=1808&meta_id=159262), [2] (https://cityofpt.us/publicwo Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Reid & Dunne, 1984 (https://doi.org/10.1029/WR020i011p01753); Sugden & Woods, 2007 (https://doi.org/10.1111/j.1752-1688.2007.00016.x) Runoff acceleration. Roads in mountain watersheds transform slow subsurface flow into rapid surface runoff. Cutslope interception can account for more than 79% of road overland flow, contributing 10–30% of total flood discharge in some basins (Kastridis 2020). — Kastridis, 2020 (https://doi.org/10.3390/f11111201) Salmonid embryo survival. Fine sediment in spawning gravel reduces salmonid egg survival. In studied Pacific Northwest streams, when fine sediment exceeded 13% of redd composition, no steelhead or coho salmon eggs survived. Chinook salmon are the most susceptible to sediment loading, followed by coho, steelhead, and cutthroat trout (McHenry et al. 1994; Lotspeich & Everest 1983; EPA 2005). — U.S. Environmental Protection Agency, UNKN (https://www.epa.gov/sites/default/files/2015-10/documents/ch3c.pdf); U.S. Environmental Protection Agency, 2005 (https://www.epa.gov/sites/default/files/2015-10/documents/ch3c.pdf) Persistence after abandonment. Road impacts on hydrology persist for decades after roads stop being used. Forest roads in northern Idaho abandoned for 30–50 years still showed an order of magnitude lower saturated hydraulic conductivity than undisturbed forest floor (Foltz et al. 2009; Trombulak & Frissell 2000). — Foltz et al., 2009 (https://doi.org/10.1016/j.jenvman.2009.01.014); Trombulak & Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Frissell, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x); Trombulak et al., 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Roadless areas protect my community. Do not repeal the Roadless Rule, supported overwhelmingly by citizens! CommentID: RLC-20260908-SCXNGZ

Dear USDA Leadership: As an angler, I don't oppose road-building everywhere. I oppose road-building in country where the rule already said no, the science still says no, and the agency hasn't shown why the answer should change. The 2001 Rule has been a quiet, working piece of policy for two decades. The Department doesn't have to do anything dramatic — just leave it in place. Visiting the Wilson Creek and Harper Creek Wilderness Study Area is one of my favorite backpacking and fishing trips I've ever take. The remoteness was humbling. The Harper Creek Wilderness Study Area was one of the harder, more remote hikes I'd done at the time and gave me a great appreciation for how important it is to have these kinds of places. Regarding the Harper Creek in the Pisgah National Forest, North Carolina: “The area remains a Wilderness Study Area despite being recommended for full Wilderness designation by the U.S. Forest Service since 1987 and having bipartisan congressional support in the 1990s. On December 16, 2001, the area was protected under the Roadless Area Conservation Rule, which designated it as an Inventoried Roadless Area comprising 7,325 acres.” “Large-scale railroad logging commenced in the region around 1910. More significantly, the area became a major site for uranium prospecting from the 1950s through the 1970s. The North Harper Creek Prospect underwent extensive core drilling. Exploration identified uranium deposits in the Wilson Creek Gneiss, with speculative resources estimated at 4 to 8 million pounds of U₃O₈. The remoteness and expense of mining in this area is what has saved it.” “Influence of water exchange and dissolved oxygen in redds on survival of steelhead trout embryos. Survival of embryos relates positively to dissolved oxygen and apparent velocity of intragravel water, and positively to gravel permeability and gravel size. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1961 (https://doi.org/10.1577/1548-8659(1961)90[469:IOWEAD]2.0.CO;2)” “Sediment production from road surfaces was measured on gravel-surfaced forest roads. Road surface erosion rates were found to be substantially elevated compared to undisturbed forest conditions, with sediment production directly related to traffic levels, road surface material, and road gradient. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1984 (https://doi.org/10.1029/WR020i011p01753)” “Water and sediment inputs are fundamental drivers of river ecosystems, but river management tends to emphasize flow regime at the expense of sediment regime. Managing for a desired balance between sediment supply and transport capacity is not only tractable, given current geomorphic process knowledge, but also essential because of the importance of sediment regimes to aquatic and riparian ecosystems, the physical template of which depends on sediment-driven river structure and function. — BioScience / Oxford Academic, 2015 (https://doi.org/10.1093/biosci/biv002)” In earnest, CommentID: RLC-20260906-JAUUAF

Dear Secretary Rollins and Chief Schultz, Forest carbon storage is one of the few low-friction climate tools we have left. I read this record. Keep the Rule. Undisturbed headwaters means that I get to enjoy the forests for recreation, as the water quality is critical to supporting the livelihood of the plants and animals within the forest. A stable, undisturbed forest contributes to the broader stability of the surrounding environment. Rescinding the Roadless Rule means losing what I just described. That's not something you can undo. I am young enough to have never known a time when these forests were unprotected by the Roadless Rule. And I hope that I never that I never do. I hope my children and my grandchildren never do. The water that supports forest ecology, supports downstream water supply for our towns and cities, the water that supports our recreation should be unequivocally protected. Regarding the Southern Massanutten in the George Washington National Forest, Virginia: Headwater Integrity and Reference Watershed Function — The Southern Massanutten area contains the headwaters of Mountain Run, Morgan Run, Fridley Run, and seven other tributary systems that feed into the Shenandoah River drainage. Morgan Run watershed, designated as a Reference Watershed by the… "All treatments resulted in significant increases in stream temperature. In the first year after logging, daily maximum temperatures during July and August increased in clearcut catchments by an average of 1.5°C (range 0.2 to 3.6°C), in patch-buffered catchments by 0.6°C (range -0.1 to 1.2°C), and in continuously buffered catchments by 1.1°C (range 0.0 to 2.8°C)." — Forest Ecology and Management (Elsevier), 2012 At every stream crossing in the Southern Massanutten IRA, George Washington National Forest, road construction would create a direct conduit for sediment delivery into the channel. Road prism runoff concentrates at these points, bypassing any riparian buffer. Culverts constrict natural channel width, accelerate flow, and scour downstream substrate. Failed culverts produce catastrophic sediment pulses that restructure entire stream reaches. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Leslie M. Reid, Thomas Dunne, 1984 · Water Resources Research (https://doi.org/10.1029/WR020i011p01753) In addition to sediment generation is the the freshwater extinction risk. Aquatic species face disproportionate extinction risk globally. A multi-taxon assessment of 23,496 freshwater species found that 24% are threatened with extinction, driven primarily by pollution, habitat fragmentation, and sediment loading from upstream disturbance (Sayer et al. 2025). — Sayer, Catherine A.; Fernando, Eresha; Jimenez, Randall R.; et al., 2025 · Nature (https://doi.org/10.1038/s41586-024-08375-z) It is imperative to keep the Rule in place to protect our watersheds for all of us now and for all of us in the future. Don't do it. Keep the Rule. With Respect, Concerned Virginian CommentID: RLC-20260903-HUPX2M

To the U.S. Department of Agriculture: As a rural resident, I've never thought of the roadless rule as an environmental cause — I've thought of it as a basic management standard that keeps the landscape I live in functional. Regarding the Cube Iron - Silcox in the Lolo National Forest, Montana: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. Sediment generation. Forest roads generate substantially more sediment than undisturbed forest. A heavily used gravel road segment in the Pacific Northwest delivered roughly 130 times more sediment than an abandoned road, and paved segments yielded less than 1% of the sediment from gravel surfaces (Reid & Dunne 1984; Sugden & Woods 2007). — Leslie M. Reid, Thomas Dunne, 1984 · Water Resources Research (https://doi.org/10.1029/WR020i011p01753) Rescinding the Roadless Rule would open the Cube Iron - Silcox, Lolo National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The roadless rule protects americas greatest asset wild public lands The Department is urged to resist the proposed rescission and to affirm the continued operation of the Roadless Area Travis Rehm

I am a citizen of Ohio which is a state less affected by this rule, but I do travel a lot throughout this country. I am writing in opposition to the rescission of the Roadless Rule. There are many reasons this is a bad idea. I see on the maps that many areas of the Tongass National Forest and Chugach and Chichagof regions would be affected in Alaska. Having just had the privilege to travel there in June, I am familiar with those beautiful and pristine areas. The Americans who live in these regions are part of the land, many descending from the indigenous peoples that have been there for centuries. While being "modern" Americans, they hunt, use plants medicinally in ways most of us in the midwest do not. This is culturally sacred land to them and to many of us who have visited. The areas around Icy Strait points and College Fiord would certainly be damaged by unneccessary roads, roads that increase fire danger, harm native plants and wildlife and the drinking water of the people there and in surrounding regions. Roads increase sediment which interupts the growth and survival of plants and animals in and near these water sources. "While natural resources have economic value, cultural resources have social value because communities use them to form their identities today. Cultural resources are inherently valuable to diverse groups of people who have a living connection to the places, people, and events of the past. — National Park Service, National Center for Preservation Technology and Training, 2025 (https://www.nps.gov/articles/000/preservation-matters-disasters-cultural-resources-and-wildland-fire.htm)" "Sediment production from road surfaces was measured on gravel-surfaced forest roads. Road surface erosion rates were found to be substantially elevated compared to undisturbed forest conditions, with sediment production directly related to traffic levels, road surface material, and road gradient. — Reid, L.M., 1984 · Water Resources Research (https://doi.org/10.1029/WR020i011p01753)" Reviewing the harm that unnecessary roads could do to the water supply alone should be enough to put the brakes on this measure! We already have the Colorado River and Lake Mead at record lows endangering the water supplies of millions of people. These currently protected roadless areas provide water supplies for 124 million Americans. "The US National Forests are the headwaters of many of our great rivers and one of the largest sources of municipal water supply in the nation, serving over 60 million people in 3,400 communities in 33 states. Roads are a major cause of water pollution. Because it provides significant protection for upper watersheds, the Roadless Rule is vital for maintaining clean drinking water for communities across the country. — Earthjustice and 350+ co-signing organizations, 2025 (https://earthjustice.org/wp-content/uploads/2025/09/roadless-rule-ngo-sign-on-letter-submitted-9_19_2025.pdf)" Our citizens need this water and once the damage to the surrounding watersheds and ecosystems is done, it can not be reversed to pre-damage levels. When does the welfare of Americans finally outweigh the needs of industry in this country?? I say the time is now. Please do not rescind the Roadless Rule. Sincerely, Amy Taylor