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To the Department of Agriculture and the Forest Service: As someone whose work depends on knowing the difference between revision and erasure, I want to be direct: this isn't a reform, it's a rollback. I grew up going to this area, seeing the redbuds in bloom in the spring, swimming in the river in the summer. Nature is our shared heritage, and it supports clean, bountiful water, clean air, and life. I will lose clean and abundant water, breathable air, home for animals who help to maintain vegetation and the water cycle, recreation space for myself, and knowledge that nature is out there, regulating conditions for life on Earth. Regarding the Tuolumne River in the Stanislaus National Forest, California: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. 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 et al., 2025 (https://doi.org/10.1038/s41586-024-08375-z) Rescinding the Roadless Rule would open the Tuolumne River, Stanislaus 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. Roads degrade watersheds. They cause erosion; silt up streams, harming fish; and they enable widespread logging that actually makes fires worse because it dries out the land. Trees and land are responsible for nearly half of rain over continents. The more we cut trees, the more we exacerbate never-ending drought. A rule that has survived multiple administrations and multiple rounds of circuit-court review should not be rescinded on the present record. Very truly yours, Erica Gies CommentID: RLC-20261007-D7HXTD

To the Roadless Rule Rulemaking Docket: As a rural resident, I address the Department on the record and assert that the administrative rationale advanced in support of the proposed rescission does not meet the standard of reasoned decision-making required of an agency that has represented, across administrations, a commitment to watershed protection on National Forest lands. Regarding the South Mills River in the Pisgah National Forest, North Carolina: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. 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 et al., 2025 (https://doi.org/10.1038/s41586-024-08375-z) Rescinding the Roadless Rule would open the South Mills River, 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 extremely concerned about the harmful effects road building in the Roadless Area would have on the source of my community’s drinking water supply. 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. I'm against this. Keep the Rule in place. Yours truly, CommentID: RLC-20260925-UDMZQM

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

Dear Secretary Rollins: Scientific training means being able to say what the evidence doesn't support, not just what it does. It doesn't support this rescission. I am an outdoors enthusiast who grew up spending time outside all the time. As I grew to love science through school I have tied it back into my love for the outdoors I can point to one morning that captures all of it. One of my major research projects regards various human made pollutants such as PFAS (or forever chemicals). In this area in particular we have seen the direct effects of various environmental contaminants from manufacturing runoff. This has included PFAS, the forests around us and the clean water are fading with more and more human involvement The landscape at the center of the preceding account exists in its present condition because the Roadless Rule has held; rescission would remove the only regulatory mechanism capable of sustaining that condition. Regarding the Tracy Ridge in the Allegheny National Forest, Pennsylvania: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. 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) Rescinding the Roadless Rule would open the Tracy Ridge, Allegheny 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 have seen extensive evidence of human activities affecting downstream water. With the recent pollution from a new factory in the region killing large quantities of fish this impact is even more noticeable. I live across the street from our River yet I can not swim it, nor drink from it due to pollution down stream. Rescission of the roadless rule would prove to send further pollution down stream. 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 nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. 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. 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. This comment joins the record in opposition to the proposed rescission action. Warm regards,

Dear Chief: Submitting these comments as a wildlife observer rather than as a represented party, I respectfully but firmly oppose the proposed rescission on grounds the Department's own NEPA record substantiates: that the affected acreage is disproportionately occupied by species of high conservation concern. If this rule becomes nothing then our protections wholly become nothing. The more our policies crumble, the more we are at risk of losing everything for the gain of rich getting richer. Water is life. These forests are our lives. Do not give up on them so quickly. The Department's obligation under the National Environmental Policy Act and its own governing statutes requires genuine consideration of interests of the kind described here; this comment invites that consideration. Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. 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) Rescinding the Roadless Rule would my local Ouachita 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. Water is life. Water remembers. Do not forget what we cannot lose. Twenty-five years of implementation, repeated judicial affirmation, and the absence of a reasoned basis for change all counsel against rescission; the Rule should be maintained. Yours sincerely, CommentID: RLC-20260828-PRH3W9

Dear Secretary Rollins and Chief Schultz, I came to climate through the practical side — heat, water, fire, my landscape changing around me in ways my parents and grandparents have never seen. This rescission reads as breaking a working part of a system that's already strained. These lands filter my water, preserve the wildlife and ecosystems I rely on for health and hapiness, limit wildfires that could kill, maim, or otherwise ruin the lives of the American people, and much more. A single memory can't stand for the whole of that attachment Every major milestone in my life has happened in nature, from playing in streams as a child with my mother, to the best times with friends and family, to learning how to forage when money was short, to my wedding. The awe and majesty of the natural world seeps into every part of me. That is how it should remain. The Department is therefore urged, as a matter of both law and policy, to retain the Rule and to reject the present proposal. Regarding the Big Laurel Branch Addition in the Cherokee National Forest, Tennessee: The DEIS must include quantified sediment yield modeling for every road construction scenario considered. This modeling must estimate sediment production from road surfaces, cut slopes, and fill slopes; identify sediment delivery points at each stream crossing; and calculate cumulative sediment loading at the watershed outlet. Qualitative statements about best management practices do not satisfy this requirement. The DEIS must include quantified sediment yield modeling for every road construction scenario considered. This modeling must estimate sediment production from road surfaces, cut slopes, and fill slopes; identify sediment delivery points at each stream crossing; and calculate cumulative sediment loading at the watershed outlet. Qualitative statements about best management practices do not satisfy this requirement. The DEIS must include quantified sediment yield modeling for every road construction scenario considered. This modeling must estimate sediment production from road surfaces, cut slopes, and fill slopes; identify sediment delivery points at each stream crossing; and calculate cumulative sediment loading at the watershed outlet. Qualitative statements about best management practices do not satisfy this requirement. The DEIS must include quantified sediment yield modeling for every road construction scenario considered. This modeling must estimate sediment production from road surfaces, cut slopes, and fill slopes; identify sediment delivery points at each stream crossing; and calculate cumulative sediment loading at the watershed outlet. Qualitative statements about best management practices do not satisfy this requirement. “32 million acres—nearly a third of the total "emergency" area—is land that has high or very high importance for drinking water, based on data from the Forest Service's own analysis. — Dr. Dawn Woodard, Dr. Matthew McKinzie, Gabrielle Berthel, 2025 (https://www.nrdc.org/media/what-usdas-emergency-logging-map-gets-dangerously-wrong)” “A multi-taxon global freshwater fauna assessment for The IUCN Red List of Threatened Species covering 23,496 decapod crustaceans, fishes and odonates found that one-quarter (24%) are threatened with extinction. Prevalent threats include pollution, dams and water extraction, agriculture and invasive species, with overharvesting also driving extinctions. There are 89 confirmed and an additional 178 suspected extinctions since 1500. — Nature, 2025 (https://doi.org/10.1038/s41586-024-08375-z)” “Decreased habitat connectivity has numerous well-documented effects on freshwater fish populations and communities and is recognized as a leading cause of declining freshwater diversity. The cumulative effects of small barriers such as culverts may collectively far exceed those of dams. Januchowski-Hartley and others (2013) and Diebel and others (2015) documented a ratio of 38 times and 24 times more culverts than dams in two separate North American watersheds. — U.S. Geological Survey Scientific Investigations Report, 2024 (https://doi.org/10.3133/sir20235132)” “Roads can transform slower subsurface flow to rapid surface flow, and this may alter the synchronization of hillslope runoff to the stream channel. 'Roaded' watersheds that had been 25% clearcut had higher peak flows than 'unroaded' watersheds that had been 100% clearcut. The major mechanism for the higher peak flows was the connectivity of the road system to the channel network. — CMER — The Hydrologic Impacts of Roads at Varying Spatial and Temporal Scales, 1996 (https://doi.org/10.1029/95WR03493)” I ask that these comments be read alongside the many others opposing rescission and that the Department act consistent with the weight of that record. In earnest, CommentID: RLC-20260825-3N1SRR

Dear Secretary Brooke L. Rollins: Writing as a citizen whose climate reading is sustained and whose engagement with federal land policy is a matter of attention rather than profession, I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule on the present record. I use this area for hiking and cold-water trout fishing. One visit made that connection concrete. My first time fly fishing in the Taos area was on Rio Hondo, which is fed by snowmelt and springs in the Wheeler Peak area. It is where I learned to trout fish in cold mountain water. The Department is not being asked to weigh an abstract preference; it is being asked to weigh a concrete, demonstrated interest of the kind the Rule was enacted to protect. Regarding the Wheeler Peak Wilderness in the Carson National Forest, New Mexico: Road construction generates more sediment per unit area than any other land use on national forest lands. The Wheeler Peak Wilderness IRA, Carson National Forest, has none of this sediment loading because it has no roads. Rescission of the Roadless Rule removes the regulatory barrier that prevents the introduction of the single most damaging non-point source pollutant into this watershed. The hydrological integrity of the Wheeler Peak Wilderness IRA, Carson National Forest, depends on the absence of roads. Road networks alter watershed hydrology at three scales: locally, by creating impervious surfaces and intercepting subsurface flow; at the reach scale, by delivering sediment at stream crossings and removing canopy; and cumulatively, by increasing peak flows and reducing baseflow across the drainage. All three scales of impact begin with the first mile of road. The DEIS must provide watershed-level analysis specific to the Wheeler Peak Wilderness IRA, Carson National Forest — not programmatic generalizations applied across all inventoried roadless areas. The geology, soils, slopes, precipitation, stream network, and downstream uses of this watershed are specific to this place, and the analysis must reflect that specificity. "Road construction increases soil compaction up to 200 times relative to undisturbed sites. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The surfaces of unpaved roads can route fine sediments to streams, lakes, and wetlands, increasing the turbidity of the waters. The consequences of past sediment delivery are long-lasting and cumulative, and cannot be effectively mitigated. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas." — Conservation Biology (Wiley), 2000 Road construction increases soil compaction up to 200 times relative to undisturbed sites. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The surfaces of unpaved roads can route fine sediments to streams, lakes, and wetlands, increasing the turbidity of the waters. The consequences of past sediment delivery are long-lasting and cumulative, and cannot be effectively mitigated. Our review underscores the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded areas. — Conservation Biology (Wiley), 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) A multi-taxon global freshwater fauna assessment for The IUCN Red List of Threatened Species covering 23,496 decapod crustaceans, fishes and odonates found that one-quarter (24%) are threatened with extinction. Prevalent threats include pollution, dams and water extraction, agriculture and invasive species, with overharvesting also driving extinctions. There are 89 confirmed and an additional 178 suspected extinctions since 1500. — Nature, 2025 (https://doi.org/10.1038/s41586-024-08375-z) Twenty-five years of implementation, repeated judicial affirmation, and the absence of a reasoned basis for change all counsel against rescission; the Rule should be maintained. Thank you, Scott Walker, ScEdD