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The perspective I bring here is a resident's perspective — shaped by place, by duration, and by the kind of attention that comes from living with land rather than visiting it. The Roadless Rule protects our beautiful ecosystems from outside parties that want to destroy them for personal gain. The destruction of our land does not benefit us -- the ones who will be here to feel the impact of this decision. National parks are federally protected land, carefully selected as integral environments to preserve habitats that are necessary for the survival of plants, animals, and people. Roadless places are essential to my state and my community. People depend on them for their livelihoods: tourism, hunting, fishing, hiking, outdoor enthusiasts, etc. This land is known and needs to remain untouched for people who depend on a healthy ecosystem to survive. Spending days in roadless areas allowed me to grow closer to my family and better understand nature. I have been able to watch animal families year after year and I have learned that we need untouched ecosystems for our own health. I also have experience with the destruction of roadways to plants and animals. Roads do not discriminate against wildlife. Construction and reconstruction of roads has led to invasive plant species and the deaths of a variety of animals, just trying to survive. Since 2001, the Roadless Rule has helped protect critical habitat for animals and plants protected under the Endangered Species Act, with more species protected each year. Rescinding the rule would harm the wild homes of more than 500 protected species, including American wolverines, gray wolves, Canada lynx, grizzly bears, Quino checkerspot butterflies, and northern spotted owls (as well as countless species not protected under the Act, like Alexander Archipelago wolves and Queen Charlotte goshawks). — Diversity, 2025 (https://www.biologicaldiversity.org/campaigns/Roadless-Rule-rollback/) Roads of all kinds affect terrestrial and aquatic ecosystems in seven general ways: (1) increased mortality from road construction, (2) increased mortality from collision with vehicles, (3) modification of animal behavior, (4) alteration of the physical environment, (5) alteration of the chemical environment, (6) spread of exotic species, and (7) increased alteration and use of habitats by humans. The 13,107,812 km of road lanes in the conterminous United States have destroyed at least 4,784,351 ha of land and water bodies that formerly supported plants, animals, and other organisms. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated. — Trombulak et al., 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Regarding the Caribou - Speckled Ext in the White Mountain National Forest, Maine: Caribou - Speckled Ext and Dartmouth Range in White Mountain National Forest operate as complementary habitat for 23 shared species. The 24.0-mile corridor between them enables the gene flow and demographic rescue that prevent local extinction — particularly for imperiled species: Northern Myotis (G2), Tricolored Bat (G3). "Incorporating effects of human-made barriers in isolation-by-distance regressions, Epps et al. (2005) found evidence that fenced highways cause a rapid decrease of gene flow between populations of desert bighorn sheep (Ovis canadensis nelsonii) in southern California." — Corlatti et al. 2009, Conservation Biology (review citing Epps et al. 2005), 2005 The roadless condition of both Caribou - Speckled Ext and Dartmouth Range currently maintains an unfragmented corridor of 24.0 miles across White Mountain National Forest. This intact landscape sustains population connectivity for 23 species, including Northern Myotis (G2), Tricolored Bat (G3). The 2001 Roadless Rule preserves this corridor; rescission exposes it to road construction that the network cannot absorb. I would like to be upfront and stress the importance of learning to work with nature rather than destroy the environments we are dependent upon. The rescission takes away the 25 year old protection that has guarded the lands that hold our clean drinking water, native plants and animals which maintain a healthy, balanced ecosystem, and support local economies. The Department is responsible for and expected to promote conservation of the land, water, plants, and animals. By rescinding the 2001 Roadless Rule, the Department is neglecting that duty to ensure protected lands remain preserved. If the Department refuses to do its duty, who else will do it? Do not destroy the trust of the public by choosing to neglect what you have chosen to dedicate yourself to.

I adamantly am opposed to the revision of the Roadless Rule. I live in North Carolina. I previously have lived in California, Colorado, and New York, all of which have areas currently protected by the Rule. I am concerned in regards primarily to watershed and drinking water safety, wildfire safety, biodiversity and habitat protection, and recreation opportunities. With regards to watershed and drinking water safety: the drinking water of the United States needs these protected areas to remain safe and clean to feed our wells and municipal water reserves. Western states are already struggling to manage sharing water resources. With current trends, streamflow reductions of 10-35% are likely for western states in the next fifty years (Barnett and Pierce 2009). "A 10% drop in streamflow is considered calamitous by municipal water districts." (DellaSala et al., 2011)(https://doi.org/10.2489/jswc.66.3.78A) The cost of sedimentation due to road runoff would massively impact these already-stressed waters. According to the 2011 study by DellaSala et al., water treatment plants and highway departments save up to an estimated $18 Billion from avoiding sedimentation caused by logging in IRA watersheds.(https://doi.org/10.2489/jswc.66.3.78A). With regards to biodiversity and habitat protection, Trombulak et al. (2000) notes the seven ways that roads affect ecosystems: "(1) increased mortality from road construction, (2) increased mortality from collision with vehicles, (3) modification of animal behavior, (4) alteration of the physical environment, (5) alteration of the chemical environment, (6) spread of exotic species, and (7) increased alteration and use of habitats by humans. The 13,107,812 km of road lanes in the conterminous United States have destroyed at least 4,784,351 ha of land and water bodies that formerly supported plants, animals, and other organisms. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated." (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Once these roads are built, it is impossible in any foreseeable future to undo these effects. With regards to wildfire safety, the vast majority of fires take place in the areas closest to roads, according to a 2025 study by the Wilderness Society. (https://roadless.org/resources/roads-fire-risk-analysis-2025.pdf) "From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.7 fires/1,000 hectares), followed closely by that in Inventoried Roadless Areas (1.9 fires/1,000 ha). The highest wildfire-ignition density was in lands within 50 meters of roads (7.4 fires/1,000 ha), and the second highest wildfire-ignition density was in lands outside of the 100-m road buffers, but not in wilderness or roadless areas (3.5 fires/1,000 ha)." Wildfires are already a massive risk to communities across not only the West and Mountain West, but also across the United States, including in North Carolina. As for recreational opportunities, the Roadless Rule currently protects many of the United States' most valued backcountry recreation areas, which I myself utilize and enjoy frequently. These forests provide clean air and water, fight climate change, and are the backbone of a $1.3 trillion outdoor recreation economy that supports 5.2 million jobs, according to a 2026 Outdoor Alliance white paper. The same paper notes that rolling back the Roadless Rule "could unwind protections for 45 million acres of national forests, putting at risk: 25,121 miles of trails, 8,659 climbing routes, 768 miles of whitewater, 10,794 miles of mountain biking. (https://www.outdooralliance.org/roadless) According to a US Fish & Wildlife Service study on the Izembek Wilderness, "Construction of a road through the existing wilderness and the predicted increase access to the wilderness via all-terrain vehicles (legal and illegal) would result in major impacts to the four indicators of wilderness character: untrammeled quality, natural quality, undeveloped quality, and opportunities for solitude or primitive and unconfined recreation." (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf) The 5000-character limit is insufficient to adequately address the many issues with rescinding the Roadless Rule. These are simply the ways in which it would affect me, personally. I urge every reviewer to take all concerns into consideration above the short-term profits of logging expansion.

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

To the USDA Roadless Rule Rulemaking Team: In my experience as an outdoor enthusiast who has used roadless national forest as a recreational and restorative resource for many years, I have come to regard the 2001 Rule as one of the few administrative instruments capable of holding the line against the gradual conversion of interior forest to roaded and managed landscape. I have been enjoying roadless areas since I was a child. I took them for granted as a restorative place. I realize now they need to be protected against those who are driven only by greed & special interests. Once these areas are destroyed, they are gone forever. We must protect them. Roads bring noise & exhaust. I love breathing clean air & hearing only wildlife. Regarding the South Mills River in the Pisgah National Forest, North Carolina: 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. 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. “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)” “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)” “Foundational environmental analysis documenting 58.5 million roadless area acres and comprehensive effects on soils, water, fish/wildlife, and socioeconomics. Core scientific record behind the Roadless Rule. — (2000/2001) (https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5057900.pdf)” “Even-aged stands took on average 30 years to recover to pre-harvest buffering state after clear-cutting. Clear-cuts led to full coupling with open-air temperatures, eliminating microclimate buffering entirely. It can take decades for a clear-cut stand to reach the same buffering capacity as a forest with continuous tree cover. From biodiversity perspective, continuous tree cover can create more temporally stable microclimatic conditions and can thus aid in maintaining microrefugia and mitigate climate warming impacts. — ScienceDirect / Agricultural and Forest Meteorology, 2025 (https://doi.org/10.1016/j.agrformet.2025.110434)” My ask is simple: keep the 2001 Rule. Gratefully, CommentID: RLC-20261005-P0VG8F

The views expressed in this comment are my own. I am submitting as an individual and do not speak for or on behalf of the University of Maryland Center for Environmental Science. I am a doctoral candidate at the University of Maryland Center for Environmental Science, Appalachian Laboratory in Frostburg, Maryland, where my research focuses on migratory bird conservation. I live in western Maryland and spend much of my recreational time in the forests and protected areas of neighboring West Virginia, including Monongahela National Forest. I ask that the environmental impact statement (EIS) examine the following issues: 1) Wildfire risk, the stated basis for this proposal. The Forest Service has justified rescission as a way to reduce wildfire risk, but the claim should be rigorously tested. A 2026 peer-reviewed analysis of national forest wildfires from 1992-2024 found ~8 ignitions/1,000 hectares within 50m of roads, compared with ~2/1,000 hectares in Inventoried Roadless Areas, roughly 4x as many. Ignition density fell with distance from roads (1). The authors conclude that building roads into roadless areas is likely to result in more fires due to increased human access and ignition sources (e.g., campfires, cigarettes, vehicle sparks). The EIS should weigh access benefits for suppression against increased ignition risk and road maintenance costs. It should also analyze eastern forests separately because central Appalachian fire regimes and fuels differ from those of western forests. 2) Habitat fragmentation and forest-interior birds. The central Appalachians hold breeding habitat for Birds of Conservation Concern, including Cerulean Warbler and Wood Thrush (7). Roads cause habitat loss, fragmentation, disturbance, mortality, invasive species spread, and changes to adjacent environments (5, 6). Traffic and industrial noise can reduce reproductive and pairing success in songbirds and alter bird communities near roads (2-4). The EIS should quantify how road construction, logging, or development in currently roadless areas would reduce interior forest habitat and affect declining species. 3) Migratory and flyway-scale effects. Large, intact Appalachian forests provide breeding and stopover habitat for birds moving along the Appalachian ridge corridor. The EIS should assess cumulative impacts on migratory birds protected under the Migratory Bird Treaty Act and how habitat loss on National Forest lands would compound pressures elsewhere in their ranges. 4) Headwater water quality. Monongahela National Forest contains headwaters of rivers that supply drinking water downstream (i.e., Potomac and Ohio River basins). Roads are a source of sediment and altered stream hydrology (6). The EIS should evaluate effects on cold-water streams, sensitive aquatic species, and source water for downstream communities, including those in Maryland. 5) Threatened and endangered species. Please assess impacts on federally listed Appalachian species, including Cheat Mountain salamander and Indiana bat, whose habitats depend on intact forests and clean water. Please include a “no action” alternative that keeps the 2001 Rule in place, along with alternatives that keep roadless protections at the state or regional level rather than rescinding them nationwide. Thank you for considering my comment. References: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Francis, C. D., Ortega, C. P., & Cruz, A. (2009). Noise Pollution Changes Avian Communities and Species Interactions. Current Biology, 19(16), 1415-1419. https://doi.org/10.1016/j.cub.2009.06.052 Habib, L., Bayne, E. M., & Boutin, S. (2007). Chronic industrial noise affects pairing success and age structure of ovenbirds Seiurus aurocapilla. Journal of Applied Ecology, 44(1), 176-184. https://doi.org/10.1111/j.1365-2664.2006.01234.x Halfwerk, W., M. Holleman, L. J., Lessells, M., & Slabbekoorn, H. (2011). Negative impact of traffic noise on avian reproductive success. Journal of Applied Ecology, 48(1), 210-219. https://doi.org/10.1111/j.1365-2664.2010.01914.x Kociolek, A. V., Clevenger, A. P., St. Clair, C. C., & Proppe, D. S. (2011). Effects of Road Networks on Bird Populations. Conservation Biology, 25(2), 241–249. http://www.jstor.org/stable/27976457 Trombulak, S. C., & Frissell, C. A. (2000). Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology, 14(1), 18-30. https://doi.org/10.1046/j.1523-1739.2000.99084.x U.S. Fish and Wildlife Service (2024). USFWS Bird Species of Concern [fact sheet]. https://www.fws.gov/media/usfws-bird-species-concern

Dear Forest Service Leadership: As an outdoor enthusiast, I am filing these comments to observe that the proposed rescission of the 2001 Roadless Area Conservation Rule would not maintain the status quo — it would change it, in a direction that favors extractive uses over the landscape conditions upon which non-motorized public access depends, and that change, once initiated through road construction, cannot be undone. Regarding the Reister Canyon in the Mendocino National Forest, California: Ground disturbance, sedimentation, and stream crossings in roadless areas degrade drinking-water supplies and aquatic habitat downstream. 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) Rescinding the Roadless Rule would open the Reister Canyon, Mendocino 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 want to protect the environment and prevent habitats from being destroyed. I'm not asking for anything unusual — just that the Department leave a working protection in place. That's my comment. With gratitude,

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I strongly oppose the Forest Service’s proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I support Alternative 1, No Action. I live in Seattle, Washington and spend most of my weekends recreating outdoors in many of Washington State's 139 roadless areas. As an avid hiker, backpacker, trail runner, skier, and climber, I am incredibly grateful and in awe of the many unique, beautiful areas that I am able to recreate in because they have been federally protected with the intent that they remain minimally or undisturbed for the enjoyment of all citizens. The rescission of the Roadless Rule would cause me to lose that peaceful experience in some of my favorite places in Washington State, such as the Alpine Lakes Adjacency (Wenatchee National Forest, Washington) where I recently hiked with a friend to see the larches glow golden in the early morning Fall sunshine. Western larches are just one of many species that are only found in specific ecological habitats and elevation bands, and are likely to further narrow their ranges due to warming climate trends. Roadless areas are critical to maintain such species: "77% of inventoried roadless areas have the potential to conserve threatened, endangered, or imperiled species" (Loucks et al., 2003 https://doi.org/10.5751/ES-00528-070205). The Roadless Rule constrains road construction specifically (while allowing for other mulit-uses like grazing) because road construction is the enabling condition for nearly every documented threat to the lands — fragmentation, sedimentation, invasive species, fire ignition, extractive activity (Trombulak & Frissell 2000, https://conbio.onlinelibrary.wiley.com/doi/10.1046/j.1523-1739.2000.99084.x), all of which would harm my ability to recreate in these wild, gorgeous regions of my home state. As both an avid outdoors person, and a constituent, I'm greatly concerned by any potential for increased wildfire risk and air quality impacts from the smoke. Unfortunately, evidence from studies suggest that rescission of the Roadless Rule would make wildfires worse, not better. A 2026 study of three decades of National Forest System wildfire data found that wilderness and Inventoried Roadless Areas (IRAs) have the lowest ignition densities of any land category studied (Aplet et al. 2026). Furthermore, wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest, and most ignitions near roads are human-caused (Narayanaraj & Wimberly 2012). Thus, it's reasonable to conclude that introduction of additional roads into current IRAs could to lead to an increase in wildfires. As a constituent in Washington State, I am also acutely aware that my access to ample, clean water is directly tied to the continued presence of undisturbed natural ecosystems, such as those that are currently protected by the Roadless Rule. If the Roadless Rule is rescinded, there will be impacts on the quality of the water available to us, which is especially concerning as Washington faces more frequent droughts: "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. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes" (DellaSala et al., 2011, https://doi.org/10.2489/jswc.66.3.78A). I am further concerned that the recission of the Roadless Rule will lead to higher costs of water in many regions of Washington State, due to higher water treatment expenses. Municipalities are actively decommissioning roads as an effective way to reduce water treatment costs: Seattle, Washington, where I am a resident, was able to defer "a $150 million filtration plant expenditure through an intensive watershed rehabilitation program that will decommission 480 km (300 mi) of roads over a 10-year period" (DellaSala et al., 2011, https://doi.org/10.2489/jswc.66.3.78A). For the reasons listed above, I oppose the proposal to rescind or alter the Roadless Rule under Alternatives 2 or 3. Instead, I request USFS take Alternative 1, the No Action alternative. Sincerely, M.T. Seattle, WA

As a wildlife biologist and spatial analyst, with a background of over a decade working in natural resources, I would like to affirm my objection to the removal of the United States Forest Service Roadless Rule. Roadless areas prevent accidental wildfires caused by anthropogenic activities such as legal or illegal camping, and vehicle presence (dragging chains while towing, hot engines igniting dry vegetation, etc.). Aplet et al. 2026 found that that land within 50 meters of a USFS forest road is up to four times more likely than roadless areas to have fire ignitions, because many fires are caused by human activity. The 2001 Rule itself (66 FR 3254) states that building roads into roadless areas would likely raise the chance of human-caused fires because more people would be present (USDA Forest Service, 2000). Wilderness areas may receive prescribed fire under some circumstances, particularly to reduce fire fuel loads, and roadless areas still receive natural fire caused by lightning. Roads and industrial logging do not prevent wildfire. The Roadless Rule contains exceptions that allow certain activities when necessary for public health and safety, and protecting resources. This includes forest management and hazardous fuels work. Roadless areas help protect wildlife, not only because large tracts of intact habitat protect wildlife populations and clean water. The negative impacts that roads can have on terrestrial invertebrates are well documented, and include mortality from construction, vehicle collisions, changes in behavior such as nesting disturbance, increased human presence, the spread of invasive species and changes to the physical landscape (Trombulak & Frissell 2000). Even just the noise from motors causes disturbance to wildlife populations, reducing individual fitness and reducing the quality of habitat (Ware et al. 2015). In addition, Roadless areas provide human communities with downstream access to clean drinking water, and clean water supports freshwater fish, invertebrates, and amphibians. Building roads increases runoff and sedimentation in mountain streams (Gucinski et al. 2001) and negatively impacts aquatic connectivity for freshwater species (Wofford et al. 2005). The USFS has a notorious backlog of deferred road maintenance for the roughly 370,000 miles of roads that comprise the National Forst System road network. According to USFS’s Fiscal Year 2025, Quarter 2 Deferred Maintenance Needs report, the deferred maintenance value for passenger-vehicle roads is $5.89 billion, and that does not include high-clearance roads. Unmaintained roads and road bridges can lead to landslides and threaten aquatic connectivity and water quality. Why build new roads when USFS consistently fails to maintain the current inventory of roads and road bridges? If roads are built and then not maintained, then any claims about how the recission of the Roadless Rule alleviating management restrictions and improving public access are moot. If no sufficient budget exists for maintaining the current infrastructure, how will USFS plan and execute maintenance of additional road miles and road bridges? As someone who resides in and holds great esteem for the State of Georgia, I must point out that there are very few large tracts of contiguous wilderness left in the Southeastern United States. Unlike the western part of the country, we have no areas of vast, unbroken wilderness. The ability to go out into the wilderness and experience natural areas away from civilization and its sounds is a priceless thing. The protection of our cultural and natural resources in the Southeastern US is priceless. Aplet, G.H., Hartger, P., et al. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology. Gucinski, H., Furniss, M.J., Ziemer, R.R., & Brookes, M.H. (2001). Forest roads: a synthesis of scientific information. Gen. Tech. Rep. PNW-GTR-509. USDA Forest Service, Pacific Northwest Research Station. doi:10.2737/PNW-GTR-509 USDA Forest Service (2000). Roadless Area Conservation Final Environmental Impact Statement. USDA Forest Service. 2025. Fiscal Year 2025, Quarter 2 Deferred Maintenance Needs. Report to the House and Senate Appropriations Committees. Trombulak, S.C., & Frissell, C.A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology 14(1): 18–30. doi:10.1046/j.1523-1739.2000.99084.x Ware, H.E., McClure, C.J.W., Carlisle, J.D., & Barber, J.R. (2015). A phantom road experiment reveals traffic noise is an invisible source of habitat degradation. PNAS 112(39): 12105–12109. doi:10.1073/pnas.1504710112. Wofford, J.E.B., Gresswell, R.E., & Banks, M.A. (2005). Influence of barriers to movement on within-watershed genetic variation of coastal cutthroat trout. Ecological Applications 15(2): 628–637.

I lived in North Carolina for 16 years and enjoyed hiking, camping and birding in Linville Gorge in the Pisgah National Forest. If the 2001 Roadless Rule (36 CFR Part 294) is rescinded, road construction could occur in previously protected roadless areas. If this happens, ground disturbance could impact the nesting habitat of the Chuck-will’s-widow and Whip-poor-will, two bird species of concern that summer in the area and nest on the ground in leaf and pine litter. The Chuck-will's-widow (Antrostomus carolinensis) has experienced a population decline of roughly 58% to 69% between 1966 and the present according to multi-decade tracking data from the North American Breeding Bird Survey. Eastern Whip-poor-will (Antrostomus vociferus) populations have dropped by an estimated 50% to 70% since the late 1960s and 1970s, and the International Union for Conservation of Nature (IUCN) lists them as Near Threatened. After road construction, traffic dust and noise could increase passive harassment of these species as the area becomes more accessible, and any logging activity would increase habitat loss and fragmentation. Trombulak and Frissell (2001) found that the presence of roads is highly correlated with changes in species composition and population sizes. If not already done, the Forest Service should complete an ESA Section 7 consultation regarding these two species of concern before deciding to rescind the Roadless Rule. Trombulak, S.C. and Frissell, C.A., Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology, 14: 18-30 (2001). https://doi.org/10.1046/j.1523-1739.2000.99084.x

Scientific Reasons to Keep Roadless Areas Roadless Comment on Docket FS-2025-0001, Special Areas; Roadless Area Conservation Decades of research on the ecological effects of roads have been synthesized in reviews and meta-analyses that reach consistent conclusions. Five syntheses support retaining the 2001 Roadless Area Conservation Rule. The four that report study counts range from 21 to 1,098 studies. Roads reduce wildlife populations well beyond the road itself. In an empirical review of 79 studies covering 131 species, Fahrig and Rytwinski (2009) found that documented negative effects of roads on animal abundance outnumbered positive effects by a factor of five (114 negative responses, 22 positive, 56 with no effect). Amphibians, reptiles, and large mammals tended to respond negatively. The authors concluded that the evidence for population-level effects is strong enough to merit routine consideration in all road construction projects. A meta-analysis of 49 studies on 234 mammal and bird species (Benítez-López et al. 2010) found that densities declined near infrastructure such as roads, with effects reaching up to about 1 km for birds and about 5 km for mammals. A road's ecological footprint is therefore far larger than its physical footprint. Roads spread invasive species. A review of 1,098 studies (Lázaro-Lobo and Ervin 2019) found that over half examined exotic or weedy plants alone, and all but one of those reported that roadsides promoted their spread. A 2026 meta-analysis of 21 studies from 10 countries (Furtado et al.) found roadside plots had 46% more non-native species, reduced vegetation structure, and a shifted species composition compared with plots farther from roads. Lázaro-Lobo and Ervin also found that roadsides benefited native species most in landscapes already heavily altered by agriculture, urbanization, and forest management, while negative effects were concentrated in areas not highly altered by humans. That describes the condition of roadless areas. Effects reach both land and water. In a foundational review of the scientific literature, Trombulak and Frissell (2000) concluded that roads are associated with negative effects on biotic integrity in both terrestrial and aquatic ecosystems. They identified seven general effects: construction mortality, vehicle-collision mortality, altered animal behavior, altered physical and chemical environments, the spread of exotic species, and increased human use. They emphasized that conservation efforts should avoid building new roads in areas that have few or none. References •Fahrig, L., and T. Rytwinski. 2009. Ecology and Society 14(1): 21. doi:10.5751/ES-02815-140121 •Benítez-López, A., R. Alkemade, and P. A. Verweij. 2010. Biological Conservation 143(6): 1307–1316. doi:10.1016/j.biocon.2010.02.009 •Lázaro-Lobo, A., and G. N. Ervin. 2019. Global Ecology and Conservation 17: e00555. doi:10.1016/j.gecco.2019.e00555 •Furtado et al. 2026. Applied Vegetation Science. doi:10.1111/avsc.70062 •Trombulak, S. C., and C. A. Frissell. 2000. Conservation Biology 14: 18–30. doi:10.1046/j.1523-1739.2000.99084.x

I am submitting this comment in strong opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule and in support of keeping the Rule, and the roughly 58 million acres of Inventoried Roadless Areas it protects, fully intact. I grew up in New England, in forests my family has hiked, camped, fished, and hunted in for generations. Growing up in Southern Maine, I've watched what happens to a woodland once a road goes through it: the understory changes, the streambanks erode, and the deep quiet that lets wildlife actually live there disappears and it is urbanized for good. As an adult, hiking in the White Mountain National Forest and the Green Mountain National Forest has become essential to my own declining health, giving me a clean and wild place to escape the noise, congestion, and industrial pollution of urban New England, the causes of cancer and disease, and clean air to breathe. Without our intact and healthy national forests, I would no longer be alive today. I'm submitting this comment because I want the roadless backcountry that still exists in this country to still exist for my family’s and friends' kids, their grandchildren, and public health. Roadless forests reduce wildfire risk — they don't cause it. Proponents of this rollback frame it as a wildfire-prevention measure. The peer-reviewed evidence says the opposite. An analysis of two decades of federal wildfire records found that human ignitions account for 84% of all U.S. wildfires and are concentrated near roads and other human infrastructure (Balch et al., 2017). A newly published analysis found that Inventoried Roadless Areas have among the lowest wildfire ignition densities of any Forest Service lands, precisely because they lack the roads that bring ignition sources — vehicles, equipment, roadside debris burning, invasive flammable vegetation — deep into the forest (Mildrexler et al., 2026). Opening these areas to road-building would predictably increase fire ignitions, not reduce them. Roadless areas protect the drinking water millions of us depend on. National forests are the largest single source of municipal water supply in the country, and Inventoried Roadless Areas contain or contribute to hundreds of municipal watersheds serving tens of millions of Americans. This isn't incidental — roads are consistently identified as one of the most significant drivers of degraded water quality and aquatic habitat, through sedimentation, altered hydrology, and chemical runoff (Trombulak & Frissell, 2000). Once roads are built into intact watersheds, that water quality doesn't come back without expensive treatment infrastructure that ratepayers, not industry, end up funding. Roadless areas are irreplaceable habitat for imperiled species. Because they aren't fragmented by roads, these areas support wide-ranging and sensitive species — from salmon and trout runs in the Pacific Northwest to grizzly bears and wolves in the Northern Rockies to migratory songbirds in Appalachian hardwood forests like the ones I grew up in. Roads are a well-documented driver of habitat fragmentation, direct wildlife mortality, and the spread of invasive species, all of which erode the ecosystem integrity these species depend on (Trombulak & Frissell, 2000). Roadless forests are a climate asset we cannot afford to degrade. Older, undisturbed forest stands sequester and store significant amounts of carbon. Road construction and the logging it enables remove exactly the large, older trees that do this work best, converting a long-term carbon sink into a source of emissions at the moment we can least afford it. This is also a fiscal issue. The Forest Service already maintains a 380,000-mile road system it cannot afford to properly maintain, with a multibillion-dollar deferred maintenance backlog. Building new roads into currently roadless backcountry adds cost with no demonstrated benefit, while degrading forest values that, once lost, cannot be restored. For these reasons — reduced wildfire risk, protected drinking water, intact wildlife habitat, and climate stability — I urge the Forest Service to withdraw this proposal and keep the Roadless Rule fully in place. References Balch, J. K., Bradley, B. A., Abatzoglou, J. T., Nagy, R. C., Fusco, E. J., & Mahood, A. L. (2017). Human-started wildfires expand the fire niche across the United States. Proceedings of the National Academy of Sciences, 114(11), 2946–2951. https://doi.org/10.1073/pnas.1617394114 Mildrexler, D. J., Berner, L. T., Law, B. E., & Booth, M. S. (2026). Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation. https://doi.org/10.1016/j.biocon.2026.111950 Trombulak, S. C., & Frissell, C. A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology, 14(1), 18–30. https://doi.org/10.1046/j.1523-1739.2000.99084.x

I’m writing to voice my OPPOSITION of the proposed rescinding of the Roadless Rule. This rule has served to protect intact forests and other lands from development for a quarter century. I live in Santa Fe, NM. Here in the desert, water is our most precious resource. In fact, it could be argued that water is the most important resource to all life. Like many cities across the western United States, Santa Fe’s water supply is dependent upon forest health. Much of our drinking water comes from the Santa Fe River Watershed which is a sub-basin of the Rio Grande Watershed with its headwaters located within the Sangre de Cristo range. If one looks at a map of this area, it is a patchwork of land uses with very few areas that are untouched, around 10%. (https://www.fs.usda.gov/sites/default/files/roadless-map-inventoried-areas-newmexico-santafe-fsmrs-072526.pdf) While living here, I have witnessed two large wildfires in our area; the largest fire in New Mexico’s history, 2022 Calf Canyon/Hermits Peak Fire and this year the Frijoles Fire. I know that rescinding the Road Rule will enable not only more roads into our wilderness, but also increased mining, logging and other human behavior that is detrimental to the health of our forest systems and have an effect on the quality and quantity of our water. The concerns I hold for where I live, can be extrapolated to the entire 44.5 million acres that the Roadless Rule has protected. My concerns are three fold: 1. The roads themselves; the mere creation of them and the “opportunities” they open up for mining, logging and general human activity in these areas. “…the presence of roads is highly correlated with changes in species composition, population sizes, and hydrologic and geomorphic processes that shape aquatic and riparian systems...Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation, as well as adding heavy metals (especially lead), salts, organic molecules, ozone, and nutrients to roadside environments. Roads promote the dispersal of exotic species by altering habitats, stressing native species, and providing movement corridors. Roads also promote increased hunting, fishing, passive harassment of animals, and landscape modifications.” Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities; Stephen C. Trombulak, Christopher A. Frissell; published 24 December 2001; (https://conbio.onlinelibrary.wiley.com/doi/10.1046/j.1523-1739.2000.99084.x) 2. Degradation of the water supply. Not only my own water supply but the water supply for 354 municipal watersheds around the country. “…it is widely accepted that forest roads may alter the hydrologic response of the watersheds, because of the alteration of the landscape and its hydrologic functioning, morphology, land uses, and hydrologic characteristics.” Impact of Forest Roads on Hydrological Processes; Aristeidis Kastridis; published 14 November 2020; (https://www.mdpi.com/1999-4907/11/11/1201) 3. Human activity increases the possibilities of fire and additional issues with watersheds and water quality. Roads allow and even invite people to travel on them. Fires occur more often near roads and most fires are caused by human activity, accounting for roughly 80% to 85% of all wildfires in the United States. It has been shown that there are more fires nearer to roads than in wilderness/roadless areas: “From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha).” Three-decade Record of Contiguous-U.S. National Forest Wildfires Indicates Increased Density of Ignitions Near Roads; Gregory H. Aplet, Phil Hartger & Matthew S. Dietz; published 29 January 2026; (https://link.springer.com/article/10.1186/s42408-026-00450-2) “…fires impact watershed characteristics that control surface runoff, including reducing vegetation cover and altering soil properties such as water repellency.” Longitudinal Propagation of Aquatic Disturbances Following the Largest Wildfire Recorded in New Mexico, USA ; Justin Nichols, Eric Joseph, Asmita Kaphle, Paige Tunby, Lina Rodríguez, Aashish Khandelwal, Justin Reale, Peter Regier, David J. Van Horn & Ricardo González-Pinzón; published 21 August 2024; (https://www.nature.com/articles/s41467-024-51306-9)

Dear Secretary Rollins and Chief Schultz, As someone who has spent a substantial portion of recreational time on public land specifically because of the conditions roadless designation maintains, I am submitting these comments to urge the Department to conduct a more rigorous accounting of public value before rescinding the 2001 Roadless Area Conservation Rule. While I know the Mt. Baker Snoqualmie National Forest best, I have also spent significant time in some of the last wild places on Earth - including the salmon runs of Alaska, wonderfully intact and protected by the Roadless Rule. I continue to explore the Mount Baker Snoqualmie National Forest, and find it beloved and respected by others who frequent it. Time in the protected forest and proximity to it is one of the reasons I live and enjoy living in the Skagit Valley. I have made my life and livelihood here, and without it I would no longer feel at home. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — 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) Rescinding the Roadless Rule would open the Mt. Baker West, Mt Baker-Snoqualmie 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. Recission of the roadless rule would be devastating for me personally and for my community who love and respect the outdoors. Unquantified Roadless-Specific Forest Health Data Supporting Causal Rationale The DEIS asserts that the 2001 Roadless Rule "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 has contributed to challenges in addressing forest health concerns" (Rationale for the Proposed Rule, pp. 18-19), yet this three-step causal chain is offered with no acreage figures, no roadless-specific fire, insect, or disease incidence statistics, and no comparison of forest health outcomes between roaded and roadless lands. An agency asserting materially changed conditions must articulate a rational connection between facts found and the choice made, not a bare assertion, under Motor Vehicle Manufacturers Association v. State Farm Mutual Automobile Insurance Co., 463 U.S. 29, 43 (1983), Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), and Lands Council v. McNair, 537 F.3d 981 (9th Cir. 2008), and unsupported factual premises violate APA 5 U.S.C. § 706(2)(A). I request quantified, roadless-specific data on acres affected, fire risk indices, and treatment backlogs, with a direct roaded-versus-roadless comparison, before this rationale is relied upon to justify rescission. Failure to Provide Sensitivity Analysis for Acreage-Derived Percentages The Draft EIS's own acknowledged 0.4-million-acre discrepancy between the 44.7-million-acre IRA figure and the 44.3-million-acre National Forest System land figure is never carried forward into any of the derivative percentages presented in the Affected Environment section, including the 56 percent Tongass figure, the 66.5 percent timber-harvest restriction figure, the 54.5 percent road-construction restriction figure, and the 2.8 percent NWPS overlap figure (pp. 20-36). Having conceded uncertainty in the base acreage, the agency cannot present percentages calculated from it as precise without disclosing how that uncertainty propagates. Under Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002), an agency that identifies a data-quality problem must grapple with its implications for downstream conclusions rather than disclose it in passing. Presenting these figures without error bars is also arbitrary and capricious under APA 5 U.S.C. § 706(2)(A). I request that the agency provide sensitivity ranges or error bars for every acreage-derived percentage in this section before finalizing the rescission. I oppose this rescission, clearly and without qualification. I'm asking the Department to withdraw the proposal. With respect, E Burnham CommentID: RLC-20260908-0HAQRV

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

I am a California resident who strongly opposes repealing the Roadless Area Conservation Rule. Protected areas are absolutely essential to biodiversity and conservation of at-risk species, and the lands that fall under the roadless rule are no exception. Conservation and biodiversity is not just a matter of ethics and animal rights, it is a matter of human survival. Humans rely on the health of the ecosystem in which we live more than we may realize in our day-to-day lives. Biodiverse ecosystems are necessary for continued pharmaceutical research and drug development, prosperous agriculture that provides abundant nutritious food, freedom from devastating levels of zoonotic diseases, and protection against climate change (1). A 2021 analysis found that lands protected by the roadless rule can provide suitable habitat to half (57%) of wildlife species of conservation concern. The report also highlights protected lands in southern California as one of the most habitat-diverse areas; as a Los Angeles resident, I am particularly committed to safeguarding habitats for vulnerable species in my own backyard (2). West Nile virus (a serious and potentially fatal infection spread through mosquitos) activity has reached a five-year high in California, with 46 reported cases (compared with the 5-year average of 17.6 cases) (3). One likely cause of this uptick: loss of bird biodiversity. When bird species diversity is low, there is a documented increased human risk of contracting West Nile disease. This is because ecosystems with low bird diversity tend to have high numbers of species that amplify the virus, whereas more diverse ecosystems contain those species, as well as others that are more resistant to the infection, therefore slowing the spread (4). Land protected by the roadless rule provides unique benefits to wildlife due to their “relative ecological intactness, absence of most conflicting uses, and adjacency to existing protected areas”, meaning national parks (2). Introducing roads to natural landscapes directly harms wildlife in that area. A 2001 article outlines seven main harms as a result of roadbuilding: “mortality from road construction, mortality from collision with vehicles, modification of animal behavior, alteration of the physical environment, alteration of the chemical environment, spread of exotics, and increased use of areas by humans” (5). Introducing roads to land protected by the roadless rule, which provide important habitat for at-risk species, will further endanger their survival and further upset the already struggling ecological balance. We will surely feel the knock-on effects of this loss of biodiversity, particularly in the context of a warming planet. Citations: 1. Ledesma, L. (2025, February 18). Biodiversity. World Health Organization. https://www.who.int/news-room/fact-sheets/detail/biodiversity 2. 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,ISSN 2351-9894, https://doi.org/10.1016/j.gecco.2021.e01943. 3. CA Department of Public Health. (n.d.). California west nile virus website. Westnile.ca.gov | California West Nile Virus Website. https://westnile.ca.gov/ 4. Keesing, F., Belden, L., Daszak, P. et al. Impacts of biodiversity on the emergence and transmission of infectious diseases. Nature 468, 647–652 (2010). https://doi.org/10.1038/nature09575 5. Trombulak, S.C. and Frissell, C.A. (2000), Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology, 14: 18-30. https://doi.org/10.1046/j.1523-1739.2000.99084.x

To the USDA Roadless Rule Rulemaking Team: As someone who has planned and completed extended non-motorized journeys into areas protected under the 2001 Rule, I respectfully submit that my interest in the Rule's continuation is well-founded in direct knowledge of what the Rule has preserved — knowledge that the Department should treat as substantive public comment, not merely as preference. I was born in a rural area, in the foothills the Appalachian mountains. My entire life has centered around enjoying the surrounding wilderness. Obviously some roads are good. But we have plenty already. Furthermore when people have too much easy access thats the areas that are mistreated. Trashed, graffitied, and also as I am sure you are aware, there are 4 times as many fires in forests with roads than roadless forests. Please uphold the protections for these wild places so dear to me Among many days in these forests, one has stayed with me. I always choose areas to hike without roads because there is peace there. The animals are relaxed and playful. I also am able to find a deep sense of calm and rejuvenation with doesn't happen with the sounds of motors around The standing connection and the specific experience above together illustrate what the Rule has made possible over twenty-five years of operation. Regarding the Ellicott Rock 1 in the Sumter National Forest, South Carolina: Headwater Protection for Native Brook Trout and Endemic Crayfish — The Upper Chattooga River headwaters originating in this 301-acre area represent some of the last refuges for native brook trout in South Carolina, a species highly vulnerable to siltation and temperature increases. The area also protects s… Roads alter the physical environment in ways that persist. Road construction compacts soil to roughly 200 times the density of undisturbed forest soil, alters at least eight major physical characteristics of the environment, and creates disturbance patterns that persist for decades — including on logging skid trails 40 years after last use (Trombulak & Frissell 2000). — Stephen C. Trombulak, Christopher A. Frissell, 2000 · Conservation Biology (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Rescinding the Roadless Rule would open the Ellicott Rock 1, Sumter 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. Once this destruction has been done, it cannot be undone. I urge you to uphold protections. I do not want to live in a world where my quality of life has been so drastically reduced to never experiencing the peace, tranquility, rejuvenation, grounding, wonder, and absolute magic of untouched forest. The Rule should remain in full force; the Department is urged to decline the proposed rescission action. With kind regards, CommentID: RLC-20260901-UZX3J2

Dear Chief Schultz, As an outdoor enthusiast, I've seen what roads do to a landscape I'd been walking into for years. The areas within the Mount Baker Snoqualmie National Forest are truly some of the most spectacular places I have seen. They are a place where I can feel more at home than my own home. They are sacred to me, and to so many forms of life. I visit them regularly with my partner, it is a cradle for our love and the love of our Earth. Seeing them threatened, along with so many other treasured landscapes that are nationally protected by the roadless rule, fills my heart with anxiety and my eyes full of tears. One occasion in particular illustrates what that relationship means in practice. The first time I went swimming in the Nooksack, though the Snoqualmie was no less immaculate. These Rivers have cleansed my soul with their waters every time I have visited. Whether I submerge myself or not they have never failed to heal and rejuvenate my heart. It’s not just for the pristine nature of their waters, to which additional road construction would in fact be detrimental, but also for the complex ecosystems they nourish, which simply cannot survive the way they are now if the roadless rule would be rescinded. Everything is connected and all of it can be felt on the banks of each stream, or even just underneath any one of the trees in the forest. The experience recounted and the connection it reflects are offered as evidence that the Rule's continuation serves identifiable, concrete public interests that the present proposal fails adequately to weigh. Regarding the Mt. Baker West in the Mt Baker-Snoqualmie National Forest, Washington: Interior Forest Habitat for Spotted Owls and Marbled Murrelets — The North Pacific Maritime Silver Fir-Western Hemlock and Subalpine Parkland forests provide interior forest conditions required by northern spotted owl (*Strix occidentalis caurina*, federally threatened with critical habitat designation)… “At intermediate scales, roads disrupt soil structures and hydrological pathways and alter plant and animal communities. Chemical pollution from vehicle exhaust (primarily NOX) enriches roadside soil and changes plant composition, favoring a few dominant flowering plants at the expense of more sensitive plant species (for example, ferns, mosses, and lichens). The extent of this effect can range up to 200 m from multilane highways and up to 35 m from two-lane highways. — National Academies Press / Transportation Research Board, 2005 (https://doi.org/10.17226/11535)” “Two centuries of road building, logging, and aggregate mining have contributed to a ~82% (6200 km2) reduction in unlogged, roadless (>1 km from roads) habitat in Algonquin Park at a mean decline rate of 32 km2/yr. There are at least ~5500 km of roads that fragment Algonquin Park into 732 roadless habitats covering 18% of the Park's area. Decline of roadless habitat has contributed to the impairment of ecological integrity and decline of at least 34 species across all trophic levels, including at least 17 species-at-risk. — MDPI / Biosphere, 2026 (https://doi.org/10.3390/biosphere2010001)” “70% of remaining forest is within 1 km of the forest's edge, subject to the degrading effects of fragmentation. A synthesis of fragmentation experiments spanning multiple biomes and scales, five continents, and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75% and impairs key ecosystem functions by decreasing biomass and altering nutrient cycles. Effects are greatest in the smallest and most isolated fragments, and they magnify with the passage of time, with average species loss >20% after 1 year and >50% after 10 years. — PMC / Science Advances, 2015 (https://doi.org/10.1126/sciadv.1500052)” “Road construction increases soil compaction up to 200 times relative to undisturbed sites, likely decreasing the survival of soil biota. A road transforms the physical conditions on and adjacent to it, creating edge effects with consequences that extend beyond the time of the road's construction. At least eight physical characteristics of the environment are altered by roads: soil density, temperature, soil water content, light, dust, surface-water flow, pattern of runoff, and sedimentation. Long-term use of roads leads to soil compaction that persists even after use is discontinued; the consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated. — Conservation Biology / Wiley Online Library, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “)” The Rule should remain in full force; the Department is urged to decline the proposed rescission action. Respectfully submitted, CommentID: RLC-20260823-F7M9J8

To the Roadless Rule Rulemaking Docket: For an outdoor enthusiast, roadless public land is not a luxury — it's the version of public land that delivers what public land is for. Regarding the Woodford 09086 in the Green Mountain and Finger Lakes National Forests, Vermont: Population-level impacts of not assessed severity across not assessed scope are documented for Northern Myotis (Myotis septentrionalis, G2, E) in the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests, driven by 6.1 - Recreational activities. The roadless character of Woodford 09086 currently prevents the infrastructure penetration that initiates 6.1 - Recreational activities. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for Northern Myotis. The agency cannot satisfy its analytical obligations with a national-level discussion of roadless values. The DEIS must address 6.1 - Recreational activities as it affects Northern Myotis (Myotis septentrionalis) specifically within the Woodford 09086 IRA, Green Mountain and Finger Lakes National Forests. "Grazing by domestic herbivores is the most widespread land use on the planet, and also a major global change driver in grasslands. We show that aridity partly explains the responses of biodiversity and multifunctionality to long-term livestock grazing. Grazing greatly reduced biodiversity and multifunctionality in steppes with higher aridity, while had no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relative lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity." — Nature Communications, 2023 “The current national forest road system includes 380,000 miles of roads. The agency also has a road reconstruction and maintenance backlog of approximately $8.4 billion, and it receives only about 20 percent of the annual funding needed to maintain its road system up to safety and environmental standards. — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-james-furnish-statement-before-senate-20000726-stelprdb5137345.pdf)” “When the 2001 Rule was issued, the NFS road system was over 386,000 miles long. The FS argued that budget constraints, coupled with the size of the forest road system, prevented the agency from managing the road system to required safety and environmental standards. For example, in issuing the 2001 Rule, the FS indicated that there was an estimated $8.4 billion in deferred maintenance and reconstruction on NFS roads and that, in addition to the 2001 Rule, it sought additional measures to control the transportation share of its budget. — Congressional Research Service, 2020 (https://www.congress.gov/crs_external_products/R/PDF/R46504/R46504.2.pdf)” “Roads cause habitat loss and fragmentation not only through their physical occupation, but also through traffic noise. The results showed that the habitat loss due to noise effect zone is dramatically higher than that due to road land-take only (35% versus 1.04% of the total area). We conclude that, although the roads are breaking apart the patches by land-take, road noise not only dissects habitat patches but takes much larger proportions of or even functionally eliminates entire patches. — Hossein Madadi | Hossein Moradi | Alireza Soffianian | Abdolrassoul Salmanmahiny | Josef Senn | Davide Geneletti, 2017 · Environmental Impact Assessment Review (https://doi.org/10.1016/j.eiar.2017.05.003)” “Construction of roads, utility corridors and other human infrastructure kills any sessile or slow-moving animal and all vegetation in the path of the feature. Roads and other linear infrastructure negatively impact wildlife through increased mortality, decreased habitat amount and quality, changing species movement patterns, and fragmentation of populations into smaller subpopulations, which are more vulnerable to local extinction. — Trombulak, S. C., and C. A. Frissell, 2000 · Conservation Biology (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. — René E. van Dijk, Toine Morel, Karen Zwerver, Paul van Els, Ruud P. B. Foppen, 2025 · Landscape Ecology (https://doi.org/10.1007/s10980-025-02100-5)” Nothing in the proposal persuades me that the Rule has failed to serve the purposes for which it was adopted. Sincerely, Dr. Becky Phillips

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

Dear Secretary Brooke L. Rollins: In my experience as an outdoor enthusiast who has used national forests in multiple regions over many years, I have come to understand that roadless areas are not the norm but the exception — the product of deliberate regulatory protection — and that the proposed rescission would remove the instrument responsible for maintaining that exception. My time spent in nature not only enriches my life but helps me restore my energy, feeling recharged to continue working as a health care provider contributing to the public health and well being of my community. The Rule has, for nearly twenty-five years, preserved the character of places like the one described here; rescinding it would be an irreversible administrative act with irreversible consequences on the ground. Regarding the Griffith Lake 09084 in the Green Mountain and Finger Lakes National Forests, Vermont: What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. What separates recreating in the Griffith Lake 09084 IRA from roaded portions of Green Mountain and Finger Lakes National Forests is the roadless condition itself. Roaded areas offer motorized noise, dust, fragmented habitat, and degraded streams. The Griffith Lake 09084 IRA offers the opposite — and that distinction is the entire basis of its recreational value. 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. “Analysis of 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads versus just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. Ignition density decreased steadily as distance from roads increased, irrespective of designation. The study concludes that "building roads into roadless areas is likely to result in more fires." — Research - Fire Safety” “Roads change soil density, temperature, soil water content, light levels, dust, surface waters, patterns of runoff, and sedimentation. The surfaces of unpaved roads can route fine sediments to streams, lakes, and wetlands, increasing the turbidity of the waters, reducing productivity and survival or growth of fishes. Roads have been responsible for the majority of hillslope failures and gully erosion in most steep, forested landscapes. Alteration of hydrodynamics and sediment deposition can result in changes in channels or shorelines many kilometers away, both down- and up-gradient of the road crossing. — Conservation Biology, 2000 (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” The Department is urged to give full weight to the administrative record compiled over more than two decades before proceeding with any rescission action. Yours truly, Jen Walsh CommentID: RLC-20260823-4QZHY9