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I am writing regards to the rescission of the 2001 Roadless Rule. I am opposed to the rescission of this rule. I am a geologist , parent, educator, and outdoor recreation enthusiast living in the southwestern United States. I am a US-born citizen who has been paying taxes on my earnings for 50+ years. Here are some of the reasons I oppose eliminating the Roadless Rule. 1.Regarding wildfire control: Most wildfires are human-triggered. It is a documented fact that more roads in wilderness areas facilitate more human-caused fires. (Healey, 2020; https://iopscience.iop.org/article/10.1088/1748-9326/aba031 ; Balch et al.2017, https://www.pnas.org/doi/10.1073/pnas.1617394114 ; NPS, https://www.nps.gov/articles/wildfire-causes-and-evaluation.htm ). More roads lead to more people lighting campfires or smoking in formerly roadless areas. I know from my own outdoor experiences that many people are irresponsible with flames in combustible landscapes. In addition, vehicles themselves can also generate the sparks for wildfires. This is not uncommon in Arizona, where quartz-rich rocks in access roads are a bad companion to dragging metal chains. 2.Invasive plant species are promulgated when roads are built in roadless areas. (again, see Healey 2020). For example, here in AZ, invasive buffel grass and “stinkweed” are both deadly to native vegetation and provide excellent fuel for wildfires. 3.Regarding watershed/river/landslide/erosion negative effects: the USDA’s own preliminary environmental impact acknowledges negative impacts would result from building more roads in roadless areas, particularly in reference to the Tongass Forest (https://usfs-public.app.box.com/s/gomzq6rruwsds8rw50o3j3g429utj8f6/file/2415112742244 ; see also Pew Trust, 2026 https://www.pew.org/en/research-and-analysis/articles/2026/10/05/us-department-of-agriculture-proposes-eliminating-the-roadless-rule#:~:text=Roads%20and%20logging%20can%20send,concentrating%2C%20or%20diverting%20natural%20flows. ) Building more roads leads to loss of vegetation, increased erosion, more sediment load in watersheds which harms wildlife habitats and water quality, and higher landslide potential. Through my geologic and recreational experiences in Arizona, Washington State, Colorado, Oregon, and other western states, I can vouch for the negative geologic and biologic effects of road building in western roadless areas. 4.Regarding outdoor recreation: this is a non-political issue for many citizens throughout the political spectrum. Hunters, anglers, hikers, campers, and fans of the beauty of America’s wild places appreciate the majesty of places where human impact is minimized. the treasure of its iconic wild places. 5.The federal lands impacted by the Roadless Rule already have roads of various types in them. Do we really need more roads in these beautiful, fragile, unique American landscapes? In summary: More roads in the Roadless Areas will have negligible effects on wildfire management, but potentially tragic consequences on water supplies, wildlife, and the landscape in these remarkable areas. The treasure of American wild places will be irreparably harmed by the rescission of the Roadless Rule. Unlike inert gold, the living treasure of the Roadless Areas must be protected and nurtured by all of us to benefit us and future generations. Please respect my concerns, the concerns of American tribes and Alaska natives (https://tlingitandhaida.gov/news/roadlessrulerollbackopposition/) (https://www.wilderness.org/articles/press-release/ncai-and-tws-condemn-administrations-proposal-rescind-roadless-rule) , and the almost one million commentors on this proposal; and reconsider the rescission of the Roadless Rule. Thank you for considering my opinion and concerns.

Repealing the Roadless Rule would be an absolute disaster. The proposal states that it is in order to reduce forest fires, but this is not based in science. Including decades of research, the Fire Ecology study conducted by Gregory H. Aplet et al, showed that wildfire ignition in areas within 50 meters of a road are far, far higher (https://doi.org/10.1186/s42408-026-00450-2). In addition, 84% of fires are caused by humans, according to Balch et al’s research published in the Proceedings of the National Academy of Sciences. (https://doi.org/10.1073/pnas.1617394114) Building more roads, with more humans present along those roads, will lead to more fires. In addition, repealing the rule will harm our drinking water. Logging and roads lead to sediment build up, which contaminates the watershed. I myself live in an area that relies on national forests for its drinking water and regularly hike and bird watch in several roadless areas, including the Tahoe Rim Trail, Kingsbury Stinger Trail, Sierra Canyon, and Genoa Peak. These are vital areas of subalpine woodland and mixed conifer forests that wildlife and our water sources rely on. Please do not repeal the Roadless Rule.

Dear Secretary Rollins and Chief Schultz: As a grandparent, I know the importance of stewardship, not consuming everything but leaving for the next generation what was left for me. We've been taking our grandkids to National Forests and roadless areas since they were very small. My first outdoors photos of my eldest grands were on the Mt Baker side of Stevens Pass, followed by many trips in the Cascades, including the Chiwawa and Chelan area. While my home address may be Mount Vernon, my real home is a cabin outside the Mt Baker Snoqualmie NF, nearby is the OkaWen NF. I step outside and I'm in the forest. I walk a little ways, I'm in the national forest. I'm closer to roadless nf than I am to a super market or hospital. It's a wonderful place for grandkids, grand nieces and nephews to visit. Wildlife is abundant, streams are beautiful. But it's the PNW and landslides from disturbed soils are a concern. Fires are constantly starting along the national forest roads where people drive and camp. No road would have been built where the Little Giant Fire started. And when it burned long enough to escape its valley, it tumbled down the slopes and leapt over the Chiwawa River and then it jumped the nf road. And studies show this, we do not need more roads to stop fires. We need safe slopes so another Oso does not happen. We need good water in our aquifers and wells. 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. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. “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)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Healey, 2020 (https://doi.org/10.1088/1748-9326/aba031)” A rule that has survived multiple administrations and multiple rounds of circuit-court review should not be rescinded on the present record. CommentID: RLC-20261006-SLBYA0

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

I vigorously oppose this proposed rescission. The stated reasons for this rescission are false, misleading, or timber industry propaganda. In particular, the reason relating to preventing wildfires is ridiculous. The facts are contrary to this reason. When USDA Secretary Brooke Rollins announced the rescission of the 2001 Roadless Rule on June 23, 2025, the headline rationale was wildfire. Roads, the argument went, are needed to "manage fire" inside America's 44.5 million acres of inventoried roadless areas. The peer-reviewed science says exactly the opposite. What the published research actually shows: The most decisive data point comes from a 2026 study in Fire Ecology by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz of The Wilderness Society. The authors analyzed 32 years of contiguous-U.S. wildfire records across all eight Forest Service regions. Their finding: 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). That is roughly a fourfold difference. Ignition density decreased steadily as distance to roads increased — from about 6 fires per 1,000 ha within 250 m of a road to fewer than 2 fires per 1,000 ha beyond 2,000 m. The pattern holds for human-caused, natural, and undetermined fires alike. As the authors conclude: "building roads into roadless areas is likely to result in more fires." A separate national analysis (Balch et al., Proceedings of the National Academy of Sciences, 2017) explains why. Human-started wildfires accounted for 84% of all U.S. wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Roads are the primary vector through which human ignitions reach previously remote landscapes. What about fire severity? Bradley, Hanson, and DellaSala (Ecosphere, 2016) found that forests with higher levels of protection burned at lower severity, not higher, even though they generally carry the highest biomass and fuel loads. Johnston et al. (Environmental Research Letters, 2021) confirmed that while roadless areas saw greater fire extent over three decades, there was no significant difference in fire severity after accounting for biophysical conditions — and suggested the greater extent of fire may even confer ecological resilience. The Wildland-Urban Interface claim doesn't hold up either Forest Service Chief Tom Schultz testified to the Senate Energy and Natural Resources Committee that 24.5 million acres of inventoried roadless areas sit within one mile of the Wildland-Urban Interface (WUI), calling that figure "our primary concern." The Wilderness Society performed a straightforward GIS analysis using the Forest Service's own WUI dataset. The actual figure is 2.8 million acres — a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not the 42% Schultz implied. Even if every acre near the WUI mattered, the Forest Service already has 23.3 million acres of non-roadless forest land available near communities for fuel reduction. There is no operational need to build new roads through pristine backcountry to address the genuine fire risk facing homes and infrastructure. What this means for the rescission The wildfire rationale is the only public-facing justification USDA has offered for rescinding the Roadless Rule. The actual Federal Register notice tells a different story: it cites Executive Orders 14192 (deregulation), 14225 (timber production), and 14154 (energy unleashing), and states the goal is to facilitate domestic production of "timber, energy and mineral production... to the maximum possible extent." Wildfire is the cover story. Industrial access is the policy. Anyone responding to the rulemaking should know that the empirical case for the wildfire rationale collapses on contact with the published science. Roads bring fire. Roadless areas are not the problem. They are part of the solution. Sources Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, article 8. doi.org/10.1186/s42408-026-00450-2 Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. doi.org/10.1073/pnas.1617394114 Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10), e01492. doi.org/10.1002/ecs2.1492

Dear Secretary Rollins: Please keep the roadless areas roadless and do not rescind FS-2025-0001. More roads is not better for fire prevention - more roads actually means MORE human-caused fires, while roadless areas allow trees - especially old-growth trees, to store moisture and carbon. There is a great deal of documentation on this, including: https://www.pnas.org/doi/full/10.1073/pnas.1617394114 and https://www.wilderness.org/sites/default/files/media/file/Summary%20NFS%20roads%20fire%20paper%20-%202025.pdf. Many areas are dealing with the spread of non-native, invasive plants that overtake and kill/suppress native plants that the ecosystem depends on - everything from the insects to birds and mammals and people. For example, I have seen invasive knapweed overtake native vegetation at a very alarming rate in NW Montana just over the past 10 years. A USDA study showed that roads are strongly associated with the spread of invasive plant species in national forests. Non-native plants are twice as common within 152 meters (500 feet) of a road as farther away. Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data. Again, from USDA research/data. Millions of people rely on clean water that has its source in these areas where moisture is stored and water is filtered naturally. Building new roads will be incredibly destructive to these water sources. The rule also protects sensitive streams and rivers from erosion caused by effects of road-building leading to more logging which leads to more soil blowing into streams and suffocating wildlife, killing eggs of endangered fish and amphibians, etc. There are already so many roads and trails accessible to motorized vehicles, atv's etc. Roadless areas are still accessible by walking in - I've done that, and the experience is pretty incredible due to the great diversity of plants, trees, wildlife, birds. We don't need every acre of forest and public land to have roads. There is a massive backlog of needed maintenance on roads and bridges already existing on on USFS land...we simply cannot afford to build more when so much work needs to be done to make the ones already in existence safe. It would be irresponsible to spend money to create any new roads while this backlog exists. Hundreds of protected species that are in danger of becoming threatened or extinct rely on roadless areas to live and reproduce. There are entire, intact ecosystems in roadless areas - nature still existing the way it was designed to. Migration corridors - which we are still learning more about and about the effects of development and fragmentation on them - are preserved by roadless areas. We should be studying the lessons to be learned from these intact ecosystems rather than destroying them. Again, people can still access these areas on foot, causing far less disturbance. Finally, many roadless areas are home to or used by indigenous people who vehemently oppose rescinding the roadless rule as it would lead to likely extensive damage to sacred sites, culturally significant places where food and traditional medicines are gathered, and treaty resources. Roadless areas also actually attract tourism and are economically positive for nearby communities. Many people are drawn to these areas for the unique opportunity to recreate in an area without roads. There are roads everywhere, so these few areas where there are no roads and the subsequent opportunities to view wildlife, hike in peace, etc. are unique. The National Environmental Policy Act (NEPA) regulation requires that the government conduct environmental impact assessments - this takes time and has not been done. This rule was created with documented, bipartisan support after over 600 public meetings and over 1.6 million comments submitted. See this study documenting that 76% of the US population supports keeping the roadless rule: https://www.pew.org/en/research-and-analysis/articles/2026/02/18/an-update-on-the-roadless-rule. For the sake of future generations and everyone who benefits from and/or stands to possibly face harm from a full rescission, please leave the roadless rule intact. Thank you.

Dear Tom Schultz, Growing up and living near and exploring Craggy Mountain is wonderful and I wouldn't trade it for the world I spend my spare time wandering and foraging on and around Craggy. Craggy belongs to us, the public, and to the wildlife who depend on it for survival. It is not for sale or development! Taking away the roadless will ruin and take away these experiences from me. It will take critical habitat from wildlife. It will harm my aquifer and it will take away income as I rely on the tourist drawn to the trails and pristine beauty of Craggy Mountain. As a working artist it will destroy my inspiration. It will also increase rather than decrease fire risk Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: The physical footprint of road construction — grading, drainage installation, stream crossings — destabilizes slopes and generates chronic sediment inputs that intensify 7.1.2 - Suppression in fire frequency/intensity in the Craggy Mountain IRA. NEPA requires the agency to take a hard look at the effects of rescission on Gray's Lily (Lilium grayi) in the Craggy Mountain IRA. The DEIS fails this standard without site-specific analysis of 7.1.2 - Suppression in fire frequency/intensity at the severity and scope documented by NatureServe. "The mortality of wildlife resulting from collisions with vehicles is considered one of the main negative effects of roads on numerous species. Roadkill can increase the risk of local extinction by reducing effective population size and genetic diversity, while also limiting demographic and genetic rescue mechanisms. Estimates can reach to 340 million of birds killed on the roads in USA, 194 million birds, 29 million mammals in Europe and 17 million of birds and mammals in Latin America." — Scientific Data (Nature), 2024 “Human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, dominated an area seven times greater than that affected by lightning fires, and were responsible for nearly half of all area burned. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Sixty percent of the total land area of the coterminous United States was dominated by human-started wildfires, whereas only 8% of the area was dominated by lightning fires. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” The Department should keep the Roadless Rule in place. I think the record supports that, and so does the public. In earnest, CommentID: RLC-20261006-C5H9RX

Dear Department of Agriculture Leadership: Greetings, I am writing in support of maintaining the Roadless Rule. For more than 3 decades, I have been a back-country hiker and camper in many of the wilderness areas of our beautiful country, from the forests of North Carolina, New York, Ohio, Minnesota, Oregon, Washington, New Mexico, California, Arizona, Colorado and Utah. I spend as much time as possible outdoors and I have seen all variety of conditions of forests, parks and public lands. The forests and undeveloped areas are cherished. I have hiked and camped in these lands and there is NOTHING like being in the healthy and undivided forests that are teeming with biodiversity and healthy trees and clean water. In places where roads are built, development always follows. These undeveloped lands are precious to maintain drinking water, biodiversity, and climate stability. You can SEE the difference in the biodiversity and the health of forests that have been reduced to mere strips of a few trees. All life begins to disappear. I want my children to be able to witness the wild places that I have seen. I want them to know that the animals in their story books are NOT extinct. We need our country's wild places left without roads to preserve the spirit of American land and freedom. Regarding the Three Sisters in the Deschutes National Forest, Oregon: Rescission of the Roadless Rule exposes the Three Sisters IRA, Deschutes National Forest, to road construction that will convert a zero-road-sediment watershed into one with chronic, irreversible non-point source pollution. The Forest Service has not demonstrated that any management objective justifies this degradation. "Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. 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." — Journal of Soil and Water Conservation, 2011 The Three Sisters IRA, Deschutes National Forest, currently has no impervious road surfaces, no exposed cut or fill slopes, and no stream crossings delivering sediment to channels. This is what "roadless condition" means in hydrological terms: the watershed functions as if roads do not exist, because they do not. Every road mile constructed subtracts from this condition permanently. The 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. “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)” “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205)” “Builds the first national forest-fragmentation database using high-resolution land cover data combined with road density. Demonstrates a methodology for assessing forest intactness across the U.S. and quantifies how few large intact forest patches remain, strengthening the case that the remaining roadless tracts are disproportionately valuable for biodiversity and ecosystem function. — Heilman et al., 2002 (https://doi.org/10.1641/0006-3568(2002)052[0411:FFOTCU]2.0.CO;2)” “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)” With appreciation, CommentID: RLC-20261006-93YZ3Q

Dear Secretary Brooke L. Rollins, I am writing to demand that roadless areas remain protected. These areas are invaluable and cannot be restored once lost. Future generation deserve no less. Short-sighted greed cannot be allowed to take away our children's future. I have visited the Canaan Valley for over 50 years. The chance to be in roadless areas as a young person actually changed my life. I learned to listen, hear, see, and love. I learned how to be quiet and know what is good about this life. The Canaan Loop is one of the most valuable recreational areas in West Virginia. The recreation economy is essential for the area. The chance to be in the wilderness is essential for both West Virginians and others (perhaps native West Virginians, like me) from surrounding states. Regarding the Canaan Loop in the Monongahela National Forest, West Virginia: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Rescinding the Roadless Rule would open the Canaan Loop, Monongahela National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “National-scale analysis found 77% of roadless areas have potential to conserve threatened & endangered species, with strong concordance with grizzly recovery zones. — Loucks et al., 2003 (https://doi.org/10.5751/ES-00528-070205)” “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943)” “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Tongass roadless areas contain very large biomass and soil carbon stocks, underscoring old-growth protection as a critical climate solution with global significance. — DellaSala et al., 2022 (https://doi.org/10.3390/land11050717)” “On steep terrain, 21% of trees were damaged by excavators and 33% of trees were damaged by bulldozers during forest road construction, and on very steep terrain, 27% of trees were damaged by excavators and 44% of trees were damaged by bulldozers during forest road construction.” The forests covered by this Rule are irreplaceable. The Rule itself should be treated the same way. Yours truly, CommentID: RLC-20261006-OCPMQB

Dear Secretary Rollins, I am a human, and a part of nature. I want a sustainable future which includes clean water. Rescission will mean I lose a sense of freedom. This is truly an area I feel connected, grounded, and free. That is because of the quiet, the wildlife, the trees, and the mountains. It also impacts more than one spot. Rescinding the Roadless Rule means an increase in fire danger and negative impacts to water quality, both of which are of high importance. Regarding the Dome Peak in the Routt NF, Colorado: 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. “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." — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2)” “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)” These are public lands. Keep them whole. Respectfully submitted, CommentID: RLC-20261005-ZWI59Q

Dear Secretary: From the vantage of a wildlife observer and native plant advocate who has walked the boundary between roaded and roadless units of the same forest, I can attest that the difference is detectable, and on that basis I oppose the proposed rescission. Quiet, untouched places in nature like the Devil's Den are the sole remaining places humans can go to calm nervous systems undoing the cortisol damage created by man made work environments, affordability stressors and unchecked marketing our current society bestows on its' inhabitants. Paved roads immediately reduce permeable surface area and increase the speed at which water travels, impacting native flora and fauna and access to clean, fresh water. Invest in public railways or public transportation instead. Regarding the Devil's Den 09083 in the Green Mountain and Finger Lakes National Forests, Vermont: Roads, disturbance, and altered ecosystems create invasion pathways that let non-native plants, pathogens, and animals displace native biota. Non-native species concentrate near roads. A 2025 study tracking plant communities at varying distances from roads found non-native species in 94 percent of roadside plots, 27 percent of adjacent plots, and only 15 percent of plots furthest from the road. Roads also altered the underlying soil conditions in ways that favored non-native plants over native species (Clavel et al. 2025). — Clavel et al., 2025 (https://doi.org/10.1111/oik.11075) Rescinding the Roadless Rule would open the Devil's Den 09083, Green Mountain and Finger Lakes National Forests to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. 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. As the climate warms and species ranges shift northward and upslope, intact roadless areas are emerging as some of the most important climate refugia on the continent. Their unfragmented condition shelters cool microclimates, intact hydrology, and the connected habitat corridors that wildlife and plant communities need to adapt as conditions change. A growing body of peer-reviewed science identifies inventoried roadless areas as disproportionately important both as ecosystem-scale refugia — high-quality, undisturbed substrate that holds carbon and buffers temperature — and as species-scale refugia for cold-adapted, drought-sensitive, and otherwise climate-vulnerable populations. They also anchor portions of the Pacific, Central, Mississippi, and Atlantic migratory bird flyways, providing the unfragmented stopover and breeding habitat that hundreds of species depend on. Fragmenting these areas with new roads severs the very connectivity that climate adaptation requires. “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)” Please see attached issues with invasive species not addressed by the literature of the rule repeal. Rescission of the Roadless Area Conservation Rule is opposed; its retention is respectfully requested. Best, C.N.

I oppose the Roadless Area Conservation proposal for the following reasons, which are all quoted. "The most decisive data point comes from a 2026 study in Fire Ecology by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz of The Wilderness Society. The authors analyzed 32 years of contiguous-U.S. wildfire records across all eight Forest Service regions. Their finding: 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). That is roughly a fourfold difference. Ignition density decreased steadily as distance to roads increased — from about 6 fires per 1,000 ha within 250 m of a road to fewer than 2 fires per 1,000 ha beyond 2,000 m. The pattern holds for human-caused, natural, and undetermined fires alike. As the authors conclude: "building roads into roadless areas is likely to result in more fires." A separate national analysis (Balch et al., Proceedings of the National Academy of Sciences, 2017) explains why. Human-started wildfires accounted for 84% of all U.S. wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Roads are the primary vector through which human ignitions reach previously remote landscapes. What about fire severity? Bradley, Hanson, and DellaSala (Ecosphere, 2016) found that forests with higher levels of protection burned at lower severity, not higher, even though they generally carry the highest biomass and fuel loads. Johnston et al. (Environmental Research Letters, 2021) confirmed that while roadless areas saw greater fire extent over three decades, there was no significant difference in fire severity after accounting for biophysical conditions — and suggested the greater extent of fire may even confer ecological resilience. The Wildland-Urban Interface claim doesn't hold up either Forest Service Chief Tom Schultz testified to the Senate Energy and Natural Resources Committee that 24.5 million acres of inventoried roadless areas sit within one mile of the Wildland-Urban Interface (WUI), calling that figure "our primary concern." The Wilderness Society performed a straightforward GIS analysis using the Forest Service's own WUI dataset. The actual figure is 2.8 million acres — a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not the 42% Schultz implied. Even if every acre near the WUI mattered, the Forest Service already has 23.3 million acres of non-roadless forest land available near communities for fuel reduction. There is no operational need to build new roads through pristine backcountry to address the genuine fire risk facing homes and infrastructure. What this means for the rescission The wildfire rationale is the only public-facing justification USDA has offered for rescinding the Roadless Rule. The actual Federal Register notice tells a different story: it cites Executive Orders 14192 (deregulation), 14225 (timber production), and 14154 (energy unleashing), and states the goal is to facilitate domestic production of "timber, energy and mineral production... to the maximum possible extent." Wildfire is the cover story. Industrial access is the policy. Anyone responding to the rulemaking should know that the empirical case for the wildfire rationale collapses on contact with the published science. Roads bring fire. Roadless areas are not the problem. They are part of the solution." I am quoting the sources used for the above as well: Sources Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, article 8. doi.org/10.1186/s42408-026-00450-2 Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. doi.org/10.1073/pnas.1617394114 Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10), e01492. doi.org/10.1002/ecs2.1492 Johnston, J. D., et al. (2021). Does conserving roadless wildland increase wildfire activity in western US national forests? Environmental Research Letters, 16(8), 084040. doi.org/10.1088/1748-9326/ac13ee The Wilderness Society (2025). Forest Service Chief Grossly Exaggerates Roadless Rule Concern: WUI Analysis. PDF

I am writing as a concerned citizen, California resident, and nature enthusiast. I was alarmed by the recent proposal to rescind the Roadless Rule. I have read the 8/18/2026 USDA press release (https://www.usda.gov/about-usda/news/press-releases/2026/08/18/usda-acts-remove-roadless-rule-restrictions-exacerbate-rising-wildfire-risk) on the rationale behind their proposal, and I strongly disagree. The USDA press release cites an effort to bring decision-making back to local forest services and to assist in decreasing wildfire risk. However, what is absent in the press release is any data from ecological and forestry scientists about whether repealing the Roadless Rule would decrease wildfire risk. What is also absent from the press release are statements from local forest managers (not state governors, but statements from state forest managers) about instances where the current Roadless Rule has significantly harmed their overall ability to care for the land. It is absolutely ridiculous to call for rescinding the Roadless Rule without presenting all this information to the American public. When I performed my own investigation, I found information that contradicts what was presented in the USDA press release. Humans are a major cause of wildfires, and any potential roads that are built as a result of rescinding the Roadless Rule will likely increase the incidence of wildfires. Additionally, areas protected under the Roadless Rule burn at the same rate as areas that do not, so it seems illogical for the USFS to argue that rescinding the Roadless Rule is an effective means of risk reduction. https://www.pnas.org/doi/10.1073/pnas.1617394114 https://iopscience.iop.org/article/10.1088/1748-9326/aba031 Finally, I am worried that removal of the Roadless Rule is the canary in the coal mine for excessive logging and destruction of our old growth forests. As a California resident, there are no words to describe the awe and serenity one experiences when in nature and hiking among towering trees that are centuries old. These forests have seen the creation of America, have lived through our national history with us, and are now so uncommon in the world around us. It would be devastating to lose this part of our history and heritage.

I am a citizen who absolutely admires and visits roadless areas within America's national forests and national parks and I support the No Action alternative in the current DEIS. I strongly oppose removing the 2001 roadless area conservation rule. Please consider a FULL environmental review with experts in this field as this is a large proposal affecting over 44.7million acres. The idea of rescinding the Roadless Rule concerns me as it holds importance to the existing wildlife, outdoor recreation community and the outdoor recreation economy. These lands contain many animals and amphibians, some of which are considered critical species and need these lands to survive a world in which land continues to get developed with no space for wildlife (https://www.ecologyandsociety.org/vol7/iss2/art5/ ,https://www.sciencedirect.com/science/article/pii/S2351989421004935?via%3Dihub ). The rescission would remove vital protections for approximately 45 million acres of backcountry national forests, including more than 25,000 miles of trails and 10,000 climbing routes. There are also miles of white water and mountain biking that add such a wonderful element to outdoor activities. Nature inspires me, different activities allow me to grow and I know it has a similar effect on so many people. These areas protect several sources of water for about 25 million Americans and the trees matter to our carbon footprint; we recently heard about earth’s temperature, it seems reasonable to believe that we need to help save the natural existing elements of this world. ( https://www.tandfonline.com/doi/pdf/10.2489/jswc.66.3.78A ; https://www.sci-tech-today.com/stats/global-warming-statistics/ ). We also know of several American towns without clean water, let us not add more to the list. Our existing road infrastructure could benefit from the money mentioned in the discussion of bring roads to these areas. Some may say building roads would give jobs but it comes with long-term cost to the world, those at power should consider pivoting that talking point to better develop what already exists or to spend money on the companies that can clean up existing roads and stop fires in general. Regarding wildfires, we have data that for the last 32 years wildfire ignition is significantly lower in roadless areas, specifically stating “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha)”(https://link.springer.com/article/10.1186/s42408-026-00450-2 Gregory H Aplet). Research also says humans are the cause of a large percentage of wildfires ( https://www.pnas.org/doi/full/10.1073/pnas.1617394114 ). Therefore, these roadless areas should not be the one to blame. We must ask the question “who profits from this” every time we want to strip conservation rules. All the factors mentioned in the proposal would ultimately worsen an already negative trajectory for climate change, space for wildlife and humans, and affect water sources. As a citizen of the United States, I implore you to please do a full environmental review and to find resources with no connections or fundings from these companies that want to use this space.

My future and my health depend on Roadless Rule protection. I am in graduate school, getting my master's degree in Clinical Mental Health Counseling. I dedicate my life to helping others, so I have a tremendous amount of work to do. It is threatened by the climate crisis and by people who are supposed to uphold environmental protections instead of destroying them. On behalf of humanity, especially the next generation, the Roadless Rule must remain as is. As the future generation and a human. Regarding the Mt. Baker West in the Mt. Baker-Snoqualmie National Forest, Washington: Roadless areas store carbon, buffer temperature extremes, and provide intact refugia where species can shift in response to a warming climate. Cold-water fish habitat is shrinking. Climate warming has reduced cold-water habitat in western U.S. streams, and modest additional warming would shrink it further. (Isaak & Young 2023; Mejia et al. 2023). — Isaak & Young, 2023 (https://doi.org/10.1139/cjfas-2022-0302); Mejia et al., 2023 (https://doi.org/10.1111/gcb.16844) 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. Building more roads in national forests would be a drain on taxpayers. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide, and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. 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. “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)” I can not fathom losing the forests I've hiked in throughout my life, and that should be enjoyed by future generations. The Forest Service should know how essential complex forests are to our climate, aka our future. This impacts everyone who breathes air, drinks water, and eats food. These roadless areas are what save us from the worst of these 4 disasters: fires, flooding, droughts, and landslides. As the Forest Service should know, trees sequester a significant amount of carbon, with young trees absorbing 22 lbs of CO₂ annually and mature trees absorbing an average of 48 to 55 lbs of CO₂ per year, sequestering more as they grow. This cools our environment, which is crucial, and prevents devastating wildfires. The cooler environment aids more precipitation, allowing more water to settle deep in the ground where trees store the water in their roots. When it's overly dry due to the heat from global warming, and it hasn't rained substantially for prolonged periods of time, the water, when it does rain, runs off the dirt's dry surface (instead of absorbing in like a sponge when the dirt is properly watered), causing flooding. Again, we need more trees to sequester more carbon so there is less heat, causing more fires. These complex forests also help prevent landslides by holding dirt in place with their roots. Areas with roads experience all these issues in high severity. Countless studies prove this. The Forest Service should know that these roadless areas are priceless and irreplaceable. No amount of money is worth the amount of harm and life-threatening devastation it would cause. Not even close. The forests these rules protect aren't hypothetical. They're real places with real ecological function. Don't open them up to road construction. In earnest, Shira Williamson - Age 27

My name is Emilee Simpson and I am an undergraduate biology student at Brigham Young University. I am writing to express my opposition to the rescission of the 2001 Roadless Area Conservation Rule. One of the main reasons why I am opposed to this rescission is that construction of access roads through national forest lands can fragment habitats and isolate wildlife populations. Many animals exhibit a strong aversion to roads because of traffic noise and artificial light (Xiong et al., 2025). Roads can also restrict wildlife movement between habitat patches, potentially reducing gene flow and increasing genetic isolation between populations (Corlatti et al., 2009). Over time, reduced connectivity can make populations more vulnerable to environmental change and other disturbances. Although increased roads may provide flexibility for forest management and wildfire response, human activity is also an important consideration. Balch et al. (2017) found that human-started fires accounted for 84% of recorded wildfires in the United States from 1992-2012. Increasing road access could provide more opportunities for human activity and potentially create additional ignition sources. Increased road access to address wildfire risk could overlook the important role that humans already play in wildfire occurrence. Road construction and subsequent vehicle traffic can also facilitate the introduction and dispersal of non-native plant species, creating another potential issue associated with expanding road networks (Son et al., 2024). Another, more personal reason I am opposed to this rescission is because of the experiences I have had in National Forests with my family. Some of my favorite memories have been created by backpacking and hiking into extremely remote, pristine areas of our National Forests. These experiences have given me an appreciation for places where people can escape and experience nature with little human disturbance. I am concerned that increasing the number of roads will greatly increase access to some of my favorite spots and could change by increasing human use and disturbance. I am also concerned about the potential for increased access to contribute to pollution, invasive species, and other impacts. I believe that expanding access should be approached carefully, especially because of the existing challenges associated with maintaining areas currently accessible to the public. For these reasons, I am in favor of retaining the 2001 Roadless Area Conservation Rule rather than rescinding it. Thank you for taking the time to read my comment and I hope you consider my concerns. 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 Corlatti, L., Hacklander, K., Frey-Roos, F. (2009). Ability of wildlife overpasses to provide connectivity and prevent genetic isolation. Conservation Biology, 23(3), 548-56. DOI: 10.1111/j.1523-1739.2008.01162.x. Son, D., Chu, Y., & Lee, H. (2024). Roads as conduits for alien plant introduction and dispersal: The amplifying role of road construction in Ambrosia trifida dispersal. Science of The Total Environment, 912, Article 169392. https://doi.org/10.1016/j.scitotenv.2023.169392 Xiong, G., Yang, F., Wang, T., He, R., and Li, L. (2025). Impact of road infrastructure on wildlife corridors in Hainan rainforests. Transportation Research Part D: Transportation and Environment, 139:104539.

I am writing as a resident of Alpharetta, Georgia, to submit formal comments urging the U.S. Department of Agriculture and the U.S. Forest Service to maintain full protections under the 2001 Roadless Area Conservation Rule (36 C.F.R. § 294) and reject any proposal to rescind or weaken protections across Inventoried Roadless Areas (IRAs). Under the National Environmental Policy Act (NEPA), the Forest Service must base its Environmental Impact Statement (EIS) on high-quality, peer-reviewed science. Published research from the past decade demonstrates that roadless conservation is vital for water security, wildfire mitigation, and biodiversity. I request that the agency evaluate the following substantive findings: * Watershed Protection and Municipal Drinking Water Intact forest catchments are essential for municipal water supplies. For North Georgia and metro Atlanta, headwaters in the Chattahoochee-Oconee National Forests replenish the Chattahoochee River and Lake Lanier. Landscape-scale modeling shows unfragmented forest cover is the single most effective barrier against nonpoint-source pollution, directly minimizing sediment runoff into drinking water sources (Woznicki et al., 2023). Furthermore, sediment fingerprinting confirms that unpaved mountain access roads alter hydrology and act as dominant, disproportionate sources of fine sediment, driving bank erosion and water degradation (Nosrati & Collins, 2019). Road building in IRAs will elevate turbidity and impose steep remediation costs on downstream utilities. * Anthropogenic Wildfire Ignitions and Road Proximity The assertion that road construction aids wildfire mitigation contradicts modern fire science. Nationwide spatial analyses show human-ignited wildfires account for 84% of all U.S. wildfires, tripling fire season length and vastly expanding the "fire niche" into seasons lacking lightning ignitions (Balch et al., 2017). These ignitions cluster heavily along road corridors. Linear infrastructure overrides climatic controls, multiplying ignition frequency (Syphard et al., 2017), while expanding road networks and wildland-urban interfaces escalates wildfire risk to communities (Radeloff et al., 2018). Roadless protections prevent introducing continuous human ignition vectors into interior forests. * Ecological Integrity and Biodiversity Refugia Global mapping shows that undisturbed, roadless landscapes provide critical refugia and connectivity essential to buffer against rapid biodiversity loss (Hoffmann et al., 2024). Linear infrastructure fragments habitats, disrupts migration corridors, and facilitates invasive species colonization into interior stands (Hoffmann et al., 2024). In the Southern Appalachians, roadless tracts protect vital habitat for vulnerable taxa, including native brook trout and interior songbirds. * Fiscal Liabilities and Maintenance Backlogs The Forest Service already faces a deferred maintenance backlog exceeding several billion dollars across 370,000+ miles of system roads. Constructing new roads in steep, erosion-prone terrain creates long-term capital liabilities that the agency cannot maintain, heightening catastrophic failure risks during storm events. Conclusion The peer-reviewed record reinforces the necessity of the 2001 Roadless Rule. I urge the Forest Service to select the No-Action Alternative and retain nationwide roadless protections. Sincerely, Monet P. Alpharetta, GA References Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. https://doi.org/10.1073/pnas.1617394114 Hoffmann, M. T., et al. (2024). Mapping roadless areas in regions with contrasting human footprint. Scientific Reports, 14, 5528. https://doi.org/10.1038/s41598-024-55283-3 Nosrati, K., & Collins, A. L. (2019). Investigating the importance of recreational roads as a sediment source in a mountainous catchment. J. Hydrol., 569, 506–518. https://doi.org/10.1016/j.jhydrol.2018.12.019 Radeloff, V. C., et al. (2018). Rapid growth of the US wildland-urban interface raises wildfire risk. PNAS, 115(13), 3314–3319. https://doi.org/10.1073/pnas.1718850115 Syphard, A. D., et al. (2017). Human presence diminishes the importance of climate in driving fire activity across the United States. PNAS, 114(52), 13750–13755. https://doi.org/10.1073/pnas.1713885114 Woznicki, S. A., et al. (2023). Modeling future land cover and water quality change to support drinking water source protection. JAWRA, 59(4), 726–742. https://doi.org/10.1111/1752-1688.13109

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 oppose rescinding the 2001 Roadless Area Conservation Rule (The Rule). The justification and proposed alternative for rescinding The Rule are flawed and disregard the overwhelming support for The Rule by the public, who are the true landowners. The multi-year process that led to 2001 Roadless Rule was thorough and responsive to input, politics, the environment, and had overwhelming public support. While roadless public land continues to be a political football, the public support for roadless lands has not diminished. A current poll shows that a majority of U.S. citizens polled, 76% across all political identities, support roadless protection. The public remains quite clear about their position in favor of protecting their roadless public lands. The current justification to rescind The Rule is for fire protection via road building for fire preventive thinning and for easier access to fight fires when they ignite. However, studies, including those done by the USFS, show that road access increases chances of fire starts, and does not improve overall acreage affected by fires on roaded versus unroaded lands. Government data shows that 84% of wildfires in the U.S. between 1992 and 2012 were human-caused and more recently, 75% of fires were human-caused in a study of southern California. On USFS lands, 78% of fires started within ½ mi of a road. Roads are tied to increases in invasive plant species, such as cheat grass, that increase flammable fuels and outcompete ignition resistant native plants. Whether you apply science or common sense, roadless areas represent what is likely our best protection against ignitions on federal and adjacent private land through simple lack of human access. The data supports keeping them intact as our best safeguard against fire. Additionally, fire hazard treatment to reduce fire risk is specifically allowed for in The Rule. The USFS has already successfully thinned to reduce hazardous fuels on almost two million acres of roadless land. This represents 17% of roadless areas which is commensurate with the 19% thinning that has taken place on general forest lands. Broadcast burning accounts for about 50% of treatments in each designation of roadless and general forest land. Since fire protection/prevention treatments are already being practiced at nearly the same level in roadless as they are in general forest lands, increasing the fire risk by removing the roadless protection is illogical, environmentally and economically costly, and lacks public support. In regards to economics, as of 2024, the USFS had over 300,000 miles of road, with deferred road maintenance of over 5 million dollars and the same for other maintenance obligations such as buildings and bridges. Given the current reduction in force and budget, it’s a reasonable assumption that this obligation has not been reduced. The justification is just not there for the USFS to rescind The Rule, that has overwhelming public support, to build more roads that they can’t afford to maintain and that contradicts current evidence that more roads mean more fires. This is particularly true given that fire treatment efforts are already being successfully applied within roadless areas at basically the same rate as in general forest lands. The evidence for the irreplaceable value of roadless areas in regard to clean drinking water including municipalities, fish and wildlife habitat, and recreation are well documented and are the key values associated with roadless areas by 95% of surveyed voters. These same values are also essential to sustaining local economies that rely on recreation, hunting, nature watching, and hiking. Let’s focus on protecting these values by fortifying The Rule, not rescinding it. I visit roadless areas to recreate numerous times every year. I have worked and recreated in roadless areas in over a dozen States since childhood. Roadless areas serve as a foundation for my life and well-being and I consider it a basic right as a U.S. citizen that my government protect roadless areas as was agreed to by the 2001 Roadless Rule. References https://www.pew.org/en/research-and-analysis/articles/2026/02/18/an-update-on-the-roadless-rule) (https://www.pnas.org/doi/10.1073/pnas.1617394114, https://storymaps.arcgis.com/stories/4d9978ecdfb246e4a53b8a5681b631cb, https://research.fs.usda.gov/download/treesearch/61251.pdf, https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=National+USFS+Fire+Occurrence+Point, https://www.fs.usda.gov/about-agency/features/fire-never-starts, (https://www.fs.usda.gov/sites/default/files/fs_media/fs_document/FY24-forest-system-stats.pdf) ( https://data.fs.usda.gov/geodata/edw/datasets.php?xmlKeyword=Hazardous+Fuel+Treatment, https://storymaps.arcgis.com/stories/4d9978ecdfb246e4a53b8a5681b631cb, https://www.sciencedirect.com/science/article/abs/pii/S0143622811001731)

Repealing the Roadless Rule will not aid in wildfire mitigation. Rather, it will have devastating consequences on 44.5 million acres of American forests and the vital ecosystem services they provide. Therefore, as a concerned citizen who has worked in conservation and water resources and resident of Illinois, I oppose the recession of the Roadless Rule. Roadless Areas Protect Drinking Water DellaSalla, Karr, and Olson (2023) find that the development of roadless areas degrades water quality through sedimentation. Inventoried roadless areas (IRAs) are within the watersheds of many urban and rural municipal drinking water sources. The development of IRAs would lead to costly mass sedimentation, potentially costing municipalities millions of dollars. For example, Salem, Oregon had to spend $100 million on treatment facilities as a result of mass sedimentation due to logging in its watershed. Talty et al. (2020) have found that there are 10,929 HUC-12 watersheds wholly or partially contained within IRAs that have at least some of their area within a drinking water protection area. These provide drinking water to over 48 millions people. Keeping these IRAs roadless is essential to maintaining drinking water quality for millions of people. Developing Roadless Areas is Detrimental to Fire Mitigation Contrary to the justification provided for repealing the Roadless Rule Act, studies indicate that the development of roads in IRAs would be detrimental to fire mitigation efforts. In Fire Ecology, Aplet, Hartger, and Dietz (2026) find that IRAs had a significantly smaller wildfire-ignition density than lands within 50 m of roads, concluding that “…results suggest that building roads into roadless areas is likely to result in more fires.” Additionally, Balch et al. (2017) find that human-started wildfires make up at least 84% of wildfire and about half of total areas burned. They state that “ignitions caused by human activities are a substantial driver of overall fire risk to ecosystems and economies. Actions to raise awareness and increase management in regions prone to human-started wildfires should be a focus of United States policy to reduce fire risk and associated hazards.” Thus, repealing the Roadless Rule Act will not meaningfully assist in fire mitigation efforts and in fact may increase wildfire risks. Roadless Areas Promote Biodiversity According to Loucks et al. (2003), “77% of inventoried roadless areas have the potential to conserve threatened, endangered, or imperiled species.” IRAs provide vital, undisturbed habitat for America’s wildlife that faces increasing threats of habitat fragmentation and destruction. More than 80% of American mammal and reptile species and 90% of American bird, amphibian, and fish species can be found in IRAs, including 1400 species designated threatened or endangered by the Endangered Species Act. IRAs are an essential part of the conservation of American wildlife. In my home state of Illinois, IRAs such as Eagle Creek provide irreplaceable habit for a variety of species. The intact canopy of IRAs provides temperature moderation that helps support whooping cranes (Grus americana). Intact forests that maintain cool microclimates and preserve hydrologic function also create habitat for Mead’s milkweed (Asclepias meadii). This undisturbed Southern Interior Mixed Hardwood Forest also supports species including French's shootingstar (Primula frenchii), gray myotis (Myotis grisescens), and tricolored bat (Perimyotis subflavus). The habitat of these species and more would be jeopardized by the recession of the Roadless Rule. The loss of these habitats will have negative effects on Illinois wildlife, recreation, tourism, and more. The Roadless Rule is vital towards protecting wildlife habitat and protecting drinking water and should not be repealed. Citations: Dominick A. DellaSala, James R. Karr & David M. Olson (2011) Roadless areas and clean water, Journal of Soil and Water Conservation, 66:3, 78A-84A, http://doi.org/10.2489/jswc.66.3.78A 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 ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 J.K. Balch, B.A. Bradley, J.T. Abatzoglou, R.C. Nagy, E.J. Fusco, & A.L. Mahood, Human-started wildfires expand the fire niche across the United States, Proc. Natl. Acad. Sci. U.S.A. 114 (11) 2946-2951,https://doi.org/10.1073/pnas.1617394114 (2017). Loucks, C., N. Brown, A. Loucks, and K. Cesareo. 2003. USDA Forest Service roadless areas: potential biodiversity conservation reserves. Conservation Ecology 7(2): 5. [online] URL: http://www.consecol.org/vol7/iss2/art5/ Talty MJ, Mott Lacroix K, Aplet GH, Belote RT. Conservation value of national forest roadless areas. Conservation Science and Practice. 2020; 2:e288. https://doi.org/10.1111/csp2.288