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To the Roadless Rule Rulemaking Team:Edit salutation I am writing as a naturalist and concerned citizen opposing the rescission of the Roadless Rule. The proposal would destroy the places and wildlife that I love. I am concerned about how it would affect the Chattahoochee National Forest, a place I go for peace, recreation, and wildlife appreciation. Boggs Creek in the Chattahoochee National Forest protects the headwaters of Dicks Creek and Cowrock Creek, which form the foundation of a cold-water stream network that supports species dependent on stable, unwarmed water. The hellbender (*Cryptobranchus alleganiensis*, near threatened, IUCN), a fully aquatic salamander that requires high dissolved oxygen and temperatures below 74°F, depends on the riparian shade and groundwater inputs that an intact, roadless headwater forest provides. The seepage salamander (*Desmognathus aeneus*, near threatened, IUCN) and Chattahoochee slimy salamander (*Plethodon chattahoochee*, imperiled, IUCN) occupy the saturated seepage zones and riparian margins of these headwater systems, where they are sensitive to both temperature fluctuation and hydrological disruption. Maintaining the roadless condition preserves the forest canopy and soil structure that regulate streamflow and temperature across the entire downstream drainage. Boggs Creek harbors multiple rare plant species adapted to the specific microclimates of Southern Appalachian cove forests and seepage zones: small whorled pogonia (*Isotria medeoloides*, federally threatened), mountain sweet pepperbush (*Clethra acuminata*, apparently secure, IUCN), mountain dwarf-dandelion (*Krigia montana*, vulnerable, IUCN), jewelled wakerobin (*Trillium simile*, vulnerable, IUCN), and mountain meadow-rue (*Thalictrum clavatum*, apparently secure, IUCN). These species occupy narrow ecological niches—seepage slopes, cove bottoms, and specific soil and moisture conditions—that are vulnerable to disturbance and slow to recover. The roadless condition protects the hydrological stability and undisturbed soil structure these plants require; once disrupted, the recovery of rare plant populations can take decades or longer, if restoration is possible at all.Edit personal connection We are already watching the decline of too many beloved species. The proposed rescission is a bad idea unsupported by science that would exacerbate and accelerate that loss. It will increase the introduction and spread of invasive species. It will increase erosion. It will negatively impact water quality. It will cause destruction in one of the things that most makes America great --- our wild and scenic spaces. I see no way that it benefits those of us who enjoy or live near the forests, only irreparable, irreversible loss.Edit what you lose Roadless areas buffer and connect existing protected lands. Roadless areas are directly adjacent to protected areas on 58 percent of their land, expanding the six largest core protected areas in the lower 48 by an average of 25 percent. They also reduce isolation between protected areas and add representation of underprotected ecosystem types — including temperate grasslands and cool temperate forests — that the existing protected-area system does not cover well (Talty et al. 2020). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Please accept my entire formal comment attached as FS-2025-0001-223869_RLC-20261007-I1RDZT.pdf I'm filing this comment because I think the rescission is wrong, and I want that on record. Please keep the Roadless Rule in place. Respectfully, Sarah E. Kelsey

Dear Secretary and Chief: As someone who loves her time in our National Forests and understands their value, I'm deeply concerned about how these forests will be degraded if there is a reversal of the 2001 Roadless Rule. If this rule is rescinded, I will lose the peaceful, quiet, and serene experience that I have had during backpacking trips in this part of the forest. More importantly, the flora and fauna that is native to the area will be adversely affected. Regarding the 09159 - Thornapple in the Chequamegon-Nicolet National Forest, Wisconsin: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the 09159 - Thornapple, Chequamegon-Nicolet 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 think that rescinding the Roadless Rule is a careless and irresponsible proposal and will have negative lasting effects on this area. Thank you, Carol Gorzek

Dear Secretary: For someone who has spent enough time outdoors to know what happens after road access opens in an area, the 2001 Rule reads as a hard-won, practically-grounded protection — not a regulatory formality. Regarding the 09186 - Shelp Lake in the Chequamegon-Nicolet National Forest, Wisconsin: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the 09186 - Shelp Lake, Chequamegon-Nicolet 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. Rescission of this rule would be a major step back for our country. It is very important that we protect the last of these natural areas that we have left. Stand by the Rule. Faithfully, CommentID: RLC-20261007-VTYAA6

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

Dear Secretary Rollins and Chief Schultz: Can we be better at taking care of our stuff? Lived here and hiked all over these beautiful trails I helped my friend backpack across the Catalina mountains and have spent lots of time enjoying the beauty of this location Regarding the Catalina St. Pk. Roadless Area in the Coronado National Forest, Arizona: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the Catalina St. Pk. Roadless Area, Coronado 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. These areas allow us to preserve our forests. Extended habitat allows the ecosystem to thrive My position hasn't changed: keep the Rule. Earnestly, CommentID: RLC-20261006-DSZLXO

Dear Forest Service Leadership: I live in the Pisgah National Forest and near the Cherokee National Forest and I want these areas to remain roadless in order to protect life. My community's water comes from these drainages and our air quality is dependent upon the health of these forests. They are are living system that support our lives. They are not resources to be used or extracted. I live just down hill from Craggy Mountain and I hike in that area and all through the Pisgah Forest area. Being able to go where there are no roads, means we must walk and that means we connect with the forest, which is an essential part of being human. In addition, roads into this area will impact our water and the habitat for animals. Already human development is forcing bears into our communities where they learn to feast on human garbage and enter homes and cars. That is unfair for all. The value of a roadless area to our health and wellbeing is critical. On Craggy you get away from the sounds of traffic, the lights of the city, and the din of small engines at work. I remember camping in roadless areas where the silence at nights is filled with the sounds of nature, the stars are breathtaking, and the presence of wildlife is all around. That is precious and missing from so many people's lives. Don't take that away. Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: 4.2 - Utility & service lines drives Unknown severity impacts across Small (1-10%) scope for Bog Turtle (Glyptemys muhlenbergii, G2, T, SAT) in the Craggy Mountain IRA, Pisgah National Forest. "From a sample of 463 nests of 17 songbird species, we evaluated how landscape features (distance to forest edge, unpaved roads, and power lines) influenced daily nest survival. For all nesting species combined, distance to unpaved road was the model that most influenced daily nest survival. Numerous nest predators, including brown-headed cowbirds, mammalian mesopredators, and snakes, have been shown to preferentially occupy habitat edge over interior. Rat snakes were frequently associated with road edges, indicating that not all edges are functionally similar." — Ecology and Evolution (PMC), 2014 Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 4.2 - Utility & service lines on Bog Turtle. “In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people. — Conservation Science and Practice (Wiley), 2020 (https://doi.org/10.1111/csp2.288)” I want you to know that there is more at risk here than there is to gain. I want you to ask yourself, "who benefits from a road into a roadless area?" If the answer is people who want to make money or further extract resources from our precious and essential forests, then your answer about building roads should be NO!! Sincerely, Cheri Torres CommentID: RLC-20261006-OPEH8V

Dear Brooke L. Rollins, I am a reproductive surgeon and healthcare sustainability researcher Studies show that natural and green spaces improve the mental and physical health of those who live nearby. Having green spaces in the middle of LA improves access to those who otherwise cannot get out of the city. Repealing the rule reduces health benefits of natural spaces and exposes patients to more traffic related pollution. This increases healthcare costs for all and creates and weakened population. Regarding the Arroyo Seco in the Angeles National Forest, California: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. Watersheds with the highest ecological integrity scores tend to have high proportions of roadless or wilderness area (over 50 percent); watersheds with the lowest integrity tend to have low proportions of roadless area and high proportions of moderate-density roads (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf); Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the Arroyo Seco, Angeles 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. Your actions transfer increased health costs to other governmental agencies, for what benefit? This is a formal objection to rescission, entered for the record.

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

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

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

To the USDA Roadless Rule Rulemaking Team: As a conservationist, I track public land outcomes, not just rules. The Roadless Rule's outcomes have been good. Rescinding it ends them. Since I was a kid I’ve wanted to explore public lands which lead me to making a career out of it. I’ve seen how special these places can be for generations of people and wildlife. You can’t recreate these places once they are gone. Losing more public land protections is going to affect not just me, but future generations from being able to explore these spaces. Regarding the Williams Fork Ptarmingan Adjacent in the Arapaho & Roosevelt NFs, Colorado: Alpine Tundra Habitat for White-tailed Ptarmigan — The roadless area encompasses Rocky Mountain Alpine Tundra at elevations above 11,800 feet, providing the specialized habitat that white-tailed ptarmigan depend on year-round. Colorado populations of this species have declined significantly since the 1970s, and the area's intact alpine ecosystem—with its characteristic low-growing vegetation and minimal disturbance—represents critical refuge as climate warming pushes treeline upward and reduces available tundra. Loss of connectivity between alpine patches through habitat fragmentation would isolate remaining ptarmigan populations and accelerate local extinctions. Roadless areas fill gaps in the existing protected-area network. Adding all Inventoried Roadless Areas to the U.S. protected-area system would reduce the number of imperiled wildlife species considered "poorly represented" in protected areas by 38 species. Roadless areas particularly increase representation of underprotected ecosystem types, including temperate grasslands (+57%) and cool temperate forests (+52%) (Talty et al. 2020; Dietz et al. 2021). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288); Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943); UNKNOWN, 2021 (https://doi.org/10.1016/j.gecco.2021.e01943) Rescinding the Roadless Rule would open the Williams Fork Ptarmingan Adjacent, Arapaho & Roosevelt NFs to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Removing the protections of the Roadless Rule would be heartbreaking. The habitat and species that could be destroyed… we only have so few of these protected spaces left. Why take them away to? In 2001 the Agency Found These Prohibitions Benefited Listed Species; the Rescission Never Engages Its Own Prior Finding Both Draft Biological Assessments open with the same acknowledgment (USFWS BA p. 10; NMFS BA p. 7): "In the promulgation of the 2001 Roadless Rule, the Forest Service found that the Rule's prohibitions on road construction and timber harvest were not likely to adversely affect threatened or endangered species or adversely modify designated or critical habitat; were not likely to jeopardize proposed species or adversely modify proposed critical habitat; and may beneficially affect threatened, endangered, and proposed species and critical habitat… The Services concurred with the determination." The agency thus stands on a concurred-in finding that the prohibitions it now proposes to delete benefit listed species — and the current assessments anticipate widespread adverse effects from deleting them. When an agency reverses course, it "must show that there are good reasons for the new policy," FCC v. Fox Television Stations, 556 U.S. 502, 515 (2009), and where the prior policy rested on factual findings, it may not simply disregard them — the principle applied to this very rule's Tongass history in Organized Village of Kake v. USDA, 795 F.3d 956, 966–68 (9th Cir. 2015) (en banc). Neither the DEIS nor the assessments explain what changed in the biology. I request the FEIS directly address the 2001 beneficial-effect finding and state the factual basis for departing from it. Keep the protections, please. With thanks, Kyla Nurkowski

Dear Chief Tom Schultz, My husband's grandfather was a guide on Mt. Rainier, and our extended family visits the areas he loved every summer. We camp at White River and Ohanapecosh, and walk his favorite hikes in rememberance of him. We've encountered many bears and marmots, and we've noted the change in the alpine meadows flowers. The Nisqually glacier is drastically diminished from what it was 30 years ago. I live near Mount Baker-Snoqualmie Forest in Whatcom County, Washington. 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. Headwater Cold-Water Refuge for Threatened Salmonids — The Upper Middle Fork Nooksack River and its tributaries (Clearwater Creek, Rocky Creek, Ridley Creek, and others) originate in Mt. Baker West's subalpine terrain, where glacial meltwater and high elevation maintain the cold water temperatures essential for bull trout (*Salvelinus confluentus*, federally threatened) and Dolly Varden (*Salvelinus malma*, proposed threatened under similarity of appearance). The Nooksack system currently experiences 27% lower August streamflow than natural conditions due to historical timber harvesting and glacial retreat. This roadless area's intact forest canopy and undisturbed riparian zones preserve the remaining cold-water pulse that these species depend on for spawning and rearing—a function that becomes increasingly critical as climate-driven warming reduces glacial contribution to late-summer flows. “Comprehensive assessment of the conservation value of all 240,000 km² of Inventoried Roadless Areas. The study finds IRAs would expand the U.S. protected-area system by 27% while disproportionately buffering its largest cores: adjacent IRAs add +29% to Greater Yellowstone, +38% to Central Idaho, +32% to the Bob Marshall, and +31% to the North Cascades. 96% of IRAs are wilder than the median of the contiguous U.S.; 93% lie within 10 km of an existing protected area, providing critical connectivity for climate-driven range shifts. 58% of the watersheds intersecting National Forest System lands supply drinking water to over 48 million people, and adding IRAs to the protected network would increase well-protected drinking-water watersheds by 60%. 74% of all Forest Service wilderness designated since 2000 was first an IRA — the rule is the proven pipeline for permanent congressional protection. The authors warn that because IRAs are an administrative designation, they remain vulnerable to degazettement. — Talty et al., 2020 (https://doi.org/10.1111/csp2.288)” These are public lands and making a radical change should include a serious public process should be sure to include the public. USFS's disclosures on roads and fire undermines the argument that building roads will protect forests. Very truly yours, CommentID: RLC-20260910-N4ESJF

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

Dear Forest Service Leadership: As someone who frequently hikes and recreates in the White Mountain National Forest, and visits other National Forests when possible, I am very concerned about what rescinding the 2001 Roadless Rule would do to our forests. I love these lands and have seen their value for our wildlife, our water, and our people. Allowing these forests to lost their protections would jepordize the very few places people can go to truly experience untouched, pure wilderness while also putting wildlife at risk. The bobcats, bears, deer, red squirrels and birds that I've seen roam these forests would be greatly harmed by road units and the logging threat those roads create. The cool mountain streams with clean drinking water stay that way because the area around them is unroaded. These forests allow me to breathe and reset when I visit them because they are a step away from civilization; roads ruin that too. Regarding the Presidential - Dry River Ext in the White Mountain National Forest, New Hampshire: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Roadless areas buffer and connect existing protected lands. Roadless areas are directly adjacent to protected areas on 58 percent of their land. They also reduce isolation between protected areas and add representation of underprotected ecosystem types — including cool temperate forests — that the existing protected-area system does not cover well (Talty et al. 2020). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the Presidential - Dry River Ext, White Mountain 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. Losing federal protection for our roadless areas means that crucial habitats are at risk of harmful changes. Our Alpine Zones in the White Mountains are precious. The roadless areas surrounding these summits help protect everything that supports the fragile wildlife in these mountains. The separation from urban life that roadless areas create protect the flora, fauna, and wildlife that occupies them. Forest Service Chief Tom Schultz testified to the Senate that 24.5 million acres of inventoried roadless areas are within one mile of the Wildland-Urban Interface (WUI)—calling it "our primary concern." A GIS analysis by The Wilderness Society using the Forest Service's own data found the actual figure is just 2.8 million acres—a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not 42% as Schultz claimed. The administration has 23.3 million acres of non-roadless forest land already available near the WUI for fuel reduction—without ever touching a roadless area. Moreover, 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. 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. Ultimately, rescinding the 2001 Roadless Rule puts our National Forests at risk of habitat destruction, obstructing wildlife corridors, and tainting clean waters necessary for many communities to maintain their drinking water supply. File me under opposed. ~Leandra CommentID: RLC-20260909-ARY9GR

Dear Secretary Rollins and Chief Schultz: As an outdoor enthusiast, I am compelled to note for the record that the 2001 Roadless Area Conservation Rule was not a regulatory convenience — it was the product of a sustained and voluminous public process that established, with considerable specificity, the breadth of public interest in the continued protection of these lands. If this rule is rescinded I will miss the wildlife sightings of increasingly rare species that need their own space to thrive. Regarding the Bridger in the Gallatin National Forest, Montana: Cold-Water Stream Integrity — The Bridger Range generates the headwaters of numerous streams draining both flanks — Smith Creek, Bostwick Creek, Brackett Creek, North Cottonwood Creek, Lyman Creek, and Sypes Creek among them. These channels originate in dense Northern Rockies Subalpine Woodland and Rocky Mountain Wet Subalpine Spruce-Fir Forest, which maintain riparian shading that keeps water temperatures cold enough for westslope cutthroat trout (*Oncorhynchus lewisi*). Roadless conditions preserve the intact forest buffer that prevents sediment loading in spawning reaches and keeps dissolved oxygen levels stable through summer low-flow periods. Roadless areas fill gaps in the existing protected-area network. Adding all Inventoried Roadless Areas to the U.S. protected-area system would reduce the number of imperiled wildlife species considered "poorly represented" in protected areas by 38 species. Roadless areas particularly increase representation of underprotected ecosystem types, including temperate grasslands (+57%) and cool temperate forests (+52%) (Talty et al. 2020; Dietz et al. 2021). — Talty et al., 2020 (https://doi.org/10.1111/csp2.288); Belote, 2020 (https://doi.org/10.1111/csp2.288); Dietz et al., 2021 (https://doi.org/10.1016/j.gecco.2021.e01943); UNKNOWN, 2021 (https://doi.org/10.1016/j.gecco.2021.e01943) Rescinding the Roadless Rule would open the Bridger, Gallatin National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The roadless areas provide undisturbed habitat for Montana’s wild animals. I believe many species rely upon this in order to thrive. Keep the forests as they are. Earnestly, Dennis Ochs CommentID: RLC-20260907-7FM2X2

**Public Comment on Docket FS-2025-0001 — In Support of the Roadless Rule** I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to maintain these important protections. As a Montana resident, I value our public lands not only for their incredible scenery, but for everything they provide to our communities. Roadless forests are some of the last places where people can experience truly wild landscapes - to hike, backpack, camp, hunt, fish, raft, observe wildlife, and enjoy the peace and solitude that make Montana special. **It is especially important that we protect these areas from logging and road construction.** Roadless forests should not be viewed simply as another source of timber that can be harvested when convenient. Once roads are built and trees are removed from these intact landscapes, the character of those places can be permanently changed. Roads can fragment habitat, increase human disturbance, contribute to erosion, and affect watersheds. Scientific research does not support the argument that opening roadless areas to additional roads and logging is necessary to improve forest health or reduce wildfire risk. A long-term analysis of Forest Service monitoring data found that forests inside and outside roadless areas burned at similar rates and concluded that the evidence did not support claims that eliminating road protections would improve forest health. The study also found that non-native plants were twice as common within 500 feet of roads. **[1]** There are already millions of acres of national forest where timber management can occur. We do not need to sacrifice some of our most intact and remote forests to provide additional logging opportunities. Roadless areas provide something that managed and developed forests cannot: large, relatively undisturbed landscapes where natural ecological processes can continue and where people can experience wild public lands. Research has also demonstrated the exceptional conservation value of America's roadless areas. These lands help protect watersheds and drinking-water sources, provide important wildlife habitat, contribute to carbon storage, and connect existing protected areas. **[2]** Once these intact landscapes are fragmented by roads and logging, those ecological and recreational values are much more difficult to restore. These areas are essential for clean water, wildlife habitat, biodiversity, and ecological connectivity. Montana's national forests are home to some of the state's most important fish and wildlife habitat, and protecting intact forests benefits both wildlife and the people who depend on healthy watersheds. I am particularly concerned about the implications for Montana's national forests and the places that make this state unique. From the Beartooths and Absaroka Range to the Bitterroot, Flathead, and other national forests across Montana, roadless lands provide opportunities for hiking, camping, rafting, hunting, fishing, and experiencing wild landscapes that become increasingly rare as development expands. I also do not believe that rescinding the Roadless Rule and opening these areas to additional logging and road construction is the appropriate answer to wildfire and forest-health concerns. We should address legitimate forest-management needs without eliminating protections for some of our country's remaining intact roadless landscapes. Public lands belong to all Americans, including future generations. We have a responsibility to leave future Montanans forests where they can still hike, camp, fish, raft, hunt, and experience the solitude of places that have not been fragmented by roads and logging. **Please withdraw the proposal to rescind the 2001 Roadless Area Conservation Rule and retain strong protections against road construction and commercial timber harvest in Inventoried Roadless Areas.** Montana's roadless forests are worth more standing than they are as timber. Once these places are logged and roads are built into them, we cannot simply put them back the way they were. Thank you for considering my comment. Sources; **[1]** Healey, S. P. (2020). *Long-term forest health implications of roadlessness.* **Environmental Research Letters, 15**, 104023. [https://doi.org/10.1088/1748-9326/aba031](https://doi.org/10.1088/1748-9326/aba031) **[2]** Ibisch, P. L., et al. (2020). *The conservation value of U.S. roadless areas.* **Conservation Science and Practice.** [https://doi.org/10.1111/csp2.288](https://doi.org/10.1111/csp2.288)

Dear Secretary Brooke L. Rollins and the USDA: For someone who has spent thousands of hours in roadless country, I don't need a policy brief to understand what could and would be lost here — I've been in these places more than most, and I know what makes them what they are. Roadless regions are bastions of the natural world; regions in which we can exist, as closely as possible, outside of the bustle and noise of cities. These places are rare and sparse - I have to travel more than an hour, frequently multiple hours, to reach the nearest ones. And yet I do so, frequently, because I treasure the beauty, recreation, and history that these areas maintain. The Little Blakely region of Arkansas stands for much more than what I can share in a single comment; thousands of people have traveled themselves in these undisturbed lands, not to mention the unique and threatened creatures that call this place home. There is too much that stands to be lost.

 ___ Regarding the Little Blakely in the Ouachita National Forest, Arkansas: By limiting vegetation analysis to Ozark-Ouachita Shortleaf Pine-Oak Forest in the Little Blakely IRA, the DEIS would omit Ozark-Ouachita Shortleaf Pine - Black Oak Woodland from its impact assessment entirely. The presence of Black Hickory, shortleaf pine, and sparkleberry in Ouachita National Forest confirms this Vulnerable community occurs here; the DEIS must evaluate how road construction affects its characteristic floristic composition, microsite requirements, and long-term viability. The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations, mining, and oil-and-gas drilling. “Species-level modeling shows 57% of vulnerable U.S. wildlife species have suitable habitat in roadless areas. Adding unprotected roadless areas to protected areas markedly reduces poorly-represented species of conservation concern. — Research - Wildlife Habitat” “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. — Research - Forest Fragmentation” “Road networks cause habitat fragmentation and create edges with high resource availability that can act as important channels for the spread of invasive alien plants in various habitats, including nature reserves. In natural secondary forests, species richness, density and the proportion of invasive species significantly decreased with distance from the road; natural secondary forests contained only 5 invasive versus 67 native species, yet invasive species were concentrated near road edges. Human-induced changes to environmental conditions along roadsides increase soil moisture, soil disturbance, soil nutrients, exposure to sun and soil temperature, all of which are factors known to promote plant invasions. — Diversity and Distributions / Wiley Online Library, 2025 (https://doi.org/10.1111/ddi.70002)” “Inventoried Roadless Areas (IRAs) increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. IRAs protect watersheds that deliver drinking water to over 48 million people. Adding IRAs to the protected network would increase representation of Cool Temperate Forest and Woodland by 52.2%, Temperate Grassland and Shrubland by 57.4%, and Mediterranean Scrub and Grassland by 35.5%. Only 25% (median 17.9%) of the current extent of each vegetation formation is represented in the protected area system. — Conservation Science and Practice / Wiley Online Library, 2020 (https://doi.org/10.1111/csp2.288)” Rescission of the 2001 Rule is not in the public interest; the Department should decline to proceed. Earnestly, Travis Howk

To the Roadless Rule Rulemaking Docket: As someone who has come to understand public land through years of actually being on it, I'd say the 2001 Rule is one of the policies that's done what it said it would do. Linville Gorge is a beautiful area that brings people from all over to recreate and explore. I have enjoyed hiking, fishing, and rock climbing in this area and in many other spots in Western North Carolina my whole life. This land is important to me. Altering this land would hurt the people who spend time there like I do and potential tourism in the area. One visit made that connection concrete. My first time in Linville Gorge experiencing the wilderness was breathtaking, the views and the river blew me away. Spence Ridge and Conley Cove trails are amazing resources to have access to. The Department should find in what precedes this section a demonstration that the Rule operates in practice as its framers intended: as a durable safeguard for landscapes on which the public actively depends. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: The threat mechanism classified as 7.1 - Fire & fire suppression (IUCN-CMP 7.1) is actively degrading habitat for Monarch (Danaus plexippus, G4) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, at Moderate or 11-30% pop. decline severity across Restricted (11-30%) scope. The intact, unroaded condition of Linville Gorge Addition is the functional mechanism that currently limits 7.1 - Fire & fire suppression to its assessed severity and scope. Road construction removes this constraint and permits escalation. The absence of site-specific analysis for Monarch (Danaus plexippus) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, constitutes a gap in the administrative record that exposes the final decision to legal challenge. The DEIS must evaluate 7.1 - Fire & fire suppression at the documented severity and scope. "In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people." — Conservation Science and Practice (Wiley), 2020 “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. Inadequately constructed forest roads can cause severe environmental impacts including road surface erosion and sediment yield, pollution of off-site waters, slope failures and mass movement, direct loss of habitat (by the conversion of the original land cover into an artificial surface) and indirect loss of habitat (by the fragmentation of an ecosystem into smaller and more isolated patches). — Iranian Journal of Environmental Health Science & Engineering (PMC), 2013 (https://doi.org/10.1186/1735-2746-10-23)” “In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people. — Conservation Science and Practice (Wiley), 2020 (https://doi.org/10.1111/csp2.288)” I urge the Secretary to decline this rescission and preserve the existing roadless area protections. With best wishes, CommentID: RLC-20260830-P5HY0E

To the Roadless Rule Rulemaking Team: The federal climate record is, in my judgment as a citizen, the controlling consideration in the present rulemaking, and against that record the proposed rescission of the 2001 Rule is not supportable. When I think about wildfire and the forests I care about, Coconino Rim comes to mind. My husband and I visited this area in 2018, and enjoyed our unplugged time here as a sanctuary. Being in nature is critical to our (and many others) physical and mental health, and we do not want these lands impacted, destroyed, or taken away. The Department is respectfully requested to treat that account as what it is — a demonstration of the concrete, non-speculative harm that rescission of the Roadless Area Conservation Rule would produce. Opening roadless lands to logging is NOT a strategy for reducing fire danger. In fact, road building and vegetation management reshape fire regimes by changing ignition sources, fuel loads, and landscape-scale fire behavior. Roads are where most wildfires start. A 2026 study covering 30 years of wildfire data across the entire National Forest System found that wildfire ignition density within 50 meters of roads was nearly four times higher than the average for non-wilderness, non-roadless forest lands. Wilderness areas and Inventoried Roadless Areas had the lowest ignition densities of any category studied (Aplet et al. 2026). — Gregory H. Aplet, Phil Hartger, Matthew S. Dietz, 2026 · Fire Ecology (https://doi.org/10.1186/s42408-026-00450-2) Roadless areas maintain more natural fire regimes. Because roadless areas lack the access that enables intensive suppression and the traffic that brings human ignitions, they retain fire patterns closer to what their ecosystems evolved with. Adding roads changes both ends of the equation at once (Aplet et al. 2026; USDA Forest Service 2001). — Gregory H. Aplet, Phil Hartger, Matthew S. Dietz, 2026 · Fire Ecology (https://doi.org/10.1186/s42408-026-00450-2) “In 2001, the Roadless Area Conservation Rule prohibited road construction and timber harvest in 240,000 km² of inventoried roadless areas (IRAs) located on United States Department of Agriculture Forest Service lands. Many IRAs are among the most wild, undeveloped areas both in the nation and within their respective states. IRAs increase the size of—and reduce isolation between—protected areas, likely buffering them from external stressors. In some places, IRAs protect watersheds that deliver drinking water to hundreds of thousands of people. — Conservation Science and Practice (Wiley), 2020 (https://doi.org/10.1111/csp2.288)” This comment is filed in the formal record in opposition to the proposed rescission of the Roadless Area Conservation Rule. Best regards, Aubrey CommentID: RLC-20260825-XVLHWB

Dear Mr. Schultz: As a citizen for whom the climate trajectory is not background but foreground, I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, the record for which establishes contributions to forest carbon and watershed integrity that the Department's stated rationale does not adequately engage. I have been thankful for roadless areas on our map since I first learned they existed almost 20 years ago. Not only is it advantageous from a logistical, environment, and climate standpoint, it is beneficial from a mental and quality of life standpoint as well. The lands that sustain that connection are roadless because deliberate policy has kept them so; the proposal before the Department would undo that policy without demonstrating that the public interest is better served by doing so. Regarding the Farles Prairie in the Ocala National Forest, Florida: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Roadless areas buffer and connect existing protected lands. Roadless areas are directly adjacent to protected areas on 58 percent of their land, expanding the six largest core protected areas in the lower 48 by an average of 25 percent. They also reduce isolation between protected areas and add representation of underprotected ecosystem types — including temperate grasslands and cool temperate forests — that the existing protected-area system does not cover well (Talty et al. 2020). — McKinley J. Talty, Kelly Mott Lacroix, Gregory H. Aplet, R. Travis Belote, 2020 · Conservation Science and Practice (https://doi.org/10.1111/csp2.288) Rescinding the Roadless Rule would open the Farles Prairie, Ocala 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 think that rolling back the 2001 Rule is shortsighted and selfish, not only for other species but for the future of humanity. We need to think about who and what will come next, instead we prioritize ego and perceived short-term benefits. It is already a struggle to keep ecosystems functioning well, repealing the 2001 Rule will make that mission even more difficult to obtain. And for what? Humans aren’t meant to go everywhere on this earth. Let her keep her secrets. Let her function in the natural way she figured out, without human interference. We have enough roads in this country. Why don’t we go use more on maintaining existing roads than on building frivolous new ones. The Rule's durability across administrations of both parties is evidence that it reflects sound, enduring policy; rescission is not warranted. Yours truly, CommentID: RLC-20260824-JBCEXB