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I am a Park Ranger in the state of Maine. One of my favorite pastimes is exploring the Maine woods through solitary hiking. The USDA’s own draft environmental impact statement found that repealing the rule would cause economic and environmental harm to undeveloped forests, wildlife, and water resources, while failing to mitigate wildfire risk (https://www.pew.org/en/research-and-analysis/articles/2026/10/05/us-department-of-agriculture-proposes-eliminating-the-roadless-rule). The construction of roads is not a singular threat, but rather, the gateway for the majority of threats impacting imperiled species and ecosystems throughout the country. Construction of roads and other associated development fragment habitats and disrupt the natural balance of ecosystems, meaning the ecological impact extends far beyond the road itself. Repealing the Roadless Rule would negatively impact critical watersheds, native flora and fauna species, impact on recreation, and wildfire risk. Forests, specifically, old growth forests supply drinking water to approximately 150 million Americans. These intact forests are the country’s largest filtration system and they filter water naturally, for free. Road construction and logging would undoubtedly send sediment into waterways which would degrade the water quality. Additionally, an increase in fine sediments can cause a degradation of spawning grounds (Hauer et al., 2018 (https://doi.org/10.1007/978-3-319-73250-3_8)). Other issues include the disturbance of natural flows and aquatic life. Many species, such as salmon, trout, and elk depend on undammed and unlogged streams. Approximately, 24% of flora and fauna species would be threatened by pollution and habitat fragmentation due to the construction of roads or logging operations near watersheds. (Sayer et al, 2025). Wildlife and habitat would suffer substantially if the Roadless Rule was rescinded. For example, 327 protected species and 71 critical habitats would be adversely affected, according to the draft environmental impact statement (DEIS). The Caribou - Speckled Extension in Maine is home to the federally endangered northern long-eared bat (Myotis septentrionalis) who relies on the forest canopy to hunt insects and roosts in dead trees or bark crevices during the day. The elusive Canada lynx (Lynx canadensis) can also be found in this roadless region hunting snowshoe hare. The monarch butterfly (Danaus plexippus) passes through this part of Maine during its migration while the eastern whip-poor-will (Antrostomus vociferus), a near threatened species, can be heard calling at night. This region is also a perfect habitat for federally threatened small whorled pogonia (Isotria medeoloides) an orchid that grows in acidic humus of hemlock dominated forests. As an experienced gardener/landscaper, I understand the complexity of plants needing proper growing conditions to survive versus thrive. To aid conservation efforts in the state of Maine, I have transplanted native plants from areas of plenty to areas lacking. Sometimes the plants will transplant well and other times they will struggle. Many plants require a specific soil pH in order to survive and a slight shift in pH would harm the plant. Opening up roadless areas would change the soil pH and therefore negatively affect the growing conditions of many native plants, which many species rely on. We would see a negative chain reaction due to a potential rescission. DEIS noted that road construction and timber harvest could harm terrestrial and aquatic wildlife through habitat loss and fragmentation, the introduction and spread of invasive species, barriers to wildlife movement, increase in direct mortality from wildlife-vehicle collisions, and a decline in species abundance. As a Park Ranger, I have experienced many of these concerns while exploring the Maine woods and during the mundane routines of life. Roads serve as dispersal corridors where invasive plant species are spread by humans, vehicles and animals. The roads that have cut through forested land have led to an increase in invasive plant species in both terrestrial and aquatic ecosystems. One such plant is known by the common name bittersweet (Celastrus scandens). It is considered extremely invasive in the state of Maine. It is common to find it alongside roads and power lines. Bittersweet prefers loose disturbed soil. Research indicates that invasive plant species tend to decrease with the distance from roads, whereas native species show variable distribution patterns near roads (Dai et al., 2025 (https://doi.org/10.1111/ddi.70002)).

As a Park Ranger, I have experienced many of these concerns while exploring the Maine woods and during the mundane routines of life. Roads serve as dispersal corridors where invasive plant species are spread by humans, vehicles and animals. The roads that have cut through forested land have led to an increase in invasive plant species in both terrestrial and aquatic ecosystems. One such plant is known by the common name bittersweet (Celastrus scandens). It is considered extremely invasive in the state of Maine. It is common to find it alongside roads and power lines. Bittersweet prefers loose disturbed soil. Research indicates that invasive plant species tend to decrease with the distance from roads, whereas native species show variable distribution patterns near roads (Dai et al., 2025 (https://doi.org/10.1111/ddi.70002)). Repealing the Roadless Rule would undoubtedly increase the spread of this invasive plant. Over the past two years I watched Maine DOT rebuild a section of Rt. 1 going through midcoast Maine. Many acres of habitat was destroyed to rebuild a culvert and install a new bridge. It was once a relatively easy area for wildlife movement and now it is a steep incline on both sides of the road. Road construction should keep wildlife in mind but instead it is creating more barriers for them to navigate. Wildlife across the country takes part in seasonal migration. Roadless areas allow these species to move freely without hindrance whereas wildlife in other regions face habitat loss, fragmentation, or the threat of wildlife-vehicle collisions. Wildlife-vehicle collisions are far too common. My heart breaks every time I see roadkill. I have seen hundreds of roadkill over the past few years in the region where I work. As someone who loves birds, I am deeply saddened when I see that an owl or another raptor has been struck. Usually, those predators were struck while hunting and didn’t see the vehicle until it was too late. Like most species, road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations (Beebee, 2013 (https://doi.org/10.1111/cobi.12063)). On warm rainy spring nights I would witness hundreds of frogs, salamanders, and other critters migrating to mating grounds. Unfortunately, most of them were hit by cars and did not arrive at their destination. One of the main negative effects of roads on various species is wildlife-vehicle collisions (Grilo et al., 2024 (https://doi.org/10.1038/s41597-024-04207-x)). Wildlife-vehicle collisions are already too common and repealing the Roadless Rule would create more of these unfortunate occurrences. As an avid outdoor enthusiast, I find great joy in solitary hikes where you cannot hear anything but the sounds of nature. The rescission of the Roadless Rule would put that type of recreation in jeopardy. National forests provide many types of recreation and the regions with roadless areas account for 76% of annual visits to the National Forest System. Repealing the Roadless Rule would cause hiking, fishing, hunting, and backcountry camping to decline as these types of recreation are considered more quiet and dispersed (https://www.pew.org/en/research-and-analysis/articles/2026/10/05/us-department-of-agriculture-proposes-eliminating-the-roadless-rule). Opportunities for solitude and primitive non-motorized experiences would be negatively impacted by the noise and disturbance of vehicles. Noise pollution from logging operations or road construction and visual impacts to landscapes are a concern for many Americans who value quiet recreation. (USDA Forest Service, Six Rivers National Forest, Gasquet Ranger District, Dece (https://www.nfwf.org/sites/default/files/norcal/Documents/SRNFEIS.pdf)). The Roadless Rule protects many cherished backcountry recreation areas. These forests provide us with clean air and water, sequester carbon, and are the backbone of a $1.3 trillion outdoor recreation economy that supports 5.2 million jobs. This rescission puts 45 million acres of national forest at risk (Alliance, 2026 (https://www.outdooralliance.org/roadless)). Nearly 80,000 miles, about 59%, of National Forest System Trails valued by outdoor enthusiasts across the country are at risk right now (Woodard et al., 2025 (https://www.nrdc.org/media/what-usdas-emergency-logging-map-gets-dangerously-wrong)). In conclusion, the Roadless Rule was brilliantly created 25 years ago and has proven to be effective at prioritizing conservation efforts while also providing a recreational outlet for the nation as well as aided in wildfire mitigation efforts. The Roadless Rule is not the enemy. Allowing the Roadless Rule to be rescinded would have catastrophic consequences and irreparable damage. Millions of Americans are in favor of the Roadless Rule. Please reject full repeal and reject the removal of any acreage from roadless protections.

To Whom It May Concern at the U.S. Forest Service: This protection is about the long-term and shouldn't be changed. When protecting our remaining wilderness areas, decisions shouldn't be short-sighted but holistic and applicable to entire regions. Removing this protection carves into continuous wilderness areas, creating piecemeal ecosystems. The rule should remain as it is with no exceptions, for the long term. I've lived in this region for over 30 years and continue to explore and enjoy our back-country's outdoor spaces. The wilderness is a part of why we Pacific Northwesterners call this place home. It is a sanctuary which should be admired and honored. Through photography and stories I share my experiences with those who are not able to experience this majesty. I recommend those trying to change these protections go and experience them as well. Only then will you understand the value. Somewhere around 4,000 vertical feet up from civilization is a wondrous Japanese-garden-like plateau of alpine lakes and fragile landscape that exists because we have these protections. I have spent time in this region with nothing but a backpack, my thoughts and a camera, sharing it with like-minded people. From sunrises and sunsets to chance encounters with mountain ptarmigans, pikas and marmots, over countless miles of trails and on the edges of still and calming waters, I sponge it all up. Opportunities to recharge from the business of daily city life come from these locations. The quiet and calm we experience from this, our Pacific Northwest backyard is invaluable. Removing our opportunities for these experiences removes our way of life. Regarding the Alpine Lakes Adj. in the Wenatchee National Forest, Washington: Within Wenatchee National Forest, the Alpine Lakes Adj. IRA provides habitat for Whitebark Pine (Pinus albicaulis, G3), a species subject to 7.1 - Fire & fire suppression — a threat assessed at Moderate or 11-30% pop. decline severity affecting Large (31-70%) of the population. Road construction in Alpine Lakes Adj. introduces sediment, alters hydrology, and delivers chemical contaminants to adjacent habitats — the direct physical drivers of 7.1 - Fire & fire suppression. NEPA requires the agency to take a hard look at the effects of rescission on Whitebark Pine (Pinus albicaulis) in the Alpine Lakes Adj. IRA. The DEIS fails this standard without site-specific analysis of 7.1 - Fire & fire suppression at the severity and scope documented by NatureServe. "Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 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. “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” What's protected now won't be recoverable later. Keep the Rule. Gratefully, CommentID: RLC-20261006-WQZSFQ

Dear Ms. Rollins, As a marine environmental researcher, I have studied how habitat connectivity sustains populations and ecosystems. The same principle applies on land, and it is the reason I oppose rescinding the 2001 Roadless Rule and urge the agency to select Alternative 1, No Action. As a Marylander, the closest national forest is the George Washington National Forest in Virginia and West Virginia. Connectivity is very important within this forest, as it allows for genetic exchange and therefore healthier populations, demographic rescue, which allows recolonization after local disturbance; and seasonal migration to reach dispersed resources. 19 species rely on this connection, include the American Chestnut (G3), which once dominated northeastern forests before being practically wiped out in the first half of the 20th century (Dalgleish & Swihart 2011, https://doi.org/10.1111/j.1526-100X.2011.00795.x), the Rusty-patched Bumble Bee (G2), the tricolored bat (G3), and the Virginia big-eared bat (T3) (G2 = globally imperiled, G3 = globally vulnerable, T3 = vulnerable subspecies; NatureServe ranks.) Roads undermine each of these functions. Globally, about 80% of the terrestrial surface is still roadless, but it is broken into roughly 600,000 patches, more than half of them only about 1 km² and just 7% larger than 100 km². Limiting road expansion into roadless areas may be one of the most cost-effective ways to meet biodiversity and sustainability goals (Ibisch et al., 2016, https://doi.org/10.1126/science.aaf7166). Within 1 km of roads, forests show about 18.6% lower forest cover, 2.7 m shorter canopy, reduced net primary productivity, and 23.0 more patches per km² of fragmentation. These impacts extend up to 5 km with a clear distance-decay pattern, and they are tied to roads opening wilderness to logging, hunting, mining, and colonization (Zhou et al., 2026, https://doi.org/10.1038/s41467-026-69150-4). Roads also change the habitat itself. In natural secondary forests, species richness, density, and the proportion of invasive species all decline with distance from the road, with invasives concentrated along roadsides. Roads raise soil moisture, soil disturbance, nutrients, sun exposure, and soil temperature, all of which promote plant invasions (Dai et al. 2025, https://doi.org/10.1111/ddi.70002). Additionally, as the argument for rescission is wildfire prevention, the recent study by Aplet at al. 2026 (https://doi.org/10.1186/s42408-026-00450-2) 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. Instead of breaking up habitat, and making new roads where not needed by the public, and increasing wildfire risk, perhaps first consider addressing the backlog of road repair of $6.9 Billion, a number that has no clear source or clear sampling methodology.

Dear Mr. Schultz, As an outdoor enthusiast, I respectfully submit that the proposed rescission of the 2001 Roadless Area Conservation Rule has not been accompanied by a NEPA analysis commensurate with the scope of the action — specifically, that the environmental consequences of opening 58 million acres to road-building authorization have not been adequately evaluated in the record. As someone who has grown up camping and hiking in Coldwater, it is especially important to me that it remain roadless. Regarding the Coldwater in the Cleveland National Forest, California: Roads, disturbance, and altered ecosystems create invasion pathways that let non-native plants, pathogens, and animals displace native biota. Roads carry invasion effects into forest interiors. Skid trails and forest roads extend road edge effects on plant biodiversity up to 60 meters into adjacent forest stands, serving as conduits for non-forest species and removing interior forest species. The effect is amplified by the lime, clay, and gravel used in road construction (Avon et al. 2013; Dai et al. 2025). — Avon et al., 2013 (https://doi.org/10.1016/j.biocon.2012.10.008); Dai et al., 2025 (https://doi.org/10.1111/ddi.70002); Zhao, 2025 (https://doi.org/10.1111/ddi.70002) Rescinding the Roadless Rule would open the Coldwater, Cleveland 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. Roadless areas are home to some of the most precious, and fragile ecosystems that would certainly be disturbed or destroyed by the presence of roads. Keep roadless areas roadless. Hopefully, CommentID: RLC-20261006-JXKXPI

To Whom it May Concern, I am writing as a concerned citizen, professor at Arizona State University, and frequent hiker in wilderness areas, to strongly oppose the recision of the 2001 Roadless Rule. As an educator, I submit these comments because the record of policy reversals is itself a record students will one day read, and the Department owes that future readership something more than administrative convenience dressed as regulatory reform. The devastation caused by the 2020 Bush Fire in the Tonto NF, caused by a vehicle malfunction, and resulting in 193,455 acres burned, will, it's immediately obvious, take this area generations to recover. Hiking in nearby roadless areas such as the Sycamore Trail and the Denton Trail, to say nothing of the Arizona Trail in the Boulder Roadless Area make it abundantly clear how this irreplaceable wilderness would be at even greater risk from the effects of road building. Likewise the nearby Lime Creek Roadless Area would be jeopardized. My wife and I have hiked into this backcountry area twice in the last five years. Its remoteness is a blessing for the fauna and the flora to say nothing of the people who pass through it. Any road-building would greatly increase the already very real wildfire danger, especially with the drought conditions we've had recently. More to the point, the evidence strongly contradicts the government's claims that rescinding the Roadless area rule will reduce wildfire risk. More particularly: The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). 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). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads. — Aplet et al., 2026 (https://doi.org/10.1186/s42408-026-00450-2) Moreover, currently, forty percent of lands within inventoried roadless areas have a high or very-high wildfire hazard potential, ranging from 5 percent in the Eastern Region to 60 percent in California. About 23 percent (10.2 million acres) of inventoried roadless areas managed under the 2001 Roadless Rule are within the wildland-urban interface (WUI), areas where human development intermixes with the wildland, based on the definition of WUI set out in the Healthy Forests Restoration Act of 2003. — Department of Agriculture, Forest Service, 2025 (https://www.federalregister.gov/documents/2025/08/29/2025-16581/special-areas-roadless-area-conservation-national-forest-system-lands) Also, wildfires are almost twice as likely to occur in roaded areas as in roadless areas, because roadless areas are generally located further away from communities and are harder to access — U.S. Senate, 2025 (https://www.congress.gov/bill/119th-congress/senate-bill/2042/text) Aside from the increased wildfire danger the rescission would cause, the effects on the native ecosystems would be grievous. For instance, road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Dai et al., 2025 (https://doi.org/10.1111/ddi.70002) More particularly, in the Boulder Roadless Area, the roadless condition is fundamental to preserving wilderness and recreation. Maintained trails remain free from motorized competition; fishing streams flow through undisturbed watersheds; paddling on Sycamore Creek and Canyon Lake occurs without road-related erosion or sedimentation; etc. Road construction would fragment wildlife habitat, increase erosion into fisheries, introduce motorized noise to backcountry trails, and degrade the primitive character that draws hikers here. In conclusion, I plead with you for the good of us all and not just the few who stand to profit, not to proceed with the rescission of the Roadless area rule. Sincerely, Christopher D. Johnson CommentID: RLC-20261005-GYX9A0

To the Department of Agriculture: As someone who has used roadless national forest in multiple regions and in multiple seasons, I am submitting these comments to establish that the public value the 2001 Rule has protected is observable, documented, and not recoverable once road infrastructure has been authorized and constructed within currently protected areas. I remember walking with my husband on some of our very first dates in Cheaha park and now we love to take our children. Sitting at the top of the lookout always felt like stepping back in time and getting away from all of the stress of modern life. My family loves to hike the area and bulldozed roadbeds would ruin those experiences. Regarding the Cheaha B in the Talladega National Forest, Alabama: “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.” “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)” The Analysis Concedes Recreation Losses Are "Most Likely," Quantifies Them as Costs, and Cannot Even Count the Visitors at Risk The Economic Analysis concedes at page 25: "In the long-term, any changes in aggregate economic benefit to recreationists that occur under the proposed rule are most likely to be losses because timber harvest and road construction is anticipated to negatively change the recreation settings and opportunities for trail-based and dispersed area recreation within potentially affected IRAs… The magnitude of those losses is unknown." At page 30 it books real costs: "Costs include forgone recreation benefits (minimum of $6.1 million annually) and forgone passive use values ($5.3 to $11.5 million annually) from increases in timber harvest in roadless areas." At page 28 it concedes the mechanism: "The construction and use of roads can degrade the unique characteristics of roadless areas… leading to loss of conservation values… These impacts from road development could negatively impact tourism and outdoor recreation." And at page 16 it admits it cannot even measure the exposure: "The number of recreation visits to IRAs is unknown and, thus, the recreation visitor spending in local communities associated with IRA recreation cannot be directly quantified." Certain-direction losses of unknown and unmeasured magnitude are precisely what NEPA requires an agency to analyze rather than wave through. Robertson, 490 U.S. 332; State Farm, 463 U.S. 29. I request the FEIS quantify recreation exposure (visitation and spending) in affected IRAs before relying on an analysis that concedes losses it cannot measure. When this process is over, I want the Roadless Rule still standing. I'm filing this comment to help make that happen. Most respectfully, CommentID: RLC-20260909-GQZC8R

Brooke L. Rollins and Tom Schultz, Having observed wildlife across a representative cross-section of the inventoried roadless areas in the affected region, I write as a sustained observer rather than a credentialed expert to oppose the proposed rescission, the rationale for which the field evidence does not support. This is a local area that I have enjoyed for years, and allows me to find peace in nature while enjoying knowing there are many parts of this protected forest that cannot be accessed by humans, and rather are home to the hundreds of plant and wildlife species that utilize this area for part of their life cycle. Regarding the Trabuco in the Cleveland National Forest, California: Populations of 23 species, including Arroyo Toad (G1), Belding's Savannah Sparrow (T3), California Spotted Owl (T2), Channel Island Song Sparrow (T1), Coastal California Gnatcatcher (T3), Lawrence's Goldfinch (G3), Least Bell's Vireo (T2), Riverside Fairy Shrimp (G1), Saltmarsh Common Yellowthroat (T3), Southwestern Pond Turtle (G2), Spreading Navarretia (G2), Vernal Pool Fairy Shrimp (G3), Western Spadefoot (G2), persist in both Trabuco and San Mateo Canyon (65 acres, 14.5 miles apart) because individuals move between these IRAs. This movement provides the genetic diversity and recolonization capacity that sustain both populations. Absent road construction, the 14.5-mile corridor between Trabuco and San Mateo Canyon in Cleveland National Forest remains permeable to wildlife movement. The roadless condition of both IRAs preserves gene flow, seasonal migration routes, and recolonization pathways for 23 shared species, including Arroyo Toad (G1), Belding's Savannah Sparrow (T3), California Spotted Owl (T2), Channel Island Song Sparrow (T1), Coastal California Gnatcatcher (T3), Lawrence's Goldfinch (G3), Least Bell's Vireo (T2), Riverside Fairy Shrimp (G1), Saltmarsh Common Yellowthroat (T3), Southwestern Pond Turtle (G2), Spreading Navarretia (G2), Vernal Pool Fairy Shrimp (G3), Western Spadefoot (G2). “One of the most severe consequences of habitat loss due to road construction is the creation of isolated pockets of habitat that cannot support viable populations in the long term. Reductions in the range of species may decrease probability of their successful movement between habitat patches, which affects gene flow. Genetic theory suggests that the reduction of gene flow between subpopulations may lead to greater inbreeding and loss of genetic diversity within fragments, the raw material that allows populations to evolve in response to environmental changes. — Corlatti et al. 2009, Conservation Biology, 2009 (https://doi.org/10.1111/j.1523-1739.2008.01162.x)” “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 (https://doi.org/10.1038/s41597-024-04207-x)” “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” The rescinding of this Rule would be a catastrophic blow to environmental conservation on top of already huge blows to federally protected plants and wildlife (i.e., the final rule for Rescinding the Definition of “Harm” Under the Endangered Species Act that will go into effect on September 14, 2026). The Trump Administration is destroying our natural resources with these horrific rulings and our country will be left a dust-filled, waterless, treeless, wildlife-less dump unless our elected officials take a stand once and for all for the benefit of this country and your constituents. ACT NOW and vote no. Best regards, Callie Amoaku CommentID: RLC-20260910-HNDXBG

Dear Brooke L. Rollins, Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: To the Roadless Rule Rulemaking Docket: I am writing to advocate for the Roadless Rule. I have spent the best days of my life exploring and enjoying the roadless Wilderness. I rock climb, paddle, hike, mountain bike, and guide waterfall rappelling. I have noticed that the nearer I am to a road the more trash and graffiti I encounter. The animals are startled, and also I don't experience the same sense of safety and calm and rejuvenation. The Linville Gorge is one of my favorite places on earth. I climbed my first 500 foot trad route there and it changed my life. I was able to face my fears and overcome them successfully. I climbed above the birds and watched them play in the sunlight below me. I looked out over the roadless expanse of beautiful wilderness and it filled my soul with gratitude, peace, hope and presence. I have traveled to many places and I stay on the east coast to be near the Linville Gorge. The ability to experience a place that feels untouched connects me with something timeless, my self relience, my ability to persevere in a world of obstacles. Yes, others have been there before me, but the landscape remains the same and the inspiration and healing I get from looking over the wild expansive landscape would be completely destroyed by the sight of roads or manmade disruptions. "Increases in fine sediments are known to change grain size distribution and consequently cause degradation of spawning grounds. The increase of fines clogs the pore space and can lead to 'sustained clogging,' since the turnover rate is markedly reduced or prevented even in the case of exceptional high flows. In such situations, washed out soil (e.g., from agricultural land use) or fines may lead to sedimentation of fines on coarse bed material and/or artificially placed gravel with consequent, negative impacts on embryo survival of gravel-spawning fish through suffocation." — Springer Nature — book chapter in Riverine Ecosystem Management, 2018 “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” NatureServe threat assessment data document that Appalachian Dragonhead Pogonia (Cleistesiopsis bifaria, G3,) in the Linville Gorge Addition IRA, Pisgah National Forest, faces 8.1 - Invasive non-native/alien species/diseases at Moderate or 11-30% pop. decline severity across Large (31-70%) scope. Roads enable the equipment access, land conversion, and human activity that activate 8.1 - Invasive non-native/alien species/diseases. Without road infrastructure, the extractive and development pressures behind this threat category cannot reach Appalachian Dragonhead Pogonia habitat in Linville Gorge Addition. If the DEIS does not evaluate how rescission affects Appalachian Dragonhead Pogonia (Cleistesiopsis bifaria, G3) in Linville Gorge Addition with respect to 8.1 - Invasive non-native/alien species/diseases, the agency has failed to consider an important aspect of the problem — a standard basis for finding an EIS inadequate under NEPA. An administrative record spanning more than two decades argues against rescission; the Department should act accordingly. With respect, CommentID: RLC-20260905-EKAHLJ

Dear Chief Schultz: As someone who has traveled specifically to roadless areas because of the experience they offer, I want to register that this rescission would be a real loss — not a theoretical one. I have backpacked, hiked and fished along this part of the river and love to spend time in actual nature. Not one as road took me to.. If a single memory can stand for the whole of that attachment, it is this one. We rode in by horse one year to make the journey more memorable. What is conveyed above represents the kind of public reliance interest that federal rulemaking is obligated to consider; the rescission of the Rule would extinguish protections on which millions of Americans similarly depend. Regarding the North Fork Middle Fork American River in the Tahoe National Forest, California: Waters of the United States flow through the North Fork Middle Fork American River IRA, Tahoe National Forest, establishing Clean Water Act Section 404 jurisdiction over any activity involving discharge of fill material into these streams. Road construction through the North Fork Middle Fork American River IRA, Tahoe National Forest, necessitates stream crossings where fill material is discharged directly into waters of the United States, each crossing independently requiring Section 404 authorization. The DEIS fails to analyze Clean Water Act Section 404 obligations specific to the North Fork Middle Fork American River IRA, Tahoe National Forest. The agency must identify all jurisdictional waters, assess cumulative fill material discharge from road construction, and demonstrate compliance with Section 404 permit requirements. "Section 404 of the Clean Water Act (CWA) establishes a program to regulate the discharge of dredged or fill material into waters of the United States, including wetlands. Activities in waters of the United States regulated under this program include fill for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports) and mining projects. Section 404 requires a permit before dredged or fill material may be discharged into waters of the United States, unless the activity is exempt from Section 404 regulation (e.g., certain farming and forestry activities). The basic premise of the program is that no discharge of dredged or fill material may be permitted if: (1) a practicable alternative exists that is less damaging to the aquatic environment or (2) the nation's waters would be significantly degraded." — U.S. Environmental Protection Agency “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” “Stream fragmentation is a leading threat to freshwater fish diversity and is often caused by the installation of impassable culverts at road–stream crossings. In the United States alone, millions of culverts contribute to this fragmentation. Emerging research suggests that smaller barriers, such as culverts, can have cumulative effects on riverine fragmentation that are comparable to those of large dams. — River Research and Applications (Wiley), 2026 (https://doi.org/10.1002/rra.70075)” “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 (https://doi.org/10.1038/s41597-024-04207-x)” Rescission is unwarranted; the Department should allow the 2001 Rule to stand. Warm regards, CommentID: RLC-20260902-85M1ZX

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

Dear Chief Schultz, For someone who plans trips around what public land hasn't been developed, the 2001 Rule is crucial to where I find it still worth going. The first time I visited the Coyote area, I found peace and solitude among gently flowing brooks and wind-sculpted trees, rare plants that have vanished from many local areas. I would like to see it stay that way. For twenty-five years the Rule has preserved the conditions that make connections of this kind available to the public; rescission would begin their systematic erosion. Regarding the Coyote North in the Inyo National Forest, California: "Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 "Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 "Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 "Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” Rescission of the 2001 Rule is not in the public interest; the Department should decline to proceed. Best regards,

Dear Secretary Rollins and Chief Schultz: As an outdoor enthusiast, I am filing these comments to note that road construction in currently protected roadless areas is not merely a policy question — it is a physical intervention that eliminates, at the landscape scale, the conditions that define roadless character, and no subsequent administrative action could restore those conditions within a timeframe relevant to the public now commenting on the proposed rescission. These roadless areas help to shape the future viability of our country. They give space for average people to take in nature and experience wildlife, quiet, and various recreational opportunities. The addition of roads in these spaces threaten the species that live there and how people can recreate. I started going to the Boundary Waters in 2013. My dad and grandpa started going there in the 70s when it first became a wilderness area. This space is for generations to share, not big business. That connection to the land is precisely what the 2001 Roadless Area Conservation Rule was designed to protect, and what the present proposal would place in permanent jeopardy. Regarding the South Kawishiwi River in the Superior National Forest, Minnesota: Within Superior National Forest, the South Kawishiwi River IRA provides habitat for Golden-winged Warbler (Vermivora chrysoptera, G3), a species subject to 7.1.2 - Suppression in fire frequency/intensity — a threat assessed at Slight or 1-10% pop. decline severity affecting Large - restricted of the population. 7.1.2 - Suppression in fire frequency/intensity requires infrastructure access to operate at scale. Roads are the prerequisite — they deliver the machinery, chemical inputs, and repeated human intrusion that transform this threat from latent to active in areas like South Kawishiwi River. Analysis of 7.1.2 - Suppression in fire frequency/intensity effects on Golden-winged Warbler (Vermivora chrysoptera) in South Kawishiwi River must reference the species' G3 conservation status and the documented Slight or 1-10% pop. decline severity. The DEIS lacks scientific integrity without this baseline data. "Frequent human disturbance caused by mining development and road construction in the Kalamaili Mountain Ungulate Nature Reserve (KNR) — inhabited by >80% of Chinese khulan (Equus hemionus) — has interfered with or completely blocked their movement and access to parts of the reserve. The habitat of khulan in KNR went from a good natural habitat in 2005 to deterioration due to mining development in 2011. In 2019, road construction likely hindered its recovery to pre-mining levels. Our study revealed the significant impacts that mining development and road construction have had on the distribution of core habitats, ecological corridors, and movement of khulan." — Biological Conservation (ScienceDirect), 2022 “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” Rescinding a settled rule is the kind of decision that should be made only on a strong record, and the record here doesn't support it. Kind regards,

To the U.S. Department of Agriculture: As a resident of a community whose local planning documents treat adjacent roadless National Forest as a fixed and protective landscape context, I submit that the Department's proposal would introduce a degree of land-use uncertainty that local plans have not accounted for and cannot easily absorb. I have grown up exploring these forests and understand the dire effects that logging and rampant out of state (and some misguided instate) developers have to the local ecosystem. I am staunchly opposed to rescinding any environmental protections in favor of industries that are unable or unwilling to determine sustainable ways of progressing without the destruction of our important wild areas. The shortsightedness of this rescention is staggering. The nonmarket value embedded in connections of this kind — to watershed, to forest, to a place known across years — does not appear in the proposal's economic analysis and should not be treated as though it does not exist. Regarding the Linville Gorge Addition in the Pisgah National Forest, North Carolina: The threat mechanism classified as 8.1 - Invasive non-native/alien species/diseases (IUCN-CMP 8.1) is actively degrading habitat for Bog Turtle (Glyptemys muhlenbergii, G2) in the Linville Gorge Addition Inventoried Roadless Area, Pisgah National Forest, at Serious or 31-70% pop. decline severity across Large (31-70%) scope. The roadless character of Linville Gorge Addition currently prevents the infrastructure penetration that initiates 8.1 - Invasive non-native/alien species/diseases. Rescission removes that barrier, allowing road construction to trigger the full cascade of impacts documented in NatureServe's threat assessment for Bog Turtle. The agency cannot satisfy its analytical obligations with a national-level discussion of roadless values. The DEIS must address 8.1 - Invasive non-native/alien species/diseases as it affects Bog Turtle (Glyptemys muhlenbergii) specifically within the Linville Gorge Addition IRA, Pisgah National Forest. "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 “Stream fragmentation is a leading threat to freshwater fish diversity and is often caused by the installation of impassable culverts at road–stream crossings. In the United States alone, millions of culverts contribute to this fragmentation. Emerging research suggests that smaller barriers, such as culverts, can have cumulative effects on riverine fragmentation that are comparable to those of large dams. — River Research and Applications (Wiley), 2026 (https://doi.org/10.1002/rra.70075)” “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” “The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha), and the second highest wildfire-ignition density was in other national forest lands outside of the 50-m road buffers but not in wilderness or roadless areas (3.50 fires/1000 ha). 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). For human-caused, natural, and undetermined fires, wildfire-ignition density decreased as distance to road increased: in lands between 0 and 250 m from roads, 6 fires ignited per 1000 ha, whereas fewer than 2 fires ignited per 1000 ha at a distance class of over 2000 m from roads. — Fire Ecology (Springer Nature), 2026 (https://doi.org/10.1186/s42408-026-00450-2)” The Department should treat the Rule's twenty-five-year record as the baseline against which any replacement must be measured, and on that measure the proposal falls short. Respectfully, Concerned Constituent

Dear Mr. Schultz, As someone who spends a great deal of time hiking, backpacking, and exploring our national forests, the places I value most are often the ones farthest from roads. There is something increasingly rare about being able to walk for miles through uninterrupted forest, hearing only wind, water, and wildlife rather than vehicle traffic. These roadless areas provide a kind of solitude, naturalness, and sense of discovery that cannot be recreated once roads are built. I am deeply concerned that rescinding the Roadless Rule would put these experiences at risk. Once roads are constructed, the character of these landscapes changes permanently, and opportunities to experience truly remote, undeveloped public lands become increasingly scarce. For many of us, protecting roadless areas is not an abstract policy preference. It is about preserving the places where we hike, camp, reflect, and connect with nature in its most intact form. One occasion in particular illustrates what that relationship means in practice. During my hikes of New Hampshire's 4,000-foot mountains, the most memorable moments were the long stretches of solitude. Being able to disconnect from the constant presence of roads, noise, and development, and instead experience a landscape shaped primarily by natural processes, was genuinely invigorating and restorative. That experience is becoming rare, and once roads are built into these areas, they cannot be recovered. Protecting roadless forests means preserving the opportunity for future generations to experience that same sense of solitude, wildness, and connection to nature that has meant so much to me. The standing connection and the specific experience above together illustrate what the Rule has made possible over twenty-five years of operation. Regarding the Pemigewasset Ext in the White Mountain National Forest, New Hampshire: Moderate or 11-30% pop. decline severity and Restricted - small scope characterize the impact of 5.3.3 - Unintentional effects: subsistence/small scale (species being assessed is not the target) [harvest] on Monarch (Danaus plexippus, G4) in the Pemigewasset Ext Inventoried Roadless Area, White Mountain National Forest — losses that the current Roadless Rule helps constrain. For Monarch in Pemigewasset Ext, the connection between road construction and 5.3.3 - Unintentional effects: subsistence/small scale (species being assessed is not the target) [harvest] is direct: roads deliver the disturbance vectors — sediment, access, fragmentation — that NatureServe identifies as driving Moderate or 11-30% pop. decline severity impacts on this population. Under NEPA, the agency must evaluate the direct, indirect, and cumulative effects of rescission on Monarch (Danaus plexippus) in the Pemigewasset Ext Inventoried Roadless Area, including the documented threat of 5.3.3 - Unintentional effects: subsistence/small scale (species being assessed is not the target) [harvest]. "Frequent human disturbance caused by mining development and road construction in the Kalamaili Mountain Ungulate Nature Reserve (KNR) — inhabited by >80% of Chinese khulan (Equus hemionus) — has interfered with or completely blocked their movement and access to parts of the reserve. The habitat of khulan in KNR went from a good natural habitat in 2005 to deterioration due to mining development in 2011. In 2019, road construction likely hindered its recovery to pre-mining levels. Our study revealed the significant impacts that mining development and road construction have had on the distribution of core habitats, ecological corridors, and movement of khulan." — Biological Conservation (ScienceDirect), 2022 “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” The proposed rescission should be withdrawn, and the Rule should continue as currently promulgated. In earnest, Todd Meigs

Dear Forest Service Leadership: As an outdoor enthusiast who has used areas protected under the 2001 Rule as a primary public land destination, I am submitting these comments to urge the Department to weigh the full scope of the public interest the Rule serves — an interest documented in millions of public comments, sustained through multiple administrations, and observable in the landscapes the Rule has maintained. As a climber and hiker uninterrupted and undamaged wilderness is very important to me. One visit made that connection concrete. I have spent a lot of time in the wasatch-cache national forest, and the uninterrupted aspen and pine trees takes my breath away each time and makes me proud to be able to visit such beautiful places. The account and the context in which it is situated both point to the same conclusion: the Rule should remain in force. Regarding the White Pine in the Wasatch-Cache National Forest, Utah: 7.1.1 - Increase in fire frequency/intensity drives Slight or 1-10% pop. decline severity impacts across Restricted (11-30%) scope for Pinyon Jay (Gymnorhinus cyanocephalus, G3, UR) in the White Pine IRA, Wasatch-Cache National Forest. Absent roads, White Pine functions as a refuge where Pinyon Jay is buffered from 7.1.1 - Increase in fire frequency/intensity. The roadless condition suppresses the access, fragmentation, and runoff pathways that convert this threat from potential to realized. The DEIS analysis of White Pine must incorporate NatureServe's standardized threat assessment data for Pinyon Jay (Gymnorhinus cyanocephalus, G3), including the IUCN-CMP classification (7.1.1), Slight or 1-10% pop. decline severity rating, and Restricted (11-30%) scope determination. "Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity." — Diversity and Distributions (Wiley), 2025 “Road networks are a common disturbance on the landscapes that 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. Roads serve as dispersal corridors where invasive plant propagules are spread by humans, vehicles and animals using roadways as travel paths. Research indicates that invasive plant richness and density generally decrease with the distance from roads, whereas native species show variable distribution patterns near roads. Proximity to roads often correlates with higher invasion rates, reducing native diversity. — Diversity and Distributions (Wiley), 2025 (https://doi.org/10.1111/ddi.70002)” Rescission would not be a reasoned policy choice on the record presented; the Department should not finalize it. With concern,

The first time my husband and I hiked the Graveyard Ridge area of Pisgah Forest, a 1,958-acre roadless area in North Carolina (NC), I understood what inspired the American ballet “Appalachian Spring”. I had never seen so many different species of plants, including ephemerals that bloom for only a week or two. We also hike Sam’s Knob, a 2,576-acre roadless area next to Graveyard Ridge, and hike roadless areas in Nantahala National Forest, including Cheowah Bald and Wesser Bald (through which the Appalachian Trail runs), and recently bought land within hiking distance of Tusquitee Bald, a 13,670-acre roadless area. We are so grateful that we can enjoy these places as they are now, and we hope that generations to come can experience them too. These roadless areas are accessible and used by many people- Republican and Democrat, rural and urban. Adding roads will not bring more people to them, instead they will make it easier to engage in logging and other activities (USDA Forest Service 2001, https://www.federalregister.gov/documents/2001/01/12/01-726/special-areas-roadless-area-conservation) that will degrade what brings people to these areas and helps support local economies. Roads are a vector for invasive species, and construction will damage the biodiversity that makes western NC so unique (Avon et al. 2013, https://doi.org/10.1016/j.biocon.2012.10.008; Clavel et al. 2025, https://doi.org/10.1111/oik.11075; Dai et al. 2025, https://doi.org/10.1111/ddi.70002). Roads are also where most human-caused fires start (Aplet et al. 2026, https://doi.org/10.1186/s42408-026-00450-2)—rescinding the roadless rule will do more to cause fires than prevent them. Please do not rescind the roadless rule-- these areas belong to all Americans, and all Americans deserve the chance to experience these beautiful places as they are.