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Opposition Toward Rescinding the 2001 Roadless Rule As a consulting forester with a bachelors in environmental science, I strongly oppose the USFS decision the rescind the 2001 Roadless Rule. While roads are essential for basic forestry practices; Forestry, let alone bulldozers do not belong in wilderness areas. The value of wilderness areas lies within their resilience. With the 2001 roadless rule in tact, these wilderness areas remain as ecosystem and public servants to current as well as future generations. As climate change continues to push us further into the unknown, these roadless wilderness areas provide essential buffers for water availability, wildlife populations, insects, reduced wildfire risk, and native plant dominance. (Miller Kenton, 1999). As I have seen first hand in my line of work, allowing the construction of roads in these areas will permanently dismantle the economical and ecological benefits associate with roadless areas. The environmental impacts associated with forest road construction are severe and expensive, especially in steep terrain (Caliskan, 2013). I would understand if the USFS decided to allow exceptions to this rule for the purpose of wildfire mitigation and public recreation in urban-wild land interfaces. However, to completely rescind the Roadless Rule is far too broad of a change. It is obvious that this decision is not in favor of the public interest, forest health, natural resource equity, or local economies. With several roadless areas right here in the San Juans, I can confidently say running a bulldozer uphill will have negative impacts to our local economies and environment (Holmes et-al. 2016). Traveling to a wilderness area is a spiritual experience that feels like traveling back in time. The 2001 Roadless Rule is one of the best decisions this country has ever made. To conclude, removing it would be one of this country’s biggest mistakes. Caliskan, E. Environmental impacts of forest road construction on mountainous terrain. J Environ Health Sci Engineer 10, 23 (2013). https://doi.org/10.1186/1735-2746-10-23 International Journal of Wilderness. Miller Kenton, 35-39, 1999). https://scholar.google.com/scholar?hl=en&as_sdt=0%2C6&q=ecological+benefits+of+wilderness+areas&btnG=#d=gs_qabs&t=1791332940345&u=%23p%3DR7-IhIl3-IoJ A synthesis of the economic values of wilderness TP Holmes, …, JM Bowker, …, J Englin, …, E Hjerpe, …, JB Loomis, …, S Phillips, …, R Richardson Journal of Forestry , 2016 https://scholar.google.com/scholar?hl=en&as_sdt=0%2C6&q=benifits+of+wilderness+areas&btnG=#d=gs_md_aa-d&t=1791332621420&u=%2Fscholar%3Fq%3Dinfo%3AKzYOlII3gk0J%3Ascholar.google.com%2F%26scioq%3Dbenefits%2Bof%2Bwilderness%2Bareas%26dv%3D0%26output%3Daa%26ei%3DepDFatK1Ite46rQPmoOZiAE%26scirp%3D2%26hl%3Den

Dear USDA, I believe the roadless rule is a great environmental conservation tool that benefits every American. It protects our nation's abundance of undisturbed natural areas from being destroyed. And the roadless rule gives our future generations clean water, clean air, and land for pleasure everyone can share. I support the roadless rule and do not want to see it go away. I enjoy the solitude I find in the Middle Prong Addition, which is protected by the roadless rule. I find the forest beautiful and have a strong personal connection to it. I am worried logging could drastically change the natural areas protected under the roadless rule. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Caliskan, 2013 (https://doi.org/10.1186/1735-2746-10-23) Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. Our country needs to focus on sustainable logging. A lot of the mountainous areas protected by the roadless rule are so steep that it is highly damaging to the land to harvest timber, and the trees from these steep slopes will be awkward and not tall strait trees. I am Not in favor of rescinding the roadless rule. Thank you for your consideration, Andrew Dial

To Whom It May Concern at the U.S. Forest Service: As an avid outdoor enthusiast, who spends a good deal of time on public land, the question of what gets protected permanently versus what gets decided administration by administration matters a great deal and impacts generations before and after me. I am an Oregon resident of 45 years and have spent a large majority of my outdoor time in the Mt Hood National Forest including the Salmon - Huckleberry wilderness. From camping on the Salmon river, hiking along the Salmon River trail to having my wedding ceremony on Mt Hood, this public land is my backyard and my sanctuary. Just a few months ago my husband, dog and I camped in the Salmon - Huckleberry wilderness. Going to a remote area to get away from the busyness of the city, for us is a required recharge. While we were there, just 20 minutes away a wildfire was burning toward Mt. Hood (Grasshopper fire). As we hiked through beautiful old growth forests we reminded each other that these areas are becoming scarce and to spend as much time there while we can. The Salmon River trail exists only because of the protection from erosion and wildfires by the trees and vegetation. This vegetation would be decimated and the trail would be gone if roads and logging were allowed. Regarding the Salmon - Huckleberry in the Mt. Hood National Forest, Oregon: The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. 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. “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)” Introducing roads and development into this backcountry will cause more logging and loss of vegetation. That in turn will make it more susceptible to wildfire and loss of land. In Oregon we have lost so many of our recreation lands to fire and the spaces we can be in nature are disappearing. The Salmon Huckleberry wilderness is a precious sanctuary that cannot be replaced once it's gone. Please keep this land safe for today and future generations. This land is sacred and belongs to the public. Don't sign it away. All the best, CommentID: RLC-20260930-AE1TZD

To Brooke L. Rollins and Tom Schultz, As someone who has walked the same public land for years, I notice what changes. Roads change everything. As I have visited dozens of national forests across the country, the White Mountain National Forest in the state of New Hampshire is an extension of what I call home. This includes the Sandwich Range which to me provides respite but also a reserve for valuable natural resources that should remain undisturbed. It is full of diverse biological species that intertwine into a critical ecosystem including acting as a natural barrier to reduce the advancement of invasive species heading northward in the state. I have had many visits to this area and over my years there I have appreciated the current biodiversity and unique undisturbed discoveries. This includes hidden glacial erratics tucked away in older growth forests, wetland habits with resident birds (including rare species of thrushes), and scenic views through all four seasons that are experienced here. This eden provided a benefit for its nautural residents but also visitors like me. We would lose so much as this area is not asking for more disruption including disruption of valuable habits for plants and animals. This would also have a negative impact on future generations and for those closer residents that welcome respectful visitors. Regarding the Sandwich Range in the White Mountain National Forest, New Hampshire: Interior Forest Habitat for Bat and Bird Communities — The Sandwich Range's unfragmented expanse of Northern hardwood-conifer and high-elevation balsam fir forest provides the interior forest conditions required by the federally endangered Northern Long-eared Bat and the federally threatened Canada Lynx. These species avoid forest edges and require large, continuous blocks of mature forest away from human disturbance. The roadless condition preserves the acoustic and structural integrity of the forest interior—the absence of road noise, light, and edge effects—that allows these species to forage, roost, and move through the landscape without the behavioral disruption and increased predation risk that fragmentation causes. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Caliskan, 2013 (https://doi.org/10.1186/1735-2746-10-23) Rescinding the Roadless Rule would open the Sandwich Range, 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. Roadless areas should remain roadless. I object with this proposal. There is not one reason that provides a positive future for our forests and public lands in New Hampshire and beyond. The proposed rollback of the 2001 Roadless Rule jeopardizes 44.5 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. This comment joins the record in opposition to the proposed rescission action. Best regards, Zachary Allen CommentID: RLC-20260918-A5A26V

Dear Secretary: As an outdoor enthusiast who regularly uses areas of national forest that retain their current character specifically because the 2001 Rule prohibits road construction within them, I respectfully submit that the Department's obligation under applicable statutes includes giving full weight to the public interest in those conditions before authorizing their alteration. Regarding the Woodford 09086 in the Green Mountain and Finger Lakes National Forests, Vermont: These public lands belong to the people and it is our job to protect them, including maintaining the federal protection for roadless areas. It's imperative we keep nature wild. Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Caliskan, 2013 (https://doi.org/10.1186/1735-2746-10-23) Rescinding the Roadless Rule would open the Woodford 09086, 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. Not a fan of this proposal. Pull it. With thanks, Delia O'Donnell

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

Dear Forest Service Leadership: As a healthcare worker, I know that stable systems aren't stable by accident — they're stable because something is holding them there, and removing that something has consequences. The Department is urged to retain the Roadless Area Conservation Rule in recognition of the public interest that connections of this kind represent — an interest that rescission would permanently diminish. Regarding the Balsam Cone in the Pisgah National Forest, North Carolina: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Erhan Caliskan, 2013 · Iranian Journal of Environmental Health Science & Engineering (https://doi.org/10.1186/1735-2746-10-23) Rescinding the Roadless Rule would open the Balsam Cone, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Roadless areas are not only beneficial for our environment, they support us by providing air, water, natural wonder, as well as our enjoyment. “Pisgah National Forest was established on October 17, 1916, under the authority of the Weeks Act of 1911, which authorized the federal government to purchase private land for the protection of watersheds of navigable streams. The core of the forest was formed in 1914 when Edith Vanderbilt sold approximately 86,700 acres of the Biltmore Estate to the federal government. On July 10, 1936, a significant portion of the Unaka National Forest was transferred to Pisgah. Between 1933 and 1942, the Civilian Conservation Corps operated numerous camps within the forest.” The grounds articulated in this comment support one conclusion: the Roadless Area Conservation Rule should not be rescinded. With resolve, CommentID: RLC-20260826-BFBVWM

Dear Mr. Schultz, As an angler, the rule has kept the small streams small streams. Roads change them. Don't open the door. Regarding the Lower Romero WSR in the Coronado National Forest, Arizona: Timber harvest, associated road construction, and vegetation removal directly alter roadless character and degrade habitat quality. Rescinding the Roadless Rule would open the Lower Romero WSR, 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. I am a professional ecologist and hold an advanced degree in ecology. Neither myself nor any colleague of mine with an environmental background supports recession of the roadless rule. Acting like this is for the benefit of fire safety is laughable and not supported by science. The benefits gained from this rule since its inception are immense. The roadless rule helps with so many facets of the environment, from soil erosion to cleaner air. Those that support this rescission are those that would benefit financially or politically at the expense of the rest of the American public and the environment. The roadless rule has bipartisan support from many user groups, from tree hugging conservationists to red blooded meat eating hunters. The stewardship of our natural resources is an essential component of what our federal government should provide. Like so many decisions in recent history across many disciplines, experts watch in dismay as the federal government subverts the will of the American public and actively acts against their best interest to please their corporate overlords. Where is your responsibility to your countrymen? To your planet? Where is your honor? Every day is exhausting and depressing for anyone who works in fields that are connected to the environment, from guides, to hotshot firefighters, to ecological researchers. Your duty is to listen to evidence and experts and to heed the will of the people. the rescission of the roadless rule checks neither of those boxes and makes the USA poorer, weaker and uglier. Forest road construction damages adjacent trees. Road construction on steep mountain terrain damages 21 to 33 percent of trees in the construction zone, depending on equipment used; on very steep terrain, damage rises to 27 to 44 percent. Direct habitat conversion and indirect fragmentation extend well beyond the road's physical footprint (Caliskan 2013). — Erhan Caliskan, 2013 · Iranian Journal of Environmental Health Science & Engineering (https://doi.org/10.1186/1735-2746-10-23) The Department is asked to close this proceeding without disturbing the Rule. With hope, CommentID: RLC-20260823-18J2BR

Dear Secretary: For someone who values getting out somewhere that requires effort to reach, and who has found that value in roadless areas in Colorado, this rule matters in a way that's connected to everything I do outdoors. I lived in Colorado for 3 years and made use of roadless areas year-round. That brought me an appreciation for solitude, wilderness and connection to nature. Although I live in a different part of the country now, I am inspired to find more roadless areas near me to get my fill of that quiet, peaceful recreation. Roads change things permanently. The rule prevents that. Don't rescind it. The whole point of roadless areas is the lack of access and noise. Hiking in Colorado brought a quietness to my soul that I couldn't find elsewhere. It made me aware of the value of the land in this great country of ours, and I mean value as in something worthwhile, not in a monetary sense. Regarding the Williams Fork Ptarmingan Adjacent in the Arapaho & Roosevelt NFs, Colorado: “More than 96% of these areas are located west of the 100[th] meridian, mostly concentrated in northern California, Oregon, Washington, Southeast Alaska, and in Rocky Mountain States. Road construction and reconstruction are already prohibited on 24.2 of the 58.5 million acres of inventoried roadless areas under current land management direction, whereas 34.3 million acres allow road construction and reconstruction. — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-ssummary.pdf)” “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). 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. — Erhan Caliskan, 2013 · Iranian Journal of Environmental Health Science & Engineering (https://doi.org/10.1186/1735-2746-10-23)” “Road mortality is a widely recognized but rarely quantified threat to the viability of amphibian populations. The global extent of the problem is substantial and factors affecting the number of animals killed on highways include life-history traits and landscape features. Secondary effects include genetic isolation due to roads acting as barriers to migration. Long-term effects of roads on population dynamics are often severe and mitigation methods include volunteer rescues and under-road tunnels. Despite the development of methods that reduce road kill in specific locations, there is scant evidence that such measures will protect populations over the long term. — Conservation Biology (Wiley), 2013 (https://doi.org/10.1111/cobi.12063)” “A total of 50.3 million acres of protected wilderness areas, roadless areas, and designated critical habitat, as well as 2,300 miles of wild and scenic rivers are included in the emergency declaration map area, fast-tracking destructive projects in areas that were intentionally set aside to preserve their natural values and functions. — Dr. Dawn Woodard, Dr. Matthew McKinzie, Gabrielle Berthel, 2025 (https://www.nrdc.org/media/what-usdas-emergency-logging-map-gets-dangerously-wrong)” “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. Formations with the greatest percentage increase in representation when including IRAs in the protected network include Temperate Grassland and Shrubland (57.4%), Cool Temperate Forest and Woodland (52.2%), and Mediterranean Scrub and Grassland (35.5%). — McKinley J. Talty | Kelly Mott Lacroix | Gregory H. Aplet | R. Travis Belote, 2020 · Conservation Science and Practice (https://doi.org/10.1111/csp2.288)” I am so grateful for past administrations for creating and upholding the Roadless Rule so that Americans can be proud of their land and find the peace and recreation they seek. This isn't a close call. Don't rescind. With conviction, CommentID: RLC-20260823-197LA2