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I am respectfully writing in support of Alternative 1 – No Action (2001 Roadless Rule stays in place). I oppose any proposal to partially or fully rescind the Roadless Area Conservation Rule. My family lives in a state that does not have any Roadless Area Conservation Rule areas. Our state has minimal places to go where a person can see and hear nothing but intact nature that is free from human development. To experience the pristine, untouched lands that we love we must travel. Oregon is a state that holds thousands of acres of Roadless Rule lands that we enjoy each year. It is impossible to describe how special the rivers, wildlife and forests, many them being old growth forests, have become to us. The scent of the cinnamon and vanilla bark that protects the Ponderosas is the most welcoming smell and instantly calms me every time I step out of the vehicle after a long trip to Oregon, but everything in these areas works together to create a sanctuary for living things, including my family and many others. Humans need these wild places as much as the wildlife and plant life that make up these landscapes. There is no replacing them once they are destroyed. I am forever grateful for the people that came before me who worked to protect these areas for future generations, so that I and my family and millions of others may experience them and their many benefits. I am just an ordinary citizen. While I am sure my contribution in the form of this comment will fall far below what these areas deserve from me, it is my humble attempt to implore you to please keep these areas intact and protected by supporting the 2001 Roadless Area Conservation Rule, and opting for Alterative 1 – No Action. •I ask the USDA to retain or strengthen the protections and standards in the current 2001 Roadless Area Conservation Rule. This rule helps protect rivers, water quality and wildlife as well as climate mitigation and helps retain current riparian measures. DellaSala, D.A., Karr, J.R., & Olson, D.M. (2011). Roadless areas and clean water. Journal of Soil and Water Conservation, 66(3): 78A–84A. doi.org/10.2489/jswc.66.3.78A Ellison, D., et al. (2017). Trees, forests and water: Cool insights for a hot world. Global Environmental Change, 43: 51–61. doi.org/10.1016/j.gloenvcha.2017.01.002 Standard reference on forest–water interactions and moisture recycling. •The Roadless Area Conservation Rule helps to protect old growth trees as many of the Roadless Rule areas contain tress that are larger than 21” in diameter. The 21” Rule, prohibiting logging of tress over 20” in diameter, along with the current Roadless Rule, protects Old Growth forests and the ecosystems contained within. This helps with climate mitigation, forest ecosystem health and water quality in and downstream from Roadless Areas. Mildrexler, D.J., et al. (2023). Protect large trees for climate mitigation, biodiversity, and forest resilience. Conservation Science and Practice. doi.org/10.1111/csp2.12944 Mildrexler, D.J., et al. (2020). Large trees dominate carbon storage in forests east of the Cascade crest in the United States Pacific Northwest. Frontiers in Forests and Global Change. Watson, J.E.M., et al. (2018). The exceptional value of intact forest ecosystems. Nature Ecology & Evolution. doi.org/10.1038/s41559-018-0490-x Law, B.E., et al. (2022). Strategic Reserves in Oregon’s Forests for Biodiversity, Water, and Carbon to Mitigate and Adapt to Climate Change. Frontiers in Forests and Global Change. frontiersin.org/articles/10.3389/ffgc.2022.1028401/full •The Roadless Area Conservation Rule has helped protect against wildfires. The majority of wildfires begin near areas NOT protected by the current Roadless Rule as a study by the Pacific Biodiversity Institute showed that over 90% of wildfires started within half a mile of a road. https://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf •The current Roadless Rule not only protects the lakes, streams and rivers that we and wildlife enjoy while out in nature, it also provides clean drinking water for over 25 million Americans. https://journals.plos.org/water/article?id=10.1371/journal.pwat.0000538 . Liu, N., et al. (2022). Quantifying the role of National Forest System and other forested lands in providing surface drinking water supply for the conterminous United States. USDA Forest Service Again, this is an attempt by an ordinary American, who is very much desperately, urging you to protect our public lands. Please join those that came before us in protecting these places. Stand up for public lands and the many millions who love them by supporting Alternative 1 – No Action.

I have a B.A. in Environmental Studies and Politics and a background in community advocacy and conservation. I am interested in this regulation because the Roadless Rule provides clean drinking water for 25 million Americans. I am commenting to request that the U.S. Forest Service keeps the Roadless Area Conservation Rule entirely intact and makes no changes. This rule serves the country in a multitude of ways and the results of the DEIS showed that. The DEIS did not properly justify the need for this rescission based on wildfire management, because as we know two-thirds of human caused wildfires in my home state of California are started near roads and 95% of wildfires are caused by humans. Wildfire management and preparedness is better accomplished via community programs, the federal government should be funding those programs rather than rescinding rules that protect wilderness and prevent wildfires in certain areas. I will address one of the issues that will be created by the rescission of this rule. I’ve grown up in Lake Tahoe, I’ve seen the beauty of the clear blue water, the majestic trees, the wildlife that thrives there, and the small businesses that are able to thrive and benefit off of this natural beauty. 23% of National Forest lands in the Lake Tahoe Basin are Inventoried Roadless Areas. The forests in the Lake Tahoe Basin actively protect and maintain the quality of the regional water supply. Forests do so by acting at natural filters, sponges and regulators that clean, store, and release water. When forests are clearcut they lose their ability to soak up water like a sponge. When clearcutting happens soil is degraded and the water washes down to nearby streams and rivers and forest’s water storage capacity is reduced. Forests also lose their ability to support the water cycle through transpiration. Cutting down forests to build roads increases soil erosion and lack of water retention and filtering for the water supply. 55,000 year-round residents plus huge numbers of tourists rely on the local watershed resources in the Lake Tahoe Basin. Rescinding the Roadless Rule would put these watersheds at risk and therefore expose the local community as well as the wildfire and other existing habitats at risk. My recommendation is that no action be taken and the 2001 Roadless Area Conservation Rule is kept as is. And a note to this administration, rescinding this rule will not increase American economic prosperity. Ecotourism is way more viable economically in the long term. Invest in communities, invest in small businesses, not in donors from extractive industry. Study on Roadless and Water: https://journals.plos.org/water/article?id=10.1371/journal.pwat.0000538 Sources: https://www.fs.usda.gov/about-agency/features/fire-never-starts https://www.fs.usda.gov/sites/default/files/roadless-map-inventoried-areas-california-lake-tahoe-fsmrs-072422.pdf https://www.americanforests.org/article/the-important-relationship-between-forests-and-water/ https://eos.com/blog/clear-cutting/ https://www.tahoefund.org/about-tahoe/tahoe-fun-facts/

I strongly object to ending the roadless rule. By ending this rule, it poses multiple threats to our forests and public health via increased wildfires, threatens local economies, jeopardizes clean drinking water for millions of Americans, threatens natural habitats and biodiversity, and violates the public land agreement with American taxpayers. Data shows that roads act as an ignition source for wildfires and they are the most common places for wildfires to start. The US Forest Service's own data shows that roads are highly correlated with wildfires, with the majority of wildfires being started as a result of human activity within 50 meters of a roadway. Additionally, researchers found that there is a four times greater risk of fires starting near roads compared with roadless forests (Aplet et al., 2026). The administration's claim that the Roadless Rule prevents the US Forest Service from decreasing wildfire damage is simply false; repealing this rule will result in more fires (Aplet et al., 2026), further straining already at capacity wildfire fighting resources. This also places habitats and communities in increased danger, and home and business owners assume an increased risk for property damage, which has further economic implications. Regarding public health, wildfire smoke contributes to poor air quality for millions of Americans. Wildfire smoke composition is harmful to breathe, exacerbating chronic respiratory conditions and promoting the development of reactive airway conditions, like asthma (The American Academy of Allergy, Asthma, and Immunology, 2026). The administration's continued cuts to healthcare spending creates a situation where we should be focusing on reducing chronic illness, not promoting it. The economic implications of long-term chronic conditions are well established, and air quality is a major factor in chronic disease prevention. Local economies will suffer under this rule change, with the US Forest Service’s own economists stating that revoking the rule would result in a loss of up to $9 million annually in visitor spending to nearby communities that benefit from remote public land tourism. Additionally, the agency is already behind in existing road maintenance (US Forest Service, 2026); adding more dirt roads for the primary purpose of industry accessing forests, not for the benefit of American taxpayers, will further contribute to the road maintenance spending backlog resulting in an even bigger bill for taxpayers who are ultimately footing the bill for private industry to access our public lands (US Forest Service, 2026). Drinking water quality will suffer under this rule change for approximately 25 million Americans (Olden et al., 2026; US Forest Service, 2026). Increased soil erosion, sediment run off, and pollution will jeopardize remote watersheds that provide drinking water for millions of Americans (US Forest Service, 2026). At a time when we are facing more droughts and competition with industry for fresh water, this is a disastrous situation that will result in water shortages for millions of people. Additionally, the biological assessment provided by the US Forest Service highlights the negative impact on biodiversity and 327 threatened and endangered species. Seventy-one designated critical habitats are at risk with revoking this rule (US Forest Service, 2026). Biodiversity is the cornerstone of a healthy ecosystem. These lands are pristine and untouched American wilderness. Who are we that we would destroy our own world-renowned, iconic wilderness. This is our heritage. Americans take great pride in our protected, wild, public lands and I reject any actions by the federal government that would damage this, such as revoking the Roadless Rule. As an American taxpayer I fundamentally oppose this action that would result in unnecessary increased spending of our tax dollars, poorer air and water quality, destruction of old growth habitats and wildlife populations, and what represents an egregious misuse of our public lands with nothing in return, while industry makes billions in profits at our expense. I oppose. Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, et al. (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538 The American Academy of Allergy, Asthma, and Immunology. (2026, July 16). Wildfire Smoke, Asthma and the Immune System. https://www.aaaai.org/tools-for-the-public/conditions-library/asthma/wildfire US Forest Service. (2026, August). 2001 Roadless Area Conservation Rule Rescission. Draft Environmental Impact Statement. US Department of Agriculture.

I strongly oppose the rescission of the 2001 Roadless Rule. By ending this rule, it poses multiple threats to our forests and public health via increased wildfires, threatens local economies, jeopardizes clean drinking water for millions of Americans, endangers natural habitats and ecosystem biodiversity, and violates the public land agreement with American taxpayers. Data shows that roads act as an ignition source for wildfires and they are the most common places for wildfires to start. The US Forest Service's own data shows that roads are highly correlated with wildfires, with the majority of wildfires being started as a result of human activity within 50 meters of a roadway. Additionally, researchers found that there is a four times greater risk of fires starting near roads compared with roadless forests (Aplet et al., 2026). The administration's claim that the Roadless Rule prevents the US Forest Service from decreasing wildfire damage is simply false; repealing this rule will result in more fires (Aplet et al., 2026), further straining already at capacity wildfire fighting resources. This also places habitats and communities in increased danger, and home and business owners assume an increased risk for property damage, which has further economic implications. Regarding public health, wildfire smoke contributes to poor air quality for millions of Americans. Wildfire smoke composition is harmful to breathe, exacerbating chronic respiratory conditions and promoting the development of reactive airway conditions, like asthma (The American Academy of Allergy, Asthma, and Immunology, 2026). The administration's continued cuts to healthcare spending creates a situation where we should be focusing on reducing chronic illness, not promoting it. The economic implications of long-term chronic conditions are well established, and air quality is a major factor in chronic disease prevention. Local economies will suffer under this rule change, with the US Forest Service’s own economists stating that revoking the Roadless Rule would result in a loss of up to $9 million annually in visitor spending to nearby communities that benefit from remote public land tourism. Additionally, the agency is already behind in existing road maintenance (US Forest Service, 2026); adding more dirt roads for the primary purpose of industry accessing forests, not for the benefit of American taxpayers, will further contribute to the road maintenance spending backlog resulting in an even bigger bill for taxpayers who are ultimately footing the bill for private industry to access our public lands (US Forest Service, 2026). Drinking water quality will suffer under this rule change for approximately 25 million Americans (Olden et al., 2026; US Forest Service, 2026). Increased soil erosion, sediment run off, and pollution will jeopardize remote watersheds that provide drinking water for millions of Americans (US Forest Service, 2026). At a time when we are facing more droughts and competition with industry for fresh water, this is a disastrous situation that will result in water shortages for millions of people. Additionally, the biological assessment provided by the US Forest Service highlights the negative impact on biodiversity and 327 threatened and endangered species. Seventy-one designated critical habitats are at risk with revoking this rule (US Forest Service, 2026). Biodiversity is the cornerstone of a healthy ecosystem. These lands are pristine and untouched American wilderness. Who are we that we would destroy our own world-renowned, iconic wilderness. This is our heritage. Americans take great pride in our protected, wild, public lands and I reject any actions by the federal government that would damage them, such as revoking the Roadless Rule. As an American taxpayer I fundamentally oppose this action that would result in unnecessary increased spending of our tax dollars, poorer air and water quality, destruction of old growth habitats and wildlife populations, and what represents an egregious misuse of our public lands with nothing in return, while industry makes billions in profits at our expense. I oppose. Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, et al. (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538 The American Academy of Allergy, Asthma, and Immunology. (2026, July 16). Wildfire Smoke, Asthma and the Immune System. https://www.aaaai.org/tools-for-the-public/conditions-library/asthma/wildfire US Forest Service. (2026, August). 2001 Roadless Area Conservation Rule Rescission. Draft Environmental Impact Statement. US Department of Agriculture.

I am an environmental chemist. My work is dedicated to preserving and protecting water quality for people and the environment. Much of my research focuses on how healthy, intact forests perform numerous ecosystem services that clean and store our freshwater resources. I am also an avid recreation user of backcountry areas of our national forest system, having lived in Oregon, Washington, and Montana in addition to my current home in Vermont. I know and love many places that would be affected by the proposed rescission of the Roadless Rule and have several concerns as a scientist and citizen. Our national forest system was created around the turn of the 20th century to protect water quality. I’m concerned that new roads would lead to pollution of these vital watersheds, which is all the more important as new water demands (data centers, critical minerals extraction, and more) require further water resources. Roads and their construction increase erosion and pollution to the few remaining clean river systems we have left in our country. Forested lands generate higher quality water because microorganisms in soil and plant roots filter out contaminants before water arrives at treatment facilities. Cleaner water requires less treatment and processing, thus reducing treatment costs for public utilities and the taxpayer. Across the country, a growing number of water utilities are investing in watershed protection as a means to reduce cost and limit chemical use as demand for water rises. The rationale for the proposed rule does not take water quality into account. This is an oversight, as a recent study from the University of Washington and Conservation Science Partners published this summer in PLOS Water demonstrates that the Roadless Rule supports the drinking water supply for 25 million Americans (Olden et al. 2026). The results of Olden and colleagues show that rescinding the Roadless Rule would diminish protections for rivers and may deteriorate drinking water quality and affordability, reduce recreational opportunities, and threaten freshwater biodiversity. Maintaining the current Roadless Rule protections is thus critical for sustaining ecosystem services, supporting human well-being, and advancing broader conservation and resilience goals under increasing water demands. I urge the decision makers to review the proposal with water quality safeguarding as a key criterion. Olden, Julian D., Sandra L. Postel, Michael P. Dombeck, Helen Kesting, Patrick Freeman, and Lise Comte. 2026. “Assessing the Value of the U.S. Roadless Rule for People and Nature.” PLOS Water 5 (7): e0000538. https://doi.org/10.1371/journal.pwat.0000538.

Revision of submission Comment Tracking Number mux-agkz-hkuv. I added different language to my original comment. Thank you! I am respectfully writing in support of Alternative 1 – No Action (2001 Roadless Rule stays in place). I oppose any proposal to partially or fully rescind the Roadless Area Conservation Rule. My family lives in a state with no Roadless Rule areas and minimal places to go where a person can see and hear nothing but intact nature free from human development. To experience pristine, untouched lands that we love, we must travel. Oregon holds thousands of acres of Roadless Rule lands that we enjoy each year. It is impossible to describe how special the rivers, wildlife and forests, many being old growth, have become to us. The scent of the cinnamon/vanilla bark that protects the Ponderosa is a welcoming, calming scent every time I step out of the vehicle after a long trip to Oregon. Everything in these areas works together to create a sanctuary for living things. Humans need these wild places as much as the wildlife and plant life that make up these landscapes do. I oppose new roads in these areas as roads increase logging, mining/development, increase wildfire risks, habitat/ecosystem degradation, and cutoff routes for wildlife migration. There is no replacing these areas once they are destroyed. I am just an ordinary citizen. While I am sure my contribution in the form of this comment will fall far below what these areas deserve from me, it is my humble attempt to implore you to please keep these areas intact and protected by supporting Alterative 1 – No Action. •I ask the USDA to retain or strengthen the protections and standards in the current 2001 Roadless Area Conservation Rule. This rule helps protect rivers, water quality and wildlife as well as climate mitigation and helps retain current riparian measures. DellaSala, D.A., Karr, J.R., & Olson, D.M. (2011). Roadless areas and clean water. Journal of Soil and Water Conservation, 66(3): 78A–84A. doi.org/10.2489/jswc.66.3.78A Ellison, D., et al. (2017). Trees, forests and water: Cool insights for a hot world. Global Environmental Change, 43: 51–61. doi.org/10.1016/j.gloenvcha.2017.01.002 Standard reference on forest–water interactions and moisture recycling. •The Roadless Area Conservation Rule helps to protect old growth trees as many of the Roadless Rule areas contain tress that are larger than 21” in diameter. The 21” Rule, prohibiting logging of tress over 20” in diameter, along with the current Roadless Rule, protects Old Growth forests and the ecosystems contained within. This helps with climate mitigation, forest ecosystem health and water quality in and downstream from Roadless Areas. Mildrexler, D.J., et al. (2023). Protect large trees for climate mitigation, biodiversity, and forest resilience. Conservation Science and Practice. doi.org/10.1111/csp2.12944 Mildrexler, D.J., et al. (2020). Large trees dominate carbon storage in forests east of the Cascade crest in the United States Pacific Northwest. Frontiers in Forests and Global Change. Watson, J.E.M., et al. (2018). The exceptional value of intact forest ecosystems. Nature Ecology & Evolution. doi.org/10.1038/s41559-018-0490-x Law, B.E., et al. (2022). Strategic Reserves in Oregon’s Forests for Biodiversity, Water, and Carbon to Mitigate and Adapt to Climate Change. Frontiers in Forests and Global Change. frontiersin.org/articles/10.3389/ffgc.2022.1028401/full •The Roadless Area Conservation Rule has helped protect against wildfires. The majority of wildfires begin near areas NOT protected by the current Roadless Rule as a study by the Pacific Biodiversity Institute showed that over 90% of wildfires started within half a mile of a road. https://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf •The current Roadless Rule not only protects the lakes, streams and rivers that we and wildlife enjoy while out in nature, it also provides clean drinking water for over 25 million Americans. Protecting rivers is important for water quality and also the surround ecosystems. Protecting the rivers means to also protect the habitat that surrounds them. Through the Roadless Rule, 80,000 miles of rivers receive some kind of protections, with close to 62,000 miles only finding protection through the Roadless Rule alone. https://journals.plos.org/water/article?id=10.1371/journal.pwat.0000538 . Liu, N., et al. (2022). Quantifying the role of National Forest System and other forested lands in providing surface drinking water supply for the conterminous United States. USDA Forest Service Again, this is an attempt by an ordinary American, who is very much desperately, urging you to protect our public lands. Please join those that came before us in protecting these places. Stand up for public lands and the many millions who love them by supporting Alternative 1 – No Action.

To the USDA Forest Service: I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and to ask that the Forest Service keep the Rule in place in full. Let me be direct about where I stand. I do not want a single acre given up. I am deeply disappointed by the broader pattern of public land being taken from the American people, including the shrinking of national monuments and other protections we have lost. I want more public land, not less. These are our children's lands, and I do not believe it is fair or right to rescind this Rule and take them away from the next generation. I am an elementary teacher, a graduate student in education, and a mom. My family's best memories happen on public land. On a spring break camping trip, my husband and I watched our two kids spend an entire afternoon kneeling in a creek on the Ouachita National Forest, holding quartz up to the sunlight and asking where it came from. There was no admission fee and no gift shop, just wild ground that belongs to all of us. That very forest, which covers most of the Ouachita Mountains in Arkansas and Oklahoma, contains about 35,000 acres of Inventoried Roadless Areas across six roadless areas. In other words, the backcountry my children explored is precisely the kind of land this rescission would open to road building and logging. We are saving for a small travel trailer for one reason: to see more places like that before our children grow up. Those places only stay wild if they stay roadless. I see the same thing in my classroom. When my students learn outside, the child who cannot sit still becomes the one who spots the animal tracks, and the quiet child starts asking questions. Research supports what teachers see every day. Kuo, Barnes, and Jordan (2019) reviewed hundreds of studies and found converging evidence that experiences with nature boost children's academic learning, personal development, and environmental stewardship. Roadless forests are the outdoor classrooms of the next generation, and once a road is cut, that classroom is changed for good. The wildfire justification for this rescission does not hold up. A 2026 peer reviewed study of more than three decades of national forest fire records found that ignition density was about four times higher within 50 meters of roads (7.99 fires per 1,000 hectares) than in Inventoried Roadless Areas (1.97 per 1,000 hectares). The authors concluded that building roads into roadless areas is likely to result in more fires (Aplet et al., 2026). Most human caused fires start where people and vehicles can reach. Presenting new roads as fire prevention asks the public to accept more ignitions in the name of fewer. The current Rule already allows fuel reduction work where it is needed. What it prevents is new road building and commercial logging. Rescission also threatens the water families drink. Olden et al. (2026) found that watersheds influenced by roadless areas supply drinking water to at least 25 million Americans and protect over 130,000 kilometers of streams and rivers. They concluded that rescinding the Rule may compromise drinking water quality and affordability, reduce recreation, and threaten freshwater biodiversity. Even in Arkansas, where my kids found their crystals, about 9.5 percent of the population depends on these watersheds. Meanwhile, the Forest Service already carries a multibillion dollar maintenance backlog on the roughly 370,000 miles of roads it has now. Building more roads the agency cannot afford to maintain is not stewardship. Finally, the process matters. In 2001, the Forest Service held hundreds of public meetings and received 1.6 million comments. This time, the public was given a short comment period and no federally hosted hearings. A decision this permanent deserves far more public input. Please keep the Roadless Rule, every acre of it. My students and my children are counting on these places still being wild when it is their turn to explore them. Sincerely, Kyrietta Weber Apple Valley, Minnesota References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, Article 8. https://doi.org/10.1186/s42408-026-00450-2 Kuo, M., Barnes, M., & Jordan, C. (2019). Do experiences with nature promote learning? Converging evidence of a cause-and-effect relationship. Frontiers in Psychology, 10, Article 305. https://doi.org/10.3389/fpsyg.2019.00305 Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), Article e0000538. https://doi.org/10.1371/journal.pwat.0000538

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.I live in a Massachusetts town traversed by the Appalachian Trail and just across the border from the beginning of the Long Trail. The beauty and wild character of our region is critical for our local health and well-being, as well as our tourism-driven economy. As this letter makes clear, the Roadless Rule plays a crucial role in preserving the rural character of our region.For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million-acres of National Forest System lands, or about a third of all lands managed by the USDA Forest Service (Forest Service). In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the White and Green Mountain National Forests, combined. Iconic landscapes protected by the Rule include places like New Hampshire’s Franconia Notch, Mt Moosilauke, Mt Chocorua, and the Presidential Range, as well as Vermont’s White Rocks. The famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.In the context of the current biodiversity crisis, we should be doing everything in our power to preserve wild areas to support intact ecosystems and endangered species.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.AnneMassachusetts

To the USDA Forest Service: I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule, and to ask that it be kept in place in full. I am an engineer and a father, and I want to be clear about where I stand. I do not believe any of our public lands should be taken away. These places belong to all of us, and most of all to our kids. Taking them back now, acre by acre, is something I cannot support. I will be honest: the outdoors is fairly new to me as something I lead my own family into. For much of my life it was not a big part of what I did. Over the last couple of years my wife and I have started taking our two kids out into the woods ourselves, and it has changed us. This coming summer we are planning to head out west and spend real time in our public lands and national parks. As an engineer, I plan things carefully, and the single biggest reason those plans are even possible is that this land is public, open, and undeveloped. I am trying to give my kids everything I can, and some of the best of it costs nothing and cannot be bought — it only has to be protected. Last year our family took a trip through the Black Hills National Forest and down into Colorado, and without question the time we spent in the forests was our favorite part of the entire trip. Being in nature was what we all remembered most. The Black Hills is one of the most beautiful places we have ever seen, some of the finest country in all of South Dakota, and it holds roughly 13,000 acres of Inventoried Roadless Areas. It is one of the forests specifically named as losing protection under this proposal, and we do not want it stripped. Standing among those granite spires and pine forests, it is impossible to understand how anyone could look at that place and decide it needs more roads instead of more protection. That backcountry is exactly the kind of land this rescission would open to road building and logging, and we are saving for a small travel trailer for one reason: to reach more places like it while our kids are still young. I have looked at the reasons given for this change, and as someone who works with evidence for a living, they do not hold up. The wildfire argument is the one that bothers me most. A 2026 peer reviewed study of more than thirty years of national forest fire records found that ignition density was about four times higher within 50 meters of roads than in Inventoried Roadless Areas, and concluded that building roads into roadless areas is likely to result in more fires (Aplet et al., 2026). That matches plain common sense: most human caused fires start where people and vehicles can go. The current Rule already allows fuel reduction work where it is genuinely needed. What it stops is new road building and commercial logging. Calling more roads a fire solution gets the engineering backwards. There is also the matter of cost and water. Research found that watersheds shaped by roadless areas supply drinking water to at least 25 million Americans (Olden et al., 2026). At the same time, the Forest Service already carries a multibillion dollar maintenance backlog on roughly 370,000 miles of existing roads. Building more roads the agency cannot afford to maintain is not a responsible plan. No engineer would sign off on expanding a system that is already failing its upkeep. Sincerely, Luke Weber Apple Valley, Minnesota References Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, Article 8. https://doi.org/10.1186/s42408-026-00450-2 Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), Article e0000538. https://doi.org/10.1371/journal.pwat.0000538

Dear Joshua White, Acting Director of Ecosystem Management Coordination at the USDA Forest Service, and Members of Congress: The Climate Action Collective (CAC) respectfully writes to oppose the U.S. Forest Service’s proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). We urge the Forest Service to withdraw this proposal or select Alternative 1, No Action. The Climate Action Collective was established in Fall 2023 and consists of students from the University of Vermont, Champlain College, and Saint Michael’s College who engage in grassroots political action on local climate and environmental issues. Our goals are to cultivate a close-knit, welcoming, and engaging community; provide opportunities to connect with others professionally outside the classroom; and make a tangible difference in Burlington. Our work is centered on environmental justice and intergenerational justice. As college students, we recognize the importance of ensuring that younger generations have a voice in the decisions that will greatly impact our future. For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million acres of National Forest System lands, representing about one-third of all lands managed by the USDA Forest Service (Forest Service). The Inventoried Roadless Areas (IRAs) protected by the Roadless Rule represent some of the wildest, healthiest, and most intact landscapes in the United States (https://www.pfpi.net/wp-content/uploads/2026/06/Roadless-Rule-Rescision-Threatens-Preprint-Mildrexler-et-al.-2026.pdf). More than 1.5 million Americans submitted comments in support of the Roadless Rule when it was developed, setting a record for public participation in federal rulemaking that still stands today. In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the combined White Mountain and Green Mountain National Forests. Iconic landscapes protected by the rule include Franconia Notch, Mount Moosilauke, Mount Chocorua, and the Presidential Range in New Hampshire, as well as White Rocks in Vermont. The famous Long Trail and Appalachian Trail also traverse numerous Inventoried Roadless Areas protected by the rule. Equally important, the Roadless Rule safeguards clean drinking water, helps protect against floods and droughts, and supports the region’s native biodiversity, including imperiled species such as the northern long-eared bat, brook trout, Canada lynx, Bicknell’s thrush, and American marten. Only 3.3% of New England is protected from timber harvesting and road construction, yet scientists say we must protect at least 10% of the region to support biodiversity, carbon storage, and the well-being of our communities. Rescinding the Roadless Rule would reverse decades of conservation progress and make New England’s conservation goals even more difficult to achieve. Recognizing the exceptional value of Inventoried Roadless Areas, which account for just 2% of the contiguous United States, as well as the Forest Service’s multibillion-dollar backlog of road maintenance, the agency established the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the rule’s development. A recent study found that, in New England, the Roadless Rule helps protect drinking water sources for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents receive their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest. Importantly, the Roadless Rule is also one of our most valuable tools for addressing wildfire risk. Most wildfires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). By limiting road construction and development in roadless areas, the rule helps protect these landscapes from additional human-caused fire risks. The Roadless Rule also protects culturally significant sites and areas used for subsistence. These spaces are critical to food security for many Indigenous communities and help sustain cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts. For these reasons, we urge the U.S. Forest Service to withdraw its proposal to rescind the Roadless Rule or select Alternative 1, No Action, to preserve these essential protections for future generations. Finally, we call on our members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025 (H.R. 3930 and S. 2042) to codify the Roadless Rule into law. Thank you for your time and consideration. Sincerely, The Climate Action Collective

Acting Director, Ecosystem Management Coordination, USDA Forest Service Joshua White,Dear Joshua White, USDA Forest Service Acting Director of Ecosystem Management Coordination, and Members of Congress:I'm respectfully writing to oppose the US Forest Service's proposal to rescind the 2001 Roadless Area Conservation Rule (Roadless Rule). Please drop this plan or select Alternative 1, No Action.For a quarter century, the Roadless Rule has provided an essential layer of protection for approximately 58.5 million-acres of National Forest System lands, or about a third of all lands managed by the USDA Forest Service (Forest Service). “Inventoried Roadless Areas” (IRAs) protected by the Roadless Rule represent many of the wildest, healthiest, and most intact landscapes in the United States (https://www.pfpi.net/wp-content/uploads/2026/06/Roadless-Rule-Rescision-Threatens-Preprint-Mildrexler-et-al.-2026.pdf). Over 1.5 million Americans submitted comments in support of the Roadless Rule when it was developed, a record for public participation in federal rulemaking that still holds to this day.In New England, the Roadless Rule protects 260,000 acres, or approximately one-fifth of the White and Green Mountain National Forests, combined. Iconic landscapes protected by the Rule include places like New Hampshire’s Franconia Notch, Mt Moosilauke, Mt Chocorua, and the Presidential Range, as well as Vermont’s White Rocks. The famous Long Trail and Appalachian Trail traverse numerous Inventoried Roadless Areas protected by the Roadless Rule. Equally important, the Roadless Rule safeguards clean drinking water, protects against floods and droughts, and supports the region's native biodiversity, including imperiled species like the Northern Long-eared Bat, brook trout, Canada lynx, Bicknell's Thrush, and American marten, among many others.Only 3.3% of New England is protected from timber harvest and road construction, but scientists say we must protect at least 10% of the region for the benefit of biodiversity, carbon storage, and the wellbeing of our communities. Rescinding the Roadless Rule would set our region back in time, making New England's conservation goals even harder to achieve.Recognizing the exceptional value of Inventoried Roadless Areas (totaling just 2% of the lower-48 states), as well as the Forest Service’s unsustainable multi-billion dollar road maintenance backlog, the agency promulgated the Roadless Rule as “a down payment on the well-being of future generations,” in the words of former Forest Service Chief Mike Dombeck, who oversaw the Rule’s development.A recent study found that in New England, the Roadless Rule helps to protect drinking water for 8.8% of Vermont residents and 7.3% of New Hampshire residents (https://doi.org/10.1371/journal.pwat.0000538). Additionally, 7% of Massachusetts residents get their water from sources that originate in Inventoried Roadless Areas in the White Mountain National Forest.Importantly, the Roadless Rule is also among our best tools for addressing wildfire. Most fires are started by people, and a recent study found that fires are four times more likely to start near roads (https://doi.org/10.1186/s42408-026-00450-2). The Roadless Rule also protects culturally-important sites and subsistence use areas. These spaces are critical to food security for many indigenous communities as well as for sustaining cultural and spiritual practices, including hunting, fishing, and gathering forest plants for food, medicine, and traditional arts.It is so important to protect the remaining wild places that we have in this country. This is imperative for the health of humanity because of the aforementioned "ecosystem services" that such places provide. But even more than that -- these places and their inhabitants have rights too: the rights to retain their wellness and sovereignty in a world not merely inhabited by humans, but dominated by us. Can't we draw a line somewhere, and say that we are not going to desecrate the last remaining wild places that there are?Please drop this plan to rescind the Roadless Rule or select Alternative 1, No Action.Finally, I am calling on my members of Congress to co-sponsor and pass the Roadless Area Conservation Act of 2025, H.R.3930 and S.2042, to codify the Roadless Rule in statute.Thank you.MonicaVermont

I strongly OPPOSE the proposal to rescind the 2001 Roadless Rule. The potential impacts on wildlife are staggering. While the National Forest system is multi-use, there should be significant, weighted consideration for the uses that cannot be returned once destroyed, particularly in terms of our country’s biodiversity. Even amongst plant species, functional biodiversity decreases after road construction, especially in mountainous habitats (Li et al). Roads negatively affect wildlife through effects of pollution from salt, sediment, chemical run-off, dust, noise, light (Bennett), and also increases habitat fragmentation which causes a loss of species diversity. Roadless areas additionally “protect more rare and declining land-cover types, such as aspen, whitebark pine, sagebrush and grassland communities, than existing protected areas” (Crist et al). Aside from wildlife, roadless forested watersheds also help protect water resources. Olden et al found that forested watersheds that are part of Inventoried Roadless Areas under the 2001 Roadless Rule ensure clean drinking water for more than 25 million citizens in the western US. Their paper notes that many of these forested areas “overlap substantially with high-demand hunting and fishing areas and support diverse aquatic biodiversity,” thereby benefitting the human demand for recreation. On a personal note, I hold a deep love and appreciation for the natural beauty of this country and have enjoyed spending time in public lands, including areas protected under the 2001 Roadless Rule. I have spent a great deal of time in roadless areas in Montana, including the Bitterroot, Beaverhead-Deerlodge, Lolo, and Flathead National Forests. I would be profoundly saddened if these areas were opened up for timber, mining, or other industries that would require roads built on these lands. They are special to me indeed because of recreation, but overwhelmingly because of the unique flora and fauna they preserve. This is why I believe biodiversity needs to be taken seriously as a reason to uphold the 2001 Roadless Rule. I urge the USDA to keep the 2001 Roadless Rule and reject this current proposal. Sincerely, Eliza Seigel Citations Bennett, V. J. (2017). Effects of road density and pattern on the conservation of species and biodiversity. Current Landscape Ecology Reports, 2(1), 1–11. https://doi.org/10.1007/s40823-017-0020-6 CRIST, M. R., WILMER, B., & APLET, G. H. (2005). Assessing the value of roadless areas in a conservation reserve strategy: Biodiversity and landscape connectivity in the Northern Rockies. Journal of Applied Ecology, 42(1), 181–191. https://doi.org/10.1111/j.1365-2664.2005.00996.x Li, H., Luo, P., Yang, H., Luo, C., Xie, W., Jia, H., Cheng, Y., & Huang, Y. (2022). Assessing the effect of roads on mountain plant diversity beyond species richness. Frontiers in Plant Science, 13, 985673. PubMed Central. https://doi.org/10.3389/fpls.2022.985673 Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. roadless rule for people and nature. PLOS Water, 5(7), e0000538. https://doi.org/10.1371/journal.pwat.0000538 See attached file(s).

The roadless rule currently conserves considerable swaths of the iconic American landscape for recreation, while simultaneously protecting wildlife and irreplaceable forested lands from excessive encroachment from development. I strongly oppose this revision to the roadless rule, which pretends to be in the best interest of fire mitigation, but is truthfully an attempt to dismantle our public lands for private profit. What use is it to cut down and destroy what little woods that remain just to sell them to foreign markets that are oceans away? Further, I have not yet seen the U.S. Forest Service appropriately respond to literature supporting the roadless rule as it currently stands. I would like to see detailed review and thorough response to Kilbride et al. 2026 (DOI: 10.1111/csp2.70411), Cornwall 2026 (DOI: 10.1126/science.aem2421), Olden et al. 2026 (DOI: 10.1371/journal.pwat.0000538), and Bishop 2026 (ISSN: 0001-8368). I believe in the strength of the USFS to protect the places Americans value most, and to serve many interests. I strongly disagree with the idea that these rule changes are in the best interest of the public, who you serve. We are not so poor as to have to destroy our lands, nor so rich that we can afford to.

Roadless rule comment I live in Camino, California and am writing to urge the U.S. Department of Agriculture to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. My connection to US National Forest lands includes living near a National Forest (El Dorado being the nearest), being a traditional climber, hiker, and wildlife fan and advocate. Lands without roads are important personally because they connect me directly to the wild, without the barrier of motorized vehicles. Lands like this are calmer, more beautiful, and preserve wildlife and their habitat better than lands crossed by roads. As importantly, roadless forests and lands protect watersheds and natural environments. As you know, the 2001 S. Forest Service Roadless Area Conservation Rule (Roadless Rule) established Inventoried Roadless Areas (IRAs) to protect watersheds, soil, plants, and wildlife habitats. This rule should be upheld. A 2026 paper by Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, et al., discusses the importance of the Roadless rule to this end. Per the authors, “IRA-influenced watersheds supply drinking water to at least 25 million Americans.” In this 2026 paper, Olden, JD, et al, also found through their research that IRAs overlap with many hunting and fishing areas. Rescinding the rule would likely disrupt these valuable environments that hunters and fisherman wish to continue to enjoy. IRAs protect rivers, forests, deserts, and inhabitants of these lands. Apart from watershed impact, I am concerned about wildlife habitat and landscape connectivity. Large land areas void of roads provide safer and more natural landscapes for animals. Habitats broken up by roads impact wildlife behavior. Roads through wild habitat also expose animals (including humans) to greater risk of injury and death from drivers. Roadless areas are important to me for recreation and communing with nature. When roads are far away, people are able to experience nature in a special and primitive way that is more and more difficult to do now, given increased development. I am concerned about how USDA is weighing wildfire, management flexibility, and the effects of increased access. The roadless rule does allow exceptions to construct new roads to fight and manage fires. Recision is not necessary. Additionally, roads themselves increase human access further into nature which creates more opportunities for human caused fire ignition. Before rescinding the national rule, I would like USDA to answer this question: How would USDA weigh the potential for roads to provide management access against the additional opportunities for human-caused wildfire ignitions that can accompany increased access? For these reasons, I urge USDA to retain the 2001 Roadless Area Conservation Rule and select the No Action Alternative. Thank you for considering my comments. Sources Assessing the value of the U.S. Roadless Rule for people and nature Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, et al. (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538.https://doi.org/10.1371/journal.pwat.0000538

I oppose the proposed rescission and urge the Department to select the no-action alternative, keeping the 2001 Roadless Rule in full. The stated rationale is wildfire and active management, but the peer-reviewed evidence points the other way. A 19922024 analysis of all eight contiguous Forest Service regions found 7.99 ignitions per 1,000 hectares within 50 meters of roads, against 1.97 in inventoried roadless areas, and concluded that building roads into roadless areas is likely to produce more fires (Aplet et al. 2026). The existing rule already has exceptions that allow timber projects aimed at reducing wildfire risk, so rescission is not needed to treat fuels where it matters. Rescission would also put water supplies at risk. Roadless areas are the primary protection for more than 100,000 km of streams and rivers, and watersheds they influence supply drinking water to at least 25 million Americans (Olden et al. 2026). Road construction and logging raise sediment loads and treatment costs for downstream communities. The final EIS should address these findings directly and explain how more roads would reduce, not increase, fire starts. I am a lifetime beneficiary of the services derived from US roadless areas. I have hiked the Appalachian Trail through roadless areas in Virginia, North Carolina and New Hampshire and have benefitted from the wildlife habitat services of roadless areas in many other states. Roadless areas are a uniquely American invention. No other country in the world has had the foresight to protect wildlands such as these for future generations. It is inconceivable to me that we would forgo the benefits of these uniquely productive areas on such flimsy grounds as those proposed. Sincerely, Christopher J. Ruhm, Charlottesville, VA 22901 References: Aplet, G.H., Hartger, P., & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology 22:8. https://doi.org/10.1186/s42408-026-00450-2 Olden, J.D., Postel, S.L., Dombeck, M.P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in Northern California and regularly go on walks through the redwoods and other forests. Studies show that the roadless rule keeps our forests protected. https://link.springer.com/article/10.1186/s42408-026-00450-2 According to this study, "From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas, followed closely by Inventoried Roadless Areas. The highest wildfire-ignition density was in lands within 50 m of roads, 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." Old growth forests need to be protected. Mature and Old-Growth Forests store huge amounts of carbon. They are an excellent component to help mitigate climate change. They're much more efficient at sequestering carbon than newer planted forests. When roadless areas are protected, and thus old growth forests, it gives the best chance for old growth forests to survive and grow. Once old growth trees and forests are gone, they are gone forever. This is not something that can be undone. These are forests that took centuries, some over a thousand years. They are often biodiverse and home to rare species who depend on these forests and lands for survival. The impacts are vast and may irreparable. “The roadless rule supports the drinking water supply for 25 million Americans and offers critical protection of wildlife habitat and recreational assets. In short, rivers in roadless areas are essential for both people and nature,” according to the lead author of a new study from the University of Washington and Conservation Science Partners https://journals.plos.org/water/article?id=10.1371/journal.pwat.0000538 “Forest cover is well recognized for generating economic benefits by avoiding the large capital costs of water treatment plants needed to ensure clean, safe drinking water for people." Forested lands provide higher quality water because soil microbes and plant roots filter contaminants before water arrives at treatment facilities. New road construction and logging could impair the quality of the water we drink, impacted by chemicals used during building, as well as sediment buildup in lakes and rivers, which would need to be filtered out. Please preserve the roadless rule in it's current entirety.

October 5, 2026 Dear Director, Ecosystem Management Coordination Comments on docket number FS-2025-0001-223869, Special Areas: Roadless Area Conservation I support the “no action” Alternative 1, and oppose any proposal that fully or partially rescinds the Roadless Area Conservation Rule. The rule is one of the most important land conservation policies in our nation, conserving the highest integrity forests in the US.[1] The Roadless Rule has proven its effectiveness through the many values these areas provide, clean drinking water, critical wildlife habitat and carbon storage in mature and old-growth forests, cultural values, increased human health, and world class recreation. IRAs provide these valuable and irreplaceable ecosystem services free of cost. I live in Northeast Oregon, where Roadless Areas play an integral role in connecting habitat for wildlife and providing places for recreation for our family and our community. The main justification for rescinding the rule, that more roads are needed to reduce wildfire risk, is not supported by scientific research or the DEIS. Science clearly shows that roads are the dominant place where fires start and adding more roads will increase fire risk. In a study of three decades of fire ignitions, wilderness and roadless areas had the lowest ignition densities, while areas near roads had the highest wildfire ignition density because people start the most fires.[2] The DEIS's own analysis found that “The total number of wildfires originating on NFS lands from 2014 to 2024 is lowest within wilderness, followed by potentially affected IRAs, and highest on other NFS lands (Table 18).” At 101 the DEIS states that “With increased road construction, especially open-access roads, and other human activity, there could be increased hazard from human-caused ignitions.” Burning government time and money on building more roads and logging in our country's most intact, backcountry forests will worsen wildfire risk. The Forest Service can't afford to take care of the roads it already has and runs an over $10.8 billion deferred maintenance backlog mostly due to roads.[3] Fiscal considerations of building additional roads were a major concern and rationale for the 2001 Roadless Rule. With road maintenance costs already on the rise, adding even more roads that are expensive to build and costly to maintain in remote areas is grossly uneconomic. Roadless areas provide many valuable services that are degraded by road-building like clean drinking water. A recent study found that IRAs protect watersheds that supply drinking water to over 25 million Americans.[4] One-third of the populations of Colorado, New Mexico, and Montana source drinking water to IRA-influenced watersheds, and eastern US IRAs are smaller, but disproportionately important because of their proximity to large urban centers. IRAs are critical drinking-water infrastructure for the American people. Scientific research and the DEIS show that the justifications for rescinding the Roadless Rule are wrong. I support alternative 1 and respectfully urge you to leave the Roadless Area Conservation Rule unchanged. Sincerely, Andrea Mildrexler [1] Mildrexler, D.J.; Berner, L.T.; Law, B.E.; Booth, M.S. Roadless Rule Rescission Threatens Highest Integrity Forest Ecosystems in the United States. Biol. Conserv. 2026, 321, 111950. https://doi.org/10.1016/j.biocon.2026.111950 [2] Aplet, G.H., Hartger, P., and Dietz, M.S. (2026). Three-decade record of contiguous-US national forest wildfires indicates increased density of ignition near roads. Fire Ecol. 22, 8. https://doi.org/10.1186/s42408-026-00450-2 [3] USDA Forest Service (2025b). Fiscal Year 2025, Quarter 2 Deferred Maintenance Needs. https://www.fs.usda.gov/sites/default/files/fy25-q2-deferred-maint-report.pdf. [4] Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538

The roadless rule protects our national forests, and helps preserve water quality, fish habitat, hunting grounds, outdoor recreation, and keep our uniquely wild land wild! Public lands are a uniquely American treasure and value. The roadless rule represents the culmination of policy from the largest public comment period and diverse set of stakeholders our national forest system has seen in its history. Repealing it would be shortsighted, and allow these national treasures to be pillaged instead of providing a pilgrimage to wilderness for countless Americans. The forest service’s own report (USDA Forest Service. Appendix H: Inventoried Roadless Area Characteristics. Final Environmental Impact Statement, Forest Plan Revision, Southwest Idaho Ecogroup (Boise, Payette, and Sawtooth National Forests). Pages H-1 to H-72+) indicates that roadless areas have distinctly high water quality specifically because of the lack of disturbance from roads. Roadless areas protect over 80,000 miles of streams and rivers in the contiguous United States alone, which provides clean drinking water for an estimated 25 million people (Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538). If that is not something worth protecting, I do not know what is. Our existing network of forest roads is already in a state of disrepair from lack of funding. Building more would not help maintain this existing infrastructure. Additionally, building additional roads into our national forests would provide more opportunities for human started wildfires. As discussed in Aplet, Hartger & Dietz (US national forests, 1992-2024), ignition density is highest within 50m of roads. Comparing ignition rates between 0 and 250m of roads to those ignited beyond 2000m of roads found that the closer range was 3 times as prevalent. As such, building additional roads would merely provide additional opportunities for human caused ignition. In an unprecedented age of climate change, we need to stack the deck for our forests and for humanity, and cannot risk needless loss of forests when they will already be strained through heatwaves, droughts, and desertification. Please, for the sake of future generations, and to stand by the visions of the forest service’s founding figures of Teddy Roosevelt and Gifford Pinchot, keep these forests serving the American public, not just providing a financial boon for today’s timber barons.

Re: Special Areas: Roadless Area Conservation, RIN 0596-AD66, Docket FS-2025-0001 I strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge USDA to adopt the No Action alternative. I care deeply about our last remaining wild lands, including the meagre remnants of old growth forest and minimally disturbed ecosystems that are left in our country. 1. The DEIS itself documents significant harm to water resources. According to the Forest Service's own Draft EIS, the preferred alternative would increase soil erosion, landslide risk, and sediment pollution (p. 108) in watersheds that supply drinking water to roughly 24 million Americans (p. 121). Independent peer-reviewed work confirms the stakes: a 2026 PLOS Water study (Olden et al., DOI: 10.1371/journal.pwat.0000538) mapped how the rule protects rivers, and its authors note that roadbuilding and logging can cause sediment build up in lakes and rivers, which must be filtered out, raising treatment costs for downstream communities. The agency has not demonstrated that forest-plan-level management can replace these protections. 2. Roads are well documented to harm salmon and trout. Decades of research, including Trombulak & Frissell (2000, Conservation Biology) and the Forest Service's own synthesis Forest Roads (Gucinski et al. 2001, PNW-GTR-509), show that roads increase fine sediment, alter hydrology, and block fish passage. As researchers on the 2026 study summarized, roads negatively affect trout and salmon populations by degrading water quality, fragmenting habitat and creating barriers to fish passage. Roadless watersheds are among the last intact cold-water refugia for ESA-listed salmonids, and losing them would undercut decades of federal and state recovery investment. 3. The DEIS finds broad adverse effects on imperiled wildlife. The agency's preliminary biological assessment concluded the plan is likely to adversely affect 327 threatened and endangered species and 71 designated critical habitats (p. 25, 161–162). Roadless areas cover just 2% of the land in the lower 48 states, yet provide habitat for 57% of the country's vulnerable terrestrial species, according to an analysis by the NGO Defenders of Wildlife. A Center for Biological Diversity analysis found that scrapping the rule would put 7.4 million acres of designated endangered species critical habitat and nearly 1,800 miles of protected rivers and streams at risk. The DEIS also notes that old-growth forest that has been off-limits for 25 years would be exposed to new logging (p. 78). USFS’s own analysis shows Roadless Rule repeal would harm wildlife, water, and rural communities 4. The stated rationale does not outweigh these costs. The agency concedes that funding and terrain constraints would make any actual gain in fuel-treatment capacity "modest" (p. 225), assumes timber revenue would not be sufficient to cover the costs of constructing and maintaining all new roads, and acknowledges the plan would add to the agency's $6.9 billion existing road maintenance backlog (p. 43). Unmaintained roads are a leading source of chronic sediment delivery to streams, compounding the harms above. 5. Process concerns. A 45-day comment period is inadequate for a 333-page DEIS affecting 44.7 million acres. I request an extended comment period and public hearings in affected states, including California. 6. We cannot afford to lose more of our remaining wild lands. Inventoried roadless areas are some of the last large, undeveloped forests left on public land, and once roads are cut into them, that wild character cannot be restored on any meaningful timescale. Development, fragmentation, and climate stress are already shrinking intact habitat nationwide. The Roadless Rule is one of the few safeguards keeping these places whole, and giving it up would be an irreversible loss for wildlife, clean water, and future generations. For these reasons, I urge USDA to withdraw the proposed rescission and retain the 2001 Roadless Rule. Respectfully, Amit Bhagwat, Irvine, CA

I would like to strongly urge the USDA & USFS to retain the 2001 Roadless Area Conservation Rule. The USDA may believe that rescinding the rule is necessary for wildfire prevention but current research rejects this notion. Instead, research from the USFS itself has indicated that forests with and without roads have burned at similar rates ever since the roadless rule came into effect (Healey, 2020). Given the neutrality of roads upon wildfire impact in Inventoried Roadless Areas (IRAs), it is then important to address the immense benefits of retaining IRAs in contrast to their other heavy downsides. IRAs have tremendous public recreation demand for activities like hunting and fishing. Rescission of the rule would risk destroying these opportunities against the public’s interest (Olden et al., 2026). Moreover, IRAs have been a triumph in protecting species of conservation concern (SCCs). Research shows that IRAs contain critical wildlife habitat across taxa with 57% of SCCs in the contiguous United States having suitable habitat in at least one or more IRAs. As for what we stand to lose, research suggests that increased road construction in IRAs will result in increased spread of invasive plants and damage to the watersheds that 25 million Americans rely on for clean drinking water (Healey, 2020 & Olden et al., 2026). Vehicles will bring in seeds of invasive species to IRAs that were previously undisturbed while increased industrial activity and sediment from road construction will pollute watersheds (Olden et al., 2026). Worst of all though, is that this proposed rule rescission is not fiscally sound. If the USDA truly wanted to mitigate the issues land managers and wildland firefighters face, then it would secure and commit funding resources to its already heavily backlogged maintenance requirements for the existing National Forest Road System. As of FY2023, the total cost for the USFS deferred maintenance is already at a whopping $8.6 billion. Instead the USDA is choosing to completely jeopardize all of the benefits IRAs bring us so that commercial logging can swiftly overcome this administrative hurdle for short term profit from irreplaceable old growth resources at exorbitant public expense. So, I ask once again that the USFS & USDA abandon this attempt to rescind the 2001 Roadless Area Conservation Rule. Instead, I urge them to see the tremendous cultural, social, economic, and conservation value in IRAs and the heavy threats people and ecosystems alike will face from the reckless increased road construction. I also urge the USDA & USFS to instead more closely collaborate with local land managers and state governments for the existing exceptions to IRAs backed by science and to fund the already underfunded National Forest Road System. Works Cited: Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32, e01943. https://doi.org/10.1016/j.gecco.2021.e01943 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15(10), 104023. https://doi.org/10.1088/1748-9326/aba031 Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), e0000538. https://doi.org/10.1371/journal.pwat.0000538