Read the comments.

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.

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.

I adamantly am opposed to the revision of the Roadless Rule. I live in North Carolina. I previously have lived in California, Colorado, and New York, all of which have areas currently protected by the Rule. I am concerned in regards primarily to watershed and drinking water safety, wildfire safety, biodiversity and habitat protection, and recreation opportunities. With regards to watershed and drinking water safety: the drinking water of the United States needs these protected areas to remain safe and clean to feed our wells and municipal water reserves. Western states are already struggling to manage sharing water resources. With current trends, streamflow reductions of 10-35% are likely for western states in the next fifty years (Barnett and Pierce 2009). "A 10% drop in streamflow is considered calamitous by municipal water districts." (DellaSala et al., 2011)(https://doi.org/10.2489/jswc.66.3.78A) The cost of sedimentation due to road runoff would massively impact these already-stressed waters. According to the 2011 study by DellaSala et al., water treatment plants and highway departments save up to an estimated $18 Billion from avoiding sedimentation caused by logging in IRA watersheds.(https://doi.org/10.2489/jswc.66.3.78A). With regards to biodiversity and habitat protection, Trombulak et al. (2000) notes the seven ways that roads affect ecosystems: "(1) increased mortality from road construction, (2) increased mortality from collision with vehicles, (3) modification of animal behavior, (4) alteration of the physical environment, (5) alteration of the chemical environment, (6) spread of exotic species, and (7) increased alteration and use of habitats by humans. The 13,107,812 km of road lanes in the conterminous United States have destroyed at least 4,784,351 ha of land and water bodies that formerly supported plants, animals, and other organisms. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated." (https://doi.org/10.1046/j.1523-1739.2000.99084.x) Once these roads are built, it is impossible in any foreseeable future to undo these effects. With regards to wildfire safety, the vast majority of fires take place in the areas closest to roads, according to a 2025 study by the Wilderness Society. (https://roadless.org/resources/roads-fire-risk-analysis-2025.pdf) "From 1992 to 2024, in all 8 contiguous-US Forest Service regions combined, wildfire-ignition density was lowest in designated wilderness areas (1.7 fires/1,000 hectares), followed closely by that in Inventoried Roadless Areas (1.9 fires/1,000 ha). The highest wildfire-ignition density was in lands within 50 meters of roads (7.4 fires/1,000 ha), and the second highest wildfire-ignition density was in lands outside of the 100-m road buffers, but not in wilderness or roadless areas (3.5 fires/1,000 ha)." Wildfires are already a massive risk to communities across not only the West and Mountain West, but also across the United States, including in North Carolina. As for recreational opportunities, the Roadless Rule currently protects many of the United States' most valued backcountry recreation areas, which I myself utilize and enjoy frequently. These forests provide clean air and water, fight climate change, and are the backbone of a $1.3 trillion outdoor recreation economy that supports 5.2 million jobs, according to a 2026 Outdoor Alliance white paper. The same paper notes that rolling back the Roadless Rule "could unwind protections for 45 million acres of national forests, putting at risk: 25,121 miles of trails, 8,659 climbing routes, 768 miles of whitewater, 10,794 miles of mountain biking. (https://www.outdooralliance.org/roadless) According to a US Fish & Wildlife Service study on the Izembek Wilderness, "Construction of a road through the existing wilderness and the predicted increase access to the wilderness via all-terrain vehicles (legal and illegal) would result in major impacts to the four indicators of wilderness character: untrammeled quality, natural quality, undeveloped quality, and opportunities for solitude or primitive and unconfined recreation." (https://www.fws.gov/sites/default/files/documents/2024-03/08-chapter-4-environmental-consequences.pdf) The 5000-character limit is insufficient to adequately address the many issues with rescinding the Roadless Rule. These are simply the ways in which it would affect me, personally. I urge every reviewer to take all concerns into consideration above the short-term profits of logging expansion.

I am a PhD candidate in Earth Science and I am concerned about the environmental impacts of road construction in forests currently protected by the Roadless Rule. I strongly support the No Action alternative (Alternative 1) in the current Draft Environmental Impact Statement. While the proposed rescission claims that removing roadless area protections will reduce wildfire risks, a mounting body of research evidence proves the contrary. For example, a three-decade record of national forest wildfires finds that “The ignition density of human-caused wildfires within 250 m of a road was more than three times greater than at any distance beyond 500m during the study period and exceeded the ignition density of lightning fire near roads by almost twofold.” The authors conclude that “building roads into roadless areas is likely to result in more fires” (doi.org/10.1186/s42408-026-00450-2). While the proposed rescission claims to address conservation objectives including preserving sources of public drinking water, peer-reviewed research provides strong evidence that removing protections for Inventoried Roadless Areas (IRAs) directly threaten these sources. For example, DellaSala et al. find that “Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost.” IRAs make up 661 of the 914 national forest watersheds, with 55% of the 914 watersheds acting as source areas for facilities that treat and distribute drinking water to the public. Removing roadless area protections will have costly and damaging impacts on drinking water infrastructure: “The cost-savings to water treatment plants and highway departments from avoiding sedimentation caused by logging in IRA watersheds is estimated at up to $18 billion annually” (doi.org/10.2489/jswc.66.3.78A) While the proposed rescission claims to address conservation objectives such as preserving the diversity of plant and animal species, peer-reviewed research demonstrates that removing Inventoried Roadless Area (IRA) protections will directly contradict this objective. For example, Watson et al. find that “There is a direct correlation between the risk of species extinction and human footprint. Impacts such as direct habitat loss, habitat degradation through increased isolation of plant and animal populations, greater exposure to edge effects, and invasion by disturbance-adapted species are cumulative, leading to degraded ecosystems over time and, eventually, loss of regional connectivity and biodiversity” (doi.org/10.1038/s41559-018-0490-x). Additionally, Dietz et al. find that, “Of the 537 wildlife species of conservation concern in the contiguous United States, 308 species (57%) have at least some suitable habitat in one or more inventoried roadless areas. Despite their geographic and elevational clustering and predominance of a single biome type, IRAs provide a larger proportion of suitable habitat for multiple wildlife SCCs than non-IRA lands. If all IRAs were added to the protected-area system, there would be a substantial decrease (−38) in the number of wildlife SCCs that are currently considered 'poorly represented' in protected areas.” (doi.org/10.1016/j.gecco.2021.e01943) As an outdoor enthusiast, scientist, and concerned citizen, I urge the USDA to maintain 2001 Roadless Area Conservation Rule protections in full.

I would like to oppose rescinding the federal 2001 roadless rule. This rule prohibts road construction and logging on nearly 60 million acres of Forest Service land. This rule protects our wild and wildnerness spaces, reduces risk of wildfires, and helps to support our ecosystem overall. A study conducted by the forest service based on 20 years of data itself concluded that more roads to NOT lead to better forest health and, in fact, increase the spreaad of invasive plant species and do not increase fire-management activity (Healey, 2020). Another study that analyzed 32 years of data (Aplet, Hartger, & Dietz, 2026) demonstrated that wildfires ignition rates in roadless areas is considerably lower than areas closer to roads. A 2019 study indicated that in Utah alone over 100 species of plant and animals are at risk of decline without the protections of the roadless rule (McClure, & Dickson, 2019). Additional research has indicated that rescinding the roadless rule will impact our drinking water as roads play a major role in movement and contamination of sediments in water sources (DellaSala, 2011; DaSala, Karr, & Olson, 2011). There are no long-term benefits of rescinding this rule. Any perceived benefits are short-lived and short-sighted. Citations: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 DellaSala, 2011. Roadless ares and clean water. Journal of Soil and Water Conservation, 66(3): 78A-84A DOI:10.2489/jswc.66.3.78A 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. https://doi.org/10.2489/jswc.66.3.78A Healey, 2020. Long-term forest health implications of roadlessness, 15, 1748-9326, DOI:10.1088/1748-9326, 10, Environmental Research Letters, IOP Publishing McClure, & Dickson, 2019. Predicted impacts of Utah's roadless areas proposal: Biodiversity loss, habitat fragmentation, and ecosysten degradation. Conservation Science Partners.

I am writing in opposition of rescinding the Roadless Rule. I support the Alternative 1, the No Action alternative. National forests provide people with many recreational opportunities, like hunting, fishing, hiking, camping and rafting. I personally like the opportunities for camping, hiking, swimming and just being in nature that national forests provide. We need to have pristine areas of wilderness. Wildlife needs somewhere to live without human intervention, preferably large areas that aren’t fragmented. “Habitat fragmentation is considered to be one of the single most important factors leading to loss of native species (especially in forested landscapes) and one of the primary causes of the present extinction crisis” — Heilman et al., 2002 (https://doi.org/10.1641/0006-3568(2002)052[0411:FFOTCU]2.0.CO;2) We also need clean air and water and forests help with that. “Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes.” — DellaSala et al., 2011 (https://doi.org/10.2489/jswc.66.3.78A) “Logging roads have been linked to great increases in erosion rates and sediment delivery to streams—up to 850% over rates in undisturbed habitat” — DellaSala et al., 2011 (https://doi.org/10.2489/jswc.66.3.78A) Opening up the land to more roads, logging and mining could cause more pollution, disrupt wildlife and cause fires. “our findings—that forests with the highest levels of protection from logging tend to burn least severely—suggest a need for managers and policymakers to rethink current forest and fire management direction” — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492) I believe all national forests need to be protected. Each area has its own ecosystem, habitat and climate and all are important. We need the diversity of flora and fauna of each area. Each landscape offers something unique and is worthy of protection. The national forests belong to everyone and we should not open them up to corporations, but protect and save them for future generations. Once we destroy our public lands there is no getting them back.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I strongly oppose the Forest Service’s proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule, and I support Alternative 1, No Action. I live in Seattle, Washington and spend most of my weekends recreating outdoors in many of Washington State's 139 roadless areas. As an avid hiker, backpacker, trail runner, skier, and climber, I am incredibly grateful and in awe of the many unique, beautiful areas that I am able to recreate in because they have been federally protected with the intent that they remain minimally or undisturbed for the enjoyment of all citizens. The rescission of the Roadless Rule would cause me to lose that peaceful experience in some of my favorite places in Washington State, such as the Alpine Lakes Adjacency (Wenatchee National Forest, Washington) where I recently hiked with a friend to see the larches glow golden in the early morning Fall sunshine. Western larches are just one of many species that are only found in specific ecological habitats and elevation bands, and are likely to further narrow their ranges due to warming climate trends. Roadless areas are critical to maintain such species: "77% of inventoried roadless areas have the potential to conserve threatened, endangered, or imperiled species" (Loucks et al., 2003 https://doi.org/10.5751/ES-00528-070205). The Roadless Rule constrains road construction specifically (while allowing for other mulit-uses like grazing) because road construction is the enabling condition for nearly every documented threat to the lands — fragmentation, sedimentation, invasive species, fire ignition, extractive activity (Trombulak & Frissell 2000, https://conbio.onlinelibrary.wiley.com/doi/10.1046/j.1523-1739.2000.99084.x), all of which would harm my ability to recreate in these wild, gorgeous regions of my home state. As both an avid outdoors person, and a constituent, I'm greatly concerned by any potential for increased wildfire risk and air quality impacts from the smoke. Unfortunately, evidence from studies suggest that rescission of the Roadless Rule would make wildfires worse, not better. A 2026 study of three decades of National Forest System wildfire data found that wilderness and Inventoried Roadless Areas (IRAs) have the lowest ignition densities of any land category studied (Aplet et al. 2026). Furthermore, wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest, and most ignitions near roads are human-caused (Narayanaraj & Wimberly 2012). Thus, it's reasonable to conclude that introduction of additional roads into current IRAs could to lead to an increase in wildfires. As a constituent in Washington State, I am also acutely aware that my access to ample, clean water is directly tied to the continued presence of undisturbed natural ecosystems, such as those that are currently protected by the Roadless Rule. If the Roadless Rule is rescinded, there will be impacts on the quality of the water available to us, which is especially concerning as Washington faces more frequent droughts: "When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes" (DellaSala et al., 2011, https://doi.org/10.2489/jswc.66.3.78A). I am further concerned that the recission of the Roadless Rule will lead to higher costs of water in many regions of Washington State, due to higher water treatment expenses. Municipalities are actively decommissioning roads as an effective way to reduce water treatment costs: Seattle, Washington, where I am a resident, was able to defer "a $150 million filtration plant expenditure through an intensive watershed rehabilitation program that will decommission 480 km (300 mi) of roads over a 10-year period" (DellaSala et al., 2011, https://doi.org/10.2489/jswc.66.3.78A). For the reasons listed above, I oppose the proposal to rescind or alter the Roadless Rule under Alternatives 2 or 3. Instead, I request USFS take Alternative 1, the No Action alternative. Sincerely, M.T. Seattle, WA

Subject: Docket Number: FS-2025-0001 I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule, options 2 or 3. In 2001, the Roadless Area Conservation Rule was adopted with massive public support to protect 58.5 million acres of roadless national forest land in 38 states and the Commonwealth of Puerto Rico, out of the 192 million acres of NFS land. The public comment period set a record with 1.6 million public comments submitted, indicative of the very strong public support for the Roadless Rule. The rule prohibits the logging of roadless areas in the National Forest System. (USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-ssummary.pdf) Fires: The Roadless Rule already allows for fire suppression, restoration, thinning, and fuel reduction, and wildfires are roughly four times more likely to start near roads than within roadless areas. Recent research found that wildfire-ignition density was the lowest in designated wilderness areas, followed closely by Inventoried Roadless Areas (IRAs). The highest wildfire-ignition density was in lands within 50 m of roads (Aplet, G.H., Hartger, P., &Dietz, N.S. (2026) (doi.org/10.1186/s42408-026-00450-2). A Wilderness Society review of the Forest Service’s Wildland-Urban Interface (WUI) dataset revealed less than 5% of inventoried roadless area acreage is in close proximity to the WUI. The Forest Service already has 23.3 million acres of non-roadless forest land available near communities for fuel reduction. There is no operational need to build new roads through pristine backcountry. Drinking Water: In the 48 contiguous states, 15 to 18 percent of the nation’s runoff is sourced from national forests, and roughly a third of that is derived from IRAs. Sedell et al. (2000) estimate that more than 3,400 communities in 33 states rely on national forest drinking water. The 2001 Roadless Rule is, among other things, a drinking-water policy. The 44.5 million acres it protects sit at the headwaters of rivers that feed municipal water supplies across two-thirds of the country. Repealing it would place those supplies-and the budgets of the cities that depend on them-directly in the path of new road construction. Roads are the single largest controllable input of sediment into forest streams. Erosion rates from logging roads have been documented as much as 850% higher than from undisturbed forest soils. That sediment impacts the storage capacity of reservoirs. (DellaSala, D.A. (2011) “Roadless areas and clean water.” Journal of Soil and Water Conservation, 66(3), 78A-79A. doi.org/10.2489/jswc.66.3.78A) (Sedell, J., Sharpe, M., Apple, D.D., Copenhagen, M., & Furniss, M. (2000). Water and the Forest Service, USDA Forest Service, FS-660.) Recreation: Roadless areas protect 43,826 miles of trails. Along with thousands upon thousands of Americans, my recreation takes place in the outdoors, in the forests, the lakes and rivers that flow thru the forests. I want future generations to have that option. The recreation that roadless areas provide works because access is dispersed, mechanized use is limited, and the landscapes have not been industrialized (USDA Forest Service 2016). The "amenity economies" of the rural West depend on the conditions roadless areas provide. Research describes a shift from an "Old West" economy dominated by extractive industries to a "New West" economy in which population, employment, and income growth are driven by environmental amenities, residential appeal, and recreational property. Counties with substantial protected federal lands have shown faster growth in population, employment, and per capita income than counties without — and the growth has been concentrated in service-based industries, including lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). The economic value also includes passive use — wilderness recreation generating an estimated $574 million annually in economic value (Loomis 2000). The 58.5 million acres inventoried as roadless are spread throughout 120 national forests located in 38 States and the Commonwealth of Puerto Rico (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-summary.pdf), 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 (Woodard et al., 2025). Once you build a road into a roadless area, you’ve opened it up to industrial extraction, and the wild character of that land is gone. New Mexicans, and Americans across the country, have fought to keep these forests roadless because our drinking water, our wildlife, our culture, and our way of life depend on it. Mary Needham New Mexico

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

Please keep the Roadless Rule! We need to protect freshwater resources. Rescinding the rule would increase the likelihood of additional roads, with further dangers to water quality and to aquatic species. Literature synthesis shows roaded landscapes correlate with higher sediment loads, while roadless areas act as refugia for salmonids and freshwater biodiversity (DellaSala, 2011, https://doi.org/10.2489/jswc.66.3.78A).

Dear Chief Schultz: I am writing to oppose rescinding the 2001 roadless rule. I’m an avid hunter and outdoorsman. The public land where I hunt and get meat to feed myself, where I enjoy spending my time is better off without more roads. Many times I have hiked around and swam in Sarah’s Creek in the Chattahoochee National Forest. Wildlife is abundant, the water is clean. Places like this need to be preserved and cared for, for us and future generations. If the roadless rule is rescinded, then areas like Sarah’s Creek will lose their wild character. There are relatively few places like this remaining, especially in Georgia. Regarding the Sarah's Creek in the Chattahoochee National Forest, Georgia: Road construction generates more sediment per unit area than any other land use on national forest lands. The Sarah's Creek IRA, Chattahoochee National Forest, has none of this sediment loading because it has no roads. Rescission of the Roadless Rule removes the regulatory barrier that prevents the introduction of the single most damaging non-point source pollutant into this watershed. Road construction on slopes in the Sarah's Creek IRA, Chattahoochee National Forest, intercepts subsurface flow through cut slopes, converting distributed hillslope drainage into concentrated surface runoff. This interception reduces downslope baseflow — the sustained groundwater contribution that maintains stream volume during dry periods — while simultaneously increasing peak flows during storms. The result is a flashier, less stable hydrological regime. The DEIS must provide watershed-level analysis specific to the Sarah's Creek IRA, Chattahoochee National Forest — not programmatic generalizations applied across all inventoried roadless areas. The geology, soils, slopes, precipitation, stream network, and downstream uses of this watershed are specific to this place, and the analysis must reflect that specificity. "Riparian shade restoration (2000s climate) could decrease mean August stream temperatures by 0.62°C across the study network. Removing the current riparian shade resulted in a nearly 50% loss of habitat meeting the numeric temperature water quality criteria (12°C 7DADM) for char spawning and rearing, while restoring vegetation only increased the proportion of fish habitat meeting the criteria by ~10%. The linear relationship established in our models between reach shade and stream temperature indicates an increase of ~40% reach shade should cool a stream reach by ~1°C." — Restoration Ecology (PMC/Wiley), 2022 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. “Literature synthesis shows roaded landscapes correlate with higher sediment loads, while roadless areas act as refugia for salmonids and freshwater biodiversity. — DellaSala, 2011 (https://doi.org/10.2489/jswc.66.3.78A)” Please let the Rule stand on its record. Best regards, CommentID: RLC-20260921-MUS2BE

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

I strongly support retaining the 2001 Roadless Area Conservation Rule because protecting roadless forests also protects one of America’s most important forms of public infrastructure: clean and reliable drinking water. National forests are major sources of water for communities across the United States. DellaSala, Karr, and Olson (2011), drawing on Forest Service watershed inventories and research, reported that national forests provide approximately 15–18% of the nation’s runoff in the contiguous United States, with roughly one-third of that runoff originating in Inventoried Roadless Areas. They estimated that more than 3,400 communities in 33 states rely on national-forest drinking water, representing at least 124 million people. This makes the Roadless Rule more than a forest-management policy. It is also a watershed-protection policy. The Forest Service’s own Roadless Area Conservation Final Environmental Impact Statement recognized that road construction and timber harvesting can adversely affect water quality. The agency identified sediment and nutrients entering streams, changes in water temperature, and other impacts associated with roads and forest management. It specifically concluded that limiting additional road construction in Inventoried Roadless Areas would reduce future risks to streams and drinking-water source areas. Roads can create long-term changes to how water moves across a landscape. Road surfaces, drainage structures, stream crossings, exposed soil, and road cuts can concentrate runoff and increase erosion. Sediment entering streams can degrade aquatic habitat, impair drinking-water sources, and increase treatment and maintenance costs for downstream communities. The Forest Service itself recognizes that roads can alter watershed hydrology and geomorphic processes and can degrade water quality. Its Geomorphic Road Analysis and Inventory Package (GRAIP) is specifically designed to identify road-related risks to streams and aquatic ecosystems. The public cost of water-quality degradation also deserves consideration. When sediment loads increase in municipal watersheds, communities may face additional expenses for water treatment, watershed restoration, reservoir maintenance, and regulatory compliance. These costs can ultimately fall on taxpayers and water-rate payers. The Forest Service should therefore evaluate the proposed rescission not simply by asking whether individual roads can be engineered to minimize erosion, but by examining the cumulative effects of expanding road networks across entire watersheds. I respectfully request that the Forest Service: 1. Fully evaluate the drinking-water importance of Inventoried Roadless Areas and the communities that depend on national-forest watersheds. 2. Incorporate DellaSala, Karr, and Olson (2011) and the underlying Forest Service watershed research into the environmental analysis. 3. Evaluate cumulative sediment, erosion, water-temperature, and hydrologic impacts associated with additional roads and forest activities. 4. Quantify potential increases in drinking-water treatment, watershed restoration, reservoir maintenance, and other public costs resulting from increased sedimentation. 5. Give particular consideration to roadless areas containing municipal drinking-water source areas and headwaters. 6. Explain why rescinding the Roadless Rule is necessary when the Forest Service’s own analysis recognizes that road construction can adversely affect water quality and that limiting new roads reduces future risks to drinking-water source areas. Clean water should be treated as essential public infrastructure, not simply as an environmental benefit. Intact forested watersheds naturally regulate runoff, stabilize soils, filter water, recharge groundwater, and support downstream aquatic ecosystems. Once roads introduce chronic erosion and sedimentation into a watershed, the resulting impacts can be difficult and expensive to reverse. Protecting intact watersheds is therefore a prudent investment in water security and taxpayer resources. The Forest Service should not eliminate protections for millions of acres without demonstrating that the expected benefits of additional road construction outweigh the documented risks to water quality and the potential costs to downstream communities. For these reasons, I urge the Forest Service to retain the 2001 Roadless Area Conservation Rule. References 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: 10.2489/jswc.66.3.78A. USDA Forest Service. Roadless Area Conservation Final Environmental Impact Statement, Volume 1 and Volume 3. USDA Forest Service. Geomorphic Road Analysis and Inventory Package (GRAIP).

Dear Chief Schultz: As a wildlife biologist, I understand that not every decision can wait for perfect information. But this one has better-than-adequate information. The Department is choosing not to use it. I have spent time in roadless areas in New Hampshire, Pennsylvania, West Virginia, and Minnesota. They not only provide valuable ecosystem services and wildlife habitat but also a connection to the land for millions of people. Land that belongs to the American people. It is the soul of the country. This is why I'm filing this comment. The rule should stay. Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Roadless areas function as intact reference landscapes. Roadless areas retain levels of ecological integrity that roaded landscapes have lost. (USDA Forest Service 2000; Talty et al. 2020). — USDA Forest Service, 2000 (https://www.fs.usda.gov/sites/default/files/roadless/roadless-feis-volume1.pdf) Many migratory bird species require large interior forest tracts. Minimum forest patch size for breeding viability varies by species but is large for many: 350 hectares for Ovenbird, 500–900 hectares for Acadian Flycatcher, and over 500 hectares for Kentucky Warbler. Fragmentation reduces patch size and breeding success simultaneously, and many migratory bird species are sensitive to both (USDA Forest Service 2009). — USDA Forest Service, Northern Research Station, 2009 (https://research.fs.usda.gov/treesearch/download/19723.pdf) These birds do not recognize political or international boarders. We have an obligation to protect them as do other countries in North America. Hence the Migratory Bird Treaty Act. The Roadless Rule supports our role in this international treaty. More than half of North American migratory bird species are declining. Population declines are widespread among North American migratory birds. The Connecticut Warbler has declined 62 percent since 1966; the Cerulean Warbler is declining at roughly 4.4 percent per year; the Golden-winged Warbler has lost an estimated 22 percent of its Great Lakes habitat and 43 percent of its Appalachian habitat since the 1960s. Habitat fragmentation on breeding grounds is documented as a major contributor (Hallworth et al. 2021; NRCS 2016). — Michael T. Hallworth, Erin Bayne, Emily McKinnon, Oliver Love, Junior A. Tremblay, Bruno Drolet, Jacques Ibarzabal, Steven Van Wilgenburg, Peter P. Marra, 2021 · Proceedings of the Royal Society B: Biological Sciences (https://doi.org/10.1098/rspb.2020.3164) “The planet’s remaining large and ecologically important tracts of roadless areas sustain key refugia for biodiversity and provide globally relevant ecosystem services. — Ibisch, P.L., Hoffmann, M.T., Kreft, S., Pe'er, G., Kati, V., Biber-Freudenberger, L., DellaSala, D.A., Vale, M.M., Hobson, P.R., Selva, N., 2016 · Science (https://doi.org/10.1126/science.aaf7166)” “Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes. — Dominick A. DellaSala, James R. Karr, David M. Olson, 2011 · Journal of Soil and Water Conservation (https://doi.org/10.2489/jswc.66.3.78A)” Rescinding the Roadless Rule opens these lands to private interest. Private industry works for private profit not public good. Protecting watersheds, species of concern, and forest integrity is an obligation of the federal government and your agency. Don't strip out protections that took a generation to build. With conviction, CommentID: RLC-20260826-F5WP4F

I am writing to support Alternative 1: The “No Action” alternative because I believe we should keep the Roadless Rule intact. I live in Orange County and a couple of years ago a wildfire started by a vehicle driven by fire prevention employees in Trabuco Canyon. Just a single spark burned over 23,000 acres, caused 21 injuries, and destroyed 160 structures. This is not a unique story--roads in protected areas have shown to cause more fires like this one. Clearing native plants, which in California are adapted to the dry environment, for roads leaves room for invasive plants which ignite more easily. Our land is also so precious to not only those who live here, but to visitors who spend billions of dollars every year to see our beautiful and pristine landscapes. Additionally, these areas provide vital clean water to millions of people, and destroying them for roads would compromise those supplies. "Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes." — Dominick A. DellaSala, James R. Karr, David M. Olson, 2011 · Journal of Soil and Water Conservation (https://doi.org/10.2489/jswc.66.3.78A) "Constructing roads into roadless areas would simply increase the number of fires that need to be suppressed without having a meaningful impact on the likelihood of a large fire igniting." — Aplet, G.H., Hartger, P., Dietz, M.S., 2026 · Fire Ecology (https://doi.org/10.1186/s42408-026-00450-2)

Dear Chief Schultz: Intact forests are a hedge in a warming climate. I read the science. I oppose dismantling the Rule that maintains them. I have a personal connection to nature, especially wild and free places where I can honor creation and let my heartbeat resonate within it. One occasion in particular illustrates what that relationship means in practice. Several years ago I first visited the Blue Ridge Mountains and took almost 100 pictures of water, trees, mountains, the sky at sunset. That ecosystem needs to be protected; all of our wild places need to be protected. Both the place described and the experience recounted would be materially compromised by the commercial road construction and timber extraction that rescission of the Rule would permit. Regarding the Northern Massanutten in the George Washington National Forest, Virginia: Headwater Protection for Drinking Water Supplies — The Lower Passage Creek headwaters and tributary network (Cabin Run, Dry Run, Mill Run, Stokes Branch) originate within this 9,444-acre roadless area and feed into the larger Chesapeake Bay watershed. These headwaters supply drinking water for thousands. DellaSala (2011) literature synthesis shows roaded landscapes correlate with higher sediment loads while roadless areas act as refugia for salmonids and freshwater biodiversity “Roads of all kinds affect terrestrial and aquatic ecosystems in seven general ways: (1) increased mortality from road construction, (2) increased mortality from collision with vehicles, (3) modification of animal behavior, (4) alteration of the physical environment, (5) alteration of the chemical environment, (6) spread of exotic species, and (7) increased alteration and use of habitats by humans. The 13,107,812 km of road lanes in the conterminous United States have destroyed at least 4,784,351 ha of land and water bodies that formerly supported plants, animals, and other organisms. Direct transfer of sediment and other material to streams and other water bodies at road crossings is an inevitable consequence of road construction. The consequences of past sediment delivery are long-lasting and cumulative and cannot be effectively mitigated. — Trombulak, S. C., Frissell, C. A., 2000 · Conservation Biology (https://doi.org/10.1046/j.1523-1739.2000.99084.x)” “Mass movements, roading and yarding practices, and burning can increase the supply of suspended sediment. Sediment yields recovered to pre-harvest levels within one to six years in several paired catchment studies. However, delayed mass movements related to roads and harvesting may produce elevated suspended sediment yield one or more decades after logging. — Takashi Gomi, R. Dan Moore, Marwan A. Hassan, 2005 · JAWRA Journal of the American Water Resources Association (https://doi.org/10.1111/j.1752-1688.2005.tb03775.x)” “Clean water is most closely linked to undisturbed natural ecosystems. When undisturbed watersheds in roadless and protected areas are fragmented by roads, logging, and intensive recreation development, both water quality and biodiversity decline as hydrological integrity is lost. The roaded, intensively managed landscapes of other national forest lands have been closely correlated with heavily sediment-laden streams and dramatic changes in flow regimes. — Dominick A. DellaSala, James R. Karr, David M. Olson, 2011 · Journal of Soil and Water Conservation (https://doi.org/10.2489/jswc.66.3.78A)” “Section 7(a)(2) of the ESA requires Federal agencies to consult with the United States Fish and Wildlife Service, NMFS, or both, to ensure that their actions are not likely to jeopardize the continued existence of endangered or threatened species or adversely modify or destroy their designated critical habitat. NMFS concludes that the proposed action is likely to jeopardize the continued existence of 16 ESA-listed anadromous fish species and Southern Resident killer whales, and it will result in the destruction or adverse modification of designated or proposed critical habitat for the 16 anadromous fish species. FEMA has not structured its proposed implementation of the NFIP in Oregon so that FEMA is positioned to know or reliably estimate the general and particular effects of the program on ESA-listed species or their designated critical habitat. — NOAA National Marine Fisheries Service (https://media.fisheries.noaa.gov/2022-01/2016-04-14-fema-nfip-nwr-2011-3197.pdf)” The Forest Service is not without authority here; it should use that authority to preserve the Rule, not to rescind it. Faithfully, Justine Rehak CommentID: RLC-20260823-RWOOKZ