Read the comments.

I oppose rescinding the roadless rule on the grounds that it would increasing the risk of wildfire in this country. In a study published in the journal Fire Ecology in January of 2026, scientists analyzed 32 years of data from across all U.S. forest regions and found that areas within 50 meters of roads were four times more likely to catch fire than areas that were roadless. It stands to reason, then, that building more roads into forests will increase wildfires. Wildfires not only harm the biodiversity living in our national forests, they put more carbon dioxide into the air, speeding up climate change. They also fill the air of cities and towns with smoke, endangering the health of U.S. citizens, and especially vulnerable people, such as myself. At a time when fire crews are tasked to their limits and barely able to contain the fires that have already been on the increase each fire season, rescinding this rule poses a grave threat to our country. I am citing the following study as evidence: 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 I would also like to submit the following additional evidence: Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography.

The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. I grew up going to the Eastern Sierra Nevada mountains every summer with my family to hike and fish. Some of my favorite places in the Eastern Sierras are in the Inyo and Humboldt-Toiyabe National Forests and are currently protected by the Roadless Rule, which has ensured that these areas remain pristine and continue to be a place of quiet solitude. The Roadless Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions of Americans. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only would allowing roads not reduce wildfire risk, it would actively increase the risk of wildfire. A study of wildfires across the United States for the 20-year period between 1992 and 2012 showed that 82 percent of wildfires during that period were started by human causes (Balch et al. 2017), whereas in California specifically, humans accounted for starting approximately 95 percent of wildfires (Syphard et al. 2007; Syphard and Keeley 2015). Thus, providing access to previously inaccessible areas via new roads can be expected to generate fires at a more frequent rate than very remote or urban areas by increasing the number of people, vehicles, and industrial operations entering fire-prone environments. I urge you to retain the Roadless Rule in its current form - repealing it would go against the will of the American people, who overwhelmingly support keeping the rule in place. Thank you, Tristan

DO NOT RESCIND THE ROADLESS RULE. Reasons offered for rescission are “to reduce regulatory burden” and to “return decision making …to the individual natural forest level.” Neither goal justifies the many harm this will cause. RESCINDING THE ROADLESS RULE WILL INCREASE RATHER THAN REDUCE REGULATORY BURDEN. The Roadless Rule offers clear guidance constraining road construction in designated areas—a rule that applies equally everywhere—thereby REDUCING the regulatory burden. Contrary to the stated goal of reducing regulatory burden, rescinding the rule will actually increase the burden. Requiring that each individual forest consider each new road construction proposal will increase time, effort, and COST. SOME GOALS ARE IMPORTANT ENOUGH TO REQUIRE A CONSISTENT NATIONAL POLICY RATHER THAN PATCHWORK INDIVIDUAL FOREST POLICIES. While “decision making …[at] the individual natural forest level" is reasonable for considering local landscape context, in this case the benefits of the roadless policy are so clear and important—and the potential harms so real and costly—that having a single national “Roadless Rule” is worthwhile. Rescinding the 2001 Roadless Rule contradicts oft-stated cost-saving and efficiency goals of this Administration. There are 4 key reasons to keep the 2001 Roadless Rule. 1. MAINTAINING ROADS IN NATIONAL FORESTS IMPOSES ENORMOUS COSTS ON U.S. TAXPAYERS. Road construction might be paid for by logging contracts but maintenance is not. Even if loggers pay for the construction, USFS must pay to maintain the roads. EXISTING NATIONAL FOREST ROADS ALREADY BILLIONS OF DOLLARS OF DEFERRED MAINTENCE WORK. USFS maintains 200,000 miles of roads for high-clearance vehicles (e.g., logging equipment), 65,000 miles of passenger vehicles roads, and 104,000 miles of roads “stored for future use.” USFS’s own 2023 report (references attached) a backlog of “deferred maintenance” of more than $8.6 billion in FY2023. ADDING NEW ROADS WILL INCREASE MAINTENANCE NEEDS & COSTS, FURTHER TAXING THE U.S. PUBLIC. Roads impose further indirect costs through negative impacts that are hard to calculate but no less significant. USFS (2001) itself reported that forest roads cause harms including debris slides, invasive species, dispersal of pathogens (including tree-harming insects and diseases), water pollution, trash dumping, illegal hunting, and others—including the increased risk of human-caused fires. Sedimentation from road construction affects water quality, fish, and fishing, ultimately harming people (Endicott 2008). Building more roads costs U.S. taxpayers money AND harms human health and recreation. KEEPING THE ROADLESS RULE WILL REDUCE THE BURDEN ON U.S. TAXPAYERS. 2. FOREST ROADS CAN INCREASE FIRE RISK. Roads are touted for fighting wildfires in National Forests, but areas with roads have MORE fires than roadless areas, whether from accident or arson (Syphard 2007, Yang 2007, Narayanaraj et al. 2011, 2012, 2013, Nagy 2018). USFS data (2000) show that forest fires occur nearly twice as often in roaded areas as in roadless areas, and that human-ignited wildfires (which comprise 84% of wildfires, Balch et al. 2017) are more than 5X as likely in roaded than roadless areas. Logging can reduces fuel accumulation and might in some cases reduce fire risk and severity, but that depends on how the logging is done. Many studies show that fires are more frequent for decades after logging, and can be more intense (Furlaud 2021, Levine 2022, Lindenmayer & Sylstra 2024, Lindenmayer 2022, Mackey 2023, Taylor 2014, 2020, 2021, Wilson 2022). 3. FOREST ROAD CONSTRUCTION PROMOTES SPECIES INVASIONS, REDUCING POST-HARVEST TREE REGENERATION—IMPOSING MORE COSTS. Road construction spreads weedy/invasive plant seeds through vehicle tires, construction and logging equipment, and post-construction erosion control materials (Mortensen et al. 2009). Construction-disturbed soils offer ideal beds for invasive plants to root (Jones and Grenz 2023). USFS Forest Inventory data shows that invasive species are reducing when forest tree regeneration in many national forests (Potter et al. 2022). When forests do not regenerate naturally, USFS must spend additional funds on replanting trees. 4. ROADLESS AREAS ARE VALUABLE FOR RECREATION AND BENEFIT LOCAL ECONOMIES WITH TOURIST DOLLARS. The Multiple Use Sustained Yield Act of 1960 and the National Forest Management Act of 1976 require that forests be managed to meet more than just timber demands. Passive (non-motorized) recreation thrives in roadless areas, as does wildlife habitat and biodiversity. Roadless areas offer refugia for wildlife and plant species, and offer sources of new seeds when forest regeneration fails after logging. MAINTAINING THE ROADLESS RULE IS CONSISTENT WITH LAWS REQUIRING MULTIPLE-USE FOREST MANAGEMENT. IN SUMMARY, I URGE YOU TO HALT THE PROPOSAL TO RESCIND THE ROADLESS RULE.

I am against rescinding the Roadless Rule. I recreate in many of the roadless areas. Locally, I recreate in the Storm Peak area of the San juan National Forest and the San Miguel area of the San Juan national forest. Roadless areas are critical for me and the plants and animals that live in these areas. I go to these places for solitude and renewal. I go tho these places to learn and study the natural habitat. I am a retired National Park Service ranger with over 28 years of federal government service. The National Parks today are often very overcrowded. I have turned to these roadless area for escape and to enjoy places with very little human impact. Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. Notwithstanding these findings, the DEIS concludes at p. 113 that "the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." No source is cited for that conclusion, and no estimate of the ignition increase appears anywhere in the effects analysis for either action alternative. Its two supporting assumptions are unquantified and uncommitted. At p. 109 the DEIS reasons that "not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." At p. 113 it states that "public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas." Neither alternative commits to any level of access restriction, no proportion of closed roads is estimated, no basis is given for expecting any particular proportion, and the rescission itself transfers that decision to local responsible officials. The analysis thus supplies the mitigating assumption while the rule removes the national requirement that would deliver it. The DEIS states the method for closing this gap and does not perform it. At p. 109: "As discussed in Wildfire Occurrence, past fire occurrence information on NFS lands, inventoried roadless areas, and wilderness can be used to evaluate the potential effects of new road construction." The necessary input is already in the document. Figure 15 (p. 98), "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs," is the ignition-to-road-distance gradient measured inside the affected area itself. Figure 15 appears in the body of the DEIS once, as that caption. No text discusses it and no effects analysis applies it. Because the DEIS announces this analysis, presents the data for it, and then substitutes an uncited qualitative conclusion that runs against its own cited

Dear Secretary Rollins, I strongly oppose the Proposed Rule rescinding the 2001 Roadless Rule. For the past 250 years, the cultural belief has been that the earth is an endless resource created for our own use. A belief that the wood, sand, and soil have no soul. That the land stands solely for the benefit of the American people. I’ve grown up in this period of imbalance, when waves of caterpillars strip summer trees to winter branches and ocean currents rise to take back stolen artifacts. It has always been clear to me that our constant movement and development are the root causes of catastrophes that occur all too frequently. Reading through the proposal to rescind the Roadless Rule left me drained and sad. The language wielded in the document was a shameful bastardization of the words used by the front lines trying to save nature. Hidden in the rhetoric of community autonomy and protection, I saw the real motivation for this change. It wasn’t hard to do so when a selection of Trump’s degrading Executive Orders calling for more consumption, more extraction, and more feeding of the American machine stood front and center – the same motivation for reducing protection of inventoried roadless areas. Wildfires have indeed increased in frequency and severity (Davis et al. 2024), and prolific species pose serious risks to ecosystem homeostasis (Langmaier and Lapin 2020). However, we must ask why these changes are occurring, and if developing infrastructure in these protected areas will mitigate or exacerbate risk. We must also remember that the 2001 Roadless Rule does not prevent management or intervention; it is access to funding and resources that does. Many studies over the last two decades have clearly shown that the key to reducing wildfire severity and increasing forest resilience is using prescribed burns (Stephens et al. 2023, Davis et al. 2024). Mechanical trimming improves outcomes, but it is not necessary for a meaningful impact. Building more roads will cost money that could instead go to training and employing forest managers who can perform prescribed burns. In fact, research shows that roads are direct vectors of increased wildfires. Roads bring people, and people ignite 84% of wildfires (Balch et al. 2017). Most wildfires start within 50 m of roads, with inventoried roadless areas and protected wildlands experiencing 3.5 times fewer fire ignitions (Aplet et al. 2026). If anything, the best way to reduce wildfires is to reduce road access and use. Interestingly, the 50 m distance from roads has the highest densities of prolific species (Hansen and Clevenger 2005). Prolific, or invasive, species impact ecosystems by outcompeting diverse native plants and animals, which ultimately decreases biodiversity. When an ecosystem is diverse in its residents, it can respond better to stress, similar to how a body builds up a library of immune responses. Established roads benefit prolific species in several ways. Roads themselves change soil composition and density, while sedimentation, salt use, and chemical pollutants create harsher environments where invasive species thrive. Construction and road use kill plants and animals, reducing ecosystem viability and resilience. Additionally, roadways can unpredictably alter aquatic environments by changing water flow and composition (Trombulak and Frissell 2000). Roads not only alter the landscape, but the passage of cars and the wind corridors they form also extend the distance invasive plant seeds disperse (Hansen and Clevenger 2005, Von Der Lippe and Kowarik 2007). The best way to manage prolific species has not been determined, and many of the ways we choose to do so now are more harmful than good. I also doubt that management would be appropriately funded with or without the Roadless Rule in place. All in all, the arguments made in the proposed change to the rule seem silly to me. The primary goal is clearly resource extraction for private profit. If this were not the case, the Roadless Rule would stand because it is not a sweeping nationwide restriction. It is a long-standing protection of 7.2% of the country's national forests. What will it take for us to leave even small fractions of nature to be left for itself? 600,000 comments from the American people opposing rescinding the rule? Probably not. You won’t be convinced because there’s no check attached to each comment. We know the motive is profit. We know who is pushing for the change. We know what they stand to gain – holding dollars until they die. We know what we stand to lose – areas of peace and prosperity for the balance of the world as we know it. We are moving to lose the world as we know it. Will those dollars be food? Will those dollars be clothes? Will those dollars be friends? Maybe you believe they will; I can promise you they won’t. Please adopt the No Action alternative for the Final Rule.

Please keep the amazing piece of policy, the roadless rule, live and enforced. America is its land, and it's people. I am connected to desolation wilderness in the Tahoe basin. Increased devistation will only result in a less secure climate, resulting in more wildfires and harm done to innocent families that garner no benefit from the destruction and increase to shareholder value. My name is Nathaniel Griffin and I will only suffer if this rule is removed. We must encourage sustainable practices, not allow devastation in our birthright. Thank you Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. Notwithstanding these findings, the DEIS concludes at p. 113 that "the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." No source is cited for that conclusion, and no estimate of the ignition increase appears anywhere in the effects analysis for either action alternative. Its two supporting assumptions are unquantified and uncommitted. At p. 109 the DEIS reasons that "not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." At p. 113 it states that "public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas." Neither alternative commits to any level of access restriction, no proportion of closed roads is estimated, no basis is given for expecting any particular proportion, and the rescission itself transfers that decision to local responsible officials. The analysis thus supplies the mitigating assumption while the rule removes the national requirement that would deliver it. The DEIS states the method for closing this gap and does not perform it. At p. 109: "As discussed in Wildfire Occurrence, past fire occurrence information on NFS lands, inventoried roadless areas, and wilderness can be used to evaluate the potential effects of new road construction." The necessary input is already in the document. Figure 15 (p. 98), "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs," is the ignition-to-road-distance gradient measured inside the affected area itself. Figure 15 appears in the body of the DEIS once, as that caption. No text discusses it and no effects analysis applies it. Because the DEIS announces this analysis, presents the data for it, and then substitutes an uncited qualitative conclusion that runs against its own cited sources, its effects finding for wildfire occurrence is not supported by the record before the agency. An explanation that runs counter to the evidence before the agency does not satisfy reasoned decisionmaking. Motor Vehicle Mfrs. Ass'n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983); see also Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002) (programmatic EIS may not defer analysis of an effect that is properly assessed at the programmatic scale). This is a challenge to the sufficiency of the agency's explanation under 5 U.S.C. § 706(2)(A), not to the scope or depth of analysis the agency selected. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of ne

Dear Chief: I am a wildlife artist making work about local ecology that I share in educational settings. I rely on research, conversations with biologists and my daily visits to the national forest. Having observed wildlife across a representative cross-section of the inventoried roadless areas in the affected region, I write as a sustained observer to oppose the proposed rescission, the rationale for which the field evidence does not support. My opposition rests on several issues, chief among them fire. I will note ahead of that arguement below, that rescinding the Roadless Rule will fragment habitats and increase road mortality of wildlife. Your analysis, its failure to consistently and adequately address core habitat, as well as improperly aligned data regarding management plans for listed species, fails to address the effects on health, population and distribution of the Southern California population Puma Con Color. I request that it do so. Strawberry Peak sits within the national forest that begins at the end of my block. This forest and wilderness provide the basis of research and observed ecological realities that form the basis of my livelihood. It also directly relates to my family and community safety. My lived experience runs counter to the claim roads increase fire safety. Indeed, I do not believe the DEIS has made any effort to analyze conditions that are pervasive where I live, the Santa Ana Winds. This yearly fact amplifies the fire risk roads bring to wilderness areas. Intrusions into wilderness areas raise the threat of fire. The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. I request that the Forest Service supplement the wildfire occurrence effects analysis under 7 CFR 1b.7(f)(2)(iii) to: (1) apply the Figure 15 ignition-density-by-road-distance relationship, together with the human-caused ignition rates in Table 21, to estimate the change in ignition density within potentially affected IRAs under alternatives 2 and 3 at a stated level of new road construction; (2) state the proportion of new roads assumed to be closed to public access, the basis for that assumption, and the estimated ignition effect if that proportion is not achieved; and (3) either support the conclusion at p. 113 that the net effect is "small or insignificant" with that analysis or correct it under 7 CFR 1b.7(f)(2)(v). This effect cannot be deferred to project-level analysis. The increase in ignition density follows from the nationwide removal of the road-construction prohibition across the potentially affected inventoried roadless areas, not from the siting of any single road, and the DEIS contains no tiering commitment that would carry the question forward to project-level review. Nor is a reorganized presentation of the existing text responsive: what is missing is the analysis, not its placement. Finally, because the wildfire rationale is part of the stated purpose and need for the rescission, and because the purpose and need is the basis on which alternatives were eliminated from detailed study, this analysis is also necessary to the final rule's explanation of its change in position under 5 U.S.C. §§ 553 and 706(2)(A). A response confined to the FEIS response-to-comments appendix does not discharge that obligation. If this rule is rescinded I lose the research base for my professional work and my home and community is under a graver threat from wildfire. Regarding the Strawberry Peak in the Angeles National Forest, California: this roadless area like those across the country exemplify what is most precious for our future generations and something this WE should do everything to protect: an untrammeled wilderness, the wellspring of our health and imagination, the very inspiration for our national character: freedom. Do the right thing. DO NOT RECIND THE ROADLESS RULE. All the best, Christian Kasperkovitz

I oppose rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to adopt the no-action alternative. Protection: protection (noun) The act of protecting, or the state of being protected. It means shielding someone or something from harm, injury, damage or loss. A person, thing or measure that protects, as in "the fence offers protection from the wind." Safeguarding by law or regulation, as in "environmental protection" or "legal protection." By Definition this land has been put in a status that should keep you from doing exactly this sort of proposed action, for EVER, not simply until the wind blows. By enacting the this proposition any and all integrity or trust you claim as an organization, commission, and administration will end and it will become a farce. Protection does not mean "until it's time for us to profit." Scale and irreversibility. Rescission would remove nationwide protection from about 58.5 million acres of inventoried roadless areas, and about 18.2 million acres could receive permanent roads where plans allow. Once built, a road permanently ends an area's roadless character. Protection is From roads, not for them. This proposal needs rigorous independent study and time to do so since 30, 60, or 90 days is does not afford the opportunity to conduct meaningful analysis, Unless of course, that is the goal. The rationale isn't supported. The proposal cites wildfire and forest health, but the draft EIS doesn't show that the Rule currently blocks needed management. The Rule already allows tree cutting for forest health and temporary roads in some circumstances. The claim that new roads improve fire suppression appears to rest on longer containment times in roadless areas, which may reflect deliberate managed-fire decisions rather than lack of access. NEPA analysis is inadequate. The draft EIS finds rescission likely to adversely affect 327 species and 71 critical habitats, yet defers that analysis to future projects while quantifying timber benefits in detail. Climate and carbon impacts receive only cursory treatment. Modest gains, real costs. By the agency's own estimates, rescission would yield $5.2–$11.4 million per year in timber revenue and cost recreationists about $6.1 million per year. Neither figure counts water quality, habitat, or carbon storage. Unfortunately, the USFS cannot keep up with current back-log of road maintenance and projects so to think for a moment More roads is somehow going to make things better is just hideous. Not to mention the actual added cost to taxpayers. Fires are mostly not started in the forrest naturally (only 16%) are started by lightening). They are started mostly by humans (84%) who travel by these roads and proposesd roads. More fires will not be better, even if they can be put out faster. Better alternatives exist. The Idaho and Colorado state rules show that tailored approaches can work. The agency should analyze keeping the Rule with targeted exceptions for fuels treatment near communities instead of wholesale rescission. My family uses the White Mountain National Forrest on a daily basis and needs not more roads, lumber or other resource extraction for any purpose. The preservation efforts are inadequate at best and we adem,antly oppose any proposal that threatens wildlife, water and land resources, and the Forrests as a whole. We request more conservation of our natural resources, parks, and forrests not the wholesale raping of them. I request that the Forest Service retain the 2001 Rule or, at minimum, issue a supplemental draft EIS that addresses these gaps before proceeding. Respectfully, A Lance Emrick Wentworth NH Sources: - Federal Register, Special Areas; Roadless Area Conservation (https://www.federalregister.gov/documents/2026/08/20/2026-16965/special-areas-roadless-area-conservation - Northwest Fire Science Consortium, Fire Ecology study (https://nwfirescience.org/node/10258) - Taxpayers for Common Sense, Roadless NOI comments (https://www.taxpayer.net/wp-content/uploads/2025/09/Roadless-NOI-comments-Sept2025.pdf) - USDA Forest Service road management fact sheet (https://www.fs.usda.gov/eng/road_mgt/factsheet.shtml) - Defenders of Wildlife, Deferred maintenance report (https://defenders.org/sites/default/files/2026-04/Deferred-maintenance-of-the-National-Forest-Road-System-report.pdf) Sources: - NASA Earth Observatory, People Cause Most U.S. Wildfires (https://earthobservatory.nasa.gov/IOTD/view.php?id=89757) - Balch et al. 2017, Human-started wildfires expand the fire niche across the United States (PNAS, via PubMed Central)(https://pmc.ncbi.nlm.nih.gov/articles/PMC5358354)

I vigorously oppose this proposed rescission. The stated reasons for this rescission are false, misleading, or timber industry propaganda. In particular, the reason relating to preventing wildfires is ridiculous. The facts are contrary to this reason. When USDA Secretary Brooke Rollins announced the rescission of the 2001 Roadless Rule on June 23, 2025, the headline rationale was wildfire. Roads, the argument went, are needed to "manage fire" inside America's 44.5 million acres of inventoried roadless areas. The peer-reviewed science says exactly the opposite. What the published research actually shows: The most decisive data point comes from a 2026 study in Fire Ecology by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz of The Wilderness Society. The authors analyzed 32 years of contiguous-U.S. wildfire records across all eight Forest Service regions. Their finding: Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha). That is roughly a fourfold difference. Ignition density decreased steadily as distance to roads increased — from about 6 fires per 1,000 ha within 250 m of a road to fewer than 2 fires per 1,000 ha beyond 2,000 m. The pattern holds for human-caused, natural, and undetermined fires alike. As the authors conclude: "building roads into roadless areas is likely to result in more fires." A separate national analysis (Balch et al., Proceedings of the National Academy of Sciences, 2017) explains why. Human-started wildfires accounted for 84% of all U.S. wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Roads are the primary vector through which human ignitions reach previously remote landscapes. What about fire severity? Bradley, Hanson, and DellaSala (Ecosphere, 2016) found that forests with higher levels of protection burned at lower severity, not higher, even though they generally carry the highest biomass and fuel loads. Johnston et al. (Environmental Research Letters, 2021) confirmed that while roadless areas saw greater fire extent over three decades, there was no significant difference in fire severity after accounting for biophysical conditions — and suggested the greater extent of fire may even confer ecological resilience. The Wildland-Urban Interface claim doesn't hold up either Forest Service Chief Tom Schultz testified to the Senate Energy and Natural Resources Committee that 24.5 million acres of inventoried roadless areas sit within one mile of the Wildland-Urban Interface (WUI), calling that figure "our primary concern." The Wilderness Society performed a straightforward GIS analysis using the Forest Service's own WUI dataset. The actual figure is 2.8 million acres — a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not the 42% Schultz implied. Even if every acre near the WUI mattered, 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 to address the genuine fire risk facing homes and infrastructure. What this means for the rescission The wildfire rationale is the only public-facing justification USDA has offered for rescinding the Roadless Rule. The actual Federal Register notice tells a different story: it cites Executive Orders 14192 (deregulation), 14225 (timber production), and 14154 (energy unleashing), and states the goal is to facilitate domestic production of "timber, energy and mineral production... to the maximum possible extent." Wildfire is the cover story. Industrial access is the policy. Anyone responding to the rulemaking should know that the empirical case for the wildfire rationale collapses on contact with the published science. Roads bring fire. Roadless areas are not the problem. They are part of the solution. Sources 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. doi.org/10.1186/s42408-026-00450-2 Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. doi.org/10.1073/pnas.1617394114 Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10), e01492. doi.org/10.1002/ecs2.1492

I am a veterinarian and lifelong Texas Panhandle resident, and I oppose rescission of the 2001 Roadless Area Conservation Rule (36 CFR 294, subpart B). My comments address the Department's wildfire rationale and the animal and public health consequences that the proposal and DEIS do not adequately weigh. 1. The existing rule already allows the fuels work the Department says it needs. The Purpose and Need cites wildfire risk, insect and disease infestations, and protection of the wildland-urban interface. The 2001 Rule already permits road construction where it is needed to protect public health and safety from an imminent threat of fire, flood, or other catastrophic event (§294.12(b)(1)). It also permits cutting of generally small-diameter timber to reduce the risk of uncharacteristic wildfire effects (§294.13(b)(1)(ii)). Before concluding that a nationwide rescission is necessary, the Department should quantify how many fuels or WUI projects these provisions actually blocked. If the barrier is narrow, the remedy should be narrow too. 2. New roads increase ignition risk. Most U.S. wildfires are human-caused, and human ignitions have expanded both the fire season and the fire niche (Balch et al. 2017). Ignition density rises with proximity to roads (Narayanaraj & Wimberly 2012). Opening roadless backcountry to new road access in the name of fire-risk reduction may therefore increase the ignitions it intends to prevent. The final EIS should model the added ignition risk from new road access, not only the benefit of fuel reduction. 3. Animal and public health (One Health) impacts. Land-use change and habitat fragmentation are recognized drivers of infectious disease emergence at the wildlife–livestock–human interface (Patz et al. 2004). Roads fragment habitat, alter where wildlife move and congregate, help invasive species and pathogens spread, and increase sediment delivery to streams (Trombulak & Frissell 2000). Many western grazing allotments border roadless areas. Changes in wildlife distribution and in contact rates with livestock carry disease-management consequences for producers and animal health officials. The DEIS should analyze wildlife disease, livestock–wildlife contact, and source-water impacts specifically, rather than treating them as incidental. 4. Roads the agency cannot maintain. The Forest Service already carries a large deferred-maintenance backlog on its existing road system. Poorly maintained roads are a chronic source of sediment in the watersheds that downstream communities and livestock depend on. The Department should explain how new roads would be funded and maintained before authorizing them. For these reasons, I urge the Department to withdraw the proposed rescission and retain the 2001 Roadless Rule. Any specific fuels-management barriers should be addressed through targeted amendments, not by removing protections from roughly 45 million acres.

Opposition to Rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001 (RIN 0596-AD66) I submit this comment on behalf of the Global Wildfire Collective, a program of the Conservation Biology Institute, in opposition to the proposed rescission of the Roadless Rule. The Draft EIS's central rationale, that rescission will reduce wildfire risk, is not supported by the best available science. 1. Roads concentrate human-caused ignitions. Most U.S. wildfires are started by people (Balch et al. 2017, PNAS; Headwaters Economics 2026 found 77% of 1992-2024 fires were human-ignited). Ignitions cluster along roads (Syphard et al. 2007, Ecological Applications; Syphard & Keeley 2015, Int. J. Wildland Fire). Dr. Alexandra Syphard, our Director of Science, has publicly described roads as the dominant place where ignitions occur. The Forest Service's own 2001 Final EIS concluded that new roads would likely increase human-caused fires and that prohibiting them would not increase acres burned. The Draft EIS does not explain this reversal. 2. Roads alter fuels. Building roads into roadless landscapes disturbs the land and can introduce invasive species that are often more flammable than native vegetation, compounding ignition risk. 3. The data show no fire penalty from roadless protection. Kilbride et al. (Conservation Science and Practice, doi:10.1111/csp2.70411) analyzed four decades of fire data and found inventoried roadless areas burned at rates statistically indistinguishable from developed national forest lands (rate ratio 1.13, 95% CI 0.92-1.36 for 1984-2023; 0.89 for 2014-2023). The higher burn rates sometimes attributed to roadless areas come from designated wilderness, which this rule does not affect. Healey (2020, Environmental Research Letters) found similar results. Dr. Syphard has stated that claimed fire-reduction benefits of road building are not supported by any evidence, and about 30 prominent wildfire scientists signed her letter critiquing the Draft EIS. 4. Home protection depends on where and how homes are built. Structure loss is driven largely by housing location, arrangement, and conditions near buildings (Syphard et al. 2012, PLOS ONE; Calkin et al. 2014, PNAS). Roadless areas are remote from most communities, so backcountry road building does little to protect homes and diverts attention from home hardening, defensible space, and community planning. 5. The existing rule already allows needed fire management. 36 CFR 294.13(b) permits road construction for imminent fire threats and cutting of small-diameter timber to reduce uncharacteristic wildfire effects. Prescribed fire and suppression are not prohibited. The Draft EIS does not show that full rescission is necessary. 6. Costs and process. The Forest Service cannot maintain its existing road network, and the Draft EIS does not adequately account for the long-term costs and ecological harm of new roads, including sediment and invasive species. Roadless areas protect watersheds supplying drinking water to at least 25 million people (PLOS Water, 2026). The initial 30-day comment period was far shorter than typical for an analysis of this scale, and 164 members of Congress have requested more time, public meetings, and full Tribal consultation. Robin Jones, Director, Global Wildfire Collective A program of the Conservation Biology Institute www.globalwildfirecollective.org | www.consbio.org

I am firmly opposed to rescinding the 2001 Roadless Rule for a variety of reasons and urge congressional leaders to uphold the Roadless Rule. Protected forests, landscapes, and wilderness areas have long been critical assets that help keep America prosperous and beautiful. They are an essential part of our life and values as Americans. As much as we have tied our national identity to innovation and progress, so to has conservation of the vast and beautiful wilderness present in this country been central to the American ethos. Generations before us have composed songs, poems, letters, and books regarding the splendor and majesty of the wild landscapes of our country, detailing for us the profound awe and sense of wonder they inspire. Many of those same people have expressed their belief in the importance of protecting and maintaining these for future generations. Teddy Roosevelt is one such prominent figure who encapsulates my feelings well when he spoke at the conference of governors in 1908, saying "We have become great in a material sense because of the lavish use of our resources, and we have just reason to be proud of our growth. But the time has come to inquire seriously what will happen when our forests are gone, when the coal, the iron, the oil, and the gas are exhausted, when the soils shall have been still further impoverished and washed into the streams, polluting the rivers, denuding the fields, and obstructing navigation." Not only is the splendor of the land important to conserve, but the wide variety of plant and animal habitats, waterways, and ecosystems are also crucial to maintain. Every protected wilderness has a completely unique biodiversity profile that is critical to research and our understanding of the natural world we live in. Loss of the geographic and biologic diversity through practices like construction and logging permanently destroys these environments and endangers plant and animal species who have as much as right to these lands as we do. Every animal, even down to the smallest of insect, contributes to the thriving of our ecosystems. Disrupting these habitats often leads to deleterious and unforeseen consequences that can never be undone. Humanity has already seen to the extinction and endangering of untold animal species. By upholding the Roadless Rule, we are being given an opportunity not add more species to that death toll. Finally, with regard to wildfire safety. There is legitimate evidence to support the fact that human intervention into wilderness areas contributes to an increase in wildfire frequency and actually decreases efforts at wildfire protections. This is evidenced by studies such as "Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads" by Aplet, Hartger & Dietz in 2026, "Human-started wildfires expand the fire niche across the United States" by Balch et al. in 2017, "Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States?" by Bradley, Hanson & DellaSala in 2016, and many more. The argument that logging and road building may, in some way, prevent or protect against wildfires is completely false. It is a theoretical argument that has never been proven in independent forestry research but is instead an advertising line used by the logging industry to use our forests for profit. The science, however, is clear. Human intervention in natural landscapes increases the risks of wildfires, floods, and other natural disasters. Decreasing the risk of these means putting efforts toward their conservation. Overall, I would argue that the protection and conservation of our national wilderness is a critical part of our principles and ethics as Americans. We are the most powerful country in the world and it is incumbent upon us to use that power to protect those animal and plant species who are at the mercy of what we have historically called "progress". It is our duty to use our power to maintain the splendid but vanishing natural beauty of our country for future generations. Further, the scientific consensus is clear that upholding these protected areas also helps protect ourselves from natural disasters such as wildfires and floods. Please, do the right thing for current and future Americans. Do not rescind the roadless rule.

I'm writing to submit a comment AGAINST rescinding the "Roadless Rule" (enacted in 2001) in effect across the United States. The roadless rule is essential for protecting our nation's natural landscape, one of our greatest legacies and one that affects the rest of the planet. I do not believe the listed explanations for rescinding the rule are sufficient to justify putting our nation's forests and biological health at risk. Research shows that the roadless rule "substantially complement[s] biodiversity conservation" (DeVelice & Martin, 2001), protects threatened species (Loucks et al. 2003), and that allowing road construction or resource extraction has the potential to not only endanger wildlife but public health (Talty, Mott Lacroix, Aplet & Belote, 2020; Trombulak & Frissell, 2000; ) Contrary to some arguments in favor of rescinding the rule, decades of studies have shown that roadless areas have up to four times fewer wildfire incidents (Aplet, Hartger & Dietz 2026) and that humans are responsible for the overwhelming majority of wildfires (Balch et al. 2017), so it follows that restricting human access to remote wildlands will reduce wildfire incidence. As mentioned previously, the global importance of protecting America's wildlands cannot be overstated. Multiple studies show that old-growth forests found in roadless areas are responsible for significant carbon sequestering (DellaSala, Gorelik & Walker, 2022; Buotte, Law, Ripple & Berner, 2020; Dinerstein, Buotte, Law et al., 2021). We MUST protect these areas to ensure our children and their children will live in a habitable world, not one ravaged by climate change and accelerated destruction of the natural world. I also believe exceptions or amends are necessary to provide tribal members access to remote areas; however such access could be assured via "new co-management structures" as suggested. I strongly believe that rescinding the rule will, as stated: "[expose] previously untouched areas to industrial activity, mining interests, and destructive recreational access, all of which threaten sacred sites, traditional gathering areas, water quality, and subsistence resources." One of our nation's greatest treasures is our natural landscape. We cannot allow the stripping of our land for parts or an auction to the highest bidder. PLEASE PROTECT THE ROADLESS RULE. WE ARE BEGGING YOU!

To whom it may concern, I am writing today to beg you to reconsider the rescission of the 2001 Roadless Rule. Greenlighting development in protected wilderness areas will have dire consequences for the flora, fauna, and human communities that depend on them. The inherent, intrinsic value of protecting our wilderness far outweighs any “economic” value that can be extracted from plundering it for its natural resources. Development will come with a steep cost: the fragmentation of habitat that will result will threaten biodiversity and contribute to the worsening climate crisis and general degradation of the planet, ruining the environment for generations to come. Ecosystems are fragile and complex, and they are already under threat from human activity, pollution and global warming. There are so few untouched wilderness areas left, and the Roadless Rule helps protect them. These areas will serve as vital refuge for endemic species whose very existence would be impossible without the ecosystems they evolved in. Running roads through these areas would damage habitat essential to the species that are most susceptible to a changing environment, leading to devastating losses of biodiversity (Nick M. Haddad et al’s “Habitat fragmentation and its lasting impact on Earth’s ecosystems”). Additionally, the introduction of pollutants from constructing these roads and running vehicles and increased foot-traffic through them will cause great harm as they enter root/soil, bodily, and water systems. The health of forestland and waterways will determine their ability to act as carbon sinks in this era of anthropogenic climate change; old growth forests are some of the best defenses we have against rising greenhouse gas emissions. Rescinding the Roadless Rule will cause irreparable damage to these already fragile ecosystems and introduce new problems that reduce these areas’ carbon capture potential and their ability to support life. Under the Rationale section of this proposal, it acknowledges maintaining “ecological integrity,” mitigating wildfire risk, and increasing access for forest/insect/disease management purposes, while simultaneously highlighting the need to access timber and mineral resources. These ideals cannot coexist. According to the language used in Donald Trump’s executive orders, especially E.O. 14153, it becomes clear that the true purpose of this proposal is for economic gain - the extraction and exploitation of the Earth’s precious materials. Roads often increase wildfire risk and decrease ecological integrity, as roads lead to traffic that can spawn wildfires from exhaust heat or sparks from metal scraping asphalt, rock, or other metal (Jennifer K Balch et al’s “Human-started wildfires expand the fire niche across the United States”). The increase in traffic can also lead to the movement of insects and disease, as the movement of people and cars can act as vectors that transport these. Lastly, the physical act of carving a road into the land can make it unstable, as this creates stress points and removes plants whose root systems were holding the land in place, leading to landslides. This does not sound like ecological integrity to me. Prosperity does not come from deregulation (EO 14192), destruction does. I can think of nothing more unpatriotic than ruining our country’s wilderness - landscapes that inspire patriotism through songs like “America the Beautiful” (Katharine Lee Bates and Samuel A. Ward) and “This Land Is Your Land” (Woody Guthrie). The language that is used in the executive orders that this proposal references paints a clear desire to access these lands for economic gain - an abuse of power that will undo the years of preservation granted by the Roadless Rule. 25 years ago, people foresaw the importance of protecting millions of acres of forestland, and this rule has been one of the most successful stories of land preservation this country has seen. Regulations like the 2001 Roadless Rule are put in place with good reason, researched and backed by experts. That the advice of experts can be overridden by one man’s word is extremely disappointing. Why does the Forest Service want to bend the knee to one man’s desires? The Roadless Rule was put into place to ensure that these areas could be enjoyed by everyone and continue to provide crucial habitat in a country whose landscape has already been poisoned and marred by the dangerous ideals of capitalistic growth. There are already hundreds of thousands of miles of road running throughout this country’s national parks and forestlands, providing ample connectivity and access to nature for recreation, management purposes, and beyond. To remove federal regulation sets a dangerous precedent, allowing for untold damage to occur in its absence. This land is for you and me; it is not for sale. Please protect the land, the water, and the people and animals that depend on them. Save the Roadless Rule

Over the last 13 years in particular I have seen and dealt with the significant impacts of humans on our National Forest and Wilderness areas. The areas most trashed, most harmed, most affected are those accessible by roads. I also know anecdotally and from reporting that the majority of wildfires are human caused and that the majority of them are started in places accessible to roads. So the argument that we need to recind the roadless rule for wildfire management holds little water for me. I am weary of picking up human shit, dispersing fire evidence in places where none are allowed and/or where common sense seems to fly out the window. I'm tired of the resource damage. Over the last couple decades it is also apparent that our practices of resource extraction, reliance on fossil fuels, and so on - all the things that are undeniably causing the climate change in ways that are inarguable anymore - are putting us on a path to our own extinction. We live on an exquisite planet. Spend a time in the woods near where I live and learn how precious and amazing it all is. We have much to learn from this place starting with how to stop thinking we are the king of the mountain. We need to do more than just "consult" with the tribes but perhaps get curious about how they lived here sustainably for thousands of years. And then there is the practicality of what is being proposed. We can not and do not maintain the Forest Service Roads we currently have. And even if we could we also do not have the manpower to manage more. Where will the money come from? Where will the employees come from. You have already gutted it. And in just a few minutes of research it's clear y'all simple do not know what you are doing, talking about and lack any kind of cogent plan. Additionally, the full gambit of folks who access National Forest Lands are opposed to this. Listen. Do what is right for generations to come. Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. Thirty of Sixty-Four Tribal Consultation Requests Undisposed in the Section Designated as the EO 13175 Compliance Record Re: Consultation accounting, Draft EIS Vol. I p. 17 — thirty of sixty-four tribal consultation requests are unaccounted for in the only section the Draft EIS designates as its Executive Order 13175 compliance record. 1. The Draft EIS's own figures. At Vol. I p. 17, under the heading "Consultation with Federally Recognized Tribes and Alaska Native Corporations," the Draft EIS states: "The Forest Service received 64 requests for consultation, 29 consultations have been held, and an additional 5 scheduled." Thirty of the 64 requests — 47 percent — are therefore neither held nor scheduled.

As an avid outdoor enthusiast and public lands user, roadless areas are rare and precious for millions of users. I am an adventure motorcyclist who truly appreciates motorized trails and uses them routinely. This also makes me well aware of the vast network of trails and roads already in existence and their poor condition in many cases due to lack of funds to maintain the roads and bridges. I am also a hiker, angler, and wilderness user who gains tremendous personal health benefits from solo adventures, solitude, clean water, and more benefits that roadless areas provide. Development of new roads into current roadless areas does far more damage to all of these public benefits than it does good, with dubious benefits from wildfire protection. MANY wildfires are started with careless human actions in remote location - sparks from engines, cigarette butts, target practice, and campfires. New roads into roadless areas would INCREASE fire risk, INCREASE backlog maintenance issues on rural roadways, INCREASE disturbance to wildlife and wilderness character, and DECREASE quality of life in America. The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)."

Re: Proposed rescission of the 2001 Roadless Area Conservation Rule I live in Brightwood, right at the edge of the Mt. Hood National Forest, and I'm writing because I don't want to see the Roadless Rule go away. I'll start with fire, since that's the reason being given for repeal. I'm not a fire scientist, but the research I've read doesn't back it up. People start about 84% of wildfires in this country (Balch et al. 2017, PNAS), and roads are how people get into the woods. A big look at thirty years of national forest fire records found roadless areas had about 2 ignitions per 1,000 hectares, and land within 50 meters of a road had around 7 or 8 (Aplet et al. 2026, Fire Ecology). The authors said building roads into roadless areas is likely to mean more fires. The Forest Service said the same thing in its own 2001 environmental impact statement, and I don't understand what's changed since then. I also care about hunting and fishing here, and what worries me is the habitat. Elk in Oregon consistently choose ground away from open roads (Rowland et al. 2000), so every new road takes away country they'd otherwise use. Fish are the same story. The main scientific review I found says roads harm streams and aquatic life, and that the damage is rarely fully undone, which is why it says to hold onto the roadless areas we still have (Trombulak and Frissell 2000). Good hunting and fishing depend on good habitat. This isn't a fight between hunters and environmentalists either: groups like Trout Unlimited and Backcountry Hunters and Anglers oppose repeal too. And then there's the old growth, which I think gets talked about as if it's just big trees. It's a whole habitat. The Forest Service's own researchers found that old-growth stands are critical nesting habitat for northern spotted owls (Lesmeister et al. 2019), and Trout Unlimited's president has pointed out that roadless areas are about 2% of the American landscape but shelter roughly 25% of our threatened and endangered species. Old forests also hold water in a way young or thinned forests don't. The shade, the layered canopy, and the dense understory keep the forest floor cooler, damper, and out of the wind (Frey et al. 2016, Science Advances). Forest Service researchers comparing hundreds of Northwest fires found open, younger forests had hotter, drier, windier conditions, and that those conditions fade fast once you step into an older forest (Lesmeister et al. 2021). Old-growth stands burned cooler and were less likely to burn at high severity than younger forest (Lesmeister et al. 2019). Roads and logging cut holes in that canopy, and the moisture goes with it. That is the opposite of fire prevention. The Forest Service's own documents say repeal would open about 4.8 million acres of roadless forest to more active management, which in plain terms means logging. Mt. Hood alone has 118,000 acres of roadless land. Old growth takes centuries. We don't get it back. More than 1.6 million people spoke up for this rule when it was adopted. Please keep it in place. Thank you for reading this. A.C. Eggen, Rhododendron, Oregon

I am a certified Master Naturalist and frequent outdoor visitor to state parks, natural areas and national parks in my home state of Texas. I've spend many overnights camping outdoors within earshot of howling coyotes, rustling birds and scratching land mammals. The wonder of hiking within sight of a black bear family is not soon forgotten, but can only happen if the sight, sound and destruction of cars and trucks occur far, far away from park trails. Recinding the Roadless Rule will precipitate the destruction of treasured wildlife and amazing moments found only on our protected lands. Also, as our planet warms and drought becomes commonplace, the destruction of land and property by wildfires has grown exponentially. With 80% of wildfires occuring closest to roads, the destruction by fire will grow even higher. We can't afford to lose these protected lands and jeopardize human life! Stop the destruction, KEEP the Roadless Rule as it stands. Thank you Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests.

I oppose the Roadless Area Conservation proposal for the following reasons, which are all quoted. "The most decisive data point comes from a 2026 study in Fire Ecology by Gregory H. Aplet, Phil Hartger, and Matthew S. Dietz of The Wilderness Society. The authors analyzed 32 years of contiguous-U.S. wildfire records across all eight Forest Service regions. Their finding: Wildfire-ignition density was lowest in designated wilderness areas (1.75 fires/1000 hectares), followed closely by Inventoried Roadless Areas (1.97 fires/1000 ha). The highest wildfire-ignition density was in lands within 50 m of roads (7.99 fires/1000 ha). That is roughly a fourfold difference. Ignition density decreased steadily as distance to roads increased — from about 6 fires per 1,000 ha within 250 m of a road to fewer than 2 fires per 1,000 ha beyond 2,000 m. The pattern holds for human-caused, natural, and undetermined fires alike. As the authors conclude: "building roads into roadless areas is likely to result in more fires." A separate national analysis (Balch et al., Proceedings of the National Academy of Sciences, 2017) explains why. Human-started wildfires accounted for 84% of all U.S. wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Roads are the primary vector through which human ignitions reach previously remote landscapes. What about fire severity? Bradley, Hanson, and DellaSala (Ecosphere, 2016) found that forests with higher levels of protection burned at lower severity, not higher, even though they generally carry the highest biomass and fuel loads. Johnston et al. (Environmental Research Letters, 2021) confirmed that while roadless areas saw greater fire extent over three decades, there was no significant difference in fire severity after accounting for biophysical conditions — and suggested the greater extent of fire may even confer ecological resilience. The Wildland-Urban Interface claim doesn't hold up either Forest Service Chief Tom Schultz testified to the Senate Energy and Natural Resources Committee that 24.5 million acres of inventoried roadless areas sit within one mile of the Wildland-Urban Interface (WUI), calling that figure "our primary concern." The Wilderness Society performed a straightforward GIS analysis using the Forest Service's own WUI dataset. The actual figure is 2.8 million acres — a nearly ninefold exaggeration. Less than 5% of inventoried roadless area acreage is in close proximity to the WUI, not the 42% Schultz implied. Even if every acre near the WUI mattered, 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 to address the genuine fire risk facing homes and infrastructure. What this means for the rescission The wildfire rationale is the only public-facing justification USDA has offered for rescinding the Roadless Rule. The actual Federal Register notice tells a different story: it cites Executive Orders 14192 (deregulation), 14225 (timber production), and 14154 (energy unleashing), and states the goal is to facilitate domestic production of "timber, energy and mineral production... to the maximum possible extent." Wildfire is the cover story. Industrial access is the policy. Anyone responding to the rulemaking should know that the empirical case for the wildfire rationale collapses on contact with the published science. Roads bring fire. Roadless areas are not the problem. They are part of the solution." I am quoting the sources used for the above as well: Sources 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. doi.org/10.1186/s42408-026-00450-2 Balch, J. K., et al. (2017). Human-started wildfires expand the fire niche across the United States. PNAS, 114(11), 2946–2951. doi.org/10.1073/pnas.1617394114 Bradley, C. M., Hanson, C. T., & DellaSala, D. A. (2016). Does increased forest protection correspond to higher fire severity in frequent-fire forests of the western United States? Ecosphere, 7(10), e01492. doi.org/10.1002/ecs2.1492 Johnston, J. D., et al. (2021). Does conserving roadless wildland increase wildfire activity in western US national forests? Environmental Research Letters, 16(8), 084040. doi.org/10.1088/1748-9326/ac13ee The Wilderness Society (2025). Forest Service Chief Grossly Exaggerates Roadless Rule Concern: WUI Analysis. PDF

I am writing in strong opposition to any efforts to rescind, weaken, or roll back the 2001 Roadless Area Conservation Rule. As an avid user of this wilderness and an advocate for our nation's public lands, I rely heavily on the integrity and protection of our inventoried roadless area here like Craggy Mountain, like Linville Gorge near my home. I want my child to have access to nature, and after the devastation of Helene here in Asheville, the last thing anyone needs is an increased risk of wildfire, which logging contributes to, along with landslides and flooding, which we now know we can be devastated by after the last hurricane in the area. The biodiversity of this area is rare to find these days and we rely on these watersheds for clean water, something logging will also compromise. I urge the U.S. Forest Service and the U.S. Department of Agriculture to abandon the proposed rescission and instead maintain full protection of the little forest we have left in this country, especially in this area that I covet and love so dearly. Thank you for the opportunity to provide public comment, Sincerely, Emily Snow, North Carolina native and mother to five year old child Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. Notwithstanding these findings, the DEIS concludes at p. 113 that "the net impact of new roads on fire occurrence is likely small or insignificant, given the potential for improved response times and increased initial attack success." No source is cited for that conclusion, and no estimate of the ignition increase appears anywhere in the effects analysis for either action alternative. Its two supporting assumptions are unquantified and uncommitted. At p. 109 the DEIS reasons that "not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." At p. 113 it states that "public access to roads constructed or improved under alternatives 2 and 3 can be limited to minimize fire hazard in high-risk areas." Neither alternative commits to any level of access restriction, no proportion of closed roads is estimated, no basis is given for expecting any particular proportion, and the rescission itself transfers that decision to local responsible officials. The analysis thus supplies the mitigating assumption while the rule removes the national requirement that would deliver it.