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

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 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 grew up with access to nature, Point Reyes National Seashore was in my backyard and Tahoe National Forest and Inyo National Forest only a few hours away. Backpacking, hiking, and camping in these public lands grew my admiration for the outdoors. Once you fall in love with nature, it is difficult to not be inspired to protect it. This brought me to career in environmental conservation and education, creating outdoor recreation opportunities for youth and young adults. The peace and quiet you experience while walking through the forest, moss coating the trees and fog rolling through a valley. The ridge lines you work hard to hike to and crest, with an expansive view of forest and ocean on the opposing side. These views and landscapes are at risk with the recision of the Roadless Rule. In 2018, while walking through the streets of San Francisco, a soft ash fell from the sky like snow. Fires converged to cause a darkening of the sky and air quality to plummet. Only a few years later I would awake to a dark red sky, thinking it was the middle of the night, until peering at my clock to see 8:30am lit up on the screen. The robin’s egg morning sky was gone, replaced by the dark swell of blackened clouds, like those circling Mount Doom in Mordor. Air quality was so severe that people were encouraged to stay indoors periodically throughout the summer. However, as a frontline worker working on defensible space to protect homes from fires and maintaining local, state and national parks –that wasn’t an option. My crew and I worked outside throughout these periods of poor air quality, because the nature of our work didn’t allow for indoor alternatives. Fire season has extended later into the year and made me fearful to continue to live in California, so I moved. The intensity and consistency of these fires is exacerbated by human error, such as electric companies neglecting their poles in rural areas. Research shows that wildfire ignition is lowest in designated wilderness areas, including National Forests, away from roads, because the leading cause of fires is human ignition/error (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)). Beyond fire safety, there is a magic to the wilderness and public lands that are for the people of this country. These are our backyards, our natural spaces that help people fall in love with nature and recognize the importance of protecting it. Beyond the importance of access, these lands are a refugee for wildlife and maintain clean drinking water for over 124 million people across multiple states in cities and towns alike; that statistic is over 15 years old, so with taking into account population growth, that number has surely increased (DellaSala, D. A. (2011). Roadless areas and clean water. Journal of Soil and Water Conservation, 66(3), 78A–79A). I hope that the representatives that we elected, who stand by the people and wild-lands of this country will stand up for the Roadless Rule and the protection of our forests.

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 oppose the proposal to rescind or alter the roadless rule and support alternative 1. No action alternative. Reject all sell-offs, giveaways, and/or backroom deals affecting our public lands. Our National Parks are our country’s best idea. The roadless rule has resulted in several conservation benefits including decreasing the odds of wildfires, keeping ecosystems intact, preserving sources of clean water and protecting endangered species. According to the Government’s own analysis, rescinding the roadless rule will have a negative impact on these areas. Building roads is expensive.Timber logging within USFS is unsustainable for long term profit. Increasing timber sale projects, especially in remote areas, will cost the USFS money, and contaminate watersheds. Additionally, based on a 2021 USFS report, there is already a 15.6 billion dollar backlog on maintaining the roads that are already in place. Wildfires are incredibly expensive. The national interagency Fire Center ran the numbers, we spend roughly 3 billion dollars annually to fight wildfires and that is not including property damage, contractors, or health related issues sustained while fighting wildfires. It is substantially cheaper and more sustainable to put money into fuel mitigation. Rescinding the roadless rule could increase fire risk. Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions. Recent studies have found that fires are 4 times more likely to start near a road than in a roadless area. Earlier this year, nearly 120 current and former woodland firefighters sent a letter to Congress defending the roadless rule. Repealing the roadless rule will severely harm our drinking water. Inventoried roadless areas typically have good water quality due to limited disturbance and road construction and native surface forest roads are the largest source of sediment related to timber harvest operations, and sediment delivered to surface waters is a major source of water quality degradation. Roads are the largest controllable source of forest sediment as proven in the Roadless areas and clean water. Journal of Soil and Water Conservation. For example, Salem, OR had to spend roughly $100 million after sediment from logging related disturbances contaminated the water shed. Dominick A. DellaSala’s 2011 synthesis in the Journal of Soil and Water Conservation proves that 3,400 communities across 33 states rely on national forests for drinking water, including Los Angeles, San Francisco, Denver, & California’s central valley, which provides food for the entire country. Roughly 124 million Americans stand to face contaminated water if the roadless rule is rescinded. I am a retired teacher from Long Beach, California. My family, friends and students have benefited from our National Park System. I was introduced to wilderness areas as a 15 year old student, backpacking in the Grand Canyon, on a school camping trip. The formative experience inspired me to visit National Parks every year. I am always humbled by the beauty of the wilderness areas our country has conserved. I intentionally spend/invest my travel dollars in the National Parks I visit and in the local communities because they are important to me. The tourist economy will take a big hit. Our public land system generates over a trillion dollars yearly and sustains roughly 5 million US jobs. If our National Forests are being logged and large swaths are being fenced off to mine, tourists will be less inclined to visit. Loss of recreation areas and visitor spending may result in a loss of $9 million in annual visitor spending in local communities. From Alaska to Florida, Yosemite to Yellowstone, the Grand Canyon to the Grand Tetons, these areas need to be preserved for the public benefit. The proposal to take our nation’s Crown Jewel, Yosemite, and hand pieces of it over to the ultra wealthy is repulsive and undemocratic. No part of Yosemite should be given, sold or bartered for a private road for Jeff Pori, CEO of Kingsbarn Realty Capital, or anyone else. This proposal has been litigated previously and denied. Not a sliver of the Grand Tetons should be sacrificed for a baseball field for an exhibition baseball game. Nuclear powered data centers should never be allowed on Utah land or anywhere. These lands have always been open to everyone equally for recreation, education, hiking, camping, birdwatching, fishing, and conservation. These private use proposals are an insult to every American. For the reasons listed above, fully or partially rescinding the roadless rule under alternatives 2 and 3 of the draft EIS would be a grave mistake. Just say NO to rescinding the roadless rule and protect our public lands.

I am strongly opposed to the proposal to rescind the 2001 Roadless Area Conservation Rule. The USFS projects that the removal of the roadless rule would yield only $4.6 - $10.6 million extra a year in revenue for the timber industry. In contrast, a report titled "Roadless Areas and Clean Water" by members of the Geos Institute describes that "National forests provide about 14 percent of the nation’s runoff with an estimated net value $4 billion to $27 billion." Trading portions of the invaluable resource that is fresh water for meager short-term gains in the timber industry is simply bad business. Attached is photo of an old growth forest in Larch Mountain in the Columbia River Gorge and Mount Hood National Forest, Oregon. It is part of a roadless area currently protected by the 2001 Roadless Area Conservation Rule that could be placed in jeopardy if this proposal is approved. Image by user Nickpdx on Wikimedia Commons under the Creative Commons Attribution-Share Alike license. The song "Big Yellow Taxi" originally by Joni Mitchell in 1970 comes to mind with the following lyrics: "They took all the trees, and put 'em in a tree museum And they charged the people a dollar and a half to see them No, no, no Don't it always seem to go That you don't know what you got 'til it's gone They paved paradise and put up a parking lot" Readers are encouraged to take a listen to the version created by Counting Crows. The fight to protect the old growth that is unimaginably rare in first world developed countries is not a new one. It's our job today to work to conserve the natural resource that generations struggled to protect in the past. "Wilderness is a resource which can shrink but not grow... creation of new wilderness in the full sense of the word is impossible." Aldo Leopold, A Sand Country Almanac, 1949. To protect our fresh water supplies, the deregulation of logging old-growth forests as outlined in the document FS-2025-0001-223869 must not be brought to pass. Thank you for reading. DellaSala, D.A., J.R. Karr, D. Olson, R. Nauman, J. Leonard. 2011. Roadless Areas and Clean Water. Geos Institute, Ashland, OR (www.geosinstitute.org) By w:User:Nickpdx - w:Image:DSC03591.JPG, Public Domain, https://commons.wikimedia.org/w/index.php?curid=2828857

I implore the United States Department of Agriculture to maintain the 2001 Roadless Area Conservation Rule as it is for the foreseeable future. Removing the national protections of these areas from road development has the potential to negatively impact not only recreational activities that humans enjoy and habitat quality for wildlife inside inventoried roadless areas, but it is also likely to decrease water quality and increase wildfire risk, harming land and lives outside of these protected areas (Mildrexler et al., 2026). Damage to the inventoried roadless areas with the development of new roads can include habitat fragmentation, where large swaths of old-growth forest that supported large animals like mountain lions are split into smaller sections, decreasing their capacity to provide for these bigger organisms. Splitting these protected forests could have tremendous impacts on the overall health of this ecosystem by making them uninhabitable for top predators. Long-term negative impacts of ecosystem health could also be exacerbated by the changes in human recreation surrounding these areas. The potential impacts listed on this rule include temporary closures of current recreational activities and further development of land for road-based recreation in the place of remote, self-reliant recreation. This change in human land use would likely increase noise pollution and change the behavior of wildlife that live near where new recreational structures are built. It would also further limit recreation opportunities for humans who value remote recreation surrounded by nature. As for damage that new roads could pose to greater regions and peoples surrounding inventoried roadless areas, high quality drinking water could become substantially more expensive to come by if we open these areas up for development. Building roads increases sedimentation of water sources, which degrades water quality and increases turbidity, both decreasing the amount of water available for human consumption from a watershed and increasing the amount this water needs to be treated by municipal water supply departments (DellaSala et al., 2011). Inventoried roadless areas are providing us with clean, fresh water, and, especially in recent years where we have not seen adequate snowfall in some western areas of the United States, it would be unwise for us to further deplete what reliable water sources we do have. I live in Utah County, which received terribly little snowfall this past year. When June came around, the Provo River was so low that kayaking and paddleboarding at the Provo River Delta was very difficult. We are currently in a drought and, knowing that our watershed comes through inventoried roadless areas, if roads were built that reduced our water supply further, our water recreation would be even harder or maybe impossible to do and the wildlife depending on that water, like the June Sucker, would suffer immensely. Concerning road usage in wildfire mitigation efforts, though wildfires can become larger in inventoried roadless areas because there are few breaks between trees, most wildfires are started close to roads, so building more roads would likely increase the amount of wildfires we experience (Aplet et al., 2026). In any case, the resulting damage to watersheds and habitat that come from building roads outweigh the potential benefits of having smaller but likely more wildfires that are easier to put out. Citations Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-US national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(1), 8. 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. Mildrexler, D. J., Berner, L. T., Law, B. E., & Booth, M. S. (2026). Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation, 321, 111950.

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

As a Southern California resident, I am acutely aware of the pressing water supply issues that plagues much of the state I call home. Serious concerns about harm to our already vulnerable water supply is one of many, many reasons why I am wholeheartedly against repealing the Roadless Area Conservation Rule. A 2026 study found that land protected under the roadless rule provides drinking water to 25 million Americans. Here in California alone, roughly 1 in 4 residents (9.5 million individuals) rely on water sources that are within or downstream of lands protected by the roadless rule. Further, forested lands produce high quality water by moderating water temperature, lowering sediment levels, and naturally filtering out contaminants, making it less costly to treat for human consumption (1). Land development and resource extraction such as logging worsen water quality by damaging vegetation, drastically increasing the rate of erosion and sediment deposition in water sources, polluting water sources, increasing water temperature, and altering stream patterns (1, 2). Water is not an infinite resource, and if we don’t take aggressive steps to safeguard our water supply, we will eventually find the consequences to be existential. Protecting the land that provides these water sources is necessary to continue to provide clean drinking water to a large portion of the nation’s most populous state, and ultimately, for the long-term stability of our society. Citations: 1. Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, et al. (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538 2. 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, DOI: 10.2489/ jswc.66.3.78A

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).

Repealing the Roadless Rule puts our drinking water at serious risk. Roads are the largest controllable source of sediment in our forests, something that has been well documented in research on roadless areas and clean water (DellaSala, D. A. 2011, Journal of Soil & Water Conservation, 66(3), 78A–79A). And this isn’t just theoretical. Salem, Oregon had to spend roughly $100 million after sediment from logging-related disturbances contaminated its watershed. Dominick A. DellaSala’s 2011 synthesis in the Journal of Soil & Water Conservation found that 3,400 communities across 33 states rely on national forests for their drinking water. That includes major areas like Los Angeles, San Francisco, Denver, and California’s Central Valley—which also produces food for the entire country. This impacts far more people than those living next to a national forest. Roughly 124 million Americans depend on these watersheds. Repealing the Roadless Rule means opening the door to more roads, more logging-related disturbance, more sediment entering our watersheds, and ultimately putting clean drinking water for millions of Americans at risk.

Repealing the Roadless Rule will destroy the people’s access to safe drinking water in a significant way. As proven in Roadless areas and clean water, roads are the biggest source of forest sediment that man can control. One example of this is in Salem, Oregon, where $100 million was spent after their sediment was contaminated from logging. Communities in 33 states rely on national forests for drinking water, including LA, Denver, and SF, which is close to where I live. If this rule is removed, I would be deeply saddened by our government’s actions, as over 100 million Americans may then face contaminated water. Thanks!

Destroying some of the few remaining natural areas that have not yet been sullied by roads and development would be a serious and irreversible mistake that would impact every generation to come. Repealing the Roadless Rule will severely harm our drinking water. Roads are the largest controllable source of forest sediment as proven in Roadless areas and clean water. Journal of Soil and Water Conservation, 66(3), 78A—79A. (Dellasala, D. A. 2011) for example Salem, OR had to spend roughly $100 million after sediment from logging related disturbances contaminated the watershed. Dominick A. DellaSalas 2011 synthesis in the Journal of Soil and Water Conservation proves that 3,400 communities across 33 states rely on national forests for drinking water, including Los Angeles, San Francisco, Denver and Californias Central Valley, which provides food for the ENTIRE country. Let that sink in, the entire country. Our country, like every single ecosystem, is connected. We cannot simply continue to import almost every source of food or continue to lose trading partners and opportunities of food and organics. Roughly 124 million Americans stand to face contaminated water if the Roadless Rule isn’t in place.

Director, Ecosystem Management Coordination08/22/2026 201 14th Street SW, Mailstop 1108 Washington, DC 20250-1124 Re: 2001 ROADLESS AREA CONSERVATION RULE To the U.S. Forest Service, I strongly oppose any efforts to rescind, weaken or change ANY part of the 2001 ROADLESS AREA CONSERVATION RULE. There are several reasons for my strong opposition. 1.We only have one planet and need to do what we can to protect our environment, especially the wilderness areas, which support so many diverse species. The interconnectedness of these plants and animals is critical to our own survival. Our public lands and all of their protections were put in place to acknowledge this fact. We must be the voice of the plant and animal kingdom, as they cannot speak for themselves. The Science is clear: Over two decades of peer-reviewed research demonstrates that roadless areas are critical for biodiversity conservation, wildfire safety, clean water protection, and climate resilience. (1) 2.We do not need to build roads of drill in these areas or exploit them for human greed and gain. We can and should be moving toward more wind and solar for our electric needs. We are living on stolen land and the very LEAST we can do is to respect the land and air and the water. Without these, humans will cease to exist. 3.These pristine wilderness areas provide clean drinking water for many people, farms that grow our food and all living things across the country, in fact they provide water for over 48 million people! This proposal to undo protections is undermining our entire civilization. It is short sighted. Governmental parties and administrations change on a regular basis, but our rules protecting our public lands must remain constant and even strengthen as we learn more. (2) (3) I live, hike and love the mountains of Western North Carolina one of the most beautiful and diverse areas in the country. You have the power to help keep it beautiful for the next generations to come. Let your name be on the HERO list, not the short-sighted list. Good Stewardship of what we have been given requires that we protect the place we call home. I urge the U.S. Forest Service and the U.S. Department of Agriculture (USDA) to abandon the proposed rescission and instead maintain full protections for all currently designated inventoried roadless areas. Thank you for the opportunity to provide public comment, Beatriz Coll, Resident of Asheville, NC References: 1. Wildlife Species in Roadless Areas Dietz, Barnett, Belote & Aplet (2021) 2. Conservation Science and Practice McKinley J. Talty, Kelly Mott Lacroix, Gregory H. Aplet, R. Travis Belote 2020 3. Roadless Areas and Clean Water DellaSala (2011) Journal of Soil and Water Conservation

The Roadless Area Conservation Rule (Roadless Rule) is a cornerstone of American conservation biology, vital for preserving biodiversity, safeguarding water quality, and mitigating climate change. Established in 2001, the rule protects 58.5 million acres of inventoried roadless areas within the National Forest System from timber harvesting and road construction (U.S. Department of Agriculture [USDA] Forest Service, 2001). These intact ecosystems act as critical biological strongholds, providing refuge for hundreds of threatened or endangered species that depend on large, unfragmented habitats to survive and adapt to changing conditions (Loucks et al., 2003). Furthermore, roadless areas serve as natural filtration systems, protecting municipal watersheds that supply clean, affordable drinking water to millions of Americans without the need for costly water treatment infrastructure (DellaSala et al., 2011). From a climate perspective, these pristine forests function as highly efficient carbon sinks, sequestering massive amounts of atmospheric carbon dioxide and enhancing landscape-level resilience against severe wildfires and erosion (DeGolia et al., 2022). By restricting destructive industrial development, the Roadless Rule ensures the long-term ecological integrity of public lands while maintaining primitive recreational spaces for future generations.ReferencesDeGolia, A., Marston, J., & Robertson, S. (2022). The climate value of roadless areas: Carbon sequestration and climate resilience in U.S. National Forests. Conservation Science and Practice, 4(8), e12745.DellaSala, D. A., Karr, J. R., & Olson, D. M. (2011). Roadless areas and clean water: The ecological necessity of intact watersheds. Environmental Management, 47(3), 341–355.Loucks, C., Springer, N., & Boucher, T. (2003). Mysterious regions: The value of roadless areas for biodiversity conservation. Frontiers in Ecology and the Environment, 1(7), 357–364.U.S. Department of Agriculture Forest Service. (2001). Roadless Area Conservation: Final Environmental Impact Statement (Record of Decision). Washington, DC: U.S. Government Printing Office.