Read the comments.

Dear Mr. Schultz, I'm writing as a wildlife observer to register my opposition to the rescission, with reference to the rule's actual field record rather than its sponsors' framing. One night on a backpacking trip in a roadless area, I was hanging my bear bag when I heard a rock tumble behind me. I turned to see not one, not two, but an entire pack of gray wolves crossing the steep mountain side near the creek. I watched in awe as they deftly navigated the rocky terrain and edged closer to the ridgeline, their gray and black bodies powerful yet supple. Not long after they disappeared into the mountain's own majesty, they began to howl. Better than magic, this was nature without roads. Roadless areas preserve some of the best parts of this world. The arguments for rescinding the Roadless Rule are unfounded, and the evidence for keeping it is overwhelming. Roads increase wildfire risk. A 2026 study of three decades of National Forest System wildfire data found that wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest. Wilderness and Inventoried Roadless Areas had the lowest ignition densities of any land category studied (Aplet et al. 2026). Roadless lands benefit local economies. Counties with substantial protected federal lands have grown faster in population, employment, and per-capita income than counties without them, with growth concentrated in lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). Wilderness recreation generates an estimated $574 million annually in economic value, while Western wilderness has an estimated passive-use value of roughly $168 per acre (Loomis 2000). Roads create an enormous financial burden. The Forest Service has an $8.4 billion deferred-maintenance backlog across its existing road network—an obligation the agency has acknowledged it cannot resolve. Expanding roads into currently roadless areas would only compound this burden (USDA Forest Service 2001 EA). Roads fragment wildlife habitat. Habitat connectivity allows animals to move across landscapes, reach new habitat as conditions change, and maintain the gene flow necessary for healthy populations. Roads disrupt that movement: some species avoid them, others are killed crossing them, and for many species roads function as barriers. A meta-analysis found that wildlife movement between connected habitat patches was roughly 50% higher than movement between unconnected patches (Gilbert-Norton et al. 2010). Road fragmentation can create smaller, more isolated populations with reduced genetic diversity, diminished resilience, and greater risk of local extinction (Christie & Knowles 2015). Roads fragment aquatic ecosystems, too. Road-stream crossings create potential passage barriers, usually through culverts. A poorly designed culvert can function like a small dam, preventing fish passage. The cumulative effects of small barriers such as culverts can equal or exceed those of large dams simply because there are so many more of them; some North American watersheds have 24–38 times more culverts than dams. Roadless watersheds preserve continuous headwater habitat for cold-water fish such as bull trout, cutthroat trout, and native brook trout (Lehrter et al. 2024; Sliger et al. 2026). Roads also eliminate critical forest-interior habitat. A 2024 meta-analysis found that nest success for eastern North American forest birds rises steadily from the forest edge to roughly 250 meters, after which it levels off. Species such as Wood Thrush, Cerulean Warbler, Ovenbird, and Acadian Flycatcher depend on these interior-forest conditions (Akresh et al. 2024). Roads do not merely remove the narrow strip of forest they occupy—they create edge habitat on both sides. The broader consequences are substantial. Fragmentation reduced biodiversity by 13–75% across studied ecosystems and impaired ecosystem functions including biomass production, nutrient cycling, and carbon storage (Haddad et al. 2015). The roadless condition is not what makes these lands vulnerable to disturbance. It is what makes them resilient to it. The Roadless Rule constrains road construction—the infrastructure that enables many documented threats, including fragmentation, sedimentation, invasive species, increased wildfire ignition, and extractive activity (Trombulak & Frissell 2000). It does not prohibit grazing, dispersed recreation, or other non-commercial uses, and it operates alongside existing forest plans rather than replacing them (USDA Forest Service 2001). Once roads fragment intact forests, the ecological benefits they provide are difficult or impossible to restore. Let the Roadless Rule stand. Protect the roadless lands that protect and inspire us. Sincerely, J. Harris

"Primary forests with the least disturbance history have the highest carbon storage, greatest ecological resilience, and the lowest risk of loss and damage (Rogers et al. 2022). Intact canopy moderates temperature, with the cooling effect strongest in hot and dry years — precisely when species need it most (Thom et al. 2020; Xu et al. 2022). Fragmentation by roads reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs core ecosystem functions including biomass production, nutrient cycling, and carbon storage (Haddad et al. 2015). The roadless condition is not what makes these lands vulnerable to disturbance — it is what makes them resilient to it." Additionally, may animals and plants depend on natural treefall and undisturbed areas to survive. Cutting roads through these areas threatens the very survival of many native plants and animals and could introduce non-native invasive species to the area.

Dear Chief: As someone who regularly travels on foot through areas designated as roadless under the 2001 Rule, I am in a position to observe that what the Rule protects is materially different from adjacent managed lands, and the Department's proposed rescission warrants scrutiny against that observable difference. Sam Knob and Flat Laurel Creek have some of the favorite hiking trails for me and my family. When hiking to the summit at Sam Knob, the 360 degree view across this wilderness area is breath taking. This is one of those places where hikers pause and enjoy the view and take that special picture that they want to remember. If the Roadless rule is rescinded, the development of bulldozed roadbeds across this rugged wilderness would damage the fragile balance of native plants and animals as they exist today. My family is drawn to this area specifically because it does not have developed infrastructure criss crossing the land. Regarding the Sam Knob (addition) in the Pisgah National Forest, North Carolina: Rescission of the Roadless Rule is a federal action that may affect each of the 14 listed or proposed species documented in the Sam Knob (addition) IRA, Pisgah National Forest, by removing protections that currently prevent habitat-degrading road construction and development. Federal records document 14 listed or proposed species in the Sam Knob (addition) IRA, Pisgah National Forest. ESA Section 7 requires individual consultation for each species that a federal action may affect. For the Sam Knob (addition) IRA, Pisgah National Forest, the DEIS must demonstrate that the agency has initiated or completed ESA Section 7 consultation addressing all 14 listed or proposed species, with individual determinations of effect for each species. “Road traffic had a consistent negative effect on territory densities up to approximately 650 m distance from the road for different species and ecological species groups. Within road-effect zones, densities of breeding birds were significantly lower (on average 25%) than at greater distances from the road. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing van Dijk et al. 2025, 2025 (https://doi.org/10.1007/s10980-025-02100-5)” “Habitat fragmentation strongly reduced species richness of plants and animals across experiments. Across experiments, average loss was >20% after 1 year, >50% after 10 years, and is still increasing in the longest time series measured (more than two decades). We were struck by the persistence of degradation to biodiversity and ecosystem processes and by the increase in many of the effects over time. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Haddad et al. 2015, 2015 (https://doi.org/10.1126/sciadv.1500052)” I'm filing this comment because I think the rescission is wrong, and I want that on record. Please keep the Roadless Rule in place. All the best, CommentID: RLC-20261006-KJWAM0

A 2026 study of three decades of National Forest System wildfire data found that wildfire ignition density within 50 meters of roads is roughly four times higher than in non-wilderness, non-roadless forest. Wilderness and Inventoried Roadless Areas have the lowest ignition densities of any land category studied (Aplet et al. 2026). Most ignitions near roads are human-caused. Primary forests with the least disturbance history have the highest carbon storage, greatest ecological resilience, and the lowest risk of loss and damage (Rogers et al. 2022). Intact canopy moderates temperature, with the cooling effect strongest in hot and dry years — precisely when species need it most (Thom et al. 2020; Xu et al. 2022). Fragmentation by roads reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs core ecosystem functions including biomass production, nutrient cycling, and carbon storage (Haddad et al. 2015). Research on Western U.S. economies describes a shift from extraction-based growth to amenity-based growth. Counties with substantial protected federal lands have grown faster in population, employment, and per capita income than counties without — with growth concentrated in lodging, dining, and professional services (Izon et al. 2010; Holmes & Hecox 2002). Wilderness recreation generates an estimated $574 million annually in economic value, and Western wilderness passive-use value is estimated at roughly $168 per acre (Loomis 2000). The Forest Service's own road-management strategy documents an $8.4 billion deferred maintenance backlog across the existing road network — a backlog the agency has acknowledged it cannot resolve. Expanding the road network into roadless areas would compound this maintenance burden (USDA Forest Service 2001 EA). The repeal of the Roadless Rule will result in degradation of resource values and exacerbation of environmental harms.

Separately, and as a distinct request: the Draft EIS's reference list includes Frey et al. 2016, "Spatial models reveal the microclimatic buffering capacity of old-growth forests," Science Advances. That study reports that maximum spring monthly temperatures decreased by 2.5 degrees Celsius across the observed gradient in old-growth forest structure -- a quantified finding that mature forest structure moderates the very temperature extremes the Draft EIS invokes as its justification. Because this source is already in the agency's own reference list, it is not "science or literature not previously considered" within 7 CFR 1b.7(f)(2)(iv), and no cause-and-effect showing is required of me before the agency must engage it. I supply the causal link regardless. The proposed rescission returns road-construction and timber-harvest decisions in inventoried roadless areas to individual forest plans; road construction and harvest remove canopy and simplify forest structure; that loss reduces under-canopy buffering by the magnitude Frey et al. measured; the effect is to intensify locally the temperature extremes the agency identifies as the condition justifying the rescission. The Draft EIS's only discussion of microclimate, at page 141, treats microclimate shift as a downstream consequence of habitat fragmentation citing Haddad et al. 2015, and nowhere engages the buffering magnitude or connects it to the changed-conditions rationale. The Final EIS should supplement the analysis under 7 CFR 1b.7(f)(2)(iii) to address whether the proposed action would itself intensify the temperature extremes it identifies as its own justification.

Dear Secretary Rollins and Chief Schultz: The pollution becomes more deadly. The temperatures continue to rise. Animals are dying as their homes are cut down leading to potential ecosystem collapse. If they go, we go too. As a citizen whose climate worry shapes how I vote, what I read, and now what I comment on, the 2001 Rule keeps a meaningful amount of carbon in trees. That's the version of climate action that does the math. Regarding the Big Island in the Chippewa National Forest, Minnesota: I want to Department to understand the long term effects and the world they are giving their kids and their kids kids. I want them to think of the future. Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Most remaining forest is already fragmented. Globally, 70 percent of remaining forest is within one kilometer of a forest edge — within the zone where edge effects compromise interior conditions. The remaining intact interior, including roadless areas in the National Forest System, has become disproportionately important for sustaining the species and processes that require unfragmented forest (Haddad et al. 2015). — Haddad et al., 2015 (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Big Island, Chippewa National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The proposed action should be withdrawn, and the 2001 Rule allowed to remain operative. With gratitude, CommentID: RLC-20261002-Z54EVT

I oppose the proposal to fully or partially rescind the Roadless Area Conservation Rule. I live in San Jose, California. Public lands matter to me because they allow spaces that people, me included can connect to nature. In these public lands you can see what is left of these ecosystems in action and get a better understanding of how the world around us is supposed to work. Some areas near me that will be affected are the Klamath National Forest, the Siskiyou National Forest, the Six Rivers National Forest and the El Dorado National Forest. These areas hold headwaters for major rivers that sustain wildlife, snowpact and maintain scarce wildlife habitat for threatened and endangered species. I enjoy hiking in these areas as well. In these areas, there are 21,808 miles of trails inside the affected areas, including 1,127 miles of national scenic and historic trails, and most of those miles are non-motorized. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation, and that under rescission the settings could shift toward more developed conditions. You do not have to camp inside a roadless area to be affected: the water in your drainage starts up there, and the wildlife you hope to see moves through (DEIS recreation analysis). As I am also a fisherman, an unfragmented forest or any endangered habitat for that matter is really important for rivers and their water quality. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and its own words on wide-ranging mammals like the grizzly: they “have suffered habitat loss and the extirpation or fragmentation of their populations.” (DEIS wildlife analysis; Haddad et al. 2015). Another thing is that I want the forests managed responsibly, only around 6% of the untouched old growth forest remains in the US. The purpose and need is to reduce regulatory burden and return decisionmaking to local officials, not forest health and not fire. Every conservation alternative was eliminated for failing that purpose: more acreage “would not be responsive to the deregulatory executive orders,” and one option was cut partly because analysing roadless values is “an administrative and legal burden for the agency.” The agency even monetized what roadlessness itself is worth to people who never visit: $5.3 to $11.5 million a year forgone, landing in the same range as the timber gain, which is why its own accounting cannot clear zero. And in its own words, “This proposed rescission does not mandate timber cutting or road construction”: nothing about management is promised, only the removal of the protection (DEIS purpose and need; alternatives analysis). Roads also cause fires. The agency’s own new analysis, 2014 to 2024: human-caused ignitions run 22.4 per million acres per year on roaded national forest land, against 3.0 inside the affected roadless areas. Seven and a half times. Its own conclusion: “human caused ignitions increase in abundance with proximity to roads,” and its effects analysis concedes road access could increase the number and frequency of wildfires (DEIS Table 21). Roads are also more expensive to maintain than we can afford, as this is taxpayer money. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase (DEIS economics and infrastructure analysis; USDA Cost Benefit Analysis, p. 29). Sediment and vegitation removal near or within proximity of these headwaters due to these roads in these areas harm threatened fish populations by killing eggs and raising water temperatures. The DEIS: sedimentation from harvest can promote excessive substrate movement and negatively impact fish such as bull trout by causing egg and juvenile mortality and reduced suitable habitat. Roads and their skid trails and landings contribute up to 90 percent of the sediment from a timber sale (DEIS; USFWS 2024; Patric 1976; Swift 1988). The DEIS: removing riparian vegetation can raise stream temperatures beyond what suits cold-water species, and warmer temperatures can reduce egg survival, rearing densities and growth of coho salmon. The affected area includes Essential Fish Habitat and critical habitats managed by NMFS (DEIS; Carter 2005). For the reasons stated above and many more, fully or partially rescinding the Roadless Rule under Alternatives 2 and 3 of the draft EIS would cause irreversible harm and permanently negatively effect all peoples in the US.

It was only 500 years ago when the United States had no roads at all. I ask you to reflect on what the forests, the streams, and lands must have looked like then. Imagine cresting a hill to see nothing but wild lands until the far ocean. Imagine watching buffalo and salmon migrating by the millions. Today in 2026, we cannot fathom what the lands and streams once looked like, just like future generations will be shocked that we had the chance to protect what we have and squandered it – our fresh water, our clean air, our game and fishing populations, our recreation spaces, our wild places. To date, we have only managed to protect a fraction of our lands (for example, the Roadless rule protects fewer than 60 million of the nearly 2 billion acres in the US). I am writing in strong support of maintaining the protections of the 2001 Roadless Area Conservation Rule. This is deeply personal. Many of the regions protected by the Roadless rule are areas that I frequent. I hike, bike, go birding, do photography in Southern Massanutten dozens of times a year. I have also hiked, camped, birded, and explored other Virginia/West Virginia regions including: Dry River, Skidmore, Oak Knob, Gum Run, Little River, Seneca Creek, and Dolly Sods. On the West Coast, I have hiked, camped, birded, and explored Quilcene, Mt. Zion, Alpine Lakes Adj, Thorp Mtn, Teanaway, Eagle, Larch, and San Dimas regions – among many others. As an outdoors enthusiast, I believe the DEIS inadequately addresses the recreation losses from road construction and downstream activities, and I ask that the FEIS provide a thorough analysis of lost visitor spending and local economic multipliers in all impacted regions and specifically the regions named above. Without such analysis, the agency misrepresents the economic impact of rescinding this rule. The USDA’s argument that rescinding the Roadless rule will prevent large wildfires is not credible. 78% of human-caused wildfires on National Forest start within ½ a mile of a road (based on USDA data). The Roadless rule does not preclude forest management activities that help reduce the risk of wildfire. I ask the agency to quantify the expected increase in human-caused ignitions resulting from new road access and to quantify it against claimed reductions in wildfire hazard. I am specifically interested to see this analysis in the regions mentioned above and also in all impacted regions. Furthermore, building new roads will fragment ecosystems, which are already fragile as humans continue to develop and build. Fragmentation by roads has been found to reduce biodiversity by 13-75% (Haddad et al. 2015). Once again, healthy ecosystems gives us clean air, clean water to drink, pollinators to keep our crops productive, healthy soils to grow healthy food for healthy children, beautiful lands that people travel from around the world to see, etc. I ask that the agency provide an economic and environmental analysis of the negative impact of ecosystem fragmentation from new roads on these critical environmental benefits and ecosystem services. Finally, if the agency is looking to create more rural jobs, which I wholeheartedly support, I suggest creating jobs that help preserve these precious ecosystems - it would be a win-win for everyone. Given the agency’s goal of wildfire management and rural job creation, I ask that the FEIS include an analysis of alternative methods to accomplish their goal. I believe that it would be insufficient to consider rescinding the Roadless Rule without a careful economic and environmental analysis of alternative options, including greater funding for job creation around fire fighting, invasive species management, existing road repair, and forest management. I am writing this as an outdoor enthusiast, an angler, a birder and wildlife lover, an artist whose work is inspired by the natural places that I explore, and a passionate environmentalist. The Roadless rule preserves ecosystems – lands, rivers, flora, and fauna. It provides access to people who love to hike, camp, and fish (like me), and who simply want to breathe clean air, drink clean water, and eat healthy food (also like me). Let us keep our lands as wild and healthy as possible – for the land, for ourselves, and for our children. Thank you.

Biodiversity is necessary for life on earth to continue. In a beginners ecology class one of the first and arguably most important things you learn is that the more diverse an ecosystem is, the better chance it has of surviving changes. Repealing the roadless rule would devastate these ecosystems forever change the biodiversity of the land. We are already hurtling towards the worst effects of the climate crisis. Why are we trying to speed up the progress? Is our governments main goal to kill the whole world even faster? Species Count Not Reconcilable to the Biological Assessment; Record Study on Species Representation Not Engaged The Draft EIS states at p. 141, under Assumptions Common to All Alternatives → Potentially Affected Environment → Habitat, that "[t]he most recent USFWS and NMFS data indicate that the potentially affected environment of inventoried roadless areas provides habitat for more than 300 threatened, endangered, and proposed species," and repeats the figure at p. 168. Neither statement gives the exact count, the date the data reflect, or a cross-reference to the document that produced it. The Draft Biological Assessment for USFWS species does disclose a method, and this comment does not suggest otherwise: IRA boundary shapefiles by administrative unit were imported into IPaC to compile the FWS list, NMFS species were compiled from existing consultation documents, both lists were vetted by regional Forest Service staff to remove species that do not occur on National Forest System lands, the lists were sent to the Services for review in September and October 2025, and occurrence data were drawn from GBIF and the Natural Resource Manager (Draft BA, "Species Lists" and "Data Collection and Use," p. 25). The defect is that the Draft EIS's figure cannot be reconciled to that method. The Biological Assessment reports counts only by taxonomic group — for example, "[t]he potential species list from IPaC contained 30 listed or proposed bird species on relevant Forest Service units," of which four were removed and "[t]he 26 potentially present species are organized below" (Draft BA p. 161) — and states no total. The Biological Assessment also warns that its occurrence databases "do not differentiate between DPSes of vertebrate species listed under the ESA, which causes potential inflation of exposure to these entities" (p. 25), so whether the Draft EIS's total counts distinct population segments separately changes the number materially. A reader cannot determine what "more than 300" counts, on what date, or against which vetted list. The Final EIS should make a factual correction under 7 CFR 1b.7(f)(2)(v): state the exact number of threatened, endangered, and proposed species in the potentially affected environment, state the date the species lists reflect, state whether distinct population segments are counted separately, and cross-reference the Biological Assessment's Species Lists section at each point the figure is used. This is a correction the agency can make from documents it already holds, and 7 CFR 1b.7(f)(3) directs that the Final EIS cite where it was made. Second, the figure does no analytical work as written. It appears twice in "Potentially Affected Environment" as descriptive background and is never carried into an effects conclusion — even though the Draft EIS concedes the operative mechanism on the same page, stating at p. 141 that "[a] synthesis of fragmentation experiments spanning five continents and 35 years demonstrates that habitat fragmentation reduces biodiversity by 13 to 75 percent (Haddad et al. 2015)" and that "[e]ffects tend to be greatest in the smallest and most isolated fragments, increasing over time." The record already contains the study that gives the species count its consequence. Matthew S. Dietz, Kevin Barnett, R. Travis Belote and Gregory H. Aplet, "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species," 32 Global Ecology and Conservation e01943, 1-12 (2021), appears in the Draft EIS's own reference list, is cited in full in Volume III at p. 37 (n. 201), is set out at length in Volume III at pp. 38-39 in the comment letter of the Attorneys General of Washington, California, Arizona, Massachusetts, Minnesota, New Mexico, Oregon and Vermont, and is cited again in the joint Tribal letter at Volume III p. 498. As that letter states the finding: of 537 terrestrial vertebrate species of conservation concern, 308 — 57 percent — have at least some suitable habitat in inventoried roadless areas, "even though inventoried roadless areas only cover 2% of the area of the contiguous United States"; every inventoried roadless area contains suitable habitat for at least two such species; and 81 percent of inventoried roadless area land is suitable habitat. Please show me that the people voice is more valuable than money.

This is a sloppy job at covering up the fact that they are trying to roll back key legislation that has been the only thing stopping the destruction and vandalization of these public lands. Clear cutting more old growth forests that cannot burn will only introduce 2nd growth vegetation that burns like gasoline. Do not roll this back. You will be committing acts of destruction on innocent land. This land provides far too much for you to touch it. Fragmentation Metrics in Appendix 5 Never Applied to the Comparative Effects Conclusion Appendix 5 of the Draft EIS, "Biodiversity Analysis Supplemental Information" (pp. 320–333), computes a quantitative fragmentation baseline for the potentially affected environment: mean patch area, largest patch index, mean shape index, mean distance to nearest neighbor, edge density, and clumpiness index, broken out by region and by forest type group in Tables 56 and 57. Summarizing those tables, the Draft EIS states that "Most cover types were highly aggregated (CI), with none resembling a checkerboard pattern" (p. 321). None of those metrics appears anywhere else in the Draft EIS. "Largest patch index" occurs at pp. 320 and 324; "clumpiness" at p. 324; "nearest neighbor" at p. 321. Every occurrence falls inside Appendix 5. The metrics are absent from the biodiversity affected-environment discussion at pp. 141–142, from the road-construction effects discussion at pp. 149, 159, and 162, and from the conclusion at pp. 165–166. No projected or post-rescission value is given for any of them, under any alternative. I am not claiming the Draft EIS ignores fragmentation. It discusses fragmentation qualitatively at pp. 141–142 and ties it to species sensitivity, and it discusses fragmentation and edge effects from road construction at pp. 149, 159, and 162 with reference to named species including the cerulean warbler, elk, and the marbled murrelet. My concern is narrower, and I do not believe those sections answer it: the Draft EIS's conclusion is comparative, and it is unsupported by the only measurements the Draft EIS made. At pp. 165–166 the Draft EIS concludes that road construction, road reconstruction, and timber harvest "could potentially have long-term adverse effects on biodiversity by increasing habitat fragmentation, loss of connectivity, negative edge effects, and human disturbance"; that "[t]hese impacts would likely be more frequent and broader in scale under alternative 2"; that impacts under alternative 3 "would likely have a lesser effect on biodiversity than alternative 2"; and that impacts "would likely be the least under alternative 1." That is a ranking of the three alternatives by severity of fragmentation effect. It is stated entirely in words of degree — "more frequent," "broader in scale," "lesser," "least" — with no quantity attached to any of them, while the agency's own fragmentation measurements sit unused thirty pages later. The mechanism connecting the rescission to those measurements is the one the Draft EIS itself describes. Rescinding the 2001 Rule removes the prohibition on road construction and reconstruction in inventoried roadless areas under Alternative 2, and in a reduced subset of them under Alternative 3. New roads subdivide forest patches. Subdividing patches lowers mean patch area and largest patch index, raises edge density, and increases mean distance to nearest neighbor — these follow from the metrics' own definitions, and Appendix 5's table note says as much: "Largest patch index reflects habitat continuity and approaches 0 for highly fragmented landscapes." The link from that metric change to the biodiversity outcome the Draft EIS is ranking is supplied by Haddad et al. 2015, which the Draft EIS cites at pp. 141 and 149 for the findings that habitat fragmentation reduces biodiversity by 13 to 75 percent and that effects are greatest in the smallest and most isolated fragments and increase over time. The Draft EIS therefore holds, in its own record, both the baseline values and the published relationship between a change in those values and the effect it is comparing — and applies neither to the comparison. The scale objection does not reach this request. Appendix 5's metrics were computed by the agency at the scale of the affected environment as a whole, by region and forest type group, minus the area within 100 feet of existing roads. That is a rule-scale analysis, chosen by the agency, and a baseline computed at rule scale admits of a projection at rule scale. Nothing I am asking for requires knowing where individual future roads would be sited; it requires applying a bounded range of road-density or road-mileage assumptions to a baseline the agency has already built. Under 7 CFR 1b.7(f)(2)(iii) I request that the Forest Service supplement the biodiversity effects analysis to apply the Appendix 5 metrics to a projected post-rescission condition for each alternative — at minimum.

Secretary Rollins, I am submitting this letter to express my strong opposition to the U.S. Forest Service proposal to fully or partially rescind the 2001 Roadless Area Conservation Rule. I urge the agency to fully support Alternative 1 (No Action) to keep the Roadless Rule completely intact. Our national forests and other public lands are a treasure and have been a central part of my life. I grew up hiking, camping and fishing with my family in the national forests of Colorado and Oregon. As a birder, I’m particularly concerned about what effect rescinding the Roadless Rule will have on our bird populations. I have experienced the wonder of seeing many birds that depend on intact roadless areas and careful management of our forest ecosystems: great grey owls, Clark’s nutcrackers, western tanagers, northern spotted owls, marbled murrelets, osprey and other raptors, to name a few. Unfortunately, in the last ten years, my husband and I have noticed how few birds there are as we hike trails in the Mount Jefferson Wilderness and visit estuaries at the Oregon coast. What we’ve been noticing has been part of a nation-wide story of bird loss. A 2019 study, [Decline of the North American avifauna, in the journal Science, (19 Sep 2019, Vol 366, Issue 6461, pp. 120-124) ] reported that bird populations had plummeted by 70% in the last 50 years. In real numbers, this was 3.3 billion birds, or 30% of the birds in North America that had disappeared by 2019. As to regional losses, there was an 11% decrease in Western forest birds, and 27% decrease in Eastern forest birds. Researchers estimated that forest bird populations have declined by 1.2 billion birds since 1970. In addition to this study, the 2025 State of the Birds Report by U.S. North American Bird Conservation Initiative (NABCI) at Cornell University revealed that bird populations across most habitats, including both Eastern and Western forests, have continued to experience consistent, steep declines. NABCI also reports that “…over 50% of western forest birds are declining due to habitat degradation from fire suppression and industrial timber management…” which has disrupted the mosaic of large old-growth areas and conifer and broadleaf forests that existed in the past. Building roads in forests on public lands further fragments habitat, and the concomitant extraction of timber or minerals degrades the environment even further. The agency’s own DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. (DEIS wildlife analysis; USFWS draft Biological Assessment; Haddad et al. 2015; McClure et al. 2013) High quality habitat and conservation are essential to turn around these declines. Forest conservation plans should go hand in hand with bird habitat conservation plans that employ sustainable forest management and fire-use practices that increase watershed resilience and benefit birds and people. In other words, turning around the decline in the bird populations includes forest restoration above and beyond the existing roadless areas in place now. That’s why it’s so important to not rescind any part of the 2001 Roadless Rule. In fact, the presence of a road is in itself very detrimental: The DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. The birds leave before the trees do. (DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) We need more forests and wild areas, not less. Roadless areas keep our forests intact as habitat for birds. In summary, fully or partially rescinding the Roadless Rule would be a devastating, irreversible mistake. I ask you to listen to the public, act responsibly, and do what is right for current and future generations. Keep the Roadless Rule entirely intact. Sincerely, Sarah Chaney Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The grizzly bear cubs I saw playing in a massive meadow at Yellowstone, the quiet wolf in Yosemite at five in the morning on a crisp February day, the sunrise over Death Valley: these are the things the national forests and parks have given me. I grew up camping in Kings Canyon National Park and California's state parks, and as an adult I have visited more than 10 national parks, drawn by the quiet, the stars, and the wildlife. The 2001 Roadless Area Conservation Rule protects the country where those experiences remain possible. I oppose its rescission. California holds 381 inventoried roadless areas totaling 4,389,760 acres, and 1,034 municipal water intakes across the Pacific Southwest region sit in watersheds that contain affected roadless areas. When the agency proposes to open that land, it is proposing to open the places I have gone to find the things the modern world cannot supply. This is my reliance interest, and I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The agency justifies rescission partly on wildfire and fuels management grounds. Its own record says otherwise. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire effects could increase the incidence of human-caused fires. A human-caused wildland fire is nearly five times more likely to occur on essentially roaded lands than on essentially unroaded lands." DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain why this proposal departs from those findings and reconcile the rescission with the ignition data its own analysis produced. I watched a grizzly in Yellowstone and understand in a direct way why roads and grizzlies are a poor combination. The DEIS, citing the federal grizzly recovery plan, confirms it: increased contact and conflict that come with open roads in grizzly habitat can ultimately end in grizzly mortality, and shooting, habituation and food reward all increase with the use of even secondary unpaved roads. The DEIS also finds, citing Haddad et al. 2015 and its own wildlife analysis, that habitat fragmentation reduces biodiversity by 13 to 75 percent, that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, and that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations." The agency must explain how opening these areas is consistent with its own documented findings on roads and wildlife mortality, and it must address that question as a distinct matter from fire policy. Water is a finite resource, and the agency's own data make the stakes concrete. Watersheds are already diminishing; lakes and reservoirs are running low; protecting what we have should be a top priority. The DEIS records that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Against that, the agency's own economic analysis projects only $5.2 to $11.4 million a year in timber revenue to the Forest Service, against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million. The agency also certifies no significant impact on small entities while the DEIS names outfitters, guides and tour operators as affected, and its own Cost Benefit Analysis books lost recreation benefit at a minimum of $6.1 million a year. That certification was reached by spreading losses across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. The agency should withdraw that certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. On the economics more broadly: "the total timber volume affected by this rule is less than 0.5 percent of total United States production, and the total oil and gas production from all National Forest System lands is currently about 0.4 percent of the current national production." The agency must reconcile this proposal with a Cost Benefit Analysis that cannot establish a net benefit, and explain how expanding a road system already carrying a $6.9 billion maintenance backlog is justified by returns this small. This is not about roads. It is about whose interests the agency is actually serving when it proposes to trade water quality, wildlife habitat and quiet mountain mornings for a fraction of a percent of national timber output. Sincerely, Catherine Oakland, California

Dear Brooke L. Rollins, As an outdoor enthusiast, I am filing these comments to note that the 2001 Roadless Area Conservation Rule is among the most extensively supported rules in the administrative history of the Forest Service, and the Department's obligation to engage that record — rather than override it — is a matter of basic APA fidelity. I grew up exploring this area with a backpack. The first time I pitched my own tent was right here. I don’t want this area to be used by vehicles. Regarding the Oat Mtn. in the Sequoia National Forest, California: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Most remaining forest is already near an edge. Globally, 70 percent of remaining forest is within 1 kilometer of an edge, where the buffering, cooling, and habitat-providing functions of intact interior forest are compromised. Fragmentation reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs key ecosystem functions (Haddad et al. 2015). — Haddad et al., 2015 (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Oat Mtn., Sequoia National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Keep the Roadless Rule! The DEIS's Own Invasive-Plant Section at Pages 114-116 Measures Existing Infestation, Declares the Action Alternatives Indistinguishable on an Unsupported Assumption, and Never Carries the Assessment's 81-of-134 Listed-Plant Figure The DEIS analyzes non-native invasive plant species at pp. 114-116 and identifies roads as a vector at p. 150: "Road construction, routine roadside mowing, and the use of roads have been shown to facilitate the spread of non-native invasive plant species." This comment is directed at three specific defects inside that analysis, not at its absence. 1. The extent figure does not measure the risk the section is about, and the DEIS concedes as much on the same page. At p. 114 the DEIS reports that mapped invasive plants "cover approximately 309,000 acres (270,787 for alternative 3), less than 1 percent of the potentially affected environment area," derived from existing mapped occurrences in the Threatened, Endangered, and Sensitive Plant-Invasive Species database (n.44). Two sentences later it states: "It is likely that there are populations that have been undetected and have not been mapped." A magnitude framing built on an inventory the agency describes as incomplete cannot carry the weight the "less than 1 percent" phrasing gives it. Separately and more fundamentally, the figure measures current infestation, not introduction risk in areas that are currently uninfested. The North Carolina Wildlife Resources Commission put the distinction to the agency directly: "IRAs often have less non-native invasive plants due to the lack of roads and other pathways generally associated with their spread and distribution" (DEIS Vol. III, p. 210). On that record the low current percentage identifies the resource at risk; it does not bound the effect. The FEIS should correct the disclosure to state what the figure measures, what it does not, and what the acknowledged mapping gap does to it. 2. The finding that the action alternatives do not meaningfully differ is unsupported and is contradicted by the section's own numbers. At p. 116 the DEIS concludes that "the alternatives are not expected to differ significantly in regard to their contributions to the introduction and spread of invasive species." The stated basis is that "The areas of likely operability for these activities are not expected to be significantly different under alternatives 2 and 3." No support is offered for that assumption. The same section states that "Alternative 3 has fewer acres in the potentially affected area than alternative 2" (p. 115) and reports different mapped acreages for the two - 309,000 against 270,787. A conclusion that the alternatives are indistinguishable for this resource, resting on an operability premise the analysis never demonstrates, removes invasive species from the comparison the environmental impact statement exists to make. The FEIS should either supply the operability comparison the assumption requires or withdraw the finding. 3. The listed-plant exposure the agency has already quantified appears nowhere in the DEIS. The Draft Biological Assessment for USFWS species states at p. 342: "Roads create favorable conditions for invasive plants by providing light gaps, dispersal corridors, and reduced competition. Vehicles and road maintenance equipment can spread invasive plant seeds, further contributing to their proliferation (Coffin et al. 2021)." At p. 344 it quantifies the stake: "Of the 134 plant taxa in this analysis 81 (60 percent) are threatened by invasive species sincerely, Heidi Sager

I have backpacked, photographed in these roadless lands. This regulation proposes to take away, destroy, another magnificent aspect of our country and an immense resource for short term profit. Shame. Specifically, you address roads. Road appropriations fell from $234 million in 2004 to $73 million in 2024, against a $6.9 billion deferred maintenance backlog. The supplemental funding is expiring. Maximum projected timber revenue is $5.2 to 11.4 million a year, against up to $6.1 million a year in lost recreation benefit by its own figures, and the agency’s own cost-benefit analysis states a net present value that runs to negative $92 million. The DEIS states outright that road mileage, deferred maintenance and management costs are likely to increase. (DEIS economics and infrastructure analysis; USDA Cost Benefit Analysis, p. 29.) In short, there aren’t the funds for the current roads and your budget continues to shrink. Roads and timber: Roads and timber harvesting will create forest fragmentation. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter. Marten disappear when forest cover thins; wolverine avoid roads used by winter machines. On big animals, its own words: wide-ranging mammals like the grizzly bear “have suffered habitat loss and the extirpation or fragmentation of their populations.” (DEIS wildlife analysis; USFWS draft Biological Assessment; Haddad et al. 2015; McClure et al. 2013.) In addition, the DEIS cites the findings that bird richness declines with road presence in forested habitat, and that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. (DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) Wildfire risk: Roads result in greater likelihood of fires. The majority of forest fires start within ten miles of roads. This will increase the number of forest fires while at the same time decreasing funding that would enable staff to fight them. Madness. Recreation: Absolutely. This is where thousands go for quiet country, for solace, for fishing and for hunting. The DEIS concedes the no-action alternative maintains the most opportunities for quiet, remote and self-reliant recreation, and that under rescission the settings could shift toward more developed conditions. In the DEIS’s own comparison, the rescission alternative “has the greatest potential for negative effects to scenery.” The agency understands the visual consequence and is choosing to accept it. No room for beauty, it seems, in the current administration. Mineral and Energy: No, coal has no future in this country, neither has oil. This proposed change is being built on an energy mirage, and is sacrificing short term destruction of long-term health. Water: Not mentioned! Approximately 24 million people use water that originates inside the roadless areas this action reaches, through more than 7,000 municipal water intakes. Right now that water is clean: less than 12 percent of the watersheds containing these areas have impaired streams. By the agency’s own analysis, the skid roads, trails and log landings that come with timber harvest are the main cause of soil erosion and can contribute up to 90 percent of the sediment generated by timber sale activity. (DEIS Table 35; Forests to Faucets 2.0 / EPA SDWIS.) The costs to health and increased costs of water cleaning have, I assume, not been addressed. Perhaps this administration doesn’t drink water and cartes little for those on public water supplies?

Dear Tom Schultz, I have traveled to Idaho to explore and appreciate the Smoky and Pioneer mountains every summer. I honestly don't know if I've encountered another high desert mountain terrain with as much beauty as these regions. The immense amount of species diversity and varying ecological landscapes are astounding and stunning and rely on protections such as the Roadless act to remain intact. Multiple nights spent dispersed camping with no sound but trickling creeks or rustling leaves, hikes spent IDing bird species I've not once encountered anywhere close to a road or civilization, hillsides full of high elevation blooms just thriving and making the air honey-scented. Stunning trout lazily swimming near the edges of glacial lakes that looked like jewels. All of these moments rely on these mountains remaining wild and protected. The Draft EIS's treatment of roadless-area wildlife habitat has real consequences for places like these “Species Count Not Reconciled to the Biological Assessment; Record Study on Species Representation Not Engaged The Draft EIS states (pp. 141, 168) that inventoried roadless areas provide habitat for "more than 300" threatened, endangered, and proposed species, per the "most recent USFWS and NMFS data." It gives no exact count, date, or cross-reference. The Draft Biological Assessment discloses its method — IRA shapefiles run through IPaC for the FWS list, NMFS species compiled from consultation records, both lists vetted by Forest Service staff and sent to the Services in September–October 2025, occurrence data from GBIF and NRM (BA p. 25) — but reports counts only by taxonomic group (e.g., 30 candidate bird species, 4 removed, 26 remaining, BA p. 161) and states no total. The BA also warns its databases do not differentiate between DPSs, "causing potential inflation" (p. 25). The "more than 300" figure cannot be traced to this method, and it is unclear whether it double-counts distinct population segments. Request 1: Under 7 CFR 1b.7(f)(2)(v), the Final EIS should state the exact species count, the date it reflects, whether DPSs are counted separately, and cross-reference the BA's Species Lists section wherever the figure appears — citing the correction per 7 CFR 1b.7(f)(3). Second, the figure does no analytical work. It appears only as background and is never tied to an effects conclusion — even though the same page states fragmentation reduces biodiversity 13–75% (Haddad et al. 2015), with effects "greatest in the smallest and most isolated fragments." The record already supplies the missing link: Dietz et al., "The Importance of US National Forest Roadless Areas for Vulnerable Wildlife Species" (2021), is in the Draft EIS's own reference list, cited in Vol. III (p. 37 n.201), and discussed at length in both the eight-state AG letter (Vol. III pp. 38–39) and the joint Tribal letter (Vol. III p. 498). Its finding: of 537 vulnerable terrestrial vertebrate species, 308 (57%) have suitable habitat in roadless areas — despite roadless areas covering only 2% of the contiguous U.S. — every roadless area holds habitat for at least two such species, and 81% of roadless acreage is suitable for at least five. Because this study is already in the agency's record, 7 CFR 1b.7(f)(2)(iv)'s bar on literature "not previously considered" doesn't apply — the agency need only analyze science it has already adopted. The chain is undisputed: rescission lifts road and timber-cutting prohibitions across the roadless network; the Draft EIS's own fragmentation finding predicts biodiversity loss, worst in small, isolated fragments; and Dietz et al. show this network is the disproportionate habitat base for the nation's vulnerable vertebrates — so shrinking it degrades species representation in the protected-area system. Request 2: Under 7 CFR 1b.7(f)(2)(iii), the Final EIS should state the rescission's effect on representation of species of conservation concern, using the corrected figure and engaging the Dietz finding — or explain in the response to comments why record science on this point doesn't apply. Both requests are substantive under 7 CFR 1b.11(a)(53): an unreconcilable affected-environment figure and an effects analysis that ignores a record finding are a failure to consider an important aspect of the problem, 5 U.S.C. § 706(2)(A). Both also affect the Section 7 consultation record, which rests on the same unstated baseline (BA p. 25).” Keep roadless areas roadless. Respectfully, CommentID: RLC-20260916-BIKIKN

To the U.S. Forest Service: As someone who plans around finding country roads haven't touched, I have a direct stake in the continuation of this rule. Regarding the Craggy Mountain in the Pisgah National Forest, North Carolina: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Fragmentation reduces biodiversity and ecosystem function together. A synthesis of habitat fragmentation studies spanning multiple biomes and 35 years found that fragmentation reduces biodiversity by 13 to 75 percent and impairs core ecosystem functions including biomass production, nutrient cycling, and carbon storage. Effects are strongest in the smallest and most isolated fragments and intensify with time (Haddad et al. 2015). — Haddad et al., 2015 (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Craggy Mountain, Pisgah National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. My family and I will lose the pristine wilderness, an experience that has immense value and is hard to find, especially in the East. Revoking the roadless rule will damage these special lands in ways that will be impossible to reverse. What will be gained from revoking the rule is far outweighed by what will be lost. The Department is urged to preserve the protections established by the 2001 Rule. Warm regards, CommentID: RLC-20260911-TEAPH0

To the U.S. Forest Service: As an outdoor enthusiast, I have observed that roadless areas on national forest lands are among the few remaining places where the public's experience of federal land is not mediated by motorized access, and I submit that the Department's proposed action has not adequately accounted for what the elimination of that condition would mean. I grew up going on camping trips with my family and now enjoy the outdoors as a way to disconnect from the bustle of city life and from our technology. One occasion in particular illustrates what that relationship means in practice. This past valentines day my boyfriend and I drove up Angeles Crest Highway for 1 night to enjoy a bottle of wine next to a campfire. There were no screens and we didn't have to listen to cars zooming by from a busy highway. The Rule has served as the legal foundation for the preservation of places like those referenced above; its rescission would represent an unjustified departure from twenty-five years of settled policy. Regarding the Arroyo Seco in the Angeles National Forest, California: The Arroyo Seco IRA, Angeles National Forest, harbors documented occurrences of Southern Mountain Yellow-legged Frog (Rana muscosa, G1, E). The presence of this Endangered species in an area subject to a proposed federal action triggers an independent ESA Section 7 formal consultation obligation that the agency must discharge before proceeding. The Roadless Rule currently functions as the barrier preventing activities that may affect Southern Mountain Yellow-legged Frog (Rana muscosa, E) in the Arroyo Seco IRA. Roads are not built because the rule prohibits them. Timber is not harvested because road access is unavailable. Rescission removes that barrier and enables the full suite of habitat-altering activities. If the agency finalizes rescission without completing formal consultation for Southern Mountain Yellow-legged Frog (Rana muscosa, G1, E) in the Arroyo Seco IRA, it acts in violation of ESA Section 7. Courts have consistently held that failure to consult is an independent basis for setting aside a federal action, regardless of whether actual harm to the species has occurred. "Habitat fragmentation strongly reduced species richness of plants and animals across experiments. Across experiments, average loss was >20% after 1 year, >50% after 10 years, and is still increasing in the longest time series measured (more than two decades). We were struck by the persistence of degradation to biodiversity and ecosystem processes and by the increase in many of the effects over time." — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Haddad et al. 2015, 2015 “Habitat fragmentation strongly reduced species richness of plants and animals across experiments. Across experiments, average loss was >20% after 1 year, >50% after 10 years, and is still increasing in the longest time series measured (more than two decades). We were struck by the persistence of degradation to biodiversity and ecosystem processes and by the increase in many of the effects over time. — Maine DEP NECEC Follow-up Joint NGO Comments (Appendix B), citing Haddad et al. 2015, 2015 (https://doi.org/10.1126/sciadv.1500052)” The Department should let the Rule stand. In earnest, Elyse Borst

Dear Secretary Rollins: As someone who knows the difference between land you drive to and land you have to earn on foot, I can tell you the 2001 Rule protects something that can't be reconstructed once it's gone. We hiked many areas of the White Mountains over the years and there is no comparison to the appreciation we have gained for its undisturbed beauty. The White Mountains are a national treasure and should be preserved as such. Allowing roads would be a disruption to its natural state that would take generations to recoup. The story recounted is, in substance, a case for the Rule's retention — one grounded not in regulatory theory but in the concrete experience of what roadless protection has made possible. Regarding the Sandwich Range in the White Mountain National Forest, New Hampshire: New road construction, reconstruction, and associated development fragment habitat, introduce disturbance, and eliminate roadless character. Most remaining forest is already near an edge. Globally, 70 percent of remaining forest is within 1 kilometer of an edge, where the buffering, cooling, and habitat-providing functions of intact interior forest are compromised. Fragmentation reduces biodiversity by 13 to 75 percent across studied ecosystems and impairs key ecosystem functions (Haddad et al. 2015). — Nick M. Haddad, Lars A. Brudvig, Jean Clobert, Kendi F. Davies, Andrew Gonzalez, Robert D. Holt, Thomas E. Lovejoy, Joseph O. Sexton, Mike P. Austin, Cathy D. Collins, William M. Cook, Ellen I. Damschen, Robert M. Ewers, Bryan L. Foster, Clinton N. Jenkins, Andrew J. King, William F. Laurance, Douglas J. Levey, Chris R. Margules, Brett A. Melbourne, A. O. Nicholls, John L. Orrock, Dan-Xia Song, John R. Townshend, 2015 · Science Advances (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Sandwich Range, White Mountain National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. The White Mountains do not seem to currently be, or have been under assault due to its roadlessness therefore rescission is unnecessary. The Department's obligation under the APA is to provide reasoned explanation commensurate with the significance of the policy change; that obligation has not been met, and rescission should be denied. Best, CommentID: RLC-20260829-2W61TS

Habitat fragmentation is proven to possibly lead to up to 75% of biodiversity loss. This is detrimental to our forest's animals and could lead to population imbalances. Do not increase the ability to build roads through natural lands as it is harmful to the balance of wildlife and migrating patterns. See the following articles for the harmful effects of habitat fragmentation: Nick M. Haddad et al. ,Habitat fragmentation and its lasting impact on Earth’s ecosystems.Sci. Adv.1,e1500052(2015).DOI:10.1126/sciadv.1500052 TY - JOUR AU - Mullu, Dagnachew PY - 2016/09/01 SP - T1 - A Review on the Effect of Habitat Fragmentation on Ecosystem VL - 6 JO - Journal of Natural Sciences Research ER -

Dear Secretary and Chief: I'm a student at Boston University who loves our forests, and my future depends on the policies that the Forest Service adopts today. I have lived in so many places, from England to the Pacific Northwest to New England today, and no place makes me so proud to call home. When I first moved to Boston, hiking in New Hampshire helped me connect with new friends, become more aware of the environment around me, and find a passion for trail running, hiking, and cycling. The Department is asked to conclude, on the basis of this and similar comments, that the aggregate public interest in roadless conservation outweighs the commercial interests that drive the rescission proposal. Regarding the Waterville in the White Mountain National Forest, New Hampshire: Intact roadless landscapes support functional soils, hydrology, and food webs that fragmented forests cannot replicate. Fragmentation reduces biodiversity and ecosystem function together. A synthesis of habitat fragmentation studies spanning multiple biomes and 35 years found that fragmentation reduces biodiversity by 13 to 75 percent and impairs core ecosystem functions including biomass production, nutrient cycling, and carbon storage. Effects are strongest in the smallest and most isolated fragments and intensify with time (Haddad et al. 2015). — Nick M. Haddad, Lars A. Brudvig, Jean Clobert, Kendi F. Davies, Andrew Gonzalez, Robert D. Holt, Thomas E. Lovejoy, Joseph O. Sexton, Mike P. Austin, Cathy D. Collins, William M. Cook, Ellen I. Damschen, Robert M. Ewers, Bryan L. Foster, Clinton N. Jenkins, Andrew J. King, William F. Laurance, Douglas J. Levey, Chris R. Margules, Brett A. Melbourne, A. O. Nicholls, John L. Orrock, Dan-Xia Song, John R. Townshend, 2015 · Science Advances (https://doi.org/10.1126/sciadv.1500052) Rescinding the Roadless Rule would open the Waterville, White Mountain National Forest to road construction and associated ground disturbance. The direct and indirect effects of that activity are precisely what makes a specific comment about this area necessary. Roadless areas are absolutely critical to the incredible biodiversity of the New England region, and the United States as a whole. Not only do they provide invaluable habitats for endangered species, but they also prevent the intrusion of invasive plants into the area, which would be introduced by roads fragmenting these ecosystems. They protect recreation throughout our national forests by reducing air and noise pollution, and making these places precious and safe. Roads through White Mountain National Forest would also contaminate water, release carbon into the atmosphere at a time when we are experiencing the hottest summer on record, and harm endangered species of fish, mammals, and migratory birds that call New England home. The Roadless Rule protects all of us who live in and love these places. The Department should not rescind the Roadless Area Conservation Rule. Gratefully, CommentID: RLC-20260827-DMWGC8