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I am writing regards to the rescission of the 2001 Roadless Rule. I am opposed to the rescission of this rule. I am a geologist , parent, educator, and outdoor recreation enthusiast living in the southwestern United States. I am a US-born citizen who has been paying taxes on my earnings for 50+ years. Here are some of the reasons I oppose eliminating the Roadless Rule. 1.Regarding wildfire control: Most wildfires are human-triggered. It is a documented fact that more roads in wilderness areas facilitate more human-caused fires. (Healey, 2020; https://iopscience.iop.org/article/10.1088/1748-9326/aba031 ; Balch et al.2017, https://www.pnas.org/doi/10.1073/pnas.1617394114 ; NPS, https://www.nps.gov/articles/wildfire-causes-and-evaluation.htm ). More roads lead to more people lighting campfires or smoking in formerly roadless areas. I know from my own outdoor experiences that many people are irresponsible with flames in combustible landscapes. In addition, vehicles themselves can also generate the sparks for wildfires. This is not uncommon in Arizona, where quartz-rich rocks in access roads are a bad companion to dragging metal chains. 2.Invasive plant species are promulgated when roads are built in roadless areas. (again, see Healey 2020). For example, here in AZ, invasive buffel grass and “stinkweed” are both deadly to native vegetation and provide excellent fuel for wildfires. 3.Regarding watershed/river/landslide/erosion negative effects: the USDA’s own preliminary environmental impact acknowledges negative impacts would result from building more roads in roadless areas, particularly in reference to the Tongass Forest (https://usfs-public.app.box.com/s/gomzq6rruwsds8rw50o3j3g429utj8f6/file/2415112742244 ; see also Pew Trust, 2026 https://www.pew.org/en/research-and-analysis/articles/2026/10/05/us-department-of-agriculture-proposes-eliminating-the-roadless-rule#:~:text=Roads%20and%20logging%20can%20send,concentrating%2C%20or%20diverting%20natural%20flows. ) Building more roads leads to loss of vegetation, increased erosion, more sediment load in watersheds which harms wildlife habitats and water quality, and higher landslide potential. Through my geologic and recreational experiences in Arizona, Washington State, Colorado, Oregon, and other western states, I can vouch for the negative geologic and biologic effects of road building in western roadless areas. 4.Regarding outdoor recreation: this is a non-political issue for many citizens throughout the political spectrum. Hunters, anglers, hikers, campers, and fans of the beauty of America’s wild places appreciate the majesty of places where human impact is minimized. the treasure of its iconic wild places. 5.The federal lands impacted by the Roadless Rule already have roads of various types in them. Do we really need more roads in these beautiful, fragile, unique American landscapes? In summary: More roads in the Roadless Areas will have negligible effects on wildfire management, but potentially tragic consequences on water supplies, wildlife, and the landscape in these remarkable areas. The treasure of American wild places will be irreparably harmed by the rescission of the Roadless Rule. Unlike inert gold, the living treasure of the Roadless Areas must be protected and nurtured by all of us to benefit us and future generations. Please respect my concerns, the concerns of American tribes and Alaska natives (https://tlingitandhaida.gov/news/roadlessrulerollbackopposition/) (https://www.wilderness.org/articles/press-release/ncai-and-tws-condemn-administrations-proposal-rescind-roadless-rule) , and the almost one million commentors on this proposal; and reconsider the rescission of the Roadless Rule. Thank you for considering my opinion and concerns.

I am in opposition to the plan the rescind the 2001 Roadless Area Conservation Rule. The proposed regulation claims that road construction in previously preserved areas will decrease wildfire risk. However, evidence from a 2020 study by USFS ecologist Sean Healy (1) showed that areas with and without roads burn at the same rate, suggesting that fires caused by humans using the roads offset the benefit of areas being more accessible by fire control services. Furthermore, a lack of roads in protected areas has not deterred fire prevention. The discontinuation of the Roadless Rule will have no positive effect on wildfire control and will likely increase wildfire prevalence due to logging. A 2006 study investigated wildfire severity in Sierra Nevada's unthinned and mechanically thinned forests, finding that thinned forests are more likely to be overtaken by wildfires (2). I trust the judgement of the peoples who have lived across this continent since time immemorial. As expressed in the Regulatory Certifications section of the Supplementary Information, Tribal governments majorly oppose the rescission of the Roadless Rule. Conservation of roadless areas preserves water quality, gathering areas, and sacred ancestral lands. I am in assent with either of the most frequently requested alternatives by Tribal Nations: retaining the existing rule or a strengthened roadless rule. In order to protect our forests, our wildlife, the communities who depend on them, and most importantly our Earth, it is integral that the Roadless Rule is retained. Thank you. References (1) Healy, S. P. 2020. Long-term forest health implications of roadlessness. Environ. Res. Lett. 15, 104023. (2) Hanson, C.T., Odion, D.C. 2006. Fire Severity in mechanically thinned versus unthinned forests of the Sierra Nevada, California. In: Proceedings of the 3rd International Fire Ecology and Management Congress, November 13-17, 2006, San Diego, CA

Hello, I am Sarah Zito and I oppose the recission of the 2001 Roadless Area Conservation Rule. I currently reside in the state of Washington, and prior to that, I lived in California. Both states are known for their astounding variety of biomes and public lands, including forests. I grew up camping, hiking, and backpacking in many of those forests, and now travel throughout the country to visit forests in other states. While I do use roads to get there, we do not need to add more to the ones already in existence. Many of our most scenic lands have limited or no road access, helping them to remain unspoiled and pristine. One of the main arguments for repealing the Roadless Area Conservation Rule is to allow the construction of roads to increase access for fire mitigation, but this is entirely unnecessary as Section 294.13 already permits tree thinning and emergency fire access. Another study, conducted by the US Forest Service, published in 2020 analyzed 20 years of data and found that, “…a lack of roads has not stopped fire prevention measures…” (Healey, Sean P. 2020 Long-term forest health implications of roadlessness. Environmental Research Letters. 15: 104023). This same study also found that, “roads are strongly associated with the spread of invasive plant species in national forests.” The conclusion of that study is that, “Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data.” In another paper, published this year, it was found that, “wildfire-ignition density was lowest in designated wilderness areas.” (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) Other impacts of building roads include but are not limited to the disruption of migratory routes, habitat fragmentation, deforestation, increased roadkill, the loss of biodiversity, the easier spread of invasive organisms, and an increase in air, soil, and water pollution. As an actual scientist with a background in environmental sciences and toxicology, ALL of those reasons should be concerning to EVERY person in this country, especially to those who are contemplating removing safeguards to increase these negative impacts. The destruction of our natural resources is definitely concerning to many voters, and those voters may choose to oust an elected representative who chooses to support abolishing this rule. Aside from the environmental impacts, there are also potential economic impacts to consider, such as who will be paying for these roads? If it a private corporation, will the public even be granted access to the roads? And if public lands are placed into the hands of a private corporation, will there be compensation to the general public? If the roads are paid for by our tax dollars, how will funds be allocated? We already have surmounting problems with our current infrastructure and existing roads need to be serviced before we even contemplate making additional ones. The Forest Service should choose the No Action Alternative, keeping this rule fully intact. Thank you, Sarah Zito

Please see attached document for my full comments and argument for strongly opposing rescinding the roadless area conservation act. Below is my conclusion from the document. The current roadless area rule already recognizes that there can be exceptional circumstances. It allows road construction in inventoried roadless areas when it is needed to protect public health and safety, including in response to an imminent threat of fire. This means the Roadless Rule does not require the Forest Service to ignore legitimate emergencies or community safety needs. Rather than removing the rule's protections across the board, I believe the existing exceptions and site-specific processes should continue to be used when a particular need can be demonstrated. Individual needs do not necessarily justify removing a national protection from millions of acres. What concerns me most is that some of the justification for rescinding the rule conflicts with the Forest Service's own history and research. The agency's 2001 analysis recognized the wildfire and ecological risks associated with roads (USDA Forest Service, 2001). More recent research conducted through Forest Service Research and Development found that roadless areas have not prevented fuel management and have not experienced higher rates of fire (Healey, 2020). Independent research has also found substantially higher wildfire-ignition density near roads (Aplet et al., 2026). Given that record, I urge the Forest Service to retain the 2001 Roadless Area Conservation Rule. References Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, 8. https://doi.org/10.1186/s42408-026-00450-2 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. https://doi.org/10.1088/1748-9326/aba031 Pew Charitable Trusts. (2026, October 5). U.S. Department of Agriculture proposes eliminating the Roadless Rule. U.S. Department of Agriculture, Forest Service. (2001). Roadless area conservation; Final rule. Federal Register, 66(9), 3244–3272.

I am a former USDA Forest Service employee, a backpacker, hiker, and frequent user of public lands, and I am vehemently opposed to rescinding the 2001 Roadless Rule. A USDA FS study by Sean Healy, "Long-term forest health implications of roadlessness" in 2020 from the Rocky Mountain Research Station found that increasing roads does not increase fire management, and spreads invasive plant species. The taking away of the Roadless Rule will also encroach on Native American sovereignty and access to their ancestral lands, including sacred sites, and have countless negative reverberations. It will also result in long, costly lawsuits - and I would know, as I was an employee on the most litigated National Forest in the United States of America, the Helena National Forest. As it is, more road building would mean more road maintenance, and per the USDA FS 2026 Q2 Fiscal Report, there is already over $6 billion dollars of deferred maintenance on our roads alone - and a backlog of over $11.4 billion dollars of deferred maintenance in total. The Center for Biological Diversity released a report in August 2026 that notes that rescinding the Roadless Rule would put almost 7.5 million acres of endangered animal's habitat at risk, alongside 1,500 miles of creeks, streams, and rivers, at risk for contamination by sediment and other pollutants. National Forest water sources provide drinking water for millions of Americans. I love being a Montanan, hiking on National Forest lands in one of the most intact wilderness states in the lower 48, sharing my world with wolverines, grizzly bears, wolves, and countless other species, flora and fauna alike, who would be threatened and stressed by road incursion into their habitat. Americans do not have much in terms of patrimony to be proud of. We do not have affordable healthcare. We do not have affordable college, or childcare, or family leave, and our federal minimum wage is still $7.25. In Montana, we have had to fight for so long to regain clean water, clean soil, and a healthy environment after decades of intensive resource extraction from mining, timber harvesting, and other industries gutted our land and water. What we do have is our public lands, and our access to them for not just this time but for all time - and not for greed, for enriching private corporations, but for preservation, public use, and for the flora and fauna we are so lucky to live amongst.

My name is Craig Fergus I am a residence of Front Royal Virginia and I'm writing to oppose the recession to the roadless rule. I often hike in the George Washington National Forest taking advantage of its numerous roadless areas to enjoy deeper areas of nature and can be found in other locations. However my appreciation for the continuation of the roadless rule is based primarily on the ecosystem services provided by these lower impact zones. As a wildlife biologist who has studied the impacts of roads on wildlife species, I believe the extent to which these areas contribute to healthy water quality, limit fragmentation, and in general support functioning ecosystems in a way that areas impacted by roadways cannot is something that should not be thrown away lightly. The most substantive argument I have seen for the change to the rule is one of improved fire control. However the Forest Services own research (Long-term forest health implications of roadlessness, Healey 2020) found that roadless and non-roadless areas had equal likelihood of burning. It also found that roadless areas had significantly lower numbers of invasive species. So if the agency's own data doesn't support the decision, why make the change? So again, I oppose the proposal to rescind or alter the Roadless Rule and support “Alternative 1, the No Action alternative.”

I am writing to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Our national forests are public lands held in trust for all of us. Once intact forests are opened to new roads and development, the ecological damage can extend far beyond the pavement. I urge the Forest Service to protect these landscapes rather than weaken one of the few safeguards that keeps them intact. Roadless areas are critical habitat. Dietz et al. (2021) examined 537 wildlife species of conservation concern and found that 308 species, or 57%, had suitable habitat within Inventoried Roadless Areas. These areas therefore provide meaningful protection for vulnerable wildlife. Roads also fragment habitat and disrupt ecological connectivity. Forman and Alexander (1998) documented road impacts including habitat fragmentation, barriers to wildlife movement, erosion, and altered hydrology. A road is not simply a line through a forest. It creates disturbance and access that can change how wildlife use an entire landscape. Fragmentation can prevent animals from moving between feeding, breeding, and seasonal habitats and can isolate populations that need connected habitat to survive. The argument that more roads will necessarily reduce wildfire risk is also not supported by the evidence. Aplet, Hartger, and Dietz (2026) analyzed more than three decades of national forest wildfire data and found approximately 1.97 fires per 1,000 hectares in Inventoried Roadless Areas, compared with 7.99 fires per 1,000 hectares within 50 meters of roads. Ignition density generally declined as distance from roads increased. Roads can improve firefighter access in some circumstances, but they also increase human activity and opportunities for ignition. Expanding roads should not be treated as an automatic wildfire solution. Road construction also has consequences for water and soil. Roads can compact soil, concentrate runoff, alter drainage, destabilize slopes, and increase erosion and sediment delivery to streams (Forman & Alexander, 1998). These impacts can degrade aquatic habitat and water quality far downstream. Protecting forests is also protecting the watersheds they sustain. Roads can further increase the spread of invasive plants. Healey (2020), using more than 15,000 forest inventory plots, found non-native plants were approximately twice as common within 152 meters of roads than farther away. Once invasive species become established, restoration can be difficult and expensive. I strongly oppose weakening the Roadless Rule because the burden of proof should be on those seeking to disturb intact public lands, not on those asking to preserve them. We already have roads and developed areas where infrastructure can be placed. We cannot recreate an old-growth forest, restore lost wildlife connectivity, or reverse decades of ecological change simply by deciding later that a road was a mistake. Protecting roadless areas does not prevent responsible wildfire management. Targeted actions can be evaluated where there is a demonstrated need without broadly opening protected landscapes to additional roads and development. The public has also demonstrated strong support for the Roadless Rule. A nationally representative 2019 survey found that 75% of Americans supported it, including majorities of Democrats, Independents, Republicans, and rural respondents (Pew Charitable Trusts, 2019). During a previous consideration of repeal, more than 625,000 public comments were submitted, with approximately 99% opposing repeal (Pew Charitable Trusts, 2026). Scientific evidence and public input point in the same direction: intact roadless forests are worth protecting. Public lands are a legacy we inherit and a responsibility we pass forward. I ask the Forest Service to reject the proposed rescission and retain the 2001 Roadless Area Conservation Rule. We should not sacrifice irreplaceable ecosystems for roads that can be built elsewhere. References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology. doi:10.1186/s42408-026-00450-2 Dietz, M. S., Barnett, K., Belote, R. T., & Aplet, G. H. (2021). The importance of U.S. national forest roadless areas for vulnerable wildlife species. Global Ecology and Conservation, 32, e01943. doi:10.1016/j.gecco.2021.e01943 Forman, R. T. T., & Alexander, L. E. (1998). Roads and their major ecological effects. Annual Review of Ecology and Systematics, 29, 207–231. doi:10.1146/annurev.ecolsys.29.1.207 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. doi:10.1088/1748-9326/aba031 Pew Charitable Trusts. (2019). Americans Support “Roadless Rule” to Protect Remarkable Forests. Pew Charitable Trusts. (2026). U.S. Department of Agriculture Proposes Eliminating the Roadless Rule.

Please do not repeal the Roadless Rule. The Roadless Rule protects over 58 million acres of inventoried roadless areas (IRAs) in national forest land from road-building, commercial logging, and other industrial activity. These protections are important and should be maintained. The USDA’s stated Rationale for the Proposal to repeal, i.e., that the “Roadless Rule has limited the Forest Service's ability to conduct vegetation management within inventoried roadless areas and has contributed to the lack of active management of the national forests, which in turn has contributed to challenges in addressing forest health concerns” (1) does not hold up and is not supported by the draft EIS. A study that carefully examined long-term forest health implications of roadlessness in terms of wildfires and invasive species concluded based on Forest Service data that “With the benefit of twenty years of monitoring, the best available records do not support speculation that roads are needed in IRAs to maintain forest health.“ (2). I am concerned that repealing the Roadless Rule would promote the spread of invasive plant and insect species (2). Invasive seeds and pathogens are actively moved along roads via construction equipment, logging trucks, and other vehicles. I am concerned that repealing the Roadless Rule would threaten clean water supplies on which millions of people depend. Inventoried roadless areas are home to numerous endangered and threatened species (3). Construction of roads in these areas would fragment and damage their habitats and contribute to their extinction. The draft EIS for the proposed rule rescission acknowledges on p. 233 that “By removing the Roadless Rule, roads and timber harvest are likely to penetrate much farther into roadless areas, resulting in a greater degree of fragmentation.” In addition, the draft EIS acknowledges on p.79 that “effects could also include long-term impacts such as invasive plant establishment and/or spread, a disruption in water relationships as would occur through diverting of surface or subsurface flow from road construction, or increased erosion potential through ground disturbance, and habitat fragmentation.” No evidence that those effects could be prevented is presented. Please avoid these damaging effects by keeping the Roadless Rule. I am also concerned that repealing the Roadless Rule would lead to the construction of roads through pristine and irreplaceable forests at immense public expense when there is already a huge backlog of maintenance on existing roads. I worry that the new roads would primarily serve the short-term interests of those who would profit from commercial logging and the extraction of minerals and fossil fuels, to the detriment of the environment and the public good. The knowledge that our nation’s roadless national forests exist, and that the native trees, birds, and animals within them are protected by the Roadless Rule, is a highly valuable intangible good that deserves consideration. The US public overwhelmingly supported adoption of the Roadless Rule and overwhelmingly supports keeping it (4). The draft EIS notes that of the comment letters received during the Notice of Intent comment period, approximately 99 percent were generally opposed to the proposed rule rescission. Please do not willfully ignore the evidence that the vast majority of people of this country want to keep the Roadless Rule. Please do not repeal the Roadless Rule. (1) See Published Document: 2026-16965 (91 FR 53827), Federal Register / Vol. 91, No. 160 / Thursday, August 20, 2026 / Proposed Rules, section entitled “Rationale for the Proposed Rule” (p. 53828). (2) See Healey, S. “Long-term forest health implications of roadlessness “ Environmental Research Letters. 15: 104023 (2020). DOI: https://doi.org/10.1088/1748-9326/aba031 (3) See Matthew S. Dietz, Kevin Barnett, R. Travis Belote, Gregory H. Aplet, “The importance of U.S. national forest roadless areas for vulnerable wildlife species”, Global Ecology and Conservation, Volume 32, 2021, e01943, https://doi.org/10.1016/j.gecco.2021.e01943. (4) See “Comment analysis finds over 99% opposition to repealing 2001 Roadless Rule”, report from Center for Western Priorities, September 19, 2025, updated Tuesday, September 23, and sources cited therein. (https://westernpriorities.org/2025/09/comment-analysis-finds-over-99-opposition-to-repealing-2001-roadless-rule/).

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

I am writing to state my opposition to the recission of the 2001 Roadless Rule. As a Pacific Northwest American Indian that was raised in Oregon and has volunteered countless hours learning about and practicing forest conservation techniques and strategies, I can state unequivocally that the reasons being given by the current regime's USFS decision to terminate the Roadless Rule are so blatantly false and contradictory of their own data that they can't even begin to dissemble the regime's true intent of following through with their traitorous pattern of plundering our collective commons for the benefit of wealthy private capital. The USFS's reasoning to terminate the Roadless Rule directly contradicts data and conveniently ignores salient information that aims to downplay the damage termination of the rule will cause and/or overstate the financial benefits. Here are just a few clear examples of how the USFS's reasoning falls apart under the lightest of scrutiny: 1. DEIS data shows that human-caused fire ignitions are 7-8 times denser on roaded than on roadless lands. Meanwhile, fire response times are only a few percentage points higher (97 vs 92) on roaded than on roadless lands. The manyfold increase in fire likelihood greatly overshadows the incremental gain in access to wooded areas that might be threatened by fire. 2. Research cited by the agency in 'Long-term forest health implications of roadlessness' by Sean P Healey in 2020 state clearly: "Agency management records show that a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System, although activities in areas with roads cover larger areas. Historical fire maps indicate that forests with and without roads have burned at similar rates since the Rule took effect.... Speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data." 3. The cost of building new roads is staggering when roads that we currently have are chronically underfunded. The DEIS's stated figures for road development stand at $80,000-$100,000 per mile plus an additional $5000-$50,000 per mile just in annual maintenance. The projected revenue gain is only $4-$11 million per year nationwide. Before opening these vulnerable and priceless ecological environments for logging, the public deserves a direct comparison of revenues minus the costs of development, maintenance, and ecological harm. These examples don't even make mention of the extensive damage that logging, clearcutting, and roadbuilding will have upon delicate ecosystems, watersheds, and wild animal resources that our public depend on. Therefore, it is in the public (as well as the government's) best interest to maintain the Roadless Rule to protect our land from predation by private interests that stand to privately benefit at the cost of irreparable public harm. I must insist that Alternative 1 is the only sensible decision in this matter and No Action against the Roadless Rule should therefore be taken. Sincerely, Garth D Henry

Dear Secretary Rollins and Chief Schultz: As a grandparent, I know the importance of stewardship, not consuming everything but leaving for the next generation what was left for me. We've been taking our grandkids to National Forests and roadless areas since they were very small. My first outdoors photos of my eldest grands were on the Mt Baker side of Stevens Pass, followed by many trips in the Cascades, including the Chiwawa and Chelan area. While my home address may be Mount Vernon, my real home is a cabin outside the Mt Baker Snoqualmie NF, nearby is the OkaWen NF. I step outside and I'm in the forest. I walk a little ways, I'm in the national forest. I'm closer to roadless nf than I am to a super market or hospital. It's a wonderful place for grandkids, grand nieces and nephews to visit. Wildlife is abundant, streams are beautiful. But it's the PNW and landslides from disturbed soils are a concern. Fires are constantly starting along the national forest roads where people drive and camp. No road would have been built where the Little Giant Fire started. And when it burned long enough to escape its valley, it tumbled down the slopes and leapt over the Chiwawa River and then it jumped the nf road. And studies show this, we do not need more roads to stop fires. We need safe slopes so another Oso does not happen. We need good water in our aquifers and wells. Although proponents of rolling back the Roadless Rule claim it is needed for wildfire management, the peer-reviewed science shows the opposite. A 2026 study in Fire Ecology by Aplet, Hartger & Dietz analyzed 32 years of wildfire data across all eight contiguous-U.S. Forest Service regions and found wildfire-ignition density was 7.99 fires per 1,000 hectares within 50 meters of roads, compared to just 1.97 fires per 1,000 hectares in inventoried roadless areas—a fourfold difference. A separate national analysis (Balch et al., PNAS 2017) found that 84% of all U.S. wildfires are human-caused. Roads are the primary vector for human ignitions, so building roads into roadless areas is likely to result in more fires, not fewer. Building more roads in national forests would be a drain on taxpayers. Even with the Roadless Rule in place, the Forest Service already has a 380,000-mile road system—twice as long as the U.S. highway system—crisscrossing national forests. The agency cannot afford to maintain it: the deferred-maintenance road backlog was estimated at $8.4 billion in the 2001 Final Environmental Impact Statement and is roughly $15.6 billion in today's dollars. The Government Accountability Office has repeatedly flagged Forest Service deferred maintenance as one of the largest in the federal government, and the backlog has never dropped below $5 billion. Adding new roads to inventoried roadless areas would only deepen that hole. “A national analysis of two decades of wildfire data found that human-started wildfires accounted for 84% of all wildfires, tripled the length of the fire season, and were responsible for nearly half of all area burned. Because roads are the primary vector for human ignitions, the finding directly bears on the wildfire consequences of opening roadless areas to road construction. — Balch et al., 2017 (https://doi.org/10.1073/pnas.1617394114)” “Comparing fire severity across forests under different protection regimes, the study found forests with higher levels of protection had lower severity values even though they are generally identified as having the highest overall levels of biomass and fuel loading. The result contradicts the claim that protected, intact forests are more dangerous fire risks. — Bradley et al., 2016 (https://doi.org/10.1002/ecs2.1492)” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as roaded areas. Claims that road prohibitions harm forest health are not supported by evidence. — Healey, 2020 (https://doi.org/10.1088/1748-9326/aba031)” A rule that has survived multiple administrations and multiple rounds of circuit-court review should not be rescinded on the present record. CommentID: RLC-20261006-SLBYA0

Dear Secretary Rollins, Please withdraw the proposal to repeal the 2001 Roadless Rule. I want future generations to inherit healthy forests, and I am concerned that repeal would cause lasting damage without making communities safer. A 2026 peer-reviewed study in Fire Ecology found wildfire ignition density was about four times higher within 50 meters of roads than in inventoried roadless areas (Aplet et al., DOI: 10.1186/s42408-026-00450-2). Forest Service scientist Sean Healeys 2020 study found forests with and without roads burned at similar rates after the Rule took effect. It also found non-native plants were twice as common within 500 feet of roads (DOI: 10.1088/1748-9326/aba031). These findings do not justify removing protections across the country. Please preserve the Roadless Rule and prioritize targeted, science-based measures that protect communities and forest ecosystems. Sincerely, Mona Reed The Forest Service should keep the Roadless Rule intact exactly as it is. Do not weaken or repeal this critical policy. National forests are the heart of our public lands. The Roadless Area Conservation Rule protects some of the wildest forests we have left, forests that protect critical wildlife habitat and drinking water for millions. Revoking the Roadless Rule puts landscapes, wildlife, and communities at risk. Not only is the Roadless Rule good policy, it's also wildly popular across the country, with over 600,000 people submitting comments to the US Forest Service last year in support of keeping the rule in place. And more than 20 years ago, the American people overwhelmingly called for our national forests to be protected for future generations. Revoking the Roadless Rule would destroy the natural inheritance we leave for our children.

RE: RIN 0596-AD66, Docket FS-2025-0001 Thank you for the Forest Service's work to find ways to keep our national forests healthy, and for the chance to comment. I support Alternative 1 and ask the Department to keep the 2001 Roadless Rule in place. I agree with the Department's diagnosis. Decades of fire suppression have built up fuels and closed canopies. I study butterflies and moths in the field around Clackamas and Multnomah Counties, and I see meadows filling in and open forest closing over without fire. Prescribed burning, managed wildfire and thinning are critical. Where I disagree is the prescription. New roads would make the Department's job harder. The rule is not what stands in the way. It does not restrict prescribed fire, and it already allows small-diameter cutting to reduce wildfire risk and roads to meet imminent threats. The Forest Service's Rocky Mountain Research Station found there is already more fuel treatment per square kilometer inside roadless areas than elsewhere (Healey 2020). The limit is funding and crews. A bright line is the cheapest answer. Today everyone knows the answer in a roadless area before spending a dollar. Rescission replaces that rule with a case-by-case "maybe" across about 44 million acres, decided forest by forest and likely litigated project by project. A "maybe" invites spending on long-shot roads and timber sales in remote, low-value country, and the public pays to prepare them: in the Tongass, 45 percent of timber sales offered from 1998 to 2007 drew no bids. Water providers, outfitters and recreation businesses have also relied on this rule for 25 years, and the final EIS should account for those reliance interests. The agency cannot afford more roads. The draft EIS reports that appropriated funding for the road system has fallen almost 70 percent in twenty years. Every dollar spent on new roads is not spent on burning and thinning. Roads also add fire starts: the draft EIS's own data show ignitions concentrated near roads, and Oregon's own comments cite 53 percent more ignitions than expected within 200 meters of roads. At the road stubs I visit I find broken glass, trash, shotgun shells and long-term camps, a law enforcement and fire burden that new roads would carry into country that has none today. Roads also bring invasive plants. The same Forest Service study found roads strongly associated with their spread (Healey 2020). This is a problem for everyone, including firefighters: invasive grasses such as cheatgrass cure early, fill the gaps between trees and shrubs, and carry fire faster and more often than the native plants they replace. Every new road is a new corridor for them into country that is mostly free of them today. Alternative 3 is not a narrow fix. It drops 17.9 million acres because they lie near a road or in the wildland-urban interface, plus the entire Tongass and, by Oregon Wild's count, about three quarters of Oregon's roadless acres. The fire concern near communities is already covered by the rule's exceptions. I ask that the final EIS (1) identify fire or safety projects the existing exceptions actually blocked, (2) state maintenance costs and funding for any road it expects to build or reopen, (3) explain why its goals cannot be met on roaded national forest land and the 104,000 miles of stored roads it already has, and (4) respond to the State of Oregon's comments asking for less than full repeal. Please keep the Roadless Rule and put the resources new roads would take into prescribed fire capacity, crews and maintenance of existing roads. Thank you for considering these comments.

The Roadless Rule should remain in effect. Nothing defines America more than our vast natural forests and rich landscape. While the Rule isn't perfect, lands of such importance require Federal protection, as states can already tailor the rule as needed and any opening in their management would open the door for these spaces to be tainted forever, with little to no economic benefit, and an increase in wildfire risk and further harm to the local region. Rescinding this Rule would not aid in the management of wildfires. Wildfire risk increases with roads: 90% of wildfires begin within half a mile of a road. One study showed that there were 7.4 fewer fires per 1,000 hectares in roadless areas compared to those with roads. Healey 2020 states that it's likely that any benefit gained with more agile positioning of fire-fighting assets is offset by the increase of wildfires that accompanies roads. An increase in fires would also drain local fire fighting resources. Roads increase the presence of invasive plants and trash, ruining the landscape and promoting a cycle of further management. [Healey, Sean P. 2020 Long-term forest health implications of roadlessness. Environmental Research Letters. 15: 104023.] If the roadless rule were rescinded, local economic benefit would be minimal. Consider that development is likely to occur by a multi state or even international timber or mining company, not a local operation, with a boom-and-bust cycle of development that only benefits the community in the short term (ex, look at what happened to Aberdeen WA). "American first" should mean protecting our lands from foreign development as a priority, in stark contrast to what has been allowed to play out in the Boundary Waters of Minnesota, where a Chilean mining company is now slated to ransack pristine American waters that are recreated and enjoyed by Americans. Protecting our lands and leaving the forests in their natural state as opposed to timbering and mining helps stabilize local climates and protect clean drinking water for American citizens. Revision should be the path for local control, following Idaho and Colorado's example. States can already tailor the current rule vs rescind it completely. [Aragon https://www.uwyo.edu/law/centers/center-for-land-and-water-law/blog/long-road-rescinding-roadless-rule.html]

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

I oppose the proposal to allow roads in our forests where they do not belong. Please see my attached PDF letter detailing my views. Also include below. October 5, 2026 Re: Opposed — Roadless Area Conservation Rule Docket No. FS-2025-0001 Dear Secretary Rollins: I am writing to oppose the proposed rescission of the 2001 Roadless Area Conservation Rule and urge the Forest Service to retain its protections for inventoried roadless areas. I live in southwest Oregon, where roadless lands are not an abstract concept. They are part of the landscape surrounding places such as the Kalmiopsis, Grassy Knob and Wild Rogue. These areas protect clean water, wildlife habitat, recreation and some of the last relatively intact landscapes in southwestern Oregon. I am particularly concerned with the suggestion that additional roads are needed to address wildfire risk. The Forest Service's own research deserves careful consideration before reaching that conclusion. In his 2020 peer-reviewed study, Long-term forest health implications of roadlessness, Forest Service scientist Sean Healey analyzed nearly 20 years of monitoring data and found that forests with and without roads had burned at similar rates following adoption of the Roadless Rule. He also found that fuel-management activities had not been prevented by the absence of roads. The study notes that higher human-caused ignition rates near roads may offset the firefighting advantage of increased road access. That finding is particularly relevant in western Oregon. A 2025 Forest Service analysis of more than 104,000 wildfire ignitions in Oregon and Washington from 1992–2018 found that 73 percent of ignitions west of the Cascades were human-caused. Recreation and open debris burning were the two largest identified sources. If human activity accounts for such a large proportion of wildfire ignitions in western Oregon, the assumption that more roads necessarily mean less wildfire deserves careful scrutiny. We should not increase human access into currently roadless forests without demonstrating that doing so will reduce—not increase—the risk of human-caused fire. The consequences of additional roads extend beyond fire. The Forest Service's research has documented road-related impacts on forest health, including the spread of invasive plants; Healey found non-native plants were twice as common within 500 feet of roads. The Forest Service also acknowledges that roads can contribute to sedimentation and habitat fragmentation, particularly where they cross steep slopes, sensitive soils, streams and wetlands. The Forest Service already manages more than 375,000 miles of roads. The existing Roadless Rule also contains limited exceptions for circumstances including threats to public health and safety from fire and other catastrophic events. Before permanently opening additional roadless areas, the agency should demonstrate why the existing road system and these existing provisions cannot meet legitimate access needs. The Roadless Rule has protected these landscapes for 25 years. I urge the Forest Service to fully address its own evidence concerning wildfire, human ignition, wildlife and habitat fragmentation, invasive species, water quality and the long-term costs of additional roads before rescinding this protection. Once an intact roadless landscape is fragmented by roads, we cannot simply put the landscape back the way it was. Sincerely, Bob Morrow Langlois, Oregon

I am writing to oppose any changes to the current Roadless Area Rule. I am a long-time resident of Montana, and have many family members who live in Northern Michigan, both areas that are home to and benefit from many inventoried roadless areas on US Forest Service and other Federal Public Lands. Removal or reductions of roadless rule protections would cause a noticeable detriment to my quality of life, safety, and wellbeing. As a resident of Northwest Montana, I have personally recreated in a number of inventoried roadless areas, including (but not limited to) in the Swan Mountains, Bitterroot Range, Cabinet Mountains, Beaverhead Mountains, and the area surrounding the Bob Marshall Wilderness complex. These areas feature complex, beautiful ecosystems that would be decimated by the introduction of roads. Studies show that roads bring water pollution which harms trout and other critical species (Sources: Bull Trout Distribution. 2019. Pacific States Marine Fisheries Commission, Portland, OR.; May, B. E., B. J. Writer and S. Albeke. 2012. Redband Status Update Summary. Prepared by Wild Trout Enterprises, LLC, Bozeman, MT.; Greenback Cutthroat Trout Conservation Populations. 2020. Colorado Parks & Wildlife, Denver, CO.) invasive plants and other non-native species (Source: Healey, Sean P. 2020 Long-term forest health implications of roadlessness. Environmental Research Letters. 15: 104023.) and increased risk for wildfire (source: Roadless: Active Management and Fire, A GIS data analysis and research review. Trout Unlimited, September 2, 2026: https://storymaps.arcgis.com/stories/3aecb3a57df8494d8c74582686feaefa). All of these impacts threaten my way of life and the wellbeing of my community and neighbors. I have also worked and recreated in areas of Montana that lack roadless protections. There are many of them: we do not need more. In fact, most of the roads that are built into our Forests and other public lands are currently in shambles: rutted out, eroding, and unsafe for most vehicles to actually use, so unless someone has an ATV or a dirt bike, these roads don’t actually provide increased access or safety. Due to our geography and weather, any new roads built after a recission of the roadless rule would quickly deteriorate to this same state, essentially causing scars across the landscape that don’t actually provide increased access for the majority of Americans. There is already a major deferred maintenance backlog across the National Forest System and other public lands: the US Department of Agriculture estimated recently that there is a $10.8. trillion deferred maintenance backlog, of which 55 percent is due to dilapidated roads that already exist. How does the Federal Government expect to keep up with this existing backlog, let alone deal with miles of new roads built into areas that do not currently have them. Federal Land management agencies are already facing significant reductions in funding; asking them to take on even more maintenance is just bad fiscal management. And asking them to not maintain the new roads would be unsafe, unwise, and could ultimately lead to the sell off or loss of public lands, all unacceptable outcomes. (U.S. Department of Agriculture Forest Service. 2025. FS-905 National Forest System Statistics Fiscal Year 2024. https://www.fs.usda.gov/sites/default/files/fs_media/fs_document/FY24-forest-system-stats.pdf ) I am also concerned about the myth that removing roadless protections will somehow magically bring back the US logging industry. This is false. To have an active logging industry, you need infrastructure. If you visit my area of Montana, you will see that mills no longer exist. They aren’t just closed—they have been demolished, such as the former Pyramid Lumber mill in Seeley Lake, Montana. The railroads, too, have been decommissioned. In the meantime, a thriving recreation industry has risen up, buoyed by the thriving, roadless forests which offer unapparelled recreation opportunities, thriving fish and wildlife populations. Local businesses, including lodging, restaurants, and guide services, benefit from these areas and help the local economy. If the Forest Service decides to open up the roadless areas in the Swan Range to roads and development, there would be no local economic benefit because the mill no longer exists. Any economic benefits from logging in these areas (if any) would go to out of state companies, not locals. Developing these areas would harm the local tourism economy, decimate the surrounding ecosystem, reduce recreation opportunities for locals and destroy our forests through invasive species, watershed degradation, and increased wildfire risk. Please reverse this unwise decision, and keep the roadless rule. It is of great benefit to local communities, conserves priceless ecosystems, preserves watersheds, and helps protect our communities from wildfire, invasive species.

I respectfully oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. The rule protects roughly 44.7 million acres of inventoried roadless areas, and the USDA's research does not support the premise that roads are the path to better stewardship of our public lands or wildfire resilience. Roads have been historically shown to increase ignitions, and roadless areas do not burn significantly more. The USDA Forest Service's own research shows the claim that roadlessness elevates fire risk is unsupported. A three-decade analysis of every contiguous-U.S. national forest wildfire (1992–2024) found ignition density was highest within 50 meters of roads (7.99 fires per 1,000 ha), versus 1.97 in inventoried roadless areas and 1.75 in wilderness, and this pattern held in all eight Forest Service regions. The authors conclude that building roads into roadless areas is likely to produce more fires (Aplet, Hartger & Dietz 2026, Fire Ecology 22:8). Similarly, Dr. Sean Healey of the Rocky Mountain Research Station found that forests with and without roads have burned at similar rates since the Rule took effect, and that fuel-treatment activities in roadless areas have actually been more numerous per square kilometer than elsewhere in the National Forest System (Healey 2020, Environmental Research Letters 15:104023, USDA FS contribution). Fire severity is not meaningfully worse in roadless areas. Peer-reviewed work cited by the Forest Service shows no significant difference in fire severity between roadless and roaded areas once biophysical differences are accounted for. One calibrated comparison in the Pacific Northwest found roughly 58% vs. 52% overstory mortality, a minor difference (Johnston et al. 2021; Reilly et al. 2017). Where more acres have burned in roadless areas, this partly reflects managers deliberately allowing fires to burn under appropriate conditions, which is a restoration tool, not a failure of protection. Roads degrade forest health rather than restore it. Healey (2020) analyzed over 15,000 Forest Inventory and Analysis plots and found roads are strongly associated with the spread of invasive plants: non-native plants are twice as common within 152 meters (500 feet) of a road as farther away, while root disease was only weakly correlated with distance from roads. The USDA study states that "speculation that eliminating road prohibitions would improve forest health is not supported by nearly twenty years of monitoring data." The agency cannot maintain the roads it already has. The Forest Service manages roughly 370,000–380,000 miles of system roads carrying a multi-billion-dollar deferred maintenance backlog. A 2017 USDA Office of Inspector General audit reported $3.45 billion in deferred road and bridge maintenance, and the USDA's infrastructure pages reported over $8.6 billion agency-wide in FY2023. Building new roads into roadless terrain would add liabilities taxpayers must eventually absorb. Notably, the 2001 Rule was adopted in part to ease the fiscal strain of road construction after ~386,000 miles of subsidized roads had already degraded water quality and habitat. Fire science has long favored working with, not against, roadless landscapes. Even the Forest Service's own fire management literature recognized decades ago that roadless areas contain extensive fire-adapted ecosystems where natural fire regimes can be restored without the fragmenting and igniting effects of roads (DellaSala & Frost 2001, Fire Management Today 61(2):12–23). For these reasons, I urge the USDA to withdraw this proposal and retain the 2001 Roadless Rule. If modification is actually needed, narrow, science-based adjustments through site-specific rulemaking, like what was done in Colorado and Idaho, is a more appropriate path forward instead of blanket rescission.

I am writing to submit a public comment on the Notice of Intention to rescind the 2001 Roadless Rule. Since 2001, the Roadless Rule has contributed to America’s greatness in a variety of ways. From supplying over 120 million people with clean water to protecting lands from wildfires as observed and researched by governmental groups and peer-reviewed studies. In addition, these untouched lands provide countless memories for Americans and non-Americans alike. The Roadless Rule has shown to be a tried-and-true legislative action that not only preserves nature but also provide common ground for all people to gather and protect through various efforts for everyone to enjoy. With that said, I strongly oppose the rescission of the Roadless Rule Millions of people who live in the United States rely on public water systems and most of that water comes from forested lands. The Roadless Rule has been a monumental act which provide millions of Americans with daily fresh drinking water while protecting many habitats and allowing for native plants and species to thrive. Finally, the Roadless Rule has consistently shown that this is a great law for America since the water quality tends to be better and higher when protected within the Roadless Rule areas. As recent as 2020 from the Forest Service, they stated that “a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System.” 2 Since this has come from the Forest Service itself, the reasoning to repeal the Roadless Rule per Secretary Brooke Rollins is incorrect. Further, in a 2025 public comment where 4 former Forest Service Chiefs signed off on a letter that stated, “We remain convinced that repealing the 2001 Rule will not be in the long-term interest of the American people, Forest Service employees, and the communities they serve” 3 These former leaders have overseen and managed the National Forests with extensive knowledge and experience. To dismiss their words and still move forward to remove the Roadless Rules means dismissing the evidence, observations, and experience of Mike Dombeck, Dale Bosworth, Tom Tidwell, and Vicik Christiansen; these 4 stewards who oversaw much of America and know its lands better than most. I highly recommend re-reading their letter and reconsider the removal of the Roadless Rule. Lastly, the Roadless Rule has offered countless adventures and trials throughout my life. Living near the Cleveland National Forest has given me the opportunity to appreciate Southern California in many ways. Being in that forest and hiking through the various areas discovering various creeks and seeing what Southern California really looks like with the diverse plants and animals is a stark contrast to being in the city and seeing absolutely little to no diversity or animals. The ability to be at a place where no one is around is a peace that few are able to enjoy and experience. Of course, going through Sequoia National Forest where I would walk amongst giants is a sight to behold. Once you’re off the road and hike a couple kilometers away, you forget that this is also part of California. This Roadless Rule offers a glimpse into the history of each state and what they used to look like before and gives an opportunity for future generations to also appreciate and conserve these lands. I’ve been to several National Forests and I always make it a point to hike on or through areas where vehicles cannot go in order to experience nature in its untouched form. Cleveland, Sequoia, Lolo, Snoqualmie, Gallatain, and Yellowstone are some of the National Forests I have been to and I can honestly say, that’s America in its rawest form and that’s the shock and awe that a documentary can’t do justice when you see the same scenery in-person. Seeing the power of a waterfall on a screen versus hearing and feeling that power in-person is an incomparable feeling one must experience in a lifetime. I hope to still hike these forests where no roads will run through and I urge the agency to: - Conduct a thorough environmental analysis of roadless areas to assess the impacts of additional road building; - Guarantee that no watersheds will be negatively affected by rescission; - Commit to moving forward with transparency, including a full account of how public comments were considered and concerns addressed. Regards, Quang Thai References: 1. Olden JD, Postel SL, Dombeck MP, Kesting H, Freeman P, Comte L (2026) Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water 5(7): e0000538. https://doi.org/10.1371/journal.pwat.0000538 2. Sean P Healey 2020 Environ. Res. Lett. 15 104023 (2020) Long-term forest health implications of roadlessness 3. https://forestpolicypub.com/wp-content/uploads/2025/09/Chiefs-9-15-25-Comments-to-Roadless-NOI.pdf

I oppose the rescission of the 2001 Roadless Area Conservation Rule. As a forest ecologist with a PhD in Systems Ecology from the University of Montana and an avid outdoorsman, I believe rescinding the Roadless Rule would be short-sited and ultimately irresponsible for the management of these lands and damaging to recreation value. I hike, backpack, ski, fish, and hunt extensively in and adjacent to Inventoried Roadless Areas across Montana, including in the Bitterroot, Swan, Flathead, and Sapphire Mountains. Rescinding the Roadless Rule would destroy the special values of these unique and distinctive areas beloved by myself and millions of American hunters, anglers, backpackers, climbers, hikers, and bikers. As a PhD ecologist who has conducted primary research on forest and fire management, I find the claim that rescinding the Roadless Rule would improve wildfire management incompatible with the facts. Wildfires are four times more likely to start near roads than in roadless forests due to increased human ignitions (Aplet et al. 2026), and these human-ignited wildfires tend to be the most destructive (Hantson et al. 2022), with human-caused wildfires destroying 10x more structures per unit area burned than lightning-caused wildfires (Higuera et al. 2023). Rescinding the Roadless Rule would increase the number of these destructive fires, while not meaningfully increasing the potential for forest management to address wildfire risk. The current Roadless Rule does not prevent fuel management activities to mitigate fire risk. In fact, recent research from the US Forest Service states that “a lack of roads has not stopped fire prevention measures; fuel management activities in roadless areas have actually been more numerous on a per-square kilometer basis than elsewhere in the National Forest System” (Healey 2020). Furthermore, expanding roads is fiscally irresponsible when the USFS already has an $8 billion maintenance backlog across 380,000 miles of roads. Adding roads would only increase this burden without providing the purported wildfire benefits. I strongly oppose rescinding or weakening the Roadless Rule. I support Alternative 1, the No Action alternative. Josh Beisel PhD, Systems Ecology References: Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22(1), 8. https://doi.org/10.1186/s42408-026-00450-2 Hantson, S., Andela, N., Goulden, M. L., & Randerson, J. T. (2022). Human-ignited fires result in more extreme fire behavior and ecosystem impacts. Nature Communications, 13(1), 2717. https://doi.org/10.1038/s41467-022-30030-2 Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters. 15: 104023., 15, 104023. https://doi.org/10.1088/1748-9326/aba031 Higuera, P. E., Cook, M. C., Balch, J. K., Stavros, E. N., Mahood, A. L., & St. Denis, L. A. (2023). Shifting social-ecological fire regimes explain increasing structure loss from Western wildfires. PNAS Nexus, 2(3), pgad005. https://doi.org/10.1093/pnasnexus/pgad005