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Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas buffering the Kalmiopsis and Rogue River Wilderness areas are not abstractions to me. I hike and recreate each year in the North and South Kalmiopsis wilderness areas, the Red Buttes Wilderness, the Siskiyou Wilderness, Siskiyou National Monument, and the Rogue River Wilderness. These are unique ecosystems that support threatened salmonid species, the threatened northern spotted owl, and endemic plant fauna not found anywhere else. I believe these areas are worth protecting, and I am filing this comment in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001. I bird for northern spotted owls in the Rogue Siskiyou National Forest. The agency's own draft environmental impact statement is not silent on what roads do to birds. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.). The agency has never explained, in this rulemaking, how it expects bird communities to absorb what its own cited science says they cannot. I ask the agency to reconcile its rescission proposal with those cited findings about road noise and bird abundance before this record closes. Late successional forest reserves provide clean drinking water to my rural community, and locally we use our surface waters for crop irrigation, swimming, fishing, and fresh drinking water. These beneficial uses are more valuable than gold. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. When these resources are lost, the cost and effort needed to restore them grows significantly. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. That number sits in the record. What the record does not contain is any honest accounting of what that sediment loading means for the 1,522 intakes downstream in this region alone. I want that accounting provided. The wildfire rationale offered for this rescission is the point where the agency's case collapses against its own findings. 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." I raised wildfire resiliency and clean water in my previous comment on this proposal, and I have received no response. The agency must explain on the record why this proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. This proposal also ignores a legal history the agency knows well. The record shows that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The agency has been here before. A state-by-state approach was tried. The Ninth Circuit addressed what came of it. The agency must explain how this proposal avoids those same deficiencies and must address its own prior finding that local and incremental decision-making can erode nationally significant roadless values over time. Surrendering public lands to resource extraction means losing the small remaining untouched wild areas left in the West. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. Opening these lands for private resource extraction is stealing our common resources. I want my kids and future generations to be able to enjoy these areas, to test their resolve through recreation, and to benefit from clean water and air. Has the Forest Service considered the substantial science behind wildfire resiliency and water protection that supports keeping these wild areas intact? That question belongs in this record, and this letter demands an answer. Sincerely, Bryan Duggan Coos Bay, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The scale of wilderness I have encountered while camping and hiking in national parks has never stopped surprising me. In each place, what struck me most was how vast an area existed beyond the trails, stretching out untouched. Those huge wilderness areas need to continue to exist without the roads and extraction industries now being proposed. Rescinding the Roadless Area Conservation Rule would end that. The wildfire argument the agency offers for rescission is directly contradicted by the agency's own findings. I noticed years ago that most wildland fires are caused by humans, and the record confirms it. The agency's own text 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." More people and machines in these areas means more opportunities for fires to start. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement (DEIS Table 21), which reports far higher fire density on roaded land than inside the affected roadless areas. I always have my camera when I am hiking. Landscapes, wildflowers, rocks, birds, and wild animals (if I am lucky enough to encounter them): I photograph them. The DEIS cites 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, drawing on Kroeger et al. 2022, McClure et al. 2013, and Ware et al. The agency entered these findings into its own record and then proposed to open these areas to exactly the disturbances that produce those outcomes. The agency should explain how it weighs that documented harm to bird communities against whatever benefits it claims to project. The economic case for rescission is similarly hard to sustain from the agency's own numbers. The record states that "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." Against that marginal gain, the agency's own Cost Benefit Analysis projects $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, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. The agency must reconcile the proposal with an economic analysis that cannot establish a net benefit on its own terms. The permitting burden rationale fares no better. The rule as written already states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions for existing mineral leases and community wildfire protection are also part of the existing framework. The agency has not identified which specific burdens fall outside those provisions. It should do so, with numbers, before proceeding. Finally, the regulatory flexibility certification does not hold together. The proposed rule 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 conclusion was reached by spreading a projected expenditure loss across every small firm in the sector nationally rather than examining the outfitters and guides who actually hold permits in the affected areas. The agency should withdraw that certification and conduct the assessment on the firms actually at risk, not a national average. Sincerely, Charleen Boudreau Illinois

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The Chiricahuas offer peaceful solitude, and the Santa Ritas feel like a whole other world, so close to Tucson yet entirely apart from it. I hike the Santa Rita Mountains frequently, looking for birds like elegant trogons found only in the sky islands of Arizona. These are not generic public lands to me. They are the reason I go outside. Rescinding the 2001 Roadless Area Conservation Rule would damage exactly what I am looking for when I go there, and this comment asks the agency to answer, specifically, for what its own documents already say. The Coronado National Forest holds 23 inventoried roadless areas totaling 482,687 acres, spanning the Santa Ritas, Chiricahuas, Galiuros, and Rincons, the connective tissue between the sky island ranges. Each range is an island of cool forest in a sea of hot desert. The birds I look for depend on that structure. The DEIS cites the finding 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) That is what the agency's own cited science says will happen to the habitat I walk through in the Santa Ritas. What I want to know is why that finding appears in the document and then disappears, with no projection of what it means for bird populations across the affected areas, and I ask the agency to address that gap directly. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears once and is then set aside. No projection across the 40.1 million acres of potentially affected environment follows from it. Arizona holds 78 inventoried roadless areas totaling 1,174,256 acres. The trogons I hike to see, the jaguars documented crossing from Mexico through the Santa Ritas into the Rincon Mountains and beyond, the verified species of the Coronado sky islands including Mexican spotted owl, Gould's turkey, Arizona treefrog, and ocelot: all of them live within a landscape whose integrity is measured partly by that fragmentation range. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and explain what that means for the species already documented there. The agency's own biological assessment does not soften its conclusion. "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. That is the agency's own count, from the agency's own assessment. The proposal identifies mitigation for none of it. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule is issued. The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. That number is stated and then left alone. No analysis of what harvest and roading would release under each alternative follows from it. Our public lands should be managed for wildlife, habitat, and responsible recreation, and none of those purposes is served by a document that cites a carbon figure of that scale and then draws no conclusions from it. The agency should quantify the change in carbon storage and sequestration under each alternative. The Santa Ritas are special because they are still intact. That is not sentiment; it is what the agency's own cited science describes when it documents the relationship between roads, noise, fragmentation, and biological loss. I am asking the agency to follow its own evidence to its own conclusions before it acts. Sincerely, Alex Patia Tucson, AZ

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless rule protects the increasingly globally rare expanses of wild spaces that are what truly makes this country special. I and millions like me seek wilderness areas to hike and camp for solitude, quiet, and respite, and the proposal now before this agency would strip the protection that makes those places worth seeking. I am writing to oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that the record reflect the following. Birdwatchers seek wilderness to find the rarest birds, ones most sensitive to human impact. We bring our cameras, our tourist money, and our social media accounts into these places, and the science in the agency's own record explains why roads destroy what draws us there. The DEIS cites 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) The agency must explain how rescission of the rule is consistent with this evidence in its own draft environmental impact statement, and whether it considered the economic value that birdwatchers and wildlife tourists bring to communities adjacent to these areas. The rivers, lakes, and streams within these landscapes are only enjoyable for kayaking, canoeing, and other forms of recreational paddling if they remain the unspoiled, beautiful waterways the roadless rule is meant to help ensure. Nobody wants to paddle listening to ATVs and truck engines. We want to listen to the water. And the water quality question goes further than recreation. This country already has enough water quality issues without introducing yet more pollution further upstream. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas. I ask that the agency explain how it weighs that finding against the interests of the millions of Americans whose drinking water originates in these watersheds. On the economic justification for this action, the agency's own record states that "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 the proposal with its own cost-benefit analysis, which projects $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, and explain how an action whose own numbers cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The wildfire rationale offered for rescission fares no better in the agency's own record. The DEIS states that "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." The agency has not explained why the proposal departs from these prior findings, nor has it reconciled the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. That reconciliation belongs in this record. The state-by-state alternative the agency now prefers has been tried before, and the agency's own prior rulemaking acknowledged that the USDA "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit reviewed that approach and found it wanting. The agency should explain how this proposal avoids the same deficiencies. Finally, the proposal's claim that the 2001 rule exceeded statutory authority runs directly into the Tenth Circuit's judgment, which stated: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The Tenth Circuit held that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness. The agency's basis for any contrary reading of its own authority must be stated plainly and defended in this proceeding. Our public lands are for the public, not for any one man or any powerful group of oligarchs. Our wilderness is quite literally irreplaceable, and we want it protected. Sincerely, Dr. Suzanne Scherping Baltimore, Maryland

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The roadless areas I value are quiet in a way that is genuinely rare. I go there to see the stars without light pollution and to hike away from the pervasive hum of electricity. What draws me out is the peace and wonder of the natural world we are so blessed to have, and part of that is watching the many birds that stop through roadless areas on their spring and fall migration. That is what this rescission puts at risk, and I oppose it. The agency's own record documents what roads do to birds. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) The agency then cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, but applies that range to none of the 40.1 million acres of potentially affected environment. That is not analysis; it is a number inserted and abandoned. I ask that the agency apply the cited fragmentation range to the 40.1 million acres before moving any further with this proposal. The fire rationale given for the rescission does not hold up against the agency's own data. 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." This has impacted my family numerous times as human-sparked wildfires have threated their homes on multiple occasions. The agency must explain, in its own record, why the rescission departs from those findings and how it reconciles the proposal with the ignition data in DEIS Table 21, which the agency itself placed in the document. On water: roadless areas are vital to protecting our drinking water. The agency's own data show that about 24 million Americans drink water that starts in these areas. That water is also what the wildlife I go looking for depends on. Impaired streams are more prone to contamination, with ripple effects down to human communities, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Opening these watersheds to roading and harvest is not a neutral decision, and the agency owes a clear accounting of what it expects to happen to stream quality in the affected watersheds. The carbon accounting in the DEIS has the same problem as the fragmentation analysis. The agency states: "The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons." Having stated that number, the document concludes that these lands will continue to sequester and store carbon, with no analysis of what harvest and roading would actually change. I ask that the agency quantify the change in carbon storage and sequestration under each alternative it is considering. Finally, I am sick and tired of my tax dollars going to the pockets of multimillionaire business owners instead of maintaining existing infrastructure that supports small business owners and keeps us all safe. The agency is already billions of dollars behind on maintaining the roads it has. Building new roads into country that has none, at public expense, to benefit timber interests, while that maintenance backlog grows, is not a responsible use of public funds. Fix the roads that already exist. The agency has not shown that this rescission serves anyone other than the narrow commercial interests that would benefit from access to these lands, and it should say plainly who it believes benefits and who bears the cost. Sincerely, Susan Massey Phoenix, AZ and Spokane, WA

Fishing the Chesapeake Bay is how I connect with my grandfather. I have fished it since I was little. That water, and the birds above and around it, are what bring me to this comment. I oppose the rescission of the 2001 Roadless Area Conservation Rule. I am currently conducting a research project on bird diversity, tracking calls to understand how feral cats affect bird populations. The agency's own environmental analysis found that road presence in forested habitat is associated with declining bird richness, and the DEIS cites findings that road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) My research depends on understanding what drives population change in birds. If roads enter currently roadless habitat and both noise and physical disturbance suppress bird abundance and drive species to avoid entire zones, those effects become variables I cannot control for and cannot attribute to other causes. The agency should explain, on the record, how it reconciles its own citation of these bird-abundance findings with a proposal that will expand road access into habitat where those declines are documented to occur. The regulatory flexibility analysis that accompanies this proposal cannot stand. The proposed rule 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. The certification reaches its conclusion by distributing the $9 million annual expenditure loss across every small firm in the sector nationally rather than assessing the outfitters and guides actually holding permits in the affected areas. The analysis concedes some firms may lose these receipts. A certification that ignores the firms actually at risk in the affected areas in favor of a national average is not a genuine assessment. I ask that the agency withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. The agency specifically invited comment on reliance interests. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. When an agency changes course it is required to assess the reliance interests its prior policy created. Comments like this one represent exactly such interests, and the agency invited them and then built no mechanism to weigh them. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire data argues against the proposal. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The effects analysis itself acknowledges that road access could increase the number and frequency of wildfires. That finding sits in the same document used to justify rescission, and no projection of increased ignitions follows from it. The agency must quantify the expected increase in human-caused ignitions from new road access and weigh it against the claimed reduction in wildfire hazard before it can rely on fire management as a justification here. Finally, the agency has quantified the erosion problem and then declined to follow it to its conclusion. The DEIS states that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That number appears in the document. No projection of sediment delivery to downstream water users follows it. I ask that the agency quantify projected sediment delivery to the more than 7,000 municipal intakes downstream of these areas. Sincerely, Ulysses M. Freeland, MD

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The national forests of the West are where I go for solitude and to experience wilderness. I ride trails throughout those forests, and I visit natural wild places as a birder looking for birds. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens every reason I go there, and I oppose it. The agency's own evidence on birds makes the harm concrete. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) These are not projections from outside the record; the agency put them there. Opening roadless areas to road construction would introduce exactly the road presence and noise that the cited research shows cuts richness, cuts abundance, and drives a significant share of species away entirely. The agency has not applied these findings to any estimate of what birds lose across the affected landscape. I ask the agency to do that analysis and make it part of the record before any final action is taken. The regulatory flexibility analysis deserves the same scrutiny. The proposed rule 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. The certification reaches its conclusion by spreading loss across every small firm in the sector nationally rather than examining the outfitters and guides actually holding permits in the affected areas, and the analysis itself concedes that some firms may lose those receipts. That is not a meaningful assessment of impact on the entities who will actually bear it. The agency should withdraw the certification and assess the impact on the small entities actually operating in the potentially affected roadless areas, not the national average firm. On reliance, The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I have organized my time in the West, my birding, my riding, and my pursuit of solitude around the expectation that these areas remain protected. An agency changing course is obligated to identify and weigh the reliance interests its prior policy created. The agency must identify and weigh the reliance interests described in the comments it receives, including this one. The fire analysis in the DEIS also points the wrong direction for the proposal. Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads. The effects analysis concedes that road access could increase the number and frequency of wildfires. Yet no quantification of that increase appears. The agency should quantify the expected rise in human-caused ignitions that would follow new road access and weigh it honestly against whatever wildfire hazard reduction it claims as a benefit. Finally, The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the record and then stops. No projection across the 40.1 million acres of potentially affected environment follows from it. A cited finding that the agency declines to apply to the scale of the action it is taking is not analysis; it is decoration. The agency must apply the cited fragmentation range to the 40.1 million acres of potentially affected environment and show what that means for the decision before it. Sincerely, Anne Jestadt Boise, Idaho

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Shellfish are my connection to the Pacific coast, through crabbing and clam digs along Washington's shoreline. The state I come from holds 139 inventoried roadless areas totaling 2,014,832 acres, and I hike and camp the state and national parks there, going out to see what birds reside in a given spot rather than chasing a target species. I am filing this comment to oppose the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, and I ask that the agency answer the specific points below. The wildfire rationale for rescission is contradicted by the agency's own record. 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." The proposal nonetheless invokes fire and fuels management as grounds for opening these areas to new road construction. The agency must explain on the record why the proposal departs from these findings, and must reconcile the rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is similarly unsupported by the agency's own numbers. The DEIS states that "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." Against that marginal supply-side figure, the agency's own Cost Benefit Analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, offset by recreation losses of at least $6.1 million a year, with a net present value range spanning -$92 million to +$199 million. That range cannot establish a net benefit. The agency should explain on the record how a proposal whose own analysis cannot confirm it pays off justifies expanding a road system already carrying a $6.9 billion maintenance backlog. Washington's roadless acres also protect drinking water. Across the Pacific Northwest region, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency has not addressed what road construction in these watersheds would mean for those intakes, and I ask that it do so. The birds I go out to see wherever I stop in Washington's parks and forests are precisely the species the record shows are harmed by road presence and road noise in forested habitat. The DEIS cites findings that bird richness declines with road presence, that road-noise experiments in a roadless area cut bird abundance by over a quarter, and that 31 percent of species avoided the noise entirely, drawing on Kroeger et al. 2022, McClure et al. 2013, and Ware et al. The agency should say plainly how this documented harm to bird communities inside roadless areas factors into its decision. On the legal authority question, the agency argues that the 2001 rule exceeded its statutory mandate, but the Tenth Circuit has already ruled otherwise: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address the Tenth Circuit's holding that the 2001 rule fell within authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and state the basis for any contrary position it now intends to take. Finally, the proposal argues that state-by-state approaches can substitute for a national rule. The agency's own record reflects its prior view that the Roadless Rule's "inflexible 'one-size-fits-all' nationwide rulemaking approach" was unsatisfactory. 70 Fed.Reg. at 25,656. But the last time the agency replaced the national rule with a state-specific framework, that approach was rejected in litigation. The agency has not explained how this proposal avoids those same deficiencies, or addressed its own prior finding that local decision-making can incrementally erode nationally significant roadless values. That question deserves a real answer here. Sincerely, David Lee Tacoma, Washington

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The birds brought me here. Cardinals, bluejays, red-tailed hawks, American bald eagles. Water brought me here, especially the Hudson River - the Palisades and hills and trees reflected in it, light moving across it. But I care just as deeply about people and places that have nothing to do with my daily life, and that is why I am filing this comment against the proposed rescission of the 2001 Roadless Area Conservation Rule. Public land should be managed for the benefit of the American people and their descendants. That is not a complicated principle. What belongs to us belongs to all of us, including future generations who have no voice in this rulemaking. The Bob Marshall Wilderness Complex in Montana, all 1,483,000 acres of it, is exactly the kind of place this principle was built to protect. I do not live near it. That does not matter. The spiritual blessings of places like that belong to every American, and a rule that opens them to roads and extraction forecloses those blessings permanently. I watch birds. The agency's own record should give it pause about what road-building does to them. The DEIS cites 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) Montana alone holds 235 inventoried roadless areas totaling 6,395,392 acres. Every road pushed into that landscape degrades the habitat that makes bird communities viable. I ask the agency to explain, specifically and on the record, how the rescission accounts for those documented effects on bird abundance and species avoidance in the affected roadless areas. The proposal leans on wildfire and fuels management to justify rescission. The agency's own findings say otherwise. "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." The agency must reconcile the proposal with its own ignition data in DEIS Table 21, which reports far higher fire density on roaded land, and explain why this proposal departs from its own prior findings about fire occurrence inside roadless areas. The economics do not hold up either. The agency's record states plainly: "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's own Cost Benefit Analysis projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year, with a net present value spanning negative $92 million to positive $199 million, and all of this against a $6.9 billion maintenance backlog on the existing road system. The agency cannot establish a net benefit from its own numbers. How does it justify expanding that road system on those terms? The proposal argues that state-by-state approaches can substitute for a national rule. The agency has been down that road. Its own record acknowledges "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." But the Ninth Circuit already found that local decision-making can incrementally erode nationally significant roadless values, and it rejected that state-specific substitute. The agency must address how this proposal avoids the same deficiencies the court identified the last time this was tried. Finally, the proposal questions whether the 2001 rule was within the agency's statutory authority. The Tenth Circuit resolved that question. "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The court held the rule was within the authority Congress granted under the Organic Act and MUSYA and did not create de facto wilderness. The agency must state, plainly and with legal basis, the grounds for any position to the contrary. What belongs to us belongs to all of us. That includes the people who will come after us and have no say here today. I oppose this rescission. Sincerely, Thomasin Willard Hastings-on-Hudson NY

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Migratory birds deserve continued and expected protection. That sentence is not complicated, and neither is what I am asking: the agency should keep the 2001 Roadless Area Conservation Rule in place and explain, clearly, why its own record does not already require that conclusion. The rule's ecological foundation for birds is not contested in the literature the agency itself assembled. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) Those findings describe what roads do to the forested habitat that migratory birds depend on. The agency placed them in the record and then proposed to open 40.1 million acres to road construction anyway. I want the agency to explain, specifically and on the record, how these cited findings about bird abundance and species avoidance were weighed in reaching that decision, and what it concludes will happen to migratory bird populations if the rule is rescinded. The economic case for rescission fares no better than the ecological one. The agency's own record states that "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." Those are not my numbers; they are the agency's. Against them, the agency's Cost Benefit Analysis projects $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, a net present value spanning -$92 million to +$199 million, and a road system already carrying a $6.9 billion maintenance backlog. No honest reading of that range establishes a net benefit. I ask that the agency reconcile the rescission proposal with these figures and explain how expanding a road system already in fiscal deficit is justified by a commodity contribution that its own record characterizes as less than half a percent of national production. The agency has been here before. The record recounts that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That argument did not survive judicial review the last time the agency used it to substitute state-by-state management for the national rule. The agency should address its own prior finding that local decision-making can incrementally erode nationally significant roadless values, and explain how this proposal avoids the deficiencies the Ninth Circuit identified when it last examined the state-by-state approach. The fragmentation problem is quantified in the DEIS and then simply abandoned. "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is wide, but every point in it is consequential when applied to 40.1 million acres of potentially affected environment. The agency cites the finding and projects nothing from it. The agency must apply that cited range to the full acreage at stake before this proceeding closes. Finally, the DEIS acknowledges what roads do to large mammals: "The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat." No population-level effect on big game appears anywhere in the document that follows. The agency should project the effects on big game populations and hunter opportunity before it finalizes any action under Docket FS-2025-0001. Sincerely, Melissa West Blacksburg, VA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The wildlife and natural habitats I look for exist in places clear of human development. That is not a casual preference. It is the condition that makes the finding possible, the photograph worth taking, the landscape still itself. The proposed rescission of the 2001 Roadless Area Conservation Rule threatens exactly that condition, and the agency's own record explains why. On wildfire, the agency's reasoning is its own undoing. The proposal leans on fuels management as a justification for opening roadless areas, yet the record states plainly: "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." I have lived through a fire season and seen what that means on the ground. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence, and that it reconcile the rescission with the ignition data in its own draft environmental impact statement, which reports far higher fire density on roaded land than inside the affected roadless areas. The birds I look for in forested habitat are measurably harmed by roads. The agency's own record, citing Kroeger et al. 2022, McClure et al. 2013, and Ware et al., documents that bird richness declines with road presence in forested habitat, and that road-noise experiments conducted inside a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely. Rescinding the rule that protects the quiet, unroaded character of these areas is a direct strike against the communities I go looking for. I ask that the agency explain what its analysis of bird abundance and species avoidance means for the populations dependent on currently protected roadless habitat, and that it address this finding as part of its response to comments. The elk I search out in summer depend on unroaded land with cover and forage. The agency's own cited sources find that elk avoid areas near roads and select habitat away from them, and that elk survival rates rose during a road closure and fell again when the gates were removed. Unroaded land is not incidentally good elk habitat; it is structurally necessary for it. The proposal does not reckon with this. The agency should state on the record how the rescission is consistent with the habitat relationships and survival data its own DEIS cites. The rule being proposed for rescission already contains the flexibility the agency now invokes to justify removing it entirely. The record itself acknowledges: "It generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the complaint is administrative burden, the agency should identify which specific burdens fall outside those existing exceptions, including those for existing mineral leases and community wildfire protection, and it should quantify those burdens in the record rather than assert them. On the state-by-state approach the proposal advances, the agency's own history forecloses confidence. The record notes that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible one-size-fits-all nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." That dissatisfaction was acted upon before. The Ninth Circuit reviewed the result. The agency should explain how this proposal avoids the deficiencies identified the last time this approach was tried, and address its own prior finding that local decision-making can incrementally erode nationally significant roadless values. Finally, the agency cites a quantified finding, that habitat fragmentation reduces biodiversity by 13 to 75 percent, but applies it to nothing. The 40.1 million acres that stand to be affected by this rescission represent a real landscape, with real populations of birds, elk, and the alpine habitats that support them. A finding that stark, cited in the agency's own DEIS, demands projection across the affected environment. The agency should apply that fragmentation range to the 40.1 million acres and present the result as part of its environmental analysis. Sincerely, Laura Klappenbach Firestone, Colorado

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Roadless means quiet. That is not a small thing. In places like Hardesty Mountain, in the Umpqua National Forest in Oregon, that quiet is the point. It is what makes it possible to actually hear the birds and other wildlife. I love all waters, rivers and mountain lakes included, and I believe our public lands should be managed for true multi-purpose: certain areas for sustainable tree harvest, certain areas for ecologically safe extraction, but large areas left for recreation, for clean water and air, and for all the non-human inhabitants. The 2001 Roadless Area Conservation Rule is one of the few tools we have that holds that line. I oppose its rescission. The agency's own draft environmental impact statement acknowledges what anyone who goes looking for birds already knows. The DEIS cites the finding that "road-noise experiments in a roadless area cut bird abundance by over a quarter, with 31 percent of species avoiding the noise entirely." Bird richness declines with road presence in forested habitat. These are the agency's own cited findings, from Kroeger et al. 2022, McClure et al. 2013, and Ware et al. If the agency rescinds this rule and roads follow, the habitat that makes quiet possible at Hardesty Mountain and across Oregon's 211 inventoried roadless areas totaling 1,937,741 acres is not recoverable on any human timescale. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent, and yet no projection of that range across the 40.1 million acres of potentially affected environment appears in the record. I ask the agency to apply that cited fragmentation range to the full 40.1 million acres before it takes any final action. The proposal invokes wildfire as a justification for rescission. But the agency's own record 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." That is the agency's language, not mine. DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency must explain why the proposal departs from its own prior findings and reconcile the rescission with that ignition data. The economic case for rescission is not made. The agency's own analysis projects $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, with a net present value spanning -$92 million to +$199 million. A cost-benefit analysis that cannot establish a net benefit does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. Moreover, the record states that "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." How does an action with those projected stakes, and that degree of economic uncertainty, justify permanent loss across millions of acres? The agency has not answered that question, and it must do so in this proceeding. The permitting burden argument fares no better. The rule as written states that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." Exceptions for public health and safety, existing mineral leases, and community wildfire protection already exist inside the rule. The agency has not identified which specific burdens fall outside those existing exceptions, nor has it quantified them. It should do both before the record closes. Oregon has 1,522 municipal water intakes sitting in watersheds containing affected roadless areas across the Pacific Northwest region. Clean water is one of the necessities of life I named, and it is not separable from the lands that filter and protect it. Rescission puts those watersheds at risk. The record must reflect that cost. Sincerely, John Mullen Dexter, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My family has hiked the Enchantments many times. A large photograph my son took of Lake Vivian on his graduation celebration hike hangs in our living room. My husband describes that area as a taste of heaven. I grew up in Cashmere, Washington, loving those natural spaces for exactly the reset they gave me. I now live in Spokane, and the older I get, the more I understand that protecting large areas of forest land is one of the most important actions we can take for the health of our entire planet. I oppose the rescission of the 2001 Roadless Area Conservation Rule. I support the no action alternative. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres, including more than 1,006,000 acres in the Okanogan-Wenatchee National Forest. These are places my family returns to. We love learning about birds, the American Pipit, the Dark-eyed Junco, and the occasional eagle. The agency's own data give me serious reason to worry what road-building would do to them. The DEIS cites the finding 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.)" The DEIS also cites the finding that "habitat fragmentation reduces biodiversity by 13 to 75 percent." That range appears in the document and is never applied to the 40.1 million acres of potentially affected environment. I ask that the agency apply that fragmentation range to the full extent of the affected acreage before this rule moves forward. Water protection is among my highest priorities. Creating new roads sets off a chain reaction with countless negative consequences from logging. The quality of our lives is directly linked to our access to water free from contamination. Across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. I want the agency to explain on the record how it reconciles that figure with opening these watersheds to new road construction. The process behind this rescission troubles me as much as the substance. More than 600 public meetings and 1.6 million comments shaped the original rule. No equivalent process is being conducted to undo it. So many people spoke up to get the roadless rule in place, and we should be working to protect even more wild spaces, not rolling back the protections we currently have. The proposal solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. My family's relationship with these forests is exactly the kind of reliance interest the agency invited and has not evaluated. I ask that the agency identify and weigh the reliance interests described in the comments it receives, including this one. The agency's own fire record weakens the case for opening these areas. "Human-caused ignition density is 22.4 fires per million acres per year on roaded National Forest System land against 3.0 inside the affected roadless areas (DEIS Table 21, 2014-2024), and the DEIS states that human-caused ignitions increase in abundance with proximity to roads." The agency has not quantified the expected increase in ignitions that new road access would bring or weighed that against the claimed reduction in wildfire hazard. That analysis must be done before any decision is made. Finally, the regulatory flexibility certification does not hold up. "The proposed rule 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." The certification is reached by spreading losses across every small firm nationally rather than assessing the guides and outfitters actually permitted in the affected areas. The agency should withdraw the certification and assess the operators who actually work in these places. Being in nature and photographing it helps to experience transcendent moments. More and more research shows connections between access to trees and wildlife and increased cognition and mental health. I want my children to grow up and enjoy these same spaces with their own children. Short-term profit is not worth the damage that will be done if we lose these protections. Please protect these sacred places. Sincerely, Tamara Kennedy-Gibbens Spokane, WA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 When I moved to Oregon, the ~8,000 acre Hardesty Mountain roadless area became one of my most frequented and meaningful places, and I bring my loved ones there to geek out over the old growth trees, the threatened plant and lichen species, and the unique birds in the area. The agency's own record, drawing on Kroeger et al. 2022, McClure et al. 2013, and Ware et al., acknowledges 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. Rescinding the Roadless Area Conservation Rule would expose Hardesty Mountain and the other inventoried roadless areas across Oregon, 211 of them totaling 1,937,741 acres, to the very road-building pressures the science documents as harmful. I ask the agency to explain, specifically, how that documented harm to bird communities is weighed in its proposal. Public lands should be managed for ecological health for all of us, human, animal, plant, fungi. This is where the water, air, and soils that we all depend on reside. My ecologist background informs me just how vital it is that this foundation for life be taken care of. Logging and road-building bring pollutants into waterways that are essential for all life, and the agency's own analysis acknowledges that roads and their facilities can produce up to 90 percent of the sediment from a timber sale. Across the Pacific Northwest region alone, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. Opening those watersheds to road-building is not a neutral administrative act. I want the agency to address, plainly and on the record, what it concludes happens to those intakes and the communities they serve when that sediment burden arrives. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own 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." The agency must reconcile this rescission with the ignition data in DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why its own prior findings on fire occurrence are being set aside. On the administrative burden rationale: the rule as written already provides that it "generally banned road building subject to limited exceptions including: the preservation of 'reserved or outstanding rights' or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3)." If the existing exceptions for public health and safety, mineral leases, and community wildfire protection already address the agency's stated concerns, then what specific, quantified burdens remain that only full rescission can relieve? The agency has not answered that question, and it should. The regulatory flexibility analysis accompanying this proposal 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. Spreading an aggregate expenditure loss across every small firm in the sector nationally is not an assessment of the outfitters and guides actually holding permits in these areas. The certification should be withdrawn and replaced with an analysis of the small entities actually operating in the potentially affected roadless areas. Finally, the proposal itself solicits "any reliance interests in the current rule that could be affected by this proposal" (91 FR 53830-31), and the Cost Benefit Analysis weighs none. This comment is one such interest. I commented in the 2025 round of public comments for the roadless rule, and I am exhausted that we must come back again and again in efforts to protect the health of our human and more-than-human communities. That exhaustion is itself a reliance interest: the rule has structured how people like me invest time, attention, and trust in these places. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it proceeds any further. Sincerely, Flora Eugene, OR

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The birds I look for require quiet. Finding snail kites in the Everglades, warblers in the Green Mountain National Forest, nuthatches in Lake Placid, yellow-billed cuckoos in the Appalachians: each of those searches has taken me miles from the nearest road or person. That distance is not incidental. It is the condition under which those birds exist in any useful abundance, and it is the thing this proposed rescission would put at risk across 40.1 million acres of national forest roadless areas. The agency's own draft environmental impact statement documents what roads do to birds. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) I photograph in places where there are no signs of human contact in the woods, because roads and development ruin the shots and ruin the habitat at the same time. The agency has cited the evidence and then declined to apply it. I ask the agency to explain how it reached a decision to rescind the rule while holding that evidence in its own file, and what weight, if any, it assigned those findings in reaching that conclusion. The fragmentation data receive the same treatment. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the document. No projection of what it means across the 40.1 million acres of potentially affected environment follows anywhere in the record. That is not analysis; it is citation used as decoration. The agency must apply the cited fragmentation range to the full affected acreage and put that projection in the record before any final decision is made. On wildfire, the agency's own record 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." The proposal cites wildfire and fuels management as grounds for rescission. Those two positions cannot coexist without explanation. The agency needs to reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas, and explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment. On administrative burden, the rule as written already contains exceptions. It generally banned road building subject to limited exceptions including: the preservation of "reserved or outstanding rights" or discretionary Forest Service construction necessary for public health and safety. 36 C.F.R. Section 294.12(b)(1),(3). If existing mineral leases, community wildfire protection, and public health and safety are already carved out, the agency must identify, by name and category, which specific burdens are not addressed by those exceptions, and quantify them. A general claim of permitting difficulty is not a showing. The massive shrinking of national monuments, the splitting of forests with roads: I find it difficult to understand how anyone reviews the agency's own findings on ignition rates, fragmentation, and bird abundance and concludes that opening these areas serves the public. The Forest Service held more than 600 public meetings and took 1.6 million comments to write the rule protecting them. It has held none to undo it. The asymmetry alone demands explanation. I oppose this rescission and ask the agency to answer each of these points in the final record. Sincerely, Andrew Johnson Bolton Landing, New York

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Fishing national forests across Oregon and the West, preferring un-roaded areas whenever possible, I find the proposed rescission of the 2001 Roadless Area Conservation Rule difficult to square with what the agency's own record says. These are not abstract landscapes. They are where I travel to hike and paddle away from roads, where my children fish, and where I look for river otters, Spotted Owls, Pileated Woodpeckers, and other older-forest-dependent species. The science on birds alone should give the agency pause before it proceeds. The agency's own DEIS, drawing on Kroeger et al. 2022, McClure et al. 2013, and Ware et al., cites 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. Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres. Opening those areas to roads does not merely allow equipment in; it restructures the acoustic and ecological conditions that species like the ones I watch depend on. The agency has quantified this effect in its own literature review and then proposed to move forward without explaining how the species affected by road noise and road-edge conditions will be protected under local forest plans. I ask the agency to explain, specifically, what enforceable habitat provisions in existing forest plans substitute for the bird-richness and noise-avoidance findings documented in its own DEIS. The wildfire rationale offered for rescission is undermined by the agency's own data. 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." That is not a finding from a critic of this proposal; it appears in the agency's own draft environmental impact statement, alongside DEIS Table 21, which documents higher fire density on roaded land than inside the affected roadless areas. The agency owes a clear explanation of why the proposal departs from these findings, and how it reconciles the ignition data in its own record with a justification built substantially on fire and fuels management. The sediment question deserves the same directness. The DEIS acknowledges that skid roads, trails, log landings and similar disturbances within timber sale areas are the main cause of soil erosion and "can contribute up to 90 percent of the sediment generated by timber sale activity." That figure appears and then the analysis moves on, with no projection of how much sediment would actually reach downstream watercourses if roadless protections are removed. Across the Pacific Northwest region, which includes Oregon, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The agency should quantify projected sediment delivery to those intakes before finalizing this action. Which leads directly to the drinking water problem. The DEIS states: "Approximately 24 million people use water originating within the potentially affected roadless areas, through more than 7,000 municipal intakes, and less than 12 percent of these watersheds are currently impaired." The document asserts that forest plans address public drinking water sources, but it does not identify a single enforceable plan provision that is equivalent to the protections currently found at 36 CFR 294.12 and 294.13. That is not an answer; it is a deferral. The agency must identify, forest by forest, which plan provisions carry equivalent force for municipal watersheds. Finally, the state-by-state rationale has been tested before. The DEIS itself reflects that "the USDA discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit already reviewed the last attempt to replace a national rule with state petitions, and it found that approach wanting. The agency has not explained how this proposal avoids those same deficiencies, or addressed its own prior finding that local decision-making can erode nationally significant roadless values incrementally. That question requires a direct answer in this record. The forests I fish and paddle and watch birds in are not improved by roads. Neither is the record supporting this rescission. Sincerely, Jon Bowers Portland, Oregon

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 I am writing to voice my strong opposition to the full or partial rescission of the 2001 Roadless Area Conservation Rule and submit the following points for the record. The White Mountains of New Hampshire are where I hike and camp regularly, and where I go in summer to observe shy birds like warblers, ovenbirds, and other deep forest species. The Sandwich Range, a 16,797-acre inventoried roadless area in White Mountain National Forest, is part of a landscape that is already seeing more and more traffic each year as tourists come to see my state's natural beauty. These are one of only a few pristine forests left in New England. Carving them up with more roads will bring more litter, more vehicles polluting the air, more runoff destroying the creeks and streams, would be a devastating loss to our state’s culture, history, and health. Public lands are an investment in our future. They protect our water, our air, our soil, and our connection to nature. They are a responsibility to be treasured and cared for, not plundered to line the pockets of the wealthy. The birds and wildlife I go to observe in the White Mountains depend on interior forest conditions that roads directly degrade. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) The verified species of the White Mountain include Bicknell's thrush, American marten, Canada lynx, the northern long-eared bat, moose, black bear, and brook trout. Opening roadless areas to new construction would alter the habitat conditions on which all of these species depend. I ask that the agency explain how the proposal accounts for these documented effects on bird abundance and species avoidance inside the affected roadless areas. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own record 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." I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS Table 21, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is even worse. The agency's own record states that "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 the proposal with its own Cost Benefit Analysis, which projects $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 fact that the Trump administration has already wasted countless billions of taxpayer dollars compounds that failure. The agency must explain how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system already carrying a $6.9 billion maintenance backlog. The proposal argues that the 2001 rule exceeded the agency's statutory authority, but the courts that reviewed that question held: "Exercising jurisdiction pursuant to 28 U.S.C. Section 1291, we REVERSE the district court's order granting Plaintiffs declaratory relief and issuing a permanent injunction, and REMAND the case for the district court to vacate the permanent injunction." The agency must address the Tenth Circuit's holding that the 2001 rule was within the authority Congress granted under the Organic Act and the Multiple-Use Sustained-Yield Act and did not create de facto wilderness, and explain the basis for any contrary position. Once again, I firmly opposed to the rescission of the 2001 Roadless Area Conservation Rule and demand that the agency answer to the very clear demands of the American people to leave the rule unchanged. Sincerely, J. K. Nashua, NH

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The land is ours. Once it is gone, it's gone, and there are fewer places left. I am submitting these comments in opposition to the proposed rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because what the agency is proposing to undo cannot be rebuilt once it is lost. I hike to be outside in nature. It is good for the soul. I look for wildlife and birds, and I believe the wildlife needs its space. The agency's own data make clear what opening these areas to roads does to birds specifically: 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. (Kroeger et al. 2022; McClure et al. 2013; Ware et al.) That is not a marginal effect. The agency must explain, in its response to these comments, how it expects bird communities to be protected across the affected landscape if this rule is rescinded. The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range is cited and then set aside. No projection of what it means across 40.1 million acres of potentially affected environment appears anywhere in the document. I ask that the agency apply that cited fragmentation range to the full 40.1 million acres before this rulemaking goes any further. The agency's own citation addresses what roads do to large animals too. The DEIS cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat. That finding is noted and dropped. No population-level projection follows. The agency should project the effects on big game populations and hunter opportunity under each alternative and put that analysis before the public. I have been on mountain roads that were dangerous because they were not maintained. It does not make sense to spend money to build more roads when there is not enough money to maintain the ones that already exist. Beyond the dollars, roads carry sediment. The agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale, and more than 7,000 municipal water intakes sit in watersheds fed by these roadless areas. Keep our watersheds clean. Fewer than 12 percent of those watersheds have impaired streams today, and the agency should explain on the record how that number will not grow if road construction is permitted to expand into country that has none. On carbon: The DEIS cites the estimate that these inventoried roadless areas contain about 5 percent of the stored forest carbon in the coterminous United States, roughly 0.9 billion metric tons. The document then concludes the lands will continue to sequester and store carbon, with no analysis of what harvest and roading would change. That is not analysis, it is assumption. The agency must quantify the change in carbon storage and sequestration under each alternative. The most serious failure in this record is what the agency's own biological assessment finds and then proposes to do nothing about. The agency's 428-page draft biological assessment closes: "Rescinding the 2001 Roadless Rule will increase the likelihood of road construction and timber harvests occurring in locations previously considered inventoried roadless areas. In many cases the Forest Service anticipates this increased activity to adversely affect some ESA-listed species and their designated critical habitats." The DEIS tallies the determinations: "may affect, likely to adversely affect" for 327 ESA-listed species and 71 designated critical habitats. The agency wrote those words. It anticipates the harm and proposes no mitigation. I ask that the agency disclose, species by species, how the likely adverse effects its own biological assessments identify will be avoided or mitigated, and that ESA consultation be completed and published before any final rule is issued. We need to stop developing every inch of the forest so our kids can know it. The Forest Service held more than 600 public meetings and took 1.6 million comments to write this rule. It has held none to undo it. A logged stand grows back. A road does not. The smoke from fire season is already so bad that you cannot go outside in town, cannot open windows, and it reaches people many miles from any fire. These lands filter water, hold carbon, and give wildlife the space it needs. They are not ours to spend. They belong to future generations too, and the agency should manage them that way.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The world God made is full of life and chaos, and every time I hike or camp I am trying to reach it, if only for a moment. The more we impose ourselves on those untouched spaces, the more we strip the world of God. Please, in this nation under God, do not destroy His work. Rescinding the 2001 Roadless Area Conservation Rule would do exactly that, and I oppose it completely. The wildfire argument the agency uses to justify rescission collapses against the agency's own words. 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." Forest fires already infect the air breathed across the entire country. If the agency's own record shows that roads increase ignition risk at nearly that ratio, why is new road construction being offered as a fire solution? I ask that the agency explain why this proposal departs from its own prior findings and data. On economics, the agency should be honest about what its own numbers say. The record before the agency states: "the total timber volume affected by this rule is less than 0.5 percent of total U.S. production, and the total oil and gas production from all NFS lands is currently about 0.4 percent of the current national production." We don't have enough land to consume in the way we go through smart phones. The classic consumerist mindset of wanting new instead of maintaining and fixing the used and worn is not a sound basis for federal policy. The agency already carries a $6.9 billion road maintenance backlog on a budget of about $73 million a year. The agency should reconcile this proposal with its own cost-benefit analysis, which projects $5.2 to $11.4 million a year in timber revenue against recreation losses of at least $6.1 million a year and a net present value spanning -$92 million to +$199 million, and explain how an action whose own analysis cannot establish a net benefit justifies expanding a road system already that deep in arrears. The birds are the music we are meant to hear, and the volume is turned down every tree that is cut down. That is not sentiment alone. The agency's own DEIS, citing Kroeger et al. 2022, McClure et al. 2013, and Ware et al., documents 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. Roads silence the landscape. The agency must address what this body of evidence, cited in its own DEIS, means for the biological integrity of the areas it proposes to open, and must explain why that finding does not weigh decisively against rescission. I became deeply sad when I realized that some global ancient areas I had visited were shutting down or limiting access because of deterioration under tourist foot traffic. And here we are, potentially choosing to tear down the American version of historic ancient grounds, places our descendants could never see or experience, for profit that historical precedent suggests is highly unlikely to materialize. The agency also needs to reckon with water. More than 7,000 municipal water intakes sit in watersheds fed by these roadless areas, and the agency's own analysis says roads and their facilities can produce up to 90 percent of the sediment from a timber sale. The administration has already moved to treat clean drinkable water as something less than a human right. The agency should not let that become the norm by degrading the source watersheds that supply drinking water to some 24 million Americans, and it must state on the record what alternative protection it is offering those communities. Finally, the agency tried replacing this national rule with a state-by-state approach once before. The record reflects that the USDA "discussed its dissatisfaction with the Roadless Rule and highlighted its rejection of the Roadless Rule's 'inflexible "one-size-fits-all" nationwide rulemaking approach.' 70 Fed.Reg. at 25,656." The Ninth Circuit rejected that substitution. The agency must address how this proposal avoids repeating the same legal deficiencies and must explain why local decision-making, which the agency's own prior findings said could incrementally erode nationally significant roadless values, is now adequate. Raw and roadless and real. That is what public land should be. With guidance from the native tribes that managed these lands for centuries before our ancestors arrived, we could preserve water supplies, protect the many species dependent on these lands and trees, and reduce the fire risk the agency claims to be addressing. Rescission does the opposite. I urge the agency to withdraw this proposal. Sincerely, Susi Overland Park, Kansas

The undisturbed forested areas along the four major flyways are where warblers concentrate during spring and fall migration, and those same habitats, far from major roads, are where I find the best wildlife photography. Both pursuits depend on forests that road-building has not yet reached. The proposal before the agency would rescind the 2001 Roadless Area Conservation Rule, and I oppose it. The agency's own environmental review documents what roads do to birds. 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. (source: DEIS; Kroeger et al. 2022; McClure et al. 2013; Ware et al.) That is not a marginal finding. It means that the undisturbed forested habitat I rely on for migration birding and wildlife photography would degrade in direct proportion to road construction. The DEIS also cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent. That range appears in the document, but no projection across the 40.1 million acres of potentially a!ected environment follows from it. I ask that the agency apply the cited fragmentation range to the 40.1 million acres of potentially affected environment. The wildfire rationale ordered for rescission conflicts with what the agency's own record shows. The DEIS states: "Building a road into a forest at high risk from uncharacteristic wildfire e!ects 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." If the agency's stated purpose includes protecting forests from fire, then the agency's own data argue against adding roads. I ask that the agency explain why this proposal departs from its own prior findings on fire occurrence and reconcile the rescission with the ignition data in its DEIS, which reports far higher fire density on roaded land than inside the affected roadless areas. The economic case for rescission is no stronger. The agency's record itself states: "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." Against that negligible share of national supply, the agency's own cost-benefit analysis projects timber revenue to the Forest Service of $5.2 to $11.4 million a year, set against recreation losses of at least $6.1 million a year and a net present value ranging from -$92 million to +$199 million. An analysis that cannot establish a net benefit does not justify expanding a road system already carrying a $6.9 billion maintenance backlog. The agency should reconcile the proposal with those figures and explain on the record how this action serves the public interest when its own numbers cannot confirm that it does. The agency also cites the finding that elk survival rates increased during a road closure and decreased when the gates were removed (Cole 1997), and that elk avoid roads and select unroaded habitat, yet no population-level elect on big game is projected anywhere in the document. The same gap applies to hunter opportunity. I ask that the agency project the elects on big game populations and hunter opportunity before any final decision is made. Our public land should be managed for the taxpayers who fund it, not the soulless corporations that want to profit off of it. The record assembled by the agency itself, on fire risk, on wildlife, on fragmentation, and on economics, does not support rescission. Each of the conflicts I have identified between the proposal and the agency's own data deserves a substantive, specific response in the final decision record. Sincerely, Rachel Reese Newport News VA 23602