Read the comments.

I oppose rescinding the roadless rule on the grounds that it would increasing the risk of wildfire in this country. In a study published in the journal Fire Ecology in January of 2026, scientists analyzed 32 years of data from across all U.S. forest regions and found that areas within 50 meters of roads were four times more likely to catch fire than areas that were roadless. It stands to reason, then, that building more roads into forests will increase wildfires. Wildfires not only harm the biodiversity living in our national forests, they put more carbon dioxide into the air, speeding up climate change. They also fill the air of cities and towns with smoke, endangering the health of U.S. citizens, and especially vulnerable people, such as myself. At a time when fire crews are tasked to their limits and barely able to contain the fires that have already been on the increase each fire season, rescinding this rule poses a grave threat to our country. I am citing the following study as evidence: Aplet, G.H., Hartger, P. & Dietz, M.S. Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. fire ecol 22, 8 (2026). https://doi.org/10.1186/s42408-026-00450-2 I would also like to submit the following additional evidence: Unsupported and Uncited Conclusion That New Roads Have No Material Effect on IRA Wildfire Ignition Rates The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Every year hiking with my dad in wilderness areas has shown me something that no policy brief can teach: what makes roadless country irreplaceable is precisely the absence of exploitation and intervention. Washington holds 139 inventoried roadless areas totaling 2,014,832 acres. These places can be reached by hunters, by anglers, by conservation enthusiasts, by campers, but only through effort, and that effort is part of what they are. Once a road goes in, the prior state cannot be recovered. Keep it Wild. The proposal justifies rescission in part on wildfire and fuels management grounds, but the agency's own record undercuts that argument. The DEIS states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." The agency's own data show far higher fire density on roaded land than inside affected roadless areas. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence and fuel treatment in roadless areas, and that it reconcile the rescission with the ignition data in its own DEIS Table 21. The economic case does not hold together either. The agency's own record acknowledges 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, 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, with a net present value spanning -$92 million to +$199 million. I object to the creation of an expanded opportunity economy for the wealthy at the expense of people who lead simpler, more meager lives and just want a few patches of nature to enjoy. Decisions of this kind are not making fiscal sense, particularly when the agency is already carrying a $6.9 billion road maintenance backlog on a budget of roughly $73 million a year. The agency must explain on the record how an action whose own Cost Benefit Analysis cannot establish a net benefit justifies expanding a road system the agency already cannot maintain. The proposal also claims the rule imposes administrative burdens, but the agency's own analysis of the existing rule states: "It makes little fiscal or environmental sense to build additional roads in inventoried roadless areas that have irretrievable values at risk when the agency is struggling to maintain its existing extensive road system (FEIS Vol. 1, 1-5 and 3-22)." The rule as written already contains exceptions for public health and safety, existing mineral leases, and community wildfire protection. The agency has not identified which specific operational needs fall outside those existing exceptions. I ask that it do so, and that it quantify those burdens on the record rather than assert them. Across the Pacific Northwest region, which includes Washington, 1,522 municipal water intakes sit in watersheds containing affected roadless areas. The communities drawing from those watersheds include people who are not wealthy, who rely on intact headwaters, and who are not positioned to absorb costs from sedimentation or degraded source water that road construction accelerates. The small-business certification that accompanies this proposal reaches its no-impact conclusion by spreading estimated losses across every small firm in the sector nationally rather than examining the outfitters, guides, and tour operators actually holding permits in the affected areas. The agency concedes that some of those firms may lose those receipts. Spreading a real local loss across a national average does not make the loss disappear; it makes the analysis misleading. The agency should withdraw the certification and conduct a genuine assessment of the small entities actually operating in the potentially affected roadless areas. The rule the agency proposes to rescind was built on more than 600 public meetings and 1.6 million comments. No comparable process has been offered for its undoing. There are things worth preserving so that future generations can connect with the historical experiences of Americans who long preceded them. The proponents of this rescission can find their wealth opportunities elsewhere. I ask that the agency address each of these points in the final record. Sincerely, A.M.C. Washington, DC

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

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

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Hiking in the Beaver Creek and Tower wilderness areas of the Wallowa-Whitman National Forest for the last 62 years, first with my mother and sisters when I was young and then as an adult with my daughter and nieces and nephews, has given me something I cannot fully describe and will not easily surrender. Those hikes taught me to understand and value the role national forests play in all of our lives: delivering clean air and water and protecting the ecosystems upon which we depend. I am filing this comment in opposition to the rescission of the 2001 Roadless Area Conservation Rule, Docket FS-2025-0001, because what is at stake in the Wallowa-Whitman is specific and irreplaceable, and because the agency's own record does not support what it proposes to do. Beaver Creek is 12,973 acres of isolated nature with lodgepole pines and granite cliffs. With an ever hopeful eye, you can see the paths of elk, lynx, and bears and perhaps catch a look at one of them. Tower, at 52 acres, is filled with alpine lakes and high altitude meadows with native flora, and all around are sounds of insects, birds, and small rodents. If permanent roads were built into these pristine out-back areas, it would completely alter the essence of the place. There would no longer be untrammeled vistas of granite slopes, with trees, and wildflowers and streams. That loss is not abstract. The agency's own environmental record states that wide-ranging mammals like the grizzly bear "have suffered habitat loss and the extirpation or fragmentation of their populations," and it further quotes the federal grizzly recovery plan to the effect that open roads in grizzly habitat increase contact, conflict, shooting, habituation, and food reward, ultimately ending in grizzly mortality. Elk, whose paths I have tracked at Beaver Creek, avoid areas near roads and select habitat away from them, and the agency's record found that elk survival rates rose during a road closure and fell again when the gates were removed. The agency must explain, in response to these comments, how rescission of the roadless rule is consistent with what its own biological analysis says about road presence and large mammal survival in exactly these landscapes. The proposal invokes wildfire management as justification for rescission, but the agency's own findings undercut that rationale. Its draft environmental impact statement states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." The same DEIS reports far higher fire density on roaded land than inside the affected roadless areas. The agency has not reconciled these findings with the direction it is now proposing, and I ask that it do so, specifically addressing the ignition data in DEIS Table 21. The proposal also gestures toward permitting burden, but the rule as written already accommodates the activities the agency says it cannot perform. A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." Given these existing provisions, the agency should identify on the record, by name and category, which specific burdens the current rule's exceptions for public health, safety, existing mineral leases, and community wildfire protection do not already address, and it should quantify those burdens rather than assert them. The regulatory flexibility certification 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." Oregon holds 211 inventoried roadless areas totaling 1,937,741 acres, and 1,522 municipal water intakes across the Pacific NW sit in watersheds with affected roadless areas. The guides and outfitters near Beaver Creek and Tower are specific small businesses whose receipts depend on the character of these specific places remaining intact. The agency should withdraw the certification and conduct a proper assessment of the entities actually operating in the affected 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 want the Wallowa-Whitman wilderness areas managed responsibly to safeguard access for future generations and protect the untouched landscape and ecosystems upon which we depend. That expectation was created by the rule that has been in place, and the agency is required to identify and weigh it. Let this comment stand as one the agency must address. Sincerely, Elizabeth Estabrook New York, NY

I am writing in favor of keeping the 2001 Roadless Area Conservation Rule as-is and in opposition to this proposed change that would rescind the 2001 Roadless Area Conservation Rule. Keeping roadless areas of our national forests is vital for long-term resource security, safety, and conservation. Rescinding the Roadless Rule and increasing the number and total length of roads will endanger our national forests by increasing the risk of wildfire and introduction of invasive species. Roads can increase the frequency of wildfires (eg, Narayanaraj and Wimberly 2012, Bowring et al 2024) - and even though fragmentation may reduce burn area, forest fragmentation is harmful to plants and animals in many ways and should not be viewed as an overall benefit or solution for wildfires. Similarly, roads (ie, human mediated travel) are a known dispersal pathway for invasive species (eg, Mortensen et al 2009, Ladin et al 2023, Solano et al 2021, Haubrock et al. 2026); many pest insects threaten our forests and to speed their spread into currently roadless areas could cause irreparable harm and economic loss (Lovett et al 2016). The National Forest Management Act requires that plans shall assure multiple use and sustained yield of National Forest System products and services and include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and wilderness (16 U.S.C. 1604(e)(1)). Rescinding the roadless rule will be harmful to fish and wildlife by increasing forest fragmentation, destroying habitat, increasing soil disturbance and run-off into waterways, and increasing the likelihood of human-wildlife conflicts (Croke and Hairsine 2006, Robinson et al 2010, Boston 2016). These conflicts will be great in magnitude if the roads lead to more timber production and mining. Increased timber production and mining is harmful to fish and wildlife. Furthermore, increasing roads and areas where natural resources are extracted will reduce access for recreation and have a negative economic impact on the tourism industry. The Forest Service's own analysis shows economic losses from reduced tourism and recreation caused by rescinding the Roadless Rule. Our National Forests should remain intact and roadless so Americans can enjoy them now and for centuries in the future. Short-term gains from resource extraction are not more important that the long-term integrity and preservation of our natural areas and resources for all Americans and future Americans to enjoy. Finally The rule states that "local decision making would remain subject to the substantive requirements of the Endangered Species Act". However, current changes to the Endangered Species Act means that any roads, timber harvest, of mining that removes habitat and other resources necessary for endangered species to survive would not be a violation of the Endangered Species Act. Therefore, endangered species are at highest risk by rescinding the Roadless Rule. Species cannot survive if their habitats are destroyed, degraded, and fragmented. I urge the USDA to protect our natural resources and do NOT rescind the Roadless Rule. Narayanaraj and Wimberly 2012 - https://doi.org/10.1016/j.apgeog.2011.09.004 Bowring et al 2024 - https://doi.org/10.1038/s41467-024-53460-6 Mortensen et al. 2009 - https://doi.org/10.1614/IPSM-08-125.1 Ladin et al. 2023- https://doi.org/10.1038/s41598-022-25989-3 Solano et al. 2021 - doi: 10.1093/jee/toaa278 Haubrock et al 2026 - doi: 10.1002/brv.70121 Lovett et al 2016 - https://esajournals.onlinelibrary.wiley.com/doi/pdf/10.1890/15-1176 Croke and Hairsine 2006 - https://cdnsciencepub.com/doi/10.1139/a05-016 Robinson et al 2010 - doi:10.1139/A10-002 Boston 2016 - DOI 10.1007/s40725-016-0044-x

I strongly oppose the rescission of the 2001 Roadless Rule for US National Forests. Rescission of the Roadless Rule would provide numerous harms to human, wildlife, and conservation values across the United States. Road building in forest lands is expensive and timber sales have never repaid the costs of building roads in our National Forests. Rescission of the Roadless Rule would not only cost US citizens enormously in terms of lost recreation and lost benefits of conserving forests, it would cost us financially. Rescission provides no benefit to most Americans. Among the many benefits of the Roadless Rule, it is critical to reducing severe wildfire. The majority of wildfires are started by people. Building roads into currently roadless areas makes these areas more vulnerable to wildfire. The DEIS contains multiple errors and inaccuracies in its analysis of wildfire risk that must be corrected. One critical error is that the DEIS clearly demonstrates the relationship between roads and wildfire but fails to apply this relationship to cost-benefit accounting. The DEIS finds at p. 94 that "[t]he incidence of human-caused fires generally increases with proximity to roads," and at p. 98 that "these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." Table 21 puts numbers to it: human-caused ignition density of 22.4 fires per million acres per year on other National Forest System lands against 3.0 in the potentially affected inventoried roadless areas. Figure 15 plots reported ignition density by distance to roads within those same areas. The Economic Analysis supplies the exposure distribution at p. 18: 51.5 percent of affected roadless acreage lies within one mile of a road, and 30.8 percent within a half mile. The DEIS contains a measured roaded-versus-roadless ignition differential, and the acreage distribution against which either could be applied. It applies none of them. In the Alternative 2 effects analysis the finding is restated and then set aside: "Road density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001). However, not all roads constructed under alternative 2 would be open for public access. Therefore, increased human ignitions do not necessarily follow from increased road construction." However, the DEIS nowhere states what share of roads constructed under Alternative 2 would be closed to public motor vehicle use, so no determination can be made about the effects of those closures. The cost-benefit analysis does not account for increased wildfire ignition despite claiming that it accounts for maximum costs. The Economic Analysis states at p. 26 that "[w]ith increased road construction, there could be increased hazard (which carries a cost) from human-caused ignitions," and that "[i]f there is an increase in public road access, the number and frequency of wildfires could rise." Having identified the cost, the analysis excludes it from the accounting. The Net Present Value at p. 29 is described as using "maximum potential costs and benefits," yet it carries no line for the ignition hazard. That is a factual error, independent of whether the excluded category can be monetized. Three corrections are required, all possible without new data collection. First, the Alternative 2 effects analysis must either apply Figure 15's ignition-density function and Table 21's differential to the road construction reasonably foreseeable under the alternative, or explain why the agency declines to do so. Under 7 CFR 1b.7(f)(1) the agency must analyze substantive issues, and the roads-to-ignitions relationship is an issue within 7 CFR 1b.11(a)(23) by the DEIS's own statement of the cause-and-effect relationship at p. 98. This is not deferrable to site-specific decisions: the rule-level decision removes the prohibition that presently prevents the roads, and the ignition exposure follows from the rule-level acreage, not from any single project. Second, the DEIS must disclose what proportion of roads constructed under Alternative 2 is assumed to be closed to public motor vehicle use, identify what in the proposed rule text secures that closure, and, if nothing does, withdraw the conclusion that depends on it. Third, the Net Present Value presentation at Economic Analysis p. 29 must disclose that it excludes the increased human-caused ignition cost identified at p. 26, or that cost must be included. I do not ask the agency to reach any particular conclusion about wildfire. I ask that the analysis either use the data it has assembled or say plainly that it has not, so that the record shows which. Thank you.

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

Dear USDA, As a steward to our public lands, USFS is responsible for caring for and maintaining our National Forests. These are PUBLIC LANDS, and in 2001 the Roadless Rule was established with vast public support because Americans value wild places. Over 1.6 million comments and more than 15 months of development led to the original creation of the Roadless Rule, and that public support persists 25 years later. In 2019, a Pew Charitable Trust survey found that 75% of surveyed Americans supported the rule (regardless of political party or urban/rural residency) (Pew, 2019). Last year, you received over 220,000 public comments, and ~99% of them opposed the proposed change. I strongly oppose the rescission of the Roadless Rule. US National Forests are “Lands of Many Uses." The USFS already manages over 265,000 miles of roads for recreation, wildlife viewing, and timber harvest purposes. These roads allow people of all backgrounds to get outside, but not every scenic area needs roads. Over half of USFS land is already managed without the restrictions of Wilderness or Roadless Rule regulations (OnX, 2026), so it is in the public’s best interest to keep roadless areas set aside. Roadless areas attract outdoorspeople explicitly because they lack new road construction. These are scenic, quiet, natural places, often with abundant wildlife and clean air and water. They are places without roads for logging or mineral extraction and mining. They are also places with huge networks of existing trails. For a recreationist, roadless areas strike the perfect balance between wild and accessible. According to analysis by OnX, roadless areas contain over over 13,000 miles of trails accessible to motorized vehicles such as snowmobiles, motorbikes, and 4x4s, over 19,000 miles of hiking, biking, and ski routes, and over 3000 rock climbing areas (OnX, 2026). These are not empty wasted areas, and implementing further road construction would degrade the wilderness-like experience of outdoor recreationists who seek these areas out. Along with their inherent value to recreationists, these areas have strong economic value. A 2018 economic analysis assigned over $9 billion in economic benefits just from passive and recreational use, with the added benefit to local economies with strong outdoor industries (Hjerpe and Aldrich 2018). This summer, I had the wonderful experience of exploring a roadless section of Sequoia National Forest. In that subalpine meadow, I hiked through a relatively unfragmented ecosystem, encountering birds and wildlife that would be negatively impacted by roads. Even forest roads are a threat to wildlife. One of the biggest threats to biodiversity is habitat degradation and destruction, including fragmentation. A 2006 study in Nantahala National Forest found that even narrow, unpaved logging roads with relatively low usage had a negative impact on salamander abundance, and that impact extended outward from the roadway by at least 35 meters. Further, once roads have been built, it is nearly impossible to unbuild them, and the fragmentation and negative impacts to biodiversity can continue for decades after a logging road is decommissioned (Semlitsch et al. 2006). Multiple peer reviewed studies cast doubt on the argument that adding roads will improve fire management (Aplet et al. 2026, Kilbride et al. 2026, Johnston 2021, Healey 2020, Narayanaraj and Wimberly 2012). Healey (2020), synthesized 20 years of monitoring data, and found that the USFS had actually conducted more fuel management activities per unit area in roadless areas than in other parts of the National Forest System. Further, he found that forests with roads and roadless areas burned at similar rates over 31 years. Johnston et al. (2021) concurred, noting that fire severity was the same across both classifications of land. Finally, several authors have noted that human caused wildfire ignitions are higher in areas closer to roads (Narayanaraj and Wimberly 2011, Aplet et al. 2026). They note that there is a trade-off between higher ignition rates and ability to fight fires, leading to negligible overall impact. Increasing wildfire management is not a strong argument for rescinding the roadless rule. I come to this comment wearing many hats. I am a biologist. I am a hiker and runner and birder. I gravitate towards natural areas all over the country. I have had the privilege of exploring roadless areas in Utah’s Manti La Sal National Forest, California's Sequoia National Forest, Montana's Custer-Gallatin, and Wyoming's Medicine-Bow National Forest. I grew up walking seemingly endless boardwalks that veered in and out of the roadless portion of Croatan National Forest in North Carolina, and learning from my grandparents about the creatures that lived there. I love public lands, wildlife, and outdoor recreation. I firmly oppose the rescission of the Roadless Rule, and support Alternative 1, No Action. Thank you, Caroline sources attached

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

We are losing roadless areas all across the country. Once they are penetrated by roads and vehicle, they are changed for all future generations. This must stop now. Road-Proximity Ignition Finding Rests on a Designation-Level Analysis and an Undisclosed Figure 15 At Draft EIS page 98, in the Wildfire Occurrence discussion, the agency states: "Consistent with other research findings, these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." The Comparison of Alternatives table in Chapter 2 carries that finding into the effects comparison, stating that under alternatives 2 and 3, "if there is an increase in public road access, there could be increase the number and frequency of wildfires as human-ignitions are more likely near roads." The Draft EIS therefore treats an increase in the number and frequency of wildfires arising from road proximity as a reasonably foreseeable effect of the proposed action. The analysis the Draft EIS presents does not support that finding at the magnitude asserted, for two reasons established by the document's own text. First, the two analyses the Draft EIS documents measure land designation, not road distance. Table 18 (p. 95) and Table 21 (p. 98) both compare other NFS lands, potentially affected IRAs, and wilderness, using Interagency Fire Occurrence Reporting Module (InFORM) Fire Occurrence Data Record ignitions with a point of origin on NFS lands for 2014-2024. A contrast among land designations cannot isolate a road-proximity effect, and the Draft EIS concedes the confounding on the same page. It states that "Other NFS lands typically have more land management activities, infrastructure (such as powerlines), and public recreation that can lead to human caused ignitions," and it reports that other NFS lands have "about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates" (p. 98). Natural ignitions are not caused by road access. The agency's own explanation for the natural-ignition differential - biophysical difference and detection rate - applies with equal force to the human-ignition differential in Table 21, and the Draft EIS neither tests nor excludes it before attributing that differential to roads. Second, the only analysis in the Draft EIS that measures ignitions against road distance is Figure 15, "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs" (p. 98). Unlike the captions of Tables 18 and 21, the Figure 15 caption identifies no data source and no period, and the figure carries none of the documentation supplied for those tables in footnotes 38 through 40 at page 94. The narrative does not reference Figure 15 or report any value from it - no distance classes, no ignition counts by cause, no exposed area, no densities. The one within-IRA road-distance analysis in the document is presented with none of the information a reader would need to evaluate it, while the two designation-level analyses that cannot answer the road-distance question are fully documented. I request that the Forest Service supplement the wildfire occurrence analysis (7 CFR 1b.7(f)(2)(iii)) to report the data underlying Figure 15 - the distance classes, ignition counts by cause, exposed area, and resulting ignition densities - and to state whether the road-distance relationship within the potentially affected IRAs survives the confounders the Draft EIS itself identifies at page 98. If it does not, the finding at page 98 and the Fire and Fuels row of the Comparison of Alternatives require factual correction under 7 CFR 1b.7(f)(2)(v). Absent one or the other, the Final EIS would assert a reasonably foreseeable effect for which it has disclosed no supporting analysis: not a cause-effect relationship established within the meaning of 7 CFR 1b.11(a)(23), and not a reasoned explanation under 5 U.S.C. Sec. 706(2)(A). See Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). Forum. This concern is directed to both the Draft EIS and the proposed rule. The road-proximity ignition finding supplies a factual predicate for the wildfire rationale stated in the Purpose and Need, and the Purpose and Need is the standard against which alternatives were measured for elimination from detailed study. An answer given only in the Final EIS response-to-comments appendix would leave the concern unanswered as a comment on the rule. Protect what's left. Keep the Rule.

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

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

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Enjoying nature, hiking, backpacking and occasionally hunting and fishing has meant something real to me across most of my life, and the country animals depend on is not abstract. It is the unroaded terrain where elk and other animals move and survive, where I can hike and climb away from the sound or sign of motorized travel. The National Forests across the West are where I go for that. The proposal to rescind the 2001 Roadless Area Conservation Rule would put those experiences at risk, and the agency's own record gives reasons to deny the rescission that the agency has not answered. The justification leans in part on wildfire and fuels management, but the agency's own prior findings run the other direction. The DEIS states plainly: "Consistent with other research findings, these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)” with Table 26 suggesting that the risk of ignition is about 5 times greater next to a road than a mile or more away. Opening roadless areas to road construction does not reduce ignition risk. It multiplies it. The agency must explain why the current proposal departs from that finding, and must 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. That reconciliation belongs in the record. My ability to hunt and view animals as well as their survivability is tied directly to the character of the land they use. The DEIS acknowledges this connection and then walks away from it. The record states: "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." The agency cites that finding and then projects no population-level effect on big game anywhere in the document. That is not analysis. The agency must project the effects of the proposed rescission on big game populations and on hunter opportunity across the affected landscape, and must address those projections in the final rulemaking. Hiking to a lake or peak in a wild place, without motorized travel, is a smaller version of the same principle: intact habitat holds more of what makes wild country worth going to. The DEIS’s own Conclusions recognizes that the Alternatives could have adverse impacts to biodiversity based on their own findings and quantifies what fragmentation does to that: "The DEIS cites the finding that habitat fragmentation reduces biodiversity by 13 to 75 percent." That range is significant. It appears in the record and then disappears. No projection applies it to the 40.1 million acres of potentially affected environment. A range of 13 to 75 percent means something very different at scale, and the agency has a responsibility to work through what it means here. I ask that the agency apply the cited fragmentation range to the full 40.1 million acres before it finalizes any action. Finally, the agency has invited comment on reliance interests and then declined to weigh them. 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 interest is this: I have organized how I hunt, hike, climb, fish and experience nature around the existence of this rule. The wild places I depend on for fishing without motorized travel, for hunting, for hiking and backpacking in National Forests across the West, exist in the form they do because the 2001 rule has held. That is a reliance interest the agency invited, created, and has not assessed. Under settled administrative law, an agency changing course must grapple with the reliance its prior policy generated. This comment is a record of that reliance. The agency must identify and weigh the reliance interests described in the comments it receives, including this one, before it takes any final action. To conclude, I maintain that the agency’s own document (DEIS) provides reasons to deny recission of the roadless rule. The agency must reconcile increased risk of wildfire by allowing increased road construction with suppression of wildfires by having road access, provide an analysis of the effects of the proposed rescission on big game populations and on hunter opportunity across the affected landscape factoring in biodiversity loss and not solely increased road access, and apply the cited range of potential habitat fragmentation across the full 40.1 million acres covered by the roadless rule to assess the full impact of the alternatives. Sincerely, William Rice Colorado

Dear Secretary Rollins and Chief Shultz: I am writing as an avid user of the roadless areas not only in my home state of Idaho, but across the United States. Although Idaho may have its own roadless rule, I still value the over 40 million acres of roadless areas across all America's public lands. These areas are important to me because they exist to protect watersheds, promote biodiversity of fish, wildlife, and plant species, as well as provide irreplaceable recreational opportunities. With over 300,000 miles of existing roads on National Forests today that cannot be properly maintained, more roads by means of rescinding the Roadless Rule is exactly what the Forest Service should not be attempting to do. Building roads into roadless areas is likely to result in more wildfires. Roads will not stop nor lessen the increasing amount or frequency of wildfires. More roads = more people = more fires. In the Wildfire Occurrence section on page 98 of the Draft EIS, the agency states: "Consistent with other research findings, these analyses indicate that human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires (Narayanaraj and Wimberly 2012, Parisien et al., 2016, Balch et al., 2017, Chen and Jin, 2022)." The Comparison of Alternatives table in Chapter 2 carries that finding into the effects comparison, stating that under alternatives 2 and 3, "if there is an increase in public road access, there could be an increase in the number and frequency of wildfires as human-ignitions are more likely near roads." The Draft EIS therefore treats an increase in the number and frequency of wildfires arising from road proximity as a reasonably foreseeable effect of the proposed action. The analysis presented in the Draft EIS does not support that finding at the magnitude asserted, for two reasons established by the document's own text. First, the two analyses of the Draft EIS documents measure land designation, not road distance. Table 18 (p. 95) and Table 21 (p. 98) both compare other NFS lands, potentially affected IRAs, and wilderness, using Interagency Fire Occurrence Reporting Module (InFORM) Fire Occurrence Data Record ignitions with a point of origin on NFS lands for 2014-2024. A contrast among land designations cannot isolate a road-proximity effect. It states that "Other NFS lands typically have more land management activities, infrastructure (such as powerlines), and public recreation that can lead to human caused ignitions," and it reports that other NFS lands have "about twice the density of natural ignitions than IRAs or wilderness, potentially due to biophysical differences or higher detection rates" (p. 98). Natural ignitions are not caused by road access. The agency's own explanation for the natural-ignition differential - biophysical difference and detection rate - applies equally to the human-ignition differential in Table 21, and the Draft EIS neither tests nor excludes it before attributing that differential to roads. Second, the only analysis in the Draft EIS that measures ignitions against road distance is Figure 15, "Density of reported ignitions by distance to roads and cause within the potentially affected IRAs" (p. 98). The Figure 15 caption identifies no data source and no period, and the figure carries none of the documentation supplied for those tables in footnotes 38 through 40 on page 94. The narrative does not reference Figure 15 or report any value from it - no distance classes, no ignition counts by cause, no exposed area, no densities. The one within-IRA road-distance analysis in the document is presented with none of the information a reader would need to evaluate it, while the two designation-level analyses that cannot answer the road-distance question are fully documented. I request that the Forest Service supplement the wildfire occurrence analysis (7 CFR 1b.7(f)(2)(iii)) to report the data underlying Figure 15 - the distance classes, ignition counts by cause, exposed area, and resulting ignition densities - and to state whether the road-distance relationship within the potentially affected IRAs survives the confounders the Draft EIS itself identifies on page 98. If it does not, the finding on page 98 and the Fire and Fuels row of the Comparison of Alternatives require factual correction under 7 CFR 1b.7(f)(2)(v). Absent one or the other, the Final EIS would assert a reasonably foreseeable effect for which it has disclosed no supporting analysis: not a cause-effect relationship established within the meaning of 7 CFR 1b.11(a)(23), and not a reasoned explanation under 5 U.S.C. Sec. 706(2)(A). See Kern v. Bureau of Land Management, 284 F.3d 1062 (9th Cir. 2002). This concern is directed to both the Draft EIS and the proposed rule. An answer given only in the Final EIS response-to-comments appendix would leave the concern unanswered as a comment on the rule.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 My husband, two college friends, and I have hiked through beautiful rock formations in the roadless areas of Utah for many years, camping for several nights on each trip, looking for bobcats, falcons, and hawks in the underbrush and high in the sky, and photographing formations that remind me how the earth was formed and of the many people who lived in these areas before Western people arrived. Rescinding the 2001 Roadless Area Conservation Rule would end that. This comment opposes the rescission and raises specific failures in the agency's supporting record. The agency frames this proposal in part as a wildfire management measure, but its own draft environmental impact statement undermines that framing. The DEIS states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." The DEIS also reports far higher fire density on roaded land than inside the affected roadless areas. When I walk Bunker Creek and move through its wetlands, examine its beaver dams, and look up at mature groves of quaking aspen, I am in a landscape that the agency's own data shows is less fire-prone than the roaded alternative would be. The agency must explain why the proposal departs from these findings and reconcile the rescission with its own ignition and fire-density data. The rule already permits the hazardous fuel work the agency says justifies rescission. The DEIS states: "The rule recognizes the need for tree cutting to reduce the risk of wildfire to at-risk communities. It allows tree cutting in non-upper tier within 0.5 miles from the boundary of an at-risk community, or up to 1.5 miles if certain conditions exist and the area is within a Community Wildfire Protection Plan (CWPP). A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." At the high elevation of Hancock, where I have watched big mammals traverse open land, the habitat the rule currently protects would be fragmented by roads the rule already makes unnecessary for the stated purpose. The agency must identify on the record which specific burdens are not already addressed by these existing exceptions, and quantify them. The agency's regulatory flexibility analysis does not hold together. The DEIS states: "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 is reached by spreading 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. Utah alone holds 222 inventoried roadless areas totaling 4,013,529 acres. Across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The streams I walk in Bunker Creek clean water for surrounding populations. A road there, as the agency's own water intake data suggests, would put that function at risk, affecting the communities and businesses that depend on it. The agency must withdraw the small-entity certification and assess the impact on the operators actually working in these areas, not an averaged national figure. Finally, the agency has invited reliance interests and done nothing with them. The DEIS states: "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 another reliance interest. My group has returned to these areas across many trips precisely because the rule's protections made that future predictable. Under controlling precedent, an agency reversing course must genuinely assess the reliance its prior policy created. The agency should identify and weigh the reliance interests submitted in this comment period, including this one. I ask that the agency address each of these points in the final record before proceeding further with this proposal. Sincerely, Alison Estabrook, MD North Salem, New York

Dear Brooke L. Rollins, As an outdoor enthusiast who has relied on the protection afforded by the 2001 Rule to access interior national forest in a condition substantially unmodified by motorized infrastructure, I find the Department's proposed rescission inadequately grounded in any countervailing evidence of comparable public benefit. I spend time hiking on these lands, looking at plants, and rock climbing to escape the heat of the city. It is beautiful and full of life, and a precious resource for Americans to get outside in Nevada. I remember hiking and finding clumps of cacti among the older pines and junipers and wondering how long they have existed here. I would hope my children would be able to have these same thoughts and be in awe of these plants. If this rule is rescinded, I will lose valuable untouched wilderness to vehicle disturbance, air pollution, and noise pollution. I go to these areas because they have these rules in place, and I can experience the great outdoors the traditional way - without man’s interference. It will also cut through wilderness areas, cutting them into patches of thinner areas, no good for the wildlife I want to see. Regarding the Potosi Area in the Humboldt-Toiyabe National Forest, Nevada: Conservation status G3 reflects the vulnerability of Eastern Joshua Tree (Yucca jaegeriana) in the Potosi Inventoried Roadless Area, Humboldt-Toiyabe National Forest, where 7.1 - Fire & fire suppression acts at Serious or 31-70% pop. decline severity across Restricted - small scope. Roads fragment intact habitat through cut-and-fill earthwork, compact soils, reroute surface and subsurface water flow, and create impervious surfaces — each mechanism amplifying the effects of 7.1 - Fire & fire suppression on Eastern Joshua Tree. A programmatic analysis is insufficient. The DEIS must evaluate 7.1 - Fire & fire suppression impacts to Eastern Joshua Tree (Yucca jaegeriana, G3) at the scale of the Potosi Inventoried Roadless Area, Humboldt-Toiyabe National Forest, with specificity adequate to inform the decision. "Grazing by domestic herbivores is the most widespread land use on the planet, and also a major global change driver in grasslands. We show that aridity partly explains the responses of biodiversity and multifunctionality to long-term livestock grazing. Grazing greatly reduced biodiversity and multifunctionality in steppes with higher aridity, while having no effects in steppes with relatively lower aridity. Long-term grazing had no effects in meadow steppes with relatively lower aridity, but reduced biodiversity and multifunctionality in desert steppes with higher aridity." — Nature Communications, 2023 Regarding wildfires: The DEIS's conclusion that new road construction will have no material effect on wildfire ignition rates in inventoried roadless areas is stated without support and contradicts the DEIS's own cited findings and its own data. The DEIS establishes the mechanism itself. At p. 98 it states that "human caused ignitions increase in abundance with proximity to roads, supporting the notion that roads facilitate human access, which can in turn result in more human caused fires," citing Narayanaraj and Wimberly 2012, Parisien et al. 2016, Balch et al. 2017, and Chen and Jin 2022. At p. 109 it states that "[r]oad density is linked to human-caused wildfires, and as the density of roads increases so does the probability, number, and frequency of wildfire ignitions (Cardille et al. 2001)." Every one of these sources is in the DEIS's own bibliography. The DEIS also quantifies the differential, and the relevant figure is not the one most often quoted. Table 18 (p. 95) reports all-cause ignition density of 42 fires per million acres per year on other NFS lands against 12 in potentially affected IRAs. Table 21 (p. 98) decomposes that figure by cause: human-caused ignition density is 22.4 against 3.0 — a factor of 7.5 — while the natural-ignition rates are far closer at 16.8 against 8.5. The differential the DEIS attributes to roads is therefore the human-caused component, and it is more than twice the size the all-cause comparison suggests. The Department is urged to give full weight to the administrative record compiled over more than two decades before proceeding with any rescission action. Once the roads are plowed through America’s great wilderness, it cannot be undone. Faithfully, Ali Marie

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Undeveloped land is where I go to feel in touch with nature and get away from the stress of daily life. I hike and camp in places like Mineral Canyon and Bear Valley Peak, both inventoried roadless areas in the Dixie NF in Utah. Mineral Canyon's red rocks draw me in part because it is much less congested than Zion and Bryce. Bear Valley Peak offers a range of plants that is a pleasure to see. These places matter to me, and the proposal to rescind the 2001 Roadless Area Conservation Rule would put them at risk. I oppose that rescission. The wildfire rationale the agency offers does not survive contact with its own data. The agency's draft environmental impact statement states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." Opening roadless areas like the ones I visit to new road construction would bring exactly that ignition risk into places that currently carry lower fire density than roaded land, as the agency's own DEIS Table 21 shows. I ask that the agency explain why the proposal departs from its own prior findings on fire occurrence in roadless areas, and reconcile the rescission with those ignition figures in its own record. The agency also claims the current rule creates administrative and permitting burdens, but the rule as written already accommodates the activities the agency says it cannot do. The DEIS states: "The rule recognizes the need for tree cutting to reduce the risk of wildfire to at-risk communities. It allows tree cutting in non-upper tier within 0.5 miles from the boundary of an at-risk community, or up to 1.5 miles if certain conditions exist and the area is within a Community Wildfire Protection Plan (CWPP). A temporary road may be constructed to facilitate hazardous fuel reduction within 0.5 miles of the boundary of an at-risk community." If the rule already permits these actions, the agency must identify, specifically and quantitatively, which burdens remain unaddressed by the existing exceptions for public health and safety, existing mineral leases, and community wildfire protection. That accounting belongs in the record before any rescission proceeds. I also hike where bears live, and that connection sharpens my concern about what new roads do to wildlife. The DEIS cites the federal grizzly bear recovery plan for the finding that increased contact and conflict in grizzly habitat from open roads can ultimately end in grizzly mortality, and that shooting, habituation, and food reward all increase with use of even secondary unpaved roads. The places I walk in Utah are part of a larger landscape. Utah holds 222 inventoried roadless areas totaling 4,013,529 acres, and across the Intermountain region, which includes Utah, 1,466 municipal water intakes sit in watersheds containing affected roadless areas. The cumulative exposure created by rescission, for wildlife and for water, deserves a serious response from the agency in this docket. On economic impact, the agency's own record undermines the regulatory flexibility certification. "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." Spreading a $9 million annual expenditure loss across every small firm in the sector nationally, rather than examining the outfitters and guides actually permitted in the affected areas, does not constitute a meaningful analysis. The agency should withdraw that certification and assess the firms actually operating in these roadless areas. Finally, the agency invited reliance interests and then ignored them. "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 use of Mineral Canyon and Bear Valley Peak, and my expectation that they remain undeveloped, is exactly the kind of reliance interest the agency asked about. The agency must identify and weigh the interests described in the comments it receives, including this one, before it can lawfully change course. Sincerely, Sanford Krasner Altadena, CA

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 The forest is less than an hour from my home, and I go there to decompress and camp with my kids. We love waking up early to photograph the sunrise and catch any wildlife in the peaceful morning. That connection matters to me, and the proposal to rescind the 2001 Roadless Area Conservation Rule threatens the land that makes it possible. I watched the Eaton Canyon fire and saw the devastation left in its wake. Friends lost their homes. The air quality in our neighborhood was badly affected by the smoke. I understand firsthand what fire does to communities and landscapes, which is why I cannot accept the agency's wildfire justification for this rescission at face value. The agency's own draft environmental impact statement states: "While roads allow more agile positioning of firefighting assets, they are also the site of high rates of human-caused ignition (Narayanaraj and Wimberly 2012), which account for 84% of US wildfires (Balch et al 2017)." DEIS Table 21 reports far higher fire density on roaded land than inside the affected roadless areas. The agency has not explained how expanding the road system reduces fire risk when its own data tie roads to ignition at those rates. I ask the agency to explain why the proposal departs from these prior findings and to reconcile the rescission with the ignition data already in the record. The economic case for rescission is no stronger. The agency's own record states: "By contrast, the Defendants estimate the timber industry supplies only 337 jobs, just one percent of regional employment, and $18.8 million, one percent of earnings, in the region today. Defendants project that, even with complete elimination of the Roadless Rule on the Tongass, the rule will not result in any new timber industry jobs on the Tongass over the next 100 years and regional economic impacts from the timber industry will remain the same with the Exemption as without. FEIS at 3-55." 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. The Forest Service already carries a $6.9 billion maintenance backlog on its existing road system. The agency must reconcile the proposal with that analysis and explain how an action whose own numbers cannot establish a net benefit justifies adding to that backlog. The legal and administrative burden rationale fares no better on the record. The rule as written already contains flexibility: 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)." Additional exceptions address existing mineral leases and community wildfire protection. The agency has not identified which specific burdens fall outside what these exceptions already accommodate, nor has it quantified them. It should do so before proceeding. Finally, the regulatory flexibility certification 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 supporting analysis reaches its no-impact conclusion by spreading the 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, and it concedes some of those firms may lose these receipts entirely. Averaging impact across a national pool to avoid a finding of significance for the businesses that will actually bear the loss is not a defensible methodology. The agency should withdraw the certification and conduct a proper analysis focused on the small entities operating under permits in the roadless areas at issue. Sincerely, Daniel Shapiro Los Angeles, CA