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See Attached File: As a South Dakota resident who enjoys using roadless areas, I oppose rescinding the 2001 Roadless Rule. My interest and passion come from experiencing these places. Their value to me includes solitude, viewing natural surroundings, and the opportunity to enjoy public land away from roads and vehicle traffic. Beyond my own personal enjoyment, it is also important to know that we are retaining large, intact landscapes and clean rivers and lakes. These roadless areas deserve consideration and respect. My comment concerns the proposed removal of the protections in 36 CFR Part 294, Subpart B, which restrict road construction, road reconstruction, and timber harvest in inventoried roadless areas, subject to exceptions. USDA proposes relying on individual forest planning and management decisions in place of these national protections. My personal concern is what that change would mean for wildlife, water quality, and landscapes that sustain the activities I enjoy and contribute to my community's economy. (USDA, proposed rule, 91 FR 53827, August 20, 2026.). When I choose a roadless area for fishing or hiking, the undeveloped setting is part of the reason I go. The Sand Creek Roadless Area in Wyoming is a wonderful example of a Roadless Area that my husband and I have explored multiple times. We are drawn to the roadless area for the amazing water quality that sustains an incredible fishery. My husband and I explored the Sand Creek area and found it to be a wonderfully peaceful and beautiful location that my husband and I enjoyed for hours, catching Brown Trout and then releasing them back to the water for others to enjoy. My background and career were in a science-based field, and with that background I am fully aware that a good fishery depends on healthy watersheds. Forest Service research identifies effects of roads on hydrology and aquatic habitat and emphasizes that those effects must be evaluated in their local environmental context. This supports examining individual watersheds rather than assuming that national estimates adequately describe the risks to places people fish. (Gucinski and others, Forest Roads: A Synthesis of Scientific Information, 2001, PNW-GTR-509.) I feel strongly that the NOI and DEIS fail to provide science-based rationale for rescinding a Rule that has been in place for nearly 25 years. A Rule, for example, that protected large intact landscapes for recovery of the Grizzly Bear in the Lower 48. For this reason and so many other reasons, the 2001 Roadless Rule must be retained! I recognize and encourage that where the USDA identifies a specific management problem, it should first evaluate whether existing exceptions or a narrowly tailored approach can address it while preserving roadless characteristics. Over my career in the USDA Forest Service (USDA), I gained a practical working knowledge of Forest Plans (programmatic) and NEPA (site-specific). I acknowledge that Forest Plans vary in age and thus protection for Roadless Areas if “The Rule” is rescinded. More importantly, the limitations referred to in the NOI and DEIS do not tell me whether the places I value would retain equivalent protection over time. The agency should explain what protections would remain; how it accounts for the loss of quiet recreation, how it impacts wildlife that are dependent on large intact landscapes, and how it may impact water quality and quantity. My fishing and hiking experiences have taught me that the character of a place matters as much as the ability to reach it. Once roads and development change that character, the experience may be difficult to recover. I urge USDA to retain the Roadless Rule, address demonstrated management needs through targeted approaches, and clearly disclose the local recreation and watershed consequences of any proposed change. Future generations should have the opportunity to enjoy these public lands as roadless places. le(s)

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. Changes to protections for inventoried roadless areas should be based on the best available scientific evidence. That evidence does not support treating road construction as an environmentally neutral management activity. Roads create persistent changes in forest ecosystems, including altered drainage and runoff, increased erosion and sediment delivery, habitat fragmentation, increased human access, and pathways for invasive species. These effects have been extensively documented in the scientific literature (Forman & Alexander, 1998; Trombulak & Frissell, 2000; Gucinski et al., 2001). Importantly, the ecological effects of roads extend beyond their physical footprint. Roads can reduce habitat connectivity, increase edge effects, alter wildlife movement, and facilitate the spread of non-native species (Forman et al., 2003; Gelbard & Belnap, 2003). Maintaining large, contiguous areas of forest is therefore important for preserving ecological connectivity and functioning ecosystems. There is also specific evidence relevant to claims that additional roads are necessary to improve forest health or reduce wildfire risk. Healey et al. (2016) examined nearly two decades of Forest Service monitoring data and found no significant difference in fire occurrence between roaded and roadless forests following implementation of the Roadless Rule. The study also found that non-native plants were approximately twice as common near roads. These findings do not support the assumption that increasing road access necessarily produces better wildfire or forest-health outcomes. Roadless forests provide important watershed functions as well. Roads can alter natural drainage, increase runoff and soil erosion, and transport sediment into streams, degrading aquatic habitat and water quality (Trombulak & Frissell, 2000; Gucinski et al., 2001). Landscape fragmentation is particularly concerning as climate conditions change. Large, connected forest landscapes allow species to move across their ranges in response to environmental changes and can help maintain viable populations. Protecting connectivity is therefore an important component of climate adaptation (Heller & Zavaleta, 2009). The proposed rescission would remove protections from approximately 45 million acres of National Forest System lands. At that scale, environmental impacts should be evaluated cumulatively rather than treating individual road projects as isolated disturbances. The analysis should consider the combined effects of road density, habitat fragmentation, invasive species, erosion, altered hydrology, wildlife connectivity, carbon storage, and wildfire. I am also concerned about relying solely on future forest-level planning to replace a national baseline of protection. Once an intact landscape is fragmented, some ecological effects can persist for decades and may be difficult or impossible to fully reverse. Preventing fragmentation is therefore more scientifically defensible than assuming impacts can always be mitigated after roads are constructed. I urge the Forest Service to withdraw the proposed rescission and retain national protections for inventoried roadless areas. If the agency proceeds, the environmental analysis should use the best available peer-reviewed science and long-term monitoring data and fully evaluate cumulative ecological effects. Large, relatively undisturbed forests are a finite ecological resource. Once fragmented, they cannot simply be recreated by removing a road or replanting trees. Public-land policy should recognize the scientific value of intact landscapes and prioritize their long-term ecological integrity. References Forman, R. T. T., & Alexander, L. E. (1998). Roads and their major ecological effects. Annual Review of Ecology and Systematics, 29, 207–231. Gelbard, J. L., & Belnap, J. (2003). Roads as conduits for exotic plant invasions in a semiarid landscape. Conservation Biology, 17, 420–432. Gucinski, H., et al. (2001). Forest Roads: A Synthesis of Scientific Information. USDA Forest Service, PNW-GTR-509. Healey, S. P., et al. (2016). Roads and forest fires: A longitudinal analysis of fire occurrence and non-native plant invasions in roaded and roadless forests. Forest Ecology and Management. Heller, N. E., & Zavaleta, E. S. (2009). Biodiversity management in the face of climate change. Biological Conservation, 142, 14–32. Trombulak, S. C., & Frissell, C. A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology, 14, 18–30.

Re: Rescission of the Roadless Area Conservation Rule, Docket FS-2025-0001 Dear U.S. Forest Service Officials, I respectfully urge the Forest Service to retain the 2001 Roadless Rule and reject the proposed rescission. Roadless lands are not idle land. They supply clean water, wildlife habitat, and recreation to communities nationwide, and rescission would do far more harm than good. WHAT IS AT STAKE (Forest Service roadless inventory) - Deschutes NF, central Oregon: about 137,000 acres protecting the headwaters of the Deschutes and Metolius rivers. Oregon's roadless lands protect drinking water for about 800,000 people, including Bend. - Wallowa-Whitman NF, northeast Oregon: about 515,000 acres. Its mountain streams supply Baker City, one of only two Oregon cities whose water is clean enough to go unfiltered. - Gifford Pinchot NF, southwest Washington: about 213,000 acres. Its streams supply drinking water to communities and support threatened Chinook and coho salmon, steelhead, bull trout, and the northern spotted owl. - Superior NF, northeast Minnesota: about 62,000 acres bordering the Boundary Waters, home to moose and threatened Canada lynx. - White Mountain NF, New Hampshire and Maine: about 235,000 acres, including headwaters of the Pemigewasset River, which forms the Merrimack, a drinking water source for Manchester, Nashua, and Massachusetts towns. - Bridger-Teton NF, western Wyoming: about 1.4 million acres at the headwaters of the Snake and Green rivers, feeding the Columbia and Colorado systems, with grizzly bears, wolverines, lynx, and native cutthroat trout. Nationally, roadless watersheds supply drinking water to about 25 million Americans. THE FOREST SERVICE'S OWN SCIENCE The agency's report Forest Roads: A Synthesis of Scientific Information (PNW-GTR-509) found that roads contribute more sediment to streams than any other land management activity, and that most sediment from timber harvest is tied to roads. Forest Service research on Washington's Clearwater River found fine sediment making up 15 to 25 percent of spawning gravels in heavily roaded basins, smothering salmon eggs. That matters: the Columbia Basin once produced 10 to 16 million salmon a year, and logging and road building were among the causes of its decline, alongside dams. The current DEIS itself acknowledges that new roads and logging could bring more human-caused fires, sedimentation, harm to threatened and endangered species, and recreation losses. WILDLIFE Roadless areas cover about 2 percent of U.S. land but support roughly 25 percent of threatened and endangered species. In Idaho, 75 percent of Chinook salmon and steelhead habitat is in roadless areas. The U.S. Fish and Wildlife Service has called roads probably the most imminent threat to grizzly habitat. Roads also fragment migration routes and push elk out of secure cover: in Wyoming, hunters in mostly roadless country harvest about one bull elk per 2.4 square miles, versus one per 25 square miles in heavily developed areas. THE COST OF ROADS The proposed rule anticipates permanent roads could be built across 18.2 million acres now protected. Yet the Forest Service already manages over 370,000 miles of roads with a maintenance backlog the agency puts at about $6.9 billion, and fewer than one in five roads is fully maintained. Neglected roads wash out, plug culverts, and send sediment into streams, and deferred repairs grow costly. Former Chief Mike Dombeck noted that reconstructing five miles of one road cost $1.4 million when $100,000 in earlier upkeep would have preserved it. The DEIS projects just $5 to $11 million a year in new timber revenue and admits this would not cover the cost of building and maintaining new roads. Adding roads the agency cannot maintain shifts the bill to taxpayers and downstream communities. WILDFIRE The rule already allows thinning and road access to reduce fire risk, and areas near roads have recorded nearly four times as many human-caused ignitions as roadless areas. I ask the Forest Service to keep the Roadless Rule in place and pursue any needed changes through targeted reform with full public input. Thank you for considering my comments. Sincerely, Marguerite Nico Allen, Texas

Please retain the 2001 Roadless Rule. I live in Mill Valley, California, and recently spent a weekend camping and walking among the redwoods in Humboldt Redwoods State Park. Being among those trees reminded me how much intact forests mean to me and how much I want my daughter to have opportunities to experience places like that. Although that state park is not governed by this rule, it captures why protecting wild forests is personal to me. Two scientific reasons weigh especially strongly. First, forest roads can increase erosion and carry sediment into streams, harming aquatic habitat and water quality. Second, roads fragment habitat and can disrupt wildlife movement. Keeping remaining roadless areas intact helps preserve connected ecosystems. The Forest Service’s own report, “Forest roads: a synthesis of scientific information” (2001; doi:10.2737/PNW-GTR-509), documents these ecological concerns. Please retain national roadless protections and account fully for these impacts before considering their removal.

Re: Docket No. FS-2025-0001 / RIN 0596-AD66 — Proposed Rescission of the 2001 Roadless Area Conservation Rule (36 CFR 294, Subpart B) I oppose the proposal to rescind the 2001 Roadless Area Conservation Rule, in whole or in part, and urge the Department to select the No Action alternative and retain 36 CFR 294 Subpart B. 1. Roads increase wildfire ignitions; they do not reduce them. The proposal cites wildfire risk as a primary justification, but the research points the other way. Balch et al. (2017, PNAS) found humans ignited 84% of U.S. wildfires from 1992–2012. Narayanaraj and Wimberly (2012, Applied Geography) found human-caused ignitions on national forest lands are concentrated near roads, and Syphard et al. (2007, Ecological Applications) found fire frequency is strongly tied to proximity to human infrastructure, including roads. Building roads into roadless areas expands the very access that drives ignitions. The proposal itself concedes that greater access can increase human-caused ignitions. Moreover, the existing rule already permits cutting small-diameter timber to reduce wildfire risk (36 CFR 294.13(b)(1)), so fuel treatment does not require rescission. 2. Roads fragment intact wildlife habitat. Trombulak and Frissell (2000, Conservation Biology) documented the broad ecological harms of roads: mortality, habitat fragmentation, altered animal behavior, invasive species spread, and chemical and sediment pollution. Research at the Starkey Experimental Forest (Rowland et al. 2000, Journal of Wildlife Management) showed elk consistently avoid areas near open roads, reducing effective habitat. Roadless areas provide secure big-game habitat and backcountry hunting opportunity that roaded forests cannot replace. 3. Roads degrade clean water and native trout habitat. The Forest Service’s own synthesis, Forest Roads: A Synthesis of Scientific Information (Gucinski et al. 2001, PNW-GTR-509), identifies roads as a major source of sediment delivery to streams. Assessments in the Interior Columbia Basin (Lee et al. 1997, PNW-GTR-405) found strong native salmonid populations associated with areas of low road density. Roadless areas are among the last strongholds for native cutthroat and bull trout and protect source waters for downstream communities. Once sediment and road crossings degrade these streams, recovery takes decades. 4. The Forest Service cannot maintain the roads it already has. The proposal itself acknowledges a $6.9 billion deferred maintenance backlog for roads and bridges. Every new road adds a long-term maintenance liability to an asset base the agency already cannot fund. The proposal’s own estimate of $5.2–11.4 million per year in timber revenue to the Treasury and Forest Service would take over 600 years to retire the existing backlog, even at the high end and with every dollar applied to it. Meanwhile, the agency estimates about $6.1 million per year in lost recreation benefits, largely offsetting projected revenue. From a cost-benefit standpoint, rescission adds liabilities without a credible funding source. 5. Logging and extraction are not needed here. The proposal describes management opportunities as “modest and localized” and anticipates no net change in domestic oil, gas, and coal production. If rescission produces no meaningful energy gain and limited timber, it offers little benefit in exchange for the permanent loss of intact forest. These areas are worth more standing, as habitat, watershed protection, and backcountry recreation, than cut. 6. Roadless areas buffer and connect designated wilderness, such as Citico Creek. The Citico Creek Wilderness in the Cherokee National Forest shows what protected, unroaded land can become. The Forest Service acquired this cut-over land in the 1930s and let natural processes heal it, producing a mature second-growth deciduous forest along Citico Creek with remnant old growth still present. Citico adjoins North Carolina’s Joyce Kilmer-Slickrock Wilderness, forming one of the largest blocks of intact forest in the Southern Appalachians. But wilderness boundaries alone cannot sustain these values. Wildlife ranges and watershed processes do not stop at a boundary line, and inventoried roadless areas provide the connected habitat, buffers, and travel corridors that keep wilderness from becoming an isolated island. Citico demonstrates that eastern forests recover when left unroaded; rescinding protections on similar roadless lands throughout the Cherokee and other national forests would forfeit that recovery. 7. Local planning is not an adequate substitute. Forest plans can be amended project by project, which invites the incremental degradation the 2001 Rule was designed to prevent. A consistent national standard provides durable protection that piecemeal planning cannot. For these reasons, I urge the USDA to withdraw the proposed rescission and keep the 2001 Roadless Rule in place.

As a wildlife biologist and spatial analyst, with a background of over a decade working in natural resources, I would like to affirm my objection to the removal of the United States Forest Service Roadless Rule. Roadless areas prevent accidental wildfires caused by anthropogenic activities such as legal or illegal camping, and vehicle presence (dragging chains while towing, hot engines igniting dry vegetation, etc.). Aplet et al. 2026 found that that land within 50 meters of a USFS forest road is up to four times more likely than roadless areas to have fire ignitions, because many fires are caused by human activity. The 2001 Rule itself (66 FR 3254) states that building roads into roadless areas would likely raise the chance of human-caused fires because more people would be present (USDA Forest Service, 2000). Wilderness areas may receive prescribed fire under some circumstances, particularly to reduce fire fuel loads, and roadless areas still receive natural fire caused by lightning. Roads and industrial logging do not prevent wildfire. The Roadless Rule contains exceptions that allow certain activities when necessary for public health and safety, and protecting resources. This includes forest management and hazardous fuels work. Roadless areas help protect wildlife, not only because large tracts of intact habitat protect wildlife populations and clean water. The negative impacts that roads can have on terrestrial invertebrates are well documented, and include mortality from construction, vehicle collisions, changes in behavior such as nesting disturbance, increased human presence, the spread of invasive species and changes to the physical landscape (Trombulak & Frissell 2000). Even just the noise from motors causes disturbance to wildlife populations, reducing individual fitness and reducing the quality of habitat (Ware et al. 2015). In addition, Roadless areas provide human communities with downstream access to clean drinking water, and clean water supports freshwater fish, invertebrates, and amphibians. Building roads increases runoff and sedimentation in mountain streams (Gucinski et al. 2001) and negatively impacts aquatic connectivity for freshwater species (Wofford et al. 2005). The USFS has a notorious backlog of deferred road maintenance for the roughly 370,000 miles of roads that comprise the National Forst System road network. According to USFS’s Fiscal Year 2025, Quarter 2 Deferred Maintenance Needs report, the deferred maintenance value for passenger-vehicle roads is $5.89 billion, and that does not include high-clearance roads. Unmaintained roads and road bridges can lead to landslides and threaten aquatic connectivity and water quality. Why build new roads when USFS consistently fails to maintain the current inventory of roads and road bridges? If roads are built and then not maintained, then any claims about how the recission of the Roadless Rule alleviating management restrictions and improving public access are moot. If no sufficient budget exists for maintaining the current infrastructure, how will USFS plan and execute maintenance of additional road miles and road bridges? As someone who resides in and holds great esteem for the State of Georgia, I must point out that there are very few large tracts of contiguous wilderness left in the Southeastern United States. Unlike the western part of the country, we have no areas of vast, unbroken wilderness. The ability to go out into the wilderness and experience natural areas away from civilization and its sounds is a priceless thing. The protection of our cultural and natural resources in the Southeastern US is priceless. Aplet, G.H., Hartger, P., et al. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology. Gucinski, H., Furniss, M.J., Ziemer, R.R., & Brookes, M.H. (2001). Forest roads: a synthesis of scientific information. Gen. Tech. Rep. PNW-GTR-509. USDA Forest Service, Pacific Northwest Research Station. doi:10.2737/PNW-GTR-509 USDA Forest Service (2000). Roadless Area Conservation Final Environmental Impact Statement. USDA Forest Service. 2025. Fiscal Year 2025, Quarter 2 Deferred Maintenance Needs. Report to the House and Senate Appropriations Committees. Trombulak, S.C., & Frissell, C.A. (2000). Review of ecological effects of roads on terrestrial and aquatic communities. Conservation Biology 14(1): 18–30. doi:10.1046/j.1523-1739.2000.99084.x Ware, H.E., McClure, C.J.W., Carlisle, J.D., & Barber, J.R. (2015). A phantom road experiment reveals traffic noise is an invisible source of habitat degradation. PNAS 112(39): 12105–12109. doi:10.1073/pnas.1504710112. Wofford, J.E.B., Gresswell, R.E., & Banks, M.A. (2005). Influence of barriers to movement on within-watershed genetic variation of coastal cutthroat trout. Ecological Applications 15(2): 628–637.

I oppose rescinding the 2001 Roadless Area Conservation Rule and support maintaining its protections nationwide. For me, roadless areas aren't an abstract policy issue. They are places I actually use. I regularly hike, camp, fish, hunt, and explore public lands in Virginia and across the country, and some of my most memorable experiences outdoors have happened in places that remain largely undeveloped. I caught my first native brook trout in the George Washington and Jefferson National Forests here in Virginia. Anyone who has chased brook trout in Virginia's mountains knows that catching the fish is only part of the experience. You follow small streams farther into the mountains and away from roads and developed areas. The water gets colder, the forest closes in, and eventually you find these incredible native fish surviving in small, clear headwater streams. Those experiences changed the way I look at these places. Brook trout depend on cold, clean water, and the forests surrounding their streams are part of what keeps those watersheds healthy. Roads, forest fragmentation, sedimentation, and development can change these watersheds in ways that are difficult to undo. Virginia and native brook trout are my personal connection to this issue, but my concern is nationwide. Across the country, roadless areas protect relatively intact watersheds and wildlife habitat while providing opportunities for hunting, fishing, hiking, camping, and backcountry recreation. These concerns are supported by the Forest Service's own research and analysis. The Forest Service has identified effects of forest roads on hydrology, sediment movement, aquatic habitat, habitat fragmentation, and biodiversity. Its Roadless Area Conservation Final Environmental Impact Statement identified potential impacts to aquatic habitat from roads, including excess sediment, changes in water temperature, barriers to passage, and loss of habitat connectivity. That is one of my primary concerns with rescinding a nationwide rule. The Roadless Rule doesn't make these places wilderness or prohibit all forest management. It places meaningful limits on road construction, road reconstruction, and timber harvesting while allowing exceptions when necessary. I believe that is a reasonable balance between multiple-use management and protecting our least-developed national forest lands. Removing those protections raises a basic question: What do we gain by making additional road construction and development possible in places that have remained largely roadless, and does that benefit outweigh the long-term ecological, recreational, and public value those lands already provide? I also want to pass these places and experiences on. I'm planning a camping and brook trout fishing trip with my young nephew. I want to take him into the mountains and hopefully help him catch his first brook trout. But catching a fish isn't really the most important part of that trip. I want to start teaching him about conservation, respecting public lands, and understanding why sometimes the best thing we can do for a place is leave it largely the way we found it. There is a sad irony in taking him into one of these places to teach him about conservation while we are considering removing protections intended to help keep places like it intact. I was fortunate that someone before me valued these places enough to protect them. Because of that, I had the opportunity to walk into a Virginia mountain stream and catch my first native brook trout. I'd like my nephew to have that same opportunity. And I want families across the country to continue having the opportunity to hunt, fish, camp, hike, and experience the roadless public lands that are special to them. That, to me, is what conservation is about. I understand that our national forests are managed for multiple uses and that active forest management is sometimes necessary. Supporting roadless protections doesn't mean opposing responsible forest management. It means recognizing that some of the least-developed places remaining in our national forests deserve a higher threshold before we undertake activities that could permanently change their character. For these reasons, I recommend that the Forest Service not rescind the 2001 Roadless Area Conservation Rule and instead maintain its protections for inventoried roadless areas nationwide. The existing rule allows exceptions for legitimate needs without eliminating nationwide protections. These aren't just lines on a map. They are watersheds, native fish and wildlife habitat, places to hike, hunt, and fish, places to camp with our families, and places where we can teach the next generation why conservation matters. Please keep them that way. Respectfully, Lars Antoniszczak Virginia References: USDA Forest Service, Roadless Area Conservation Final Environmental Impact Statement, Vol. 1; USDA Forest Service, Forest Roads: A Synthesis of Scientific Information (2001).

I oppose the proposed rescission of the 2001 Roadless Area Conservation Rule (RIN 0596-AD66) and ask USDA to adopt the No Action alternative. The case for rescission rests on benefits the proposed rule itself describes as uncertain. The preamble says management opportunities "would be modest and localized" and that "it is difficult to predict the potential impact rule rescission may have on timber harvest." Against those limited gains, the Department estimates about $6.1 million a year in lost value to recreationists, along with trade-offs for recreation and tourism businesses. Removing a national standard that protects 58.5 million acres needs a stronger justification than that. The wildfire rationale also cuts both ways. The proposed rule concedes that greater public access "can increase human-caused ignition potential." According to the National Interagency Fire Center, people start most wildfires in the United States, and roads bring people into country that currently has few ignition sources. The 2001 Rule already allows fuel-reduction work under its exceptions. If those exceptions have been too hard to use, the answer is to fix the approval process, not to remove protection from every inventoried roadless area. New roads also threaten water. The Forest Service reports a $6.9 billion deferred maintenance backlog for roads and bridges, and the agency's own research synthesis, Forest Roads: A Synthesis of Scientific Information (2001), identifies roads as a major source of stream sediment and a common pathway for invasive plants. Adding road mileage the agency cannot maintain will mean more erosion and more sediment in headwater streams. The proposed rule lists public drinking water among the values land management plans must address, but it offers no evidence that forest-by-forest planning will protect those sources as reliably as a national rule. Once a large unroaded area is divided by roads, its value as connected habitat and a migration corridor cannot be restored. A decision that permanent deserves a high burden of proof. Process matters as well. By the Department's account, most Tribal governments consulted oppose rescission, citing sacred sites, water quality, and subsistence resources, and only 29 of 64 requested consultations had taken place when the proposal was published. The Department has determined that this action has substantial direct effects on Tribes, so it should not be finalized until that consultation is complete. The preamble also acknowledges that later plan amendments "could increase the area where timber harvest and road construction would be allowed." Forest plans can be changed one forest at a time; the 2001 Rule provides protection that does not depend on each revision. I am a Colorado resident and a fly fisher. Colorado's state roadless rule is not affected by this proposal, but I care about trout streams and backcountry on national forests across the West, and the water quality in those streams depends on the unroaded watersheds this rule protects. Please withdraw the proposed rescission and keep the 2001 Roadless Rule in place.

Preserve the Roadless Rule I am writing to advocate for preservation of the Roadless Rule for our National Forest lands. In the Gila National Forest alone, there are 3,337 miles of designated roads, not including county, state and U.S. roads and highways. In contrast, there are 1,600 miles of designated hiking trails. This alone makes it hard to argue the need for yet more roads. The ecological impact of roads greatly exceeds that of trails. The disturbance caused by construction, maintenance, and use of roads facilitates expansion of harmful exotic plants and animals while at the same time reducing habitat for conservative native plants and sensitive animals. Watersheds are degraded by roads and fish habitat suffers due to sedimentation and interrupted water flow. According to a Forest Service report, Forest Roads: A Synthesis of Scientific Information, “In general, greater short- and long-term watershed and ecological risks are associated with building roads into unroaded areas than with upgrading, maintaining, closing, or obliterating existing roads.” Considering the proposed weakening of the Endangered Species Act to exclude habitat of listed species, further reducing habitat by constructing roads in currently roadless areas will increase stressors and impact the viability of endangered and threatened species in our national forests. As of a 2003 report (Loucks, C., N. Brown, A. Loucks, and K. Cesareo. 2003. USDA Forest Service roadless areas: potential biodiversity conservation reserves. Conservation Ecology 7(2): 5. [online] URL: http://www.consecol.org/vol7/iss2/art5/) 77% of inventoried roadless areas in the U.S. have the potential to provide critical habitat for threatened, endangered and imperiled species. Habitat loss is the leading cause of species endangerment and it is not a linear process (Hanski I. Habitat loss, the dynamics of biodiversity, and a perspective on conservation. Ambio. 2011 May;40(3):248-55. doi: 10.1007/s13280-011-0147-3). Having lost so much already, we are on the brink of a biodiversity crisis. There is no compelling reason to repeal the Roadless Rule, given the profusion of forest roads that currently exist. In contrast, the very existence of many imperiled species depends on preservation of existing roadless areas.

I am strongly opposed to rescinding the 2001 Roadless Area Conservation Rule. As a child, I found profound peace hiking and camping with my family in the Blue Ridge Mountains of Virginia. I have cherished memories of exploring those forests and seeing bears, deer, and other wildlife. Those experiences gave me a lifelong appreciation for wild places and the sense of wonder that comes from being surrounded by nature. Today, I am a mom to two little boys who are learning to care for our environment and share in the beauty of our mountains. I want them—and future generations—to have the opportunity to make those same memories. Protecting roadless forests from new roads and logging is essential for healthy wildlife habitat and ecological connectivity. The U.S. Forest Service has documented that roads can fragment habitat, affect wildlife and aquatic ecosystems, and facilitate the spread of invasive species (Gucinski et al., 2001). Research has also found that non-native plants were twice as common near roads, while finding no evidence that roadless areas inherently prevent wildfire prevention activities (Healey, 2020). I recognize that the proposed rescission would return more management authority to individual national forests. However, local management should not come at the expense of consistent protections for some of our nation's last remaining intact forests. If exceptions are needed for public safety, wildfire response, or other specific purposes, they should be narrowly tailored rather than eliminating broad protections for roadless areas. Please retain the Roadless Rule—or adopt an alternative that provides equally strong or stronger protections. Once these forests are fragmented by roads and logging, we cannot easily restore what is lost. I want my sons to inherit forests where they can hike, camp, see wildlife, and experience the same peace and wonder that shaped my childhood. Please protect these places for them and for generations to come. References Gucinski, H., Furniss, M. J., Ziemer, R. R., & Brookes, M. H. (2001). Forest roads: A synthesis of scientific information (General Technical Report PNW-GTR-509). U.S. Department of Agriculture, Forest Service. Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. https://doi.org/10.1088/1748-9326/aba031

I respectfully urge the U.S. Department of Agriculture and Forest Service to withdraw the proposal to rescind the 2001 Roadless Area Conservation Rule. The scientific literature does not support the premise that opening Inventoried Roadless Areas to additional roads and timber development will improve forest health or reduce wildfire risk. In a nationwide analysis of Forest Service lands covering 1992–2024, Aplet, Hartger, and Dietz (2026) found that wildfire ignition density was lowest in Inventoried Roadless Areas (1.97 fires/1,000 hectares) and highest within 50 meters of roads (7.99 fires/1,000 hectares). Their findings indicate that roads are associated with substantially greater wildfire ignition rates, particularly human-caused ignitions. Similarly, Healey (2020), using nearly two decades of Forest Service monitoring data, found no evidence that roadlessness prevented fire-management activities or caused poorer forest health. He also found that non-native plants were approximately twice as common within 152 meters of roads, demonstrating an important ecological cost of road development. Recent research further demonstrates that Inventoried Roadless Areas contain some of the nation's highest-integrity forests and provide significant benefits including clean water, biodiversity, carbon storage, wildlife habitat, climate regulation, and cultural values (Mildrexler et al., Berner, Law & Booth, 2026). The authors conclude that allowing additional roads into these areas would degrade ecosystem functions and could increase wildfire risk. Road construction also creates long-term financial obligations. The Forest Service already faces a substantial deferred-maintenance backlog on its existing road network. Expanding that network before adequately maintaining existing infrastructure warrants careful consideration of the full life-cycle costs to taxpayers. The Roadless Rule does not prohibit all active forest management. Existing provisions allow specified activities, including certain fire, watershed, insect and disease, and public-safety actions. The scientific evidence therefore supports maintaining the protections while using carefully targeted management tools where ecological or public-safety conditions warrant them. I ask the Forest Service to base its decision on the best available scientific evidence and retain the 2001 Roadless Area Conservation Rule. Remaining roadless forests represent an increasingly scarce national resource, and once roads and associated development fragment these landscapes, their ecological characteristics cannot readily be restored. Thank you for considering my comments. Selected professional literature Aplet, G.H., Hartger, P., & Dietz, M.S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, 8. Healey, S.P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. Mildrexler, D.J., Berner, L.T., Law, B.E., & Booth, M.S. (2026). Roadless rule rescission threatens highest integrity forest ecosystems in the United States. Biological Conservation, 111950. Gucinski, H., Furniss, M.J., Ziemer, R.R., & Brookes, M.H. (2001). Forest Roads: A Synthesis of Scientific Information. USDA Forest Service, General Technical Report PNW-GTR-509. Wisdom, M.J., et al. (2018). Research on roads, habitat fragmentation, and wildlife responses in national forest landscapes. DellaSala, D.A., & Frost, E. (2001). Research concerning fire ecology and the role of natural fire regimes in roadless forests. Law, B.E., et al. (2021). Research identifying high-priority western U.S. forests for climate mitigation and biodiversity conservation. Watson, J.E.M., et al. (2018). Research on the global importance of intact forest landscapes for biodiversity and ecosystem services.

The Conservation Commission of Norwich, VT wholeheartedly supports the 2001 Roadless Area Conservation Rule. We oppose any changes to this rule at this time. The Conservation Commission is primarily responsible for preserving the natural resources of the town of Norwich, but as residents of Vermont, we also have an interest in preserving the forests of Vermont, most notably, the Green Mountain National Forest. Forest fragmentation seriously degrades the health and long-term survival of our forests and the wildlife that depends on them. The Forest Service, itself has published numerous reports documenting the detrimental effects of fragmentation due to road building. (e.g., Gucinski, Hermann; Furniss, Michael J.; Ziemer, Robert R.; Brookes, Martha H. 2001. Forest roads: A synthesis of scientific information. General Technical Report PNW-GTR-509. Portland, Oregon: U.S. Dept. of Agriculture, Forest Service. 103 p.) We believe that the most useful regulation conserving our nation’s forests is the Roadless Rule. Any change in the rule to allow more roads in our forests would be needlessly destructive on a national scale. It would be devastating to Vermont’s Green Mountains, which are already under stress from invasives, disease, deer over browse and our warming climate.

I vehemently support the No Action alternative in the current DEIS. The Roadless Rule is extremely important to the outdoor recreation and our country’s ecology. Roadless areas provide important benefits, including clean drinking water, wildlife habitat, opportunities for recreation and solitude, and protection of undeveloped landscapes. Roadless areas are important ecological strongholds that protect large, relatively intact blocks of habitat and provide connectivity between ecosystems. The Forest Service has recognized that these areas help conserve biological diversity, maintain native plant and animal communities, and reduce habitat fragmentation caused by roads and development (Gucinski et. al. 2001). These areas also provide important habitat for our threatened, endangered, and sensitive species. Research by the USGS likewise finds that roads and other infrastructure can fragment open space, while maintaining landscape connectivity helps ecosystems remain healthy, diverse, and resilient (Watts et. al. 2007). The rescission would remove important protections for approximately 45 million acres of backcountry national forests. It is very unclear how this significant and unavoidable impact would be mitigated for (as is required per NEPA) with commensurate restoration, replacement, or protection. The No Action Alternative would therefore preserve intact ecosystems, wildlife movement corridors, natural ecological processes, and watershed functions while avoiding additional fragmentation and disturbance. It would also maintain an important network of relatively undisturbed habitat that can serve as a refuge for native species and contribute to ecosystem resilience as forests face increasing pressures from wildfire, drought, climate change, invasive species, and development. I strongly support maintaining the Roadless Rule as is. Outdoor recreation is a crucial part of our country's economy and preservation of large scale swaths of undeveloped land is critical for protecting our vulnerable species. Rescinding the Roadless Rule is unpopular and unnecessary. References Gucinski, Hermann; Furniss, Michael J.; Ziemer, Robert R.; Brookes, Martha H. 2001. Forest roads: A synthesis of scientific information. General Technical Report PNW-GTR-509. Portland, Oregon: U.S. Dept. of Agriculture, Forest Service. 103 p. Watts, R., Compton, R., McCammon, J., Rich, C., Wright, S., Owens, T., and Ouren, D., 2007, Roadless space of the conterminous United States: Science, v. 316, no. 5825, p. 736-738, https://doi.org/10.1126/science.1138141

Dear USDA Leadership: As an angler, I don't oppose road-building everywhere. I oppose road-building in country where the rule already said no, the science still says no, and the agency hasn't shown why the answer should change. The 2001 Rule has been a quiet, working piece of policy for two decades. The Department doesn't have to do anything dramatic — just leave it in place. Visiting the Wilson Creek and Harper Creek Wilderness Study Area is one of my favorite backpacking and fishing trips I've ever take. The remoteness was humbling. The Harper Creek Wilderness Study Area was one of the harder, more remote hikes I'd done at the time and gave me a great appreciation for how important it is to have these kinds of places. Regarding the Harper Creek in the Pisgah National Forest, North Carolina: “The area remains a Wilderness Study Area despite being recommended for full Wilderness designation by the U.S. Forest Service since 1987 and having bipartisan congressional support in the 1990s. On December 16, 2001, the area was protected under the Roadless Area Conservation Rule, which designated it as an Inventoried Roadless Area comprising 7,325 acres.” “Large-scale railroad logging commenced in the region around 1910. More significantly, the area became a major site for uranium prospecting from the 1950s through the 1970s. The North Harper Creek Prospect underwent extensive core drilling. Exploration identified uranium deposits in the Wilson Creek Gneiss, with speculative resources estimated at 4 to 8 million pounds of U₃O₈. The remoteness and expense of mining in this area is what has saved it.” “Influence of water exchange and dissolved oxygen in redds on survival of steelhead trout embryos. Survival of embryos relates positively to dissolved oxygen and apparent velocity of intragravel water, and positively to gravel permeability and gravel size. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1961 (https://doi.org/10.1577/1548-8659(1961)90[469:IOWEAD]2.0.CO;2)” “Sediment production from road surfaces was measured on gravel-surfaced forest roads. Road surface erosion rates were found to be substantially elevated compared to undisturbed forest conditions, with sediment production directly related to traffic levels, road surface material, and road gradient. — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1984 (https://doi.org/10.1029/WR020i011p01753)” “Water and sediment inputs are fundamental drivers of river ecosystems, but river management tends to emphasize flow regime at the expense of sediment regime. Managing for a desired balance between sediment supply and transport capacity is not only tractable, given current geomorphic process knowledge, but also essential because of the importance of sediment regimes to aquatic and riparian ecosystems, the physical template of which depends on sediment-driven river structure and function. — BioScience / Oxford Academic, 2015 (https://doi.org/10.1093/biosci/biv002)” In earnest, CommentID: RLC-20260906-JAUUAF

I am writing as a forest ecologist to strongly oppose the proposed rescission of the 2001 Roadless Area Conservation Rule. I urge the U.S. Forest Service to select the No Action alternative and retain the Roadless Rule in its entirety. The Forest Service has a responsibility to manage National Forest System lands for multiple values, including watershed protection, wildlife and fish, recreation, and sustainable resource use. Retaining roadless areas is entirely consistent with that mission. The agency's current proposal would remove the national prohibition on road construction, road reconstruction, and timber harvesting in nearly 45 million acres of National Forest System lands. The Forest Service itself acknowledges that the proposed rescission would return management decisions to individual forest-level planning processes. That shift would make protection of nationally significant, interconnected ecosystems dependent upon individual project decisions and forest plans. A national standard is warranted precisely because the ecological values at stake—watersheds, wildlife corridors, biodiversity, carbon storage, recreation, and intact landscapes—extend beyond individual forest boundaries. The scientific evidence has also become stronger, not weaker, since the Roadless Rule was adopted. The most recent research does not demonstrate that roadless status creates an unacceptable wildfire problem. Instead, it demonstrates substantial benefits for water resources and aquatic biodiversity and finds that wildfire ignition is substantially more common near roads. For these reasons, and the reasons detailed in the attached letter, I respectfully request that the U.S. Forest Service: 1.Withdraw the proposed rescission of the 2001 Roadless Area Conservation Rule. 2.Select the No Action alternative in the environmental review. 3.Fully incorporate the 2026 Fire Ecology and PLOS Water research into the agency's analysis. 4.Acknowledge and address the Forest Service's own 2020 findings regarding wildfire, fuel treatments, and road-associated invasive species (Healey 2020). 5.Continue to allow carefully targeted wildfire-resilience and forest-health treatments where authorized under the existing Roadless Rule, rather than eliminating nationwide protections. 6.Protect the water, wildlife, recreation, and ecological values of these remaining intact landscapes for future generations. The Roadless Rule represents a prudent application of the precautionary principle: where intact forests provide irreplaceable public benefits and the evidence does not demonstrate that additional roads will reduce wildfire risk, the responsible course is to preserve those landscapes. I urge the Forest Service to pay attention to the latest scientific evidence and retain the 2001 Roadless Area Conservation Rule. Sincerely, Research Forest Ecologist Sources •Aplet, G. H., Hartger, P., & Dietz, M. S. (2026). Three-decade record of contiguous-U.S. national forest wildfires indicates increased density of ignitions near roads. Fire Ecology, 22, 8. •Olden, J. D., Postel, S. L., Dombeck, M. P., Kesting, H., Freeman, P., & Comte, L. (2026). Assessing the value of the U.S. Roadless Rule for people and nature. PLOS Water, 5(7), e0000538. •Healey, S. P. (2020). Long-term forest health implications of roadlessness. Environmental Research Letters, 15, 104023. •Gucinski, H., Furniss, M. J., Ziemer, R. R., & Brookes, M. H. (2001). Forest Roads: A Synthesis of Scientific Information. USDA Forest Service, PNW-GTR-509.

To the U.S. Forest Service Roadless Rule Docket: These two facets of my connection to the lands at issue together constitute the basis of my opposition to the proposed rescission. Regarding the Chiricahua in the Coronado National Forest, Arizona: The proposed rescission of the 2001 Roadless Area Conservation Rule puts Speckled Dace (Rhinichthys osculus, G4) at risk in the Chiricahua IRA, Coronado National Forest, by removing the barrier to road construction in a watershed where this species depends on the absence of anthropogenic sediment, thermal loading, and flow alteration. This species is state-imperiled (S3) in Arizona. "Sediment production from road surfaces was measured on gravel-surfaced forest roads. Road surface erosion rates were found to be substantially elevated compared to undisturbed forest conditions, with sediment production directly related to traffic levels, road surface material, and road gradient." — USDA Forest Service — Forest Roads: A Synthesis of Scientific Information, 1984 Road surfaces in national forests produce sediment at rates 50 to 300 times higher than undisturbed forest floor. In the Chiricahua IRA, that sediment would travel via road ditches and cross-drain outlets to stream channels, where it fills interstitial spaces in substrate, reduces oxygen exchange through gravel, and eliminates the clean spawning habitat Speckled Dace (Rhinichthys osculus) requires. The Roadless Rule is one of America's most popular conservation measures, and that support has not faded. Prior to its 2001 enactment, more than 600 public hearings were held nationwide, and 1.6 million Americans weighed in to call for protection of these forestlands—more comments than any other federal rule had received at the time. When USDA announced its rescission proposal, the compressed 21-day public comment period in late 2025 drew approximately 600,000 additional comments. A detailed roadless.org analysis of the comment record found that more than 99.8% of submitters opposed the rescission. A February 2026 Pew Charitable Trusts national poll found that 76% of likely voters support the Roadless Rule compared to just 13% opposed, with bipartisan backing from 71% of Republicans, 80% of Democrats, and 80% of independents. More than 100 members of Congress have co-sponsored the Roadless Area Conservation Act of 2025 (S.2042 / H.R.3930) to codify the Rule so it could not be rolled back without an act of Congress. The proposed rollback of the 2001 Roadless Rule jeopardizes nearly 58 million acres of undeveloped backcountry forestland managed by the U.S. Forest Service, comprising around a third of the territory in our national forest system. These forests have only remained intact because of the Forest Service's nearly 25-year-old commitment not to build roads in these areas for harmful activities like major logging operations or oil-and-gas drilling. “Early quantitative analysis showing roadless areas substantially complement biodiversity conservation, with many roadless areas overlapping areas important for imperiled species. — Research - Biodiversity Conservation” “National monitoring analysis using ~20 years of data found forests in roadless areas burned at similar frequencies as road areas. Claims that road prohibitions harm forest health are not supported by evidence. — Research - Fire Safety” “Literature synthesis shows road landscapes correlate with higher sediment loads, while roadless areas act as refugia for salmonids and freshwater biodiversity. — Research - Water Quality” This rulemaking should conclude with the 2001 Rule intact. In solidarity, CommentID: RLC-20260826-6SYPT2

I strongly oppose rescinding the 2001 Roadless Area Conservation Rule and urge USDA and the U.S. Forest Service to retain nationwide protections for Inventoried Roadless Areas. The Forest Service’s own research shows roads through currently roadless forests can cause lasting ecological, hydrological, and financial harm. Once established, road networks and their impacts are difficult to reverse. Roads fragment intact ecosystems. The Forest Service’s Forest Roads: A Synthesis of Scientific Information found that roads affect aquatic habitat, terrestrial wildlife, biodiversity, hydrology, and landscape-scale ecological processes well beyond the roadway itself. Habitat fragmentation is a significant consequence of forest roads. Inventoried Roadless Areas are among our remaining large National Forest landscapes not already divided by extensive roads. Gucinski, H. et al. (2001). Forest Roads: A Synthesis of Scientific Information. USDA Forest Service, PNW-GTR-509. https://doi.org/10.2737/PNW-GTR-509 Roads can damage watersheds and aquatic habitat. The Forest Service’s environmental analysis for the original Roadless Rule identified increased sedimentation, degraded water quality, altered hydrology, reduced stream-bank stability, and loss of aquatic habitat as consequences of roads and related activities. Excess sediment can damage spawning and rearing habitat and aquatic communities. USDA Forest Service. Roadless Area Conservation Final Environmental Impact Statement, Vol. 1, Chapter 3. National Forest watersheds supply communities, agriculture, fisheries, and downstream ecosystems. Protecting intact watersheds is therefore also a form of public infrastructure protection. Roads facilitate invasive species and further disturbance. Road ecology research identifies invasive-species introduction, erosion, sedimentation, altered hydrology, aquatic fragmentation, and increased access to remote ecosystems among road-associated impacts. Roads can also facilitate additional logging, motorized use, and habitat disturbance. Coffin, A.W. et al. (2021). The Ecology of Rural Roads: Effects, Management, and Research. Issues in Ecology, Report No. 23. New roads create long-term costs for taxpayers. The Forest Service faced a deferred-maintenance backlog of more than $8.6 billion as of FY2023. Expanding the road system would add obligations for culverts, drainage, erosion control, bridges, inspections, storm repairs, reconstruction, and eventual decommissioning. USDA Forest Service, “Maintaining Infrastructure”: https://www.fs.usda.gov/science-technology/infrastructure/maintaining Before facilitating construction of additional roads, USDA should account for their full lifecycle cost—not merely their immediate economic benefits. Rescission is too broad a response to legitimate forest-management concerns. I recognize that managers need tools to address wildfire, insects, disease, and changing forest conditions. USDA states that more than 40% of Inventoried Roadless Areas have high or very high wildfire hazard potential and argues that rescission would provide greater flexibility. But that does not establish that eliminating nationwide protections across tens of millions of acres is necessary. Targeted exceptions could provide managers with needed flexibility without abandoning the presumption against constructing roads through currently roadless landscapes. The final EIS should therefore answer a fundamental question: What forest-management objectives require complete rescission of the Roadless Rule that could not be accomplished through targeted exceptions or amendments? Finally, roadless landscapes provide benefits that cannot be replaced once lost. They provide wildlife habitat, intact watersheds, hunting and fishing opportunities, hiking, trail running, backpacking, and increasingly rare landscapes free from extensive infrastructure. Public access does not require motorized infrastructure everywhere. Americans access these landscapes by trail, river, horse, ski, and foot. Their relative inaccessibility to vehicles is often precisely what gives them exceptional ecological and recreational value. I urge USDA to select the no-action alternative and retain the 2001 Roadless Area Conservation Rule. At minimum, before rescission USDA should fully evaluate habitat fragmentation, water quality and sedimentation, invasive species, the consequences of increased motorized access, the lifecycle cost of additional roads, recreational economic value, and whether targeted exceptions could address legitimate wildfire and forest-health needs without nationwide repeal. The US already contains extensive developed and road-accessible land. Remaining National Forest roadless areas are a finite public asset. The burden should be on proponents of new roads to demonstrate that they are necessary—not on the public to continually defend undeveloped landscapes from conversion. Please retain the Roadless Rule.